Cycluno Inc. Privacy Policy

When you use the CYCLUNO website, mobile application, or any of our services, we collect certain categories of information.

1.1 The information you provide to us

We may collect the following information when you register for or use Cycluno:

• Full name, business email address, phone number;
• Company name, role, and organization details;
• Account login credentials and authentication data;
• Billing and subscription information;
• Support requests, communications, and feedback;
• Content you upload or generate through the platform, including test cases, logs, reports, configuration files, and metadata.

Cycluno does not claim ownership over customer test data or proprietary code submitted through the platform.

1.2 The information we collect automatically

When you access or use our platform, we automatically collect certain technical and behavioral information, including:

• IP address, browser type, device ID, device characteristics, and operating system;
• Log data such as date/time of access, session duration, pages viewed, features used, and API calls;
• Performance, diagnostic, and error data (crash reports, latency, and uptime metrics);
• Security and fraud detection data including failed login attempts and unusual access patterns;
• Approximate location derived from IP address (and precise location only if you expressly enable it, where applicable)

This information helps us improve user experience, and maintain platform security.

1.3 The information we obtain from third parties

We may obtain additional information about you from trusted third parties for verification and operational purposes, including:

• Payment processors (to confirm subscription status, prevent fraud, and issue invoices/receipts);
• Identity/access management tools (SSO providers) and workspace administrators;
• Cloud hosting, analytics, monitoring, and logging providers;
• Developer tools and integrations you connect (e.g., CI/CD pipelines, version control, issue trackers), to the extent enabled by your configuration

We do not share or disclose your information with unrelated third parties without your consent, except when necessary to provide our services or required by law.

We collect and process your information to provide you with secure, efficient, and reliable access to the Services. Depending on context, we rely on lawful bases such as performance of a contract, legitimate interests, compliance with legal obligations, and consent (where required).

Specifically, we use your information to:

• Provide, operate, and maintain the Services, including creating workspaces/projects and enabling test generation, execution, and reporting;
• Authenticate users, administer accounts, and enforce access controls;
• Process subscriptions, billing, and payments, and maintain financial records;
• Provide support, respond to inquiries, and manage customer communications;
• Monitor and improve performance, reliability, and user experience, including troubleshooting and analytics;
• Maintain security, prevent fraud/abuse, and protect the integrity of the Services;
• Comply with applicable legal obligations, regulatory requirements, and lawful requests;
• Send service-related communications (e.g., account updates, security alerts, changes to the Services);
• Send marketing communications where permitted and subject to your opt-out rights

Cycluno uses artificial intelligence and machine-learning models to:

• generate automated test cases;
• analyze test execution results;
• identify patterns, anomalies, and performance insights.

AI processing is performed on customer-provided inputs strictly for service delivery and improvement purposes. Cycluno does not use customer data to train public or third-party AI models.

We may share personal data and/or Customer Data with trusted third parties where necessary to operate the Services, fulfil your requests, comply with legal obligations, or enhance user experience, including:

• Service providers and vendors (cloud hosting, monitoring/logging, analytics, email delivery, customer support tools);
• Payment processors and billing partners;
• Identity/SSO and security providers;
• Professional advisers (lawyers, auditors, accountants) under confidentiality;
• Law enforcement, regulators, and governmental authorities where required by law or to protect rights and safety;
• Entities involved in a business transfer (merger, acquisition, restructuring), subject to continued protection of your data.

We only share data with third parties who are bound by data protection and confidentiality obligations and who may process data only for the purposes we specify.

We use cookies and similar tracking technologies to improve your experience on the CYCLUNO platform, enhance security, remember your preferences, analyze usage patterns, and support our marketing and analytics operations.

Cookies enable us to:

• recognize your device and maintain your logged-in session;
• provide location-based results such as nearby properties and agents;
• prevent fraudulent activity and protect user accounts;
• understand how users interact with the platform so we can improve our services.

These cookies do not store personal information in plain form; instead, they store unique identifiers that help us improve your experience.

A. Type of cookies we use

Cycluno processes Personal Data and Customer Data in accordance with applicable United States federal and state privacy laws, including the laws of the State of Delaware, as well as internationally recognized data protection principles where applicable.

In particular, Cycluno adheres to the following governing principles:

• Your personal data is collected and processed in accordance with specific, legitimate and lawful purpose consented to by you, provided that further processing may be done by archiving the data for public interest, scientific or research purposes, or statistical purposes.
• The data collected is adequate, accurate and without prejudice to the dignity of the human person.
• The data collected is stored only for the period within which it is reasonably needed.
• The data collected is secured against all foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, manipulations of any kind, and damage by rain, fire or exposure to other natural elements.
• We owe a duty of care to you in respect of the data we have obtained from you.

We have put in place various security procedures as set out in this policy.

• Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site safe as possible.
• We use regular malware scanning.
• Your Personal Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology.
• All transactions are processed through a gateway provider and are not stored or processed on our servers.

In addition to the security measures we employ, you must also ensure that you take responsibility for the protection of your personal information. We will not be liable for any loss or damage caused by the activities of hackers when we have taken all necessary and reasonable steps to protect your information in our possession. You are also responsible for safeguarding your account.

Our platform may contain links to third-party websites. We are not responsible for the privacy practices or content of such third parties, and encourage you to review their privacy policies.

By providing us with your personal information, you have certain rights in accordance with the provisions of the Regulations which include:

• the right to request access to your personal data in our possession;
• the right to object to or request restriction of the processing of your personal data;
• the right to request rectification and modification of personal information which CYCLUNO keeps.
• the right to request for the deletion of your personal data in our possession;
• the right to request the transfer of your personal data to you or to a third party;
• the right to withdraw your consent at any time where we are relying on consent to process your personal data;

To exercise any of the rights listed here, please contact us through the details provided below.

You have the right to opt-out of receiving the informative materials we send to our users by clicking the “Unsubscribe” button found at the bottom of such emails. You also have the right to decline to provide your personal Information when it is requested, however, certain services or all the services may be unavailable to you. You may exercise these rights by contacting our Data Protection Officer (see Clause 12)

Cycluno operates globally and may process Personal Data in the United States and other jurisdictions. Where data is transferred internationally, we implement appropriate safeguards such as contractual protections, security measures, and recognised transfer mechanisms to ensure lawful and secure processing.

We retain Personal Data only for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, maintain security, and enforce agreements. Customer Data may be deleted or exported upon account termination, subject to contractual and legal requirements.

This includes retaining information related to:

• communication logs, support requests, and service interactions;
• payment records, commissions, fees or deposits processed through the platform;
• analytics and operational logs required to improve our services.

CYCLUNO may retain certain data after you close your account where necessary to:

• comply with statutory requirements,
• respond to legal claims or regulatory enquiries;
• investigate fraud, illegal activity, or misuse of the platform;
• maintain business records for auditing and compliance.

At the end of the retention period, your data will be securely deleted, anonymized, or archived in accordance with applicable laws.

We conduct regular reviews to ensure data retained remains accurate, relevant, and necessary. Your data may be stored for longer if:

• it is required under an ongoing contractual relationship;
• a statutory or regulatory retention period applies;
• deletion is requested but cannot be effected due to legal or compliance restrictions; or
• We have another lawful basis to retain the data.

If you have any question, request or complaints, or you require further information not already provided in this Privacy Policy, please contact our Data Protection Officer (DPO) by sending an email to business@testifyltd.com.

We maintain a data breach procedure in order to deal with incidents concerning personal information or practices leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information transmitted, stored or otherwise processed. You may contact our DPO upon becoming aware of any breach of personal information or if your access credentials have been compromised, to enable us to take the necessary steps towards ensuring the security of your personal information or account.

We may update this Privacy Policy from time to time. Where material changes are made, we will notify you by email, app notification, or website notice before such changes take effect.