Privacy Policy

Axiorem is a software platform operated by Wellness Wizard Private Limited ("Axiorem", "we", "us", or "our").

Axiorem provides AI-native learning, training, document-processing, knowledge-management, assessment, workflow, and related services to individuals and Organizations.

For privacy purposes, the party responsible for processing personal data may depend on how the Service is used, the jurisdiction involved, and the relationship between Axiorem and the relevant Organization. This Privacy Policy explains Axiorem's own processing of personal data and the principal ways Axiorem processes information when providing the Service.

This Privacy Policy applies to personal data processed through the Axiorem website, application, account systems, training platform, APIs, customer support channels, and related Service components that link to this Policy.

It applies to information you provide directly to Axiorem, information generated by use of the Service, and personal information that may be contained in Customer Content submitted by or on behalf of an Organization.

This Privacy Policy does not replace a separate enterprise Data Processing Addendum (DPA) where one is executed between Axiorem and a Customer. Where a DPA imposes specific obligations on Axiorem as a processor or service provider, the DPA controls to the extent of a conflict for the applicable processing.

Third-party websites, applications, LMS platforms, payment providers, identity providers, and other services may have their own privacy practices. Their policies apply to processing performed by those third parties.

Axiorem may act in different privacy roles depending on the processing activity.

For personal data relating to an individual's Axiorem Account, billing relationship, service usage, security, communications, and similar direct relationship, Axiorem may determine the purposes and means of processing and may therefore act as a controller, data fiduciary, or analogous role under applicable law.

Where an Organization uploads Customer Content containing personal data of employees, contractors, customers, learners, vendors, patients, or other individuals and instructs Axiorem to process that content to provide the Service, the Organization may remain the controller or data fiduciary and Axiorem may act as its processor, data processor, service provider, or analogous role, subject to applicable law and the relevant contractual arrangement.

The applicable allocation of roles should be documented in the Customer's DPA where required.

The exact information collected depends on how you use Axiorem.

Based on the current product design, Axiorem may directly receive and retain Account and identity information.

Axiorem may process Customer Content that a User or Organization chooses to upload or otherwise provide through the Service.

Customer Content may include documents, PDFs, office files, policies, SOPs, manuals, handbooks, training material, technical documents, operational records, assessments, employee information, learner information, or other data that the Customer is authorized to process.

Because Customer Content is controlled by the Customer, Axiorem generally does not determine all of the personal-data categories contained within it. A document uploaded by an Organization could contain names, identifiers, employment information, contact information, training results, health and safety information, or other personal information depending on the Customer's own practices.

Customers should not upload information they are not legally or contractually permitted to provide to Axiorem.

When you access or use the Service, Axiorem and its service providers may automatically collect certain technical and usage information necessary to operate, secure, troubleshoot, measure, and improve the Service.

Depending on the actual infrastructure, this may include:

Axiorem may receive information from third parties when necessary to provide the Service.

Examples may include:

Axiorem uses personal data only for purposes reasonably connected to the Service, the relationship with the User or Customer, applicable legal obligations, security, and other disclosed purposes.

Depending on the context, Axiorem may use personal data to:

Depending on the jurisdiction, Axiorem may rely on different legal grounds or lawful bases for processing.

Potential grounds may include:

Axiorem uses AI, retrieval, embeddings, classification, summarization, generation, and related technologies to provide requested functionality.

Where necessary to provide an AI-enabled feature, appropriate portions of Customer Content may be transmitted to the relevant AI or model provider.

Axiorem's use of Customer Content for AI processing is limited by the applicable Service configuration, customer instructions, contractual commitments, provider settings, and applicable law.

Axiorem does not intend to treat Customer Content as a general-purpose public dataset merely because it is submitted to the Service.

Unless expressly stated otherwise in an applicable agreement, Axiorem should not represent that Customer Content is used to train foundation models without verifying the actual configuration and contractual terms of the relevant AI providers.

Axiorem is designed around data minimization for source documents.

Subject to the actual production implementation, the intended workflow is that a Customer uploads a source document, temporary storage may be used to receive and process it, the document is ingested and chunked, the original active source file is removed from active cloud storage after successful processing, and the processed representation may remain associated with the relevant Project.

Deleting a Project is intended to remove associated processed representations, subject to applicable retention, backup, security, and legal limitations.

Axiorem does not state that a source document disappears from every technical system instantaneously. Temporary caches, backups, operational logs, provider-side processing, failed-job artifacts, and security systems may have different lifecycles where technically or legally necessary.

Axiorem may use cookies, local storage, pixels, SDKs, or similar technologies necessary to operate the website or Service.

These technologies may be used for:

Axiorem may disclose personal data only as reasonably necessary for the purposes described in this Policy, the Terms, a DPA, or otherwise permitted or required by law.

Recipients may include:

Where Axiorem uses third-party processors or service providers to process personal data on its behalf, Axiorem may maintain a list of relevant subprocessors or categories of subprocessors.

The list may identify, as appropriate:

Axiorem may process personal data in countries other than the country in which the User or Customer is located.

Where applicable law restricts international transfers, Axiorem will use an appropriate lawful transfer mechanism or other safeguard recognized under that law.

Depending on the applicable regime, these mechanisms may include:

Axiorem retains personal data only for as long as reasonably necessary for the purposes described in this Policy, the applicable contract, legal obligations, security requirements, dispute resolution, accounting, fraud prevention, or other legitimate operational purposes.

Retention periods vary by category and may include:

Users may request deletion of their Account subject to the processes provided by the Service.

Based on the current intended product design, deletion may include removal of direct Account identifiers.

Axiorem uses reasonable technical and organizational measures appropriate to the nature of the Service and the risks associated with processing personal data.

Depending on the production environment, measures may include:

Axiorem maintains an incident-response process intended to identify, contain, investigate, remediate, and document privacy and security incidents.

If Axiorem determines that an incident requires notification under applicable law or contract, Axiorem will provide notices in accordance with the applicable requirements.

Notification may depend on the type of data involved, the nature and severity of the incident, the likelihood of harm, applicable legal deadlines, contractual requirements, available facts, and whether disclosure would interfere with an investigation or security response.

Depending on where you live and the context in which your data is processed, you may have rights relating to personal data.

These may include:

For India-facing processing, Axiorem intends to align its privacy practices with the Digital Personal Data Protection Act, 2023 ("DPDP Act") and the Digital Personal Data Protection Rules, 2025, to the extent and from the dates on which their provisions apply to the relevant processing.

The DPDP framework recognizes concepts including Data Principal, Data Fiduciary, Data Processor, notice, consent, withdrawal of consent, access, correction, erasure-related rights, grievance handling, and obligations concerning security and processing.

The exact operational obligations that apply to Axiorem depend on the commencement status, role, category of processing, and whether Axiorem is acting as a Data Fiduciary or Data Processor for a particular activity.

Where GDPR, EU Member State data-protection law, UK GDPR, or equivalent privacy rules apply, Axiorem intends to provide the disclosures required by the applicable regime.

Depending on the processing activity, those disclosures may include:

Where applicable U.S. state privacy laws apply, Axiorem will provide the rights and disclosures required by those laws.

Depending on the applicable statute, these may include rights to:

Axiorem is primarily a business and workplace learning platform and is not intended to be directed to children.

Unless expressly stated otherwise, individuals below the minimum age permitted by applicable law should not create or use Accounts.

If Axiorem becomes aware that it has collected personal data from a child in circumstances where applicable law requires parental or guardian authorization, Axiorem may take appropriate steps to address the situation, including deletion where required.

Axiorem may send operational communications necessary to provide and secure the Service.

Where permitted, Axiorem may also send product updates, feature announcements, educational content, or marketing communications.

Recipients may opt out of non-essential marketing communications by using the unsubscribe mechanism provided in the communication or by contacting Axiorem.

Opting out of marketing communications does not necessarily stop transactional, security, or account-related messages.

Axiorem may use technical and usage information to understand Service performance, diagnose problems, improve usability, detect abuse, and improve the reliability of the platform.

Axiorem should distinguish between personal data used to operate the Service, aggregate or de-identified analytics, Customer Content, AI prompts and retrieved context, and information used for product improvement.

Customer Content should not be represented as being used for model training, product improvement, benchmarking, evaluation, or analytics unless that processing actually occurs and is permitted by the applicable legal and contractual framework.

Axiorem may generate recommendations, classifications, assessments, or other AI outputs. These outputs are not automatically equivalent to legally significant automated decisions.

Axiorem does not intend for its general-purpose Service to make final decisions about a person's employment, healthcare, credit, insurance, legal rights, or similarly consequential matters without appropriate customer controls and human review.

Where applicable law provides rights concerning solely automated decisions, profiling, or high-impact uses of AI, Axiorem and the relevant Customer are responsible for determining which obligations apply to the particular use case.

When an Organization uses Axiorem to process personal information about other people, the Organization is responsible for:

Axiorem may provide a Data Processing Addendum for enterprise Customers.

The DPA may address:

Axiorem may update this Privacy Policy to reflect changes in the Service, infrastructure, legal requirements, processing practices, or security measures.

The "Last Updated" date will identify the most recent version.

For material changes, Axiorem may provide additional notice where required, including by email, in-product notice, or other reasonable means.

If a change requires consent under applicable law, Axiorem will obtain that consent where required.

Privacy questions, requests, and concerns may be sent to:

If you have a concern regarding Axiorem's privacy practices, you should first contact Axiorem using the details above so that we can investigate and respond.

Where applicable law provides a right to complain to a supervisory authority, data-protection authority, regulator, or other competent body, you may exercise that right.

The appropriate authority depends on your location, the nature of the processing, and the applicable privacy regime.

This Privacy Policy is intended to be accurate, transparent, and consistent with Axiorem's actual technical and business practices.

Before publication, Axiorem must verify the relevant implementation details and ensure that no statement in this Policy is interpreted as a commitment to a technical control that has not been implemented, tested, and documented.

Where applicable law requires greater rights or protections than those described here, applicable law controls.