PHAX / PHAXIUS Privacy Notice
Published legal information for PHAX / PHAXIUS.
PHAX / PHAXIUS Privacy Notice
Version v1.0 | Prepared 23 April 2026 | Intended effective date: on publication
Important summary
• We collect account data, prompts and messages, support communications, technical logs, cookies or similar
session data, and payment or subscription metadata needed to run PHAX.
• Because PHAX is an AI coaching product, your prompts and conversation history may include intimate,
relationship-related, or other sensitive information. Do not submit anything you do not want processed
through the Services.
• We do not sell your personal data. We do not sell or share personal data for advertising purposes. We do
not operate a dating marketplace, match users with each other, or share your private chat content with other
PHAX users.
• Authorised personnel and authorised service providers may access personal data on a limited need-to-know
basis for support, debugging, safety, security, abuse prevention, billing, legal compliance, and tightly defined
service improvement.
• Where applicable law requires it, and where you voluntarily include special category personal data in
prompts or support communications, we process that data only on a lawful basis and an applicable Article 9
condition, including explicit consent where appropriate.
• You can request access to, correction of, deletion of, restriction of, objection to, portability of, or a copy of
personal data we hold about you by contacting privacy@phaxius.com, subject to identity verification,
applicable law, and the rights of others.
1. Who we are and how to contact us
This Privacy Notice explains how SaRi Software Technologies FZ-LLC collects, uses, stores, shares, transfers,
and protects personal data when you use PHAX / PHAXIUS, including phaxius.com, app.phaxius.com, any
account area, billing flow, AI features, support channels, and related services (together, the "Services"). It
should be read together with the PHAX / PHAXIUS Terms and Conditions.
For the purposes of applicable data protection law, SaRi Software Technologies FZ-LLC acts as the data
controller in respect of personal data processed through the Services, unless stated otherwise.
Company details: SaRi Software Technologies FZ-LLC, Licence No. 47028814, Registration No.
0000004081924, VUPR1327, Compass Building, Al Hulaila, Al Hulaila Industrial Zone-FZ, Ras Al Khaimah,
United Arab Emirates.
Privacy contact: privacy@phaxius.com. Support: support@phaxius.com. Legal notices: legal@phaxius.com.
For users in the European Union and the United Kingdom, privacy@phaxius.com is the main contact point for
data-protection queries. Where PHAX is required by applicable law to appoint an EU or UK representative, the
representative's details will be published in this Notice and on the website.
2. Scope and age limits
This Privacy Notice applies to personal data processed through the Services, including account creation, login,
AI conversations, prompts, outputs, usage limits, billing flows, subscription management, support, security,
analytics, and website access.
This Privacy Notice does not apply to third-party websites, services, payment pages, apps, browser extensions,
or platforms that we do not control. Those third parties may have their own terms and privacy policies.
PHAX is intended for adults only. You must be at least 18 years old, or the age of majority in your jurisdiction if
higher, to use the Services. We do not knowingly collect personal data from children.
3. Personal data we collect
We collect only the categories of personal data reasonably needed to operate, secure, support, improve, and bill
for the Services. Depending on how you use PHAX, this may include:
• Account and identity data: name or display name if provided, email address, account ID, login method,
authentication status, and account settings.
• User content and conversation data: prompts, messages, relationship context, notes, pasted conversations,
screenshots or uploads if enabled, AI outputs, feedback, and reports.
• Usage and product data: feature usage, message counts, credits or usage-limit status, timestamps,
subscription state, pages or screens visited, and interaction events.
• Technical and device data: IP address, browser type, device type, operating system, language, approximate
location inferred from IP, log files, error data, and security-event data.
• Payment and subscription metadata: Stripe customer ID, subscription status, plan, billing period, payment
status, invoice metadata, transaction IDs, payment failure, fraud, or dispute status. We generally do not
store full payment-card numbers or card security codes.
• Support, communications, and compliance data: emails, support tickets, screenshots you send to us, issue
history, abuse reports, account status, security events, chargebacks, and records needed to enforce our
Terms or comply with law.
4. Data about other people that you submit
PHAX is designed for personal relationship and communication support. You may paste or describe messages,
situations, screenshots, names, nicknames, relationship histories, or other information involving third parties.
You are responsible for ensuring that any personal data you submit, including information about third parties, is
lawful to share and that you have any necessary rights, permissions, consent, or other lawful basis to share it.
Please minimise third-party personal data. Do not upload or paste private information about another person
unless it is necessary for your use of the Services and you are permitted to share it.
5. How we use personal data
We use personal data to provide the Services, including account creation, login, AI response generation,
conversation history, continuity, case context, usage limits, subscriptions, and entitlements.
We use personal data to process payments, subscriptions, cancellations, refunds where applicable, customer-
portal activity, chargebacks, and access rights through Stripe or other payment providers.
We use personal data to respond to privacy, support, billing, safety, abuse, and legal requests.
We use personal data to maintain safety, security, platform integrity, fraud detection, abuse-prevention controls,
service monitoring, and entitlement enforcement.
We use personal data to debug, test, analyse, maintain, and improve the Services, including response quality,
reliability, onboarding, billing flow, product security, and user experience.
We may create aggregated or de-identified statistics that do not identify you.
We use personal data to comply with legal, accounting, tax, regulatory, dispute, audit, and enforcement
obligations and to communicate service notices, transactional messages, security alerts, billing messages, and
policy updates.
6. Legal bases for processing
Depending on your location, applicable data-protection law may require us to identify a legal basis for
processing personal data. The main legal bases we rely on are:
• Performance of a contract: creating your account, providing AI features, maintaining usage limits,
processing paid access, and delivering support.
• Legitimate interests: security, fraud prevention, debugging, product analytics, abuse prevention, service
improvement, corporate administration, and enforcing our Terms, provided those interests are not
overridden by your rights and interests.
• Legal obligation: accounting, tax records, payment disputes, sanctions compliance, lawful requests, court
orders, and other regulatory or legal obligations.
• Consent where required: optional marketing, non-essential cookies, and certain higher-risk processing
where applicable law requires consent.
• Vital interests or public-interest grounds where applicable: urgent safety situations or credible threats of
harm, used only where lawful and genuinely necessary in exceptional circumstances.
7. Special category personal data
Because PHAX is an AI coaching product, some users may voluntarily include personal data concerning health,
sex life, sexual orientation, or other special category data in prompts, uploads, or support communications.
Please submit only the content necessary to receive the Service. Avoid submitting health data, sex life
information, highly sensitive third-party data, government identifiers, passwords, private images, or financial
account details unless genuinely necessary and lawful to share.
Where applicable law requires an Article 9 condition for processing special category personal data, we rely on
the condition that best fits the context and the lawfulness of the processing, including explicit consent where you
expressly choose to submit such data to receive, operate, secure, or support the Services, and vital interests or
substantial public-interest grounds only where lawful and genuinely necessary in exceptional circumstances.
If you do not want PHAX to process special category personal data, do not submit it through the Services.
Where explicit consent is the relevant condition, you may withdraw that consent for future processing by
contacting us, but this will not affect processing already carried out lawfully before withdrawal and may limit or
prevent continued use of affected features.
8. AI processing, human access, and service monitoring
To generate PHAX responses, we process your prompts, conversation history, and other context through AI
systems and related infrastructure. Your inputs and outputs may be sent to AI, hosting, database, logging,
security, analytics, and support providers that help us provide the Services.
PHAX is a hosted software service rather than a privileged legal, medical, or therapeutic channel.
We do not sell your personal data. We do not publicly disclose your private prompts, messages, outputs, or
relationship context in marketing or case studies without your permission.
Authorised PHAX personnel and authorised service providers may access user content on a limited need-to-
know basis for support, debugging, safety, security, abuse prevention, billing, dispute handling, legal
compliance, and limited product improvement. Access must not be casual, curiosity-driven, or wider than
reasonably necessary for the relevant purpose.
If you include sensitive personal data in prompts or support communications, you are asking us to process it for
the purpose of providing, operating, securing, and supporting PHAX, subject to applicable law.
9. Automated decision-making
We do not use personal data to make solely automated decisions that produce legal effects or similarly
significant effects about you.
PHAX may generate automated outputs, suggestions, classifications, or guidance, but these are product
features and do not replace your own judgment, nor do they make binding legal or similarly significant decisions
about your rights.
10. Payments, data location, access, and Stripe
Payment processing is provided by third-party providers such as Stripe. Payment providers such as Stripe may
act as independent controllers of payment data, and may also act as processors depending on the payment
activity and applicable law. They process payment data in accordance with their own privacy notices and terms,
including Stripe's Privacy Policy.
We generally do not store full payment-card numbers or card security codes.
Personal data, including account, usage, and billing-related information, may be stored and processed in the
United Kingdom, the European Economic Area, the United Arab Emirates, the United States, India, and other
countries where our vendors or infrastructure operate.
In limited cases, authorised personnel or service providers may access certain personal data, including limited
account or transaction-related information, from outside the United Kingdom and European Economic Area,
including the United Arab Emirates. Where applicable law requires safeguards for those transfers or access
arrangements, we use appropriate lawful safeguards.
11. Cookies, local storage, and analytics
We may use cookies, local storage, pixels, log files, or similar technologies to keep you signed in, secure your
session, remember basic preferences, maintain subscription or usage state, detect abuse, understand site
performance, and troubleshoot the Services.
Essential cookies or local storage may be required for login, account security, billing, and core service
functionality.
If we use non-essential cookies or analytics that require consent in your jurisdiction, we will provide the required
choice mechanism before or when that processing begins.
12. Who we share personal data with
We share personal data only where reasonably necessary for the purposes described in this Privacy Notice and
our Terms. We do not sell your personal data. We do not sell or share personal data for advertising purposes.
We may share personal data with hosting, cloud, database, security, analytics, logging, support,
communications, AI, payment, tax, legal, accounting, or audit providers that help us operate the Services.
We may share personal data with payment providers, banks, payment networks, or dispute processors where
necessary to process payments, fight fraud, or respond to disputes or chargebacks.
We may disclose personal data where required or permitted by law, to protect rights, safety, users, PHAX, or
third parties, or as part of a financing, merger, acquisition, restructuring, sale, or transfer of assets.
13. International processing and transfers
SaRi Software Technologies FZ-LLC is established in the United Arab Emirates. We and our service providers
may process personal data in multiple jurisdictions.
Where required by applicable law, we use appropriate safeguards for international transfers, such as the
European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement, the UK
Addendum to the EU Standard Contractual Clauses, adequacy regulations or decisions, vendor data-processing
terms, technical and organisational security controls, transfer risk assessments where required, or other lawful
transfer mechanisms.
14. Retention and deletion
We keep personal data only for as long as reasonably necessary for the purposes described in this Notice,
unless a longer period is required or permitted by law.
Account data is generally kept while your account is active, then deleted or de-identified after account deletion
unless retention is required.
Prompts, conversation history, AI outputs, and relationship context are generally kept while your account is
active, then deleted or de-identified from active systems after account deletion unless we must retain them for
legal, security, fraud, billing, backup, audit, or dispute reasons.
Support communications, logs, and security records may be retained as long as needed for support, abuse
prevention, fraud, debugging, security, or legal compliance.
Payment, invoice, and subscription metadata may be retained longer where required or permitted for
accounting, tax, payment disputes, fraud prevention, and legal compliance.
Deleted data may remain in backups until overwritten under normal backup cycles.
Aggregated or de-identified data that no longer identifies you may be retained longer or indefinitely for statistics,
service quality, and business analysis.
15. Your privacy rights and data-copy requests
Depending on where you live, you may have rights to request access, a copy, correction, deletion, restriction,
portability, objection, withdrawal of consent where applicable, or information about how your data is used and
shared.
You may request a copy of the personal data PHAX has saved about you by emailing privacy@phaxius.com.
Please include the email address connected to your PHAX account and enough information for us to identify the
account.
We may ask you to verify your identity before providing a copy or taking other action. We may refuse or limit a
request where we cannot verify your identity, where the request is excessive or abusive, or where we are
required or permitted to retain or withhold information for legal, security, payment, privacy-of-others, or dispute
reasons.
If your request includes data involving another person, we may need to redact or withhold information to protect
that person's privacy and rights.
16. Account deletion
You may delete your account using any in-product deletion route we provide. You may also email
privacy@phaxius.com for deletion support.
Account deletion removes or de-identifies your account data and user content from the active PHAX product
database, subject to limited exceptions.
Account deletion is separate from subscription cancellation unless the product flow expressly states otherwise. If
you have a paid plan, you should cancel it through the billing or customer portal or other cancellation method
provided before deleting your account.
17. Security
We use reasonable technical and organisational measures designed to protect personal data, such as access
controls, secure transmission where available, role-based access, vendor controls, logging, monitoring, and
operational security practices appropriate to the nature, scope, and risk profile of the Services.
No online service can guarantee absolute security. You are responsible for keeping your login credentials, email
account, device, and payment account secure.
18. Changes to this Privacy Notice
We may update this Privacy Notice from time to time as PHAX, our vendors, legal requirements, or product
features change.
We will update the version or "Last updated" date when we publish a new version. If changes are material, we
will use reasonable means to notify users, such as email, account notice, website notice, or in-product notice.
19. Contact us and complaints
Privacy requests and data-copy requests: privacy@phaxius.com
Support: support@phaxius.com
Legal notices: legal@phaxius.com
Operator: SaRi Software Technologies FZ-LLC, VUPR1327, Compass Building, Al Hulaila, Al Hulaila Industrial
Zone-FZ, Ras Al Khaimah, United Arab Emirates.
If you are dissatisfied with our response, you may have the right to complain to the data-protection regulator in
your country of residence where applicable.