Last updated: May 2026 · Applies to: valoxi.ai and app.valoxi.ai
Privacy Policy
1. Who we are
Valoxi is a global platform for SME acquisitions, built to serve dealmakers across multiple markets. We are incorporated in the United States as ADJV LLC (registration number: 0008087631), a limited liability company registered in the State of New Mexico, whose registered address is 1209 Mountain Rd PL NE STE R, Albuquerque, NM 87110. ADJV LLC is the data controller for personal data collected through this website and platform.
Our platform has been designed from the outset to meet the data protection standards of the jurisdictions we operate in, including the United Kingdom, the European Economic Area, and the United States. We launched first in the UK because of an established user base here, and UK GDPR compliance is therefore our immediate primary obligation. As we expand into additional markets, we will maintain the same standard of data protection across all regions.
We are subject to UK GDPR by virtue of Article 3, which applies to any organisation targeting UK residents regardless of where it is incorporated. We treat that obligation seriously.
UK GDPR Article 27 Representative
As required under UK GDPR Article 27, we have designated a representative in the United Kingdom for matters relating to data protection:
- Name: Vivek Kuvelker
- Role: CTO, ADJV LLC trading as Valoxi
- Contact: data-protection@valoxi.ai
UK and EEA users may contact Vivek Kuvelker directly with any data protection queries, including requests to exercise your rights under UK GDPR.
General enquiries: hello@valoxi.ai
2. What this policy covers
This policy explains what personal data we collect, why we collect it, how we use it, who we share it with, how long we keep it, and your rights. It applies to personal data collected when you use this website and the Valoxi platform, including when you submit a request for access, create an account, use any features of the platform, or contact us.
We serve users in multiple jurisdictions. This policy sets out our baseline approach applicable to all users. Additional rights that apply to users in specific jurisdictions, including California, are set out at the end of this policy.
3. Data we collect
Data you provide directly
- — Name and email address, when you request access or create an account
- — Company name, role, and deal stage, from the request access form
- — Payment information, processed by Stripe; we do not store card details
- — Communications, emails and messages you send to us
Data collected through your use of the platform
- — Account activity: logins, feature usage, deal records created
- — Documents uploaded: all files you upload in connection with a deal
- — Analysis outputs: the results generated from your documents
- — Technical data: IP address, browser type, device type, referral source
Special notice: uploaded documents
Documents you upload to the platform may contain personal data relating to third parties, including employees, directors, and customers of target businesses. As the uploader, you are responsible for ensuring you have a lawful basis to share that data with us for processing. We process such documents solely to provide the Service to you.
We do not use documents or data you upload to train, fine-tune, or improve any AI model. Your documents are processed for the sole purpose of generating the analysis you request.
4. How we use your data
Transactional vs marketing emails
We send two distinct categories of email and each has its own legal basis.
Transactional emails (account confirmations, billing receipts, security notices, and service updates that affect your use of the platform) are sent on the basis of contract performance under UK GDPR Article 6(1)(b) and are not affected by marketing preferences.
Marketing emails (product news, feature announcements, and useful resources) are sent only with your consent under UK GDPR Article 6(1)(a). You can withdraw that consent at any time by clicking unsubscribe in any marketing email or by emailing hello@valoxi.ai. Unsubscribing from marketing does not stop transactional emails.
To provide and operate the platform
Legal basis (UK GDPR): Performance of contract, Article 6(1)(b)
- — Creating and managing your account
- — Processing documents and generating analysis
- — Processing subscription payments
- — Providing customer support
To communicate with you
Legal basis (UK GDPR): Legitimate interests, Article 6(1)(f)
- — Responding to your enquiries and support requests
- — Sending service updates and security notices
To send marketing communications
Legal basis (UK GDPR): Consent, Article 6(1)(a) where required; legitimate interests otherwise for existing subscribers
Product updates and feature announcements are sent only if you have opted in or are an existing subscriber. You can withdraw consent or opt out at any time by emailing hello@valoxi.ai or clicking unsubscribe in any email we send.
To improve the platform
Legal basis (UK GDPR): Legitimate interests, Article 6(1)(f)
We analyse aggregated, anonymised usage data to understand how the platform is used. We do not use your uploaded documents or deal-specific data for this purpose.
To comply with legal obligations
Legal basis (UK GDPR): Legal obligation, Article 6(1)(c)
Retaining financial and business records as required by applicable law; responding to lawful requests from regulators or law enforcement.
5. Data storage and locations
We use a combination of infrastructure providers across different geographic regions. The table below sets out where different categories of your data are stored and processed.
| Data layer | Provider | Location | What is stored |
|---|---|---|---|
| Document storage | Cloudflare R2 | Western Europe | NDAs, offer letters, heads of terms, uploaded company documents |
| Application and database | Replit | United States | Account data, deal metadata, financial inputs, AI analysis outputs |
| AI processing | Google Gemini | Global (Google infrastructure) | Document content during analysis only; not stored after processing |
| Authentication | Clerk | United States | User identity, SSO session data |
| Email delivery | Resend | United States | Transactional email logs and delivery receipts |
| Payments | Stripe | United States | Billing and subscription data only; no card numbers stored by us |
In practical terms: documents you upload to the platform are stored in Western Europe and never leave that region. When AI analysis runs, document content travels to Google's infrastructure solely for the duration of that analysis and is not stored afterwards. Analytical outputs and account data are processed on US-hosted infrastructure.
6. Who we share your data with
We do not sell your personal data. We share it only with the sub-processors listed below, each of whom processes data as our processor under a data processing agreement. Our full Data Processing Agreement is available at valoxi.ai/dpa.
| Sub-processor | Purpose | Location | DPA |
|---|---|---|---|
| Cloudflare, Inc. | File storage (document uploads) | Western Europe | View DPA |
| Replit, Inc. | Application hosting and database | United States | View DPA |
| Google LLC (Gemini API) | AI document analysis | Global | View DPA |
| Clerk, Inc. | User authentication and identity | United States | View DPA |
| Resend, Inc. | Transactional email delivery | United States | View DPA |
| Stripe, Inc. | Payment processing | United States | View DPA |
We also share data with professional advisers (attorneys, accountants, and insurers) where necessary under obligations of confidentiality, and with regulators and law enforcement where required by law, court order, or regulatory requirement.
7. International data transfers
ADJV LLC is based in the United States. When UK or other non-US users interact with the platform, personal data is transferred to and processed in the United States by certain sub-processors.
For transfers of UK personal data to the US, we rely on the following mechanisms:
- — Cloudflare: Standard Contractual Clauses (SCCs) incorporated into Cloudflare's Data Processing Addendum
- — Google LLC (Gemini API): Google's Data Processing Addendum for Products Where Google is a Data Processor, incorporating SCCs and UK supplementary terms (applicable to paid tier usage)
- — Replit: Data Processing Agreement incorporating standard data protection terms
- — Clerk: Data Processing Agreement incorporating SCCs
- — Resend: Data Processing Agreement incorporating SCCs
- — Stripe: Data Processing Agreement incorporating SCCs and the UK International Data Transfer Addendum
Links to each sub-processor's DPA are provided in the table in section 6 above.
8. How long we keep your data
- — Account data: duration of subscription plus 3 years after closure
- — Uploaded documents and analysis outputs: duration of subscription, then deleted within 30 days of account closure
- — Payment records: 7 years as required by applicable law
- — Communications: 3 years from last contact
- — Technical logs: 12 months
You can request deletion of your data at any time by contacting hello@valoxi.ai, subject to any legal obligations that require us to retain certain records.
9. Your rights
UK users, rights under UK GDPR
- — Access: to obtain a copy of your personal data
- — Rectification: to correct inaccurate data
- — Erasure: to request deletion in certain circumstances
- — Restriction: to request we limit how we use your data
- — Portability: to receive your data in a portable format
- — Object: to processing based on legitimate interests
- — Automated decisions: to request human review of solely automated decisions that significantly affect you
To exercise these rights, contact data-protection@valoxi.ai. We will respond within one calendar month. If unsatisfied, you may complain to the Information Commissioner's Office at ico.org.uk.
All users, general rights
Regardless of your location, you may contact us at hello@valoxi.ai to request access to, correction of, or deletion of your personal data. We will respond within a reasonable timeframe and in accordance with applicable law.
10. Security
We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, or disclosure, including encryption of data in transit and at rest and access controls at the deal level.
In the event of a data breach likely to affect your rights and freedoms, we will notify affected users and relevant regulators as required by applicable law, including within 72 hours to the ICO for breaches affecting UK residents.
11. Cookies
We use cookies on this website. Please see our Cookie Policy for full details.
12. California residents, additional rights
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):
- — The right to know what personal information we collect, use, disclose, and sell
- — The right to delete personal information we hold about you
- — The right to correct inaccurate personal information
- — The right to opt out of the sale or sharing of your personal information
- — The right to limit use of sensitive personal information
- — The right to non-discrimination for exercising your privacy rights
We do not sell or share personal information as defined under CCPA. Categories of personal information we collect include: identifiers (name, email, IP address), commercial information (subscription and payment records), and internet or electronic network activity (usage logs). We do not collect sensitive personal information as defined under CPRA.
To exercise your California privacy rights, contact hello@valoxi.ai with the subject line ‘California Privacy Request’.
13. Changes to this policy
We may update this policy from time to time. We will notify you of material changes by email. The ‘last updated’ date at the top of this page shows when it was most recently revised.
14. Contact
Questions about this policy or your personal data: hello@valoxi.ai
Data protection enquiries: data-protection@valoxi.ai
Registered legal entity: ADJV LLC (trading as Valoxi) · Registration no. 0008087631 · 1209 Mountain Rd PL NE STE R, Albuquerque, NM 87110, United States.