Privacy Policy

Last Updated: September 8, 2026

This Privacy Policy for 7x Systems LLC (“we,” “us,” or “our”) describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

• Visit our website at aisimple.co, or any website of ours that links to this Privacy Policy
• Use AI Simple, our consulting, coaching, and AI implementation services platform
• Use Swipe Inbox (swipe.aisimple.co), our email management and AI automation platform
• Engage with us in other related ways, including any sales, marketing, or events

If you have questions or concerns, please contact us at me@andrewnaegele.com.

AI Action Plan assessment. When you start an assessment, we save your name and email before collecting workflow answers. Completed screens are saved so you can resume in the same browser. We use your answers to recommend preparation resources or a discovery conversation and to prepare for any assessment you request. A necessary, secure session cookie expires after seven days. Payment details are entered on Stripe; we keep the payment status and order reference. Please describe your process without including passwords, customer records, or other sensitive information. Contact us at me@andrewnaegele.com to request access, correction, or deletion of your information.

What Information Do We Collect?

Personal information you disclose to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products, participate in activities on the Services, or otherwise contact us.

Personal information provided by you. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Email addresses
• Phone numbers
• Mailing addresses
• Usernames and passwords
• Billing addresses and payment information (credit card numbers, transaction history)
• Contact or authentication data

Payment data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by our payment processor (Stripe). You may find their privacy notice at https://stripe.com/privacy.

Information automatically collected. We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information, such as:

• IP addresses
• Browser and device characteristics (type, operating system, language preferences)
• Referring URLs
• Country, location, and time zone
• Information about how and when you use our Services
• Device identifiers
• Pages and features accessed
• Click and scroll behavior

How Do We Process Your Information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To provide and maintain our Services– Including account creation, authentication, and delivering AI Simple features
• To improve and develop our Services– To understand how users interact with our platform so we can enhance functionality and user experience
• To communicate with you– To send you service-related information, updates, marketing communications, and respond to your inquiries
• To process transactions– To manage payments, refunds, and billing
• For security and fraud prevention– To protect our Services, detect and prevent fraudulent activity, and ensure the safety and integrity of our platform
• To comply with legal obligations– To respond to legal requests and prevent harm as required by applicable law
• To power AI features– To provide AI-powered automation, content generation, and related features through third-party AI platforms

What Legal Bases Do We Rely On?

We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law. Depending on your location, the applicable legal basis may include:

• Consent– You have given us permission to process your personal information for a specific purpose. You may withdraw your consent at any time.
• Contractual necessity– Processing your information is necessary to fulfill our contractual obligations to you (e.g., providing the Services you purchased).
• Legitimate interests– Processing is necessary for our legitimate business interests, such as improving our Services, marketing, fraud prevention, and security, provided those interests are not overridden by your rights.
• Legal obligations– Processing is necessary to comply with applicable laws, regulations, or legal processes.

When and With Whom Do We Share Your Information?

We may share your information in the following situations:

• Analytics providers– We use third-party analytics services (e.g., Google Analytics) to help us understand how our Services are used.
• Payment processors– We share payment information with our payment processor (Stripe) to process transactions securely.
• AI platforms– We use third-party AI services, including Anthropic, OpenAI, Google Cloud AI, and similar AI platforms, to power AI-driven features within our Services. Data shared with these providers is limited to what is necessary for the feature to function.
• Cloud and hosting services– We use cloud infrastructure providers to host and deliver our Services.
• Email and communication services– We use third-party email service providers to send transactional and marketing communications.
• Business transfers– We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
• Legal requirements– We may disclose your information where required to comply with applicable laws, governmental requests, judicial proceedings, court orders, or legal processes.

Email Service Data (Swipe Inbox)

When you connect an email account to Swipe Inbox (swipe.aisimple.co), we access and process the following:

What we access:

• Email metadata (sender, recipient, subject, timestamps, labels/folders)
• Email content (for AI processing, rule evaluation, and swipe file extraction)
• Calendar data (for meeting briefings and availability checking)
• Contact information (for sender categorization)

What we store:

• Sender email addresses (for analytics, bulk unsubscribe, and sender categorization)
• Email summaries and AI analysis (for automation rules and personalized features)
• Swipe file extracts (marketing emails you explicitly save for reference)
• Email metadata for automation rules and insights

What we do NOT store:

• Full email body text beyond active feature processing
• Email content after rule evaluation completes (temporary processing only)

Data Controller vs Data Processor:

• For your account information (registration, authentication, usage patterns): we act as the Data Controller under GDPR.
• For email content and account data you submit to use our services: we act as the Data Processor on your behalf. You (or your organization) are the Data Controller.

Google API Services Compliance

Swipe Inbox's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

We use Google API data to:

• Read emails for AI processing and rule evaluation
• Send emails as directed by you
• Manage labels and categories
• Access metadata for automation

We do NOT use Google API data for advertising, and do not share it with third parties except as described in this policy for service delivery.

Microsoft Graph API Compliance

Swipe Inbox's use of information received from Microsoft Graph API adheres to Microsoft's data handling requirements and the Microsoft API Terms of Use.

AI Model Data Sharing

We use third-party AI services (including Google Gemini, OpenAI, and Anthropic) to power AI-driven features including email categorization, draft generation, and automation rules.

Data shared with AI providers:

• Email subject lines and body text (for processing)
• Sender and recipient information
• Your knowledge base entries (for personalized draft generation)

Zero Data Retention: Our AI providers are contractually required to process data only for service delivery. They do not use your data for model training and do not store it beyond what is necessary for abuse monitoring.

International Data Transfers

For users in the EEA, UK, or other non-US jurisdictions, personal data may be transferred to the United States. We protect international transfers through:

• Standard Contractual Clauses (European Commission-approved contracts)
• EU-US Data Privacy Framework participation by our service providers
• Appropriate technical and organizational security measures

Do We Use Cookies and Tracking?

Yes. We may use cookies, web beacons, pixels, and similar tracking technologies to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

We use both session and persistent cookies for the purposes set out below:

• Essential cookies– Required for the operation of our Services (authentication, security, load balancing).
• Analytics cookies– Help us understand how visitors interact with our Services by collecting and reporting information.
• Advertising cookies– Used to deliver relevant advertisements and track ad campaign performance.
• Functional cookies– Enable enhanced functionality and personalization (e.g., remembering your preferences).

How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If deletion is not immediately possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

As a general guideline, we retain personal information for up to 24 months following account termination or your last interaction with our Services, unless a longer period is required by law.

How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

What Are Your Privacy Rights?

Depending on your location and applicable law, you may have the following rights regarding your personal information:

• Right to access– You may request a copy of the personal information we hold about you.
• Right to correction– You may request that we correct any inaccurate or incomplete personal information.
• Right to deletion– You may request that we delete your personal information, subject to certain exceptions.
• Right to restrict processing– You may request that we restrict the processing of your personal information.
• Right to data portability– You may request a copy of your data in a structured, commonly used, and machine-readable format.
• Right to opt out– You may opt out of marketing communications at any time by clicking the unsubscribe link in our emails or contacting us directly.
• Right to withdraw consent– Where we rely on your consent to process your personal information, you may withdraw your consent at any time.

To exercise any of these rights, please contact us at me@andrewnaegele.com. We will respond to your request within 30 days.

Account information. If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

US State Privacy Rights

California residents. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below.

CCPA / CPRA. If you are a resident of California, you have specific rights regarding access to your personal information under the California Consumer Privacy Act (as amended by the California Privacy Rights Act). You have the right to request disclosure of what personal information we collect, use, disclose, and sell; the right to request deletion of your personal information; and the right to not be discriminated against for exercising your privacy rights.

Other US states. Residents of Colorado, Connecticut, Utah, Virginia, and other states with comprehensive privacy laws may have similar rights to access, correct, delete, and opt out of certain processing activities. To exercise these rights, please contact us at the information provided below.

Do We Make Updates to This Notice?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Last Updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

Governing Law

This Privacy Policy and any disputes arising out of or related to it shall be governed by and construed in accordance with the laws of the State of Wyoming, United States, without regard to its conflict of law principles.

How Can You Contact Us?

If you have questions or comments about this Privacy Policy, you may contact us at:

7x Systems LLC
1309 Coffeen Ave, Sheridan, WY 82801
Phone: (+1) 307-218-2437
Email: me@andrewnaegele.com
Website: aisimple.co

How Can You Review, Update, or Delete Your Data?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at me@andrewnaegele.com.

We will respond to your request within 30 days. In some cases, we may need to verify your identity before processing your request. If we are unable to fulfill your request, we will provide you with an explanation.

7x Systems LLC · 1309 Coffeen Ave, Sheridan, WY 82801