1. Who We Are

Apex-Lens is operated by 45Black Limited, a company registered in England and Wales. We are the data controller for personal data collected through this platform.

Contact: hello@45black.tech

2. What Data We Collect

2.1 Account Data

• Email address (required for registration)
• Display name (optional)
• Password (stored as a secure hash, never in plain text)

2.2 Usage Data

• Favourites and collections you create
• Feedback you submit
• Session information for authentication

2.3 What We Don't Collect

• We do not use tracking cookies or analytics (pilot phase)
• We do not collect special category data (health, religion, etc.)
• Anonymous browsing requires no personal data

3. How We Use Your Data

4. AI and Automated Processing

Apex-Lens uses AI (Claude by Anthropic) for the admin curation interface. This AI is used only by administrators to manage the legislation database, not to make decisions about users.

Transparency:All AI-generated content is clearly marked with an "AI-Generated" label in compliance with the EU AI Act.

5. Data Sharing

We share data with the following service providers:

• Supabase (database hosting) - EU/US
• Anthropic (AI processing, admin only) - US
• Cloudflare (hosting and CDN) - Global

All providers have appropriate data protection agreements (Standard Contractual Clauses) for international transfers.

6. Your Rights

Under GDPR, you have the right to:

• Access - Download a copy of your data
• Rectification - Correct inaccurate data
• Erasure - Delete your account and data
• Portability - Export your data in JSON format
• Object - Opt out of certain processing

Exercise your rights via your account settings or by contacting us at hello@45black.tech.

7. Data Retention

• Account data: Until you delete your account
• Favourites/collections: Until you delete them or your account
• Audit logs: 365 days (legal requirement)
• Feedback: 365 days or until resolved

8. Security

We protect your data with:

• TLS 1.3 encryption for all data in transit
• Encryption at rest for stored data
• Row-level security policies in our database
• Tamper-evident audit logging
• Regular security reviews

9. Cookies

We use only essential cookies for authentication. We do not use tracking or advertising cookies.

10. Contact and Complaints

For privacy enquiries: hello@45black.tech

You have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

11. Changes to This Policy

We may update this policy from time to time. Significant changes will be notified via email to registered users. The "Last updated" date at the top indicates the current version.