Cherry AI — Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how Disruptive Learning, S.A.P.I. de C.V. (operating as "Cherry AI," "we," "us," or "our") collects, uses, shares, and protects personal data when you visit trycherry.ai and sign up for our waiting list (the "Service").

Cherry AI is a 24/7 autonomous fiscal AI agent that automates corporate compliance. We are currently in pre-launch and collecting interest through a waiting list. This Policy applies to all visitors and individuals who submit their information through our waiting list form.

By submitting your information, you expressly acknowledge and agree to the collection and processing of your data as described in this Policy.

Applicable Law: This Policy complies with Mexico's Ley Federal de Proteccion de Datos Personales en Posesion de los Particulares ("LFPDPPP"), its Regulations, and applicable U.S. state privacy laws including the California Consumer Privacy Act ("CCPA") as amended by the CPRA.

2. Who We Are

For purposes of Mexico's LFPDPPP, Cherry AI is the party responsible ("Responsable") for the treatment of your personal data.

3. Data We Collect

During this pre-launch phase, we collect only the data you provide when joining our waiting list:

We also automatically collect basic technical data when you visit our website, including IP address, browser type, and device information, through essential cookies required for website functionality.

We do not collect financial data, tax IDs, payment information, or any sensitive personal data during this phase.

4. How We Use Your Data

4.1 Primary Purposes

• Waiting List Management — Processing your registration, assigning your place, and managing early access invitations.
• Launch Communications — Notifying you when Cherry AI launches or when early access becomes available.
• Product Updates — Sending relevant updates about Cherry AI's development and features.

4.2 Secondary Purposes (Consent-Based)

You may opt out of these at any time without losing your place on the waiting list:

• Marketing Communications — Newsletters, promotional content, and partner announcements.
• Audience Analysis — Aggregated, non-identifiable analysis of our waiting list to understand demand by industry and company size.

5. Legal Basis for Processing

6. Data Sharing

6.1 Service Providers

We may share your data with the following categories of service providers, solely to operate the waiting list:

6.2 International Data Transfers

Your data is stored primarily in Mexico. It may be transferred to the United States for cloud hosting and email delivery. For each transfer, we ensure adequate protection through standard contractual clauses or your express consent.

6.3 We Never Sell Your Data

Cherry AI does not sell, rent, or trade your personal data to third parties. This applies under both LFPDPPP and CCPA.

7. Data Retention

After the retention period, data is permanently deleted. If you convert to a paying customer at launch, your data will be governed by the full Cherry AI Privacy Policy applicable at that time.

8. Your Privacy Rights

8.1 ARCO Rights (Mexico — LFPDPPP)

If you are located in Mexico, you have the right to:

• Access — Obtain confirmation of whether we process your data and receive a copy.
• Rectification — Correct inaccurate or incomplete data.
• Cancellation — Request deletion of your data.
• Opposition — Object to processing of your data for specific purposes.

How to exercise: Email legal@trycherry.ai with subject "ARCO Request." Include your full name, account email, a copy of official ID (INE, passport), and a description of the right you wish to exercise.

Response timeline: Acknowledgment within 5 business days. Decision within 20 business days (LFPDPPP Art. 32). Execution within 15 business days of approval.

If denied, we will provide a written explanation. You may appeal to INAI (Instituto Nacional de Transparencia, Acceso a la Informacion y Proteccion de Datos Personales).

8.2 U.S. Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to:

• Know what personal information we have collected.
• Delete your personal information.
• Correct inaccurate information.
• Opt-Out — We do not sell or share personal information.
• Non-Discrimination — We will not discriminate against you for exercising your rights.

To exercise: email legal@trycherry.ai with subject "CCPA Request."

8.3 Universal Rights

• Unsubscribe — Every email includes an unsubscribe link. One click removes you from all non-essential communications.
• Deletion — Request complete removal from our waiting list at any time by emailing legal@trycherry.ai.
• Withdraw Consent — Withdraw consent for any secondary purpose without losing your place on the waiting list.

9. Cookies

Our website uses only essential cookies required for basic functionality (session management, security). We do not currently use marketing or advertising cookies.

If we add analytics cookies in the future, we will present a consent banner before activating them.

10. Data Security

We protect your data with:

• Encryption in transit (TLS 1.3) and at rest (AES-256)
• Access restricted to authorized personnel only
• NDA and confidentiality obligations for all team members
• Cloud infrastructure hosted in certified data centers (GCP)

11. Data Breach Notification

If a security breach compromises your personal data, we will notify you by email within 72 hours of confirmation, describing the breach, data affected, and remedial measures taken. Where required by law, we will also notify the appropriate authorities (INAI, state attorney general).

12. Children's Privacy

Cherry AI is a business service. We do not knowingly collect data from individuals under 18. If we discover we have collected data from a minor, we will delete it promptly.

13. Changes to This Policy

We may update this Policy as Cherry AI moves from waiting list to full product launch. Material changes will be notified by email at least 30 days before taking effect. If you disagree, you may request deletion of your data at any time.

14. Contact Us