Privacy Policy
Legal entity MB dimartec
Company code 305594435
Registered 27 July 2020
Address V. Nagevičiaus g. 3, LT-08237 Vilnius, Lithuania
Privacy contact info@sixwings.ai
We are the data controller for personal data described in this policy. This policy is governed by the laws of the Republic of Lithuania and the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR").
If ownership of SixWings transfers to a new legal entity, this policy will be updated and the new controller identified.
1. Scope
This policy covers the SixWings website, the SixWings web application, and related communications. It does not cover third-party websites we link to.
2. Data we collect
2.1 Account and billing data
- Name, work email, company name, job title
- Login credentials (passwords stored hashed) or third-party sign-in identifiers
- Subscription plan, invoices, billing address, VAT number
- Payment card data is entered directly with our payment processor. We never store full card numbers.
2.2 Customer-supplied brand and content data
Data you or your team upload, connect, or enter so SixWings can perform Generative Engine Optimization (GEO) analysis, including:
- Your brand, domain, product and positioning information
- Website, content and copy you submit or that we retrieve from your public site
- Competitor names, domains and public content
- Prompts, queries and topics you want tracked in AI answer engines
- Reports, scores and citation data generated from the above
This data is normally business information rather than personal data. If it contains personal data (for example named authors, customer testimonials, or contact details inside uploaded content), we process it as a processor on your behalf, under your instructions.
2.3 Usage and technical data
- IP address, browser and device type, language, approximate location
- Pages viewed, features used, timestamps, error and performance logs
- Cookies and similar technologies (see Section 8)
2.4 Communications
Emails, support messages, meeting notes and demo-call information you share with us.
3. Third-party AI and LLM processing
SixWings works by querying and analysing large language models and AI answer engines. To deliver the service:
- We send prompts, brand names, domains, competitor references and content you supply to third-party AI providers (for example OpenAI, Anthropic, Google, Perplexity and similar answer engines).
- These queries may be transmitted outside the EEA (see Section 7).
- We use business/enterprise API tiers where available and select providers that contractually commit not to train their models on API data. We cannot guarantee the internal behaviour of any third-party model.
Do not submit special category data, health data, financial account data, government identifiers, or confidential personal data into SixWings inputs. The service is not designed for that data.
4. Why we process data and our legal bases
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Creating and running your account | Contract |
| Delivering GEO analysis, tracking and reports | Contract |
| Billing, invoicing, tax and accounting records | Contract; legal obligation |
| Sending prompts/content to AI providers to produce results | Contract |
| Product security, abuse prevention, logging | Legitimate interests |
| Improving and debugging the product using aggregated or pseudonymised usage data | Legitimate interests |
| Marketing emails to business contacts and existing customers | Legitimate interests; consent where required |
| Non-essential cookies and analytics | Consent |
| Responding to legal requests, defending claims | Legal obligation; legitimate interests |
You may withdraw consent at any time. Withdrawal does not affect processing already carried out.
5. Sharing and processors
We do not sell personal data. We share it only with:
- Hosting and infrastructure — including Hostinger (domain and web hosting) and our application hosting and database providers
- AI and answer-engine providers — as described in Section 3
- Payment and invoicing providers
- Analytics, email, CRM and support tools used to run the business
- Professional advisers (accounting, legal) and authorities where legally required
- A successor entity if SixWings is transferred, restructured, or acquired
All processors act under written data processing agreements consistent with GDPR Art. 28. A current list of subprocessors is available on request from info@sixwings.ai.
6. Retention
| Data | Retention |
|---|---|
| Account data | Duration of the account, then up to 12 months |
| Customer-supplied brand/content data and reports | Duration of the account; deleted or returned within 30 days of termination on request |
| Billing and accounting records | 10 years (Lithuanian accounting law) |
| Server and security logs | Up to 12 months |
| Marketing contact data | Until you unsubscribe or object |
7. International transfers
Some providers, particularly AI and analytics vendors, process data outside the European Economic Area (including the United States). Where that happens we rely on:
- an EU adequacy decision (for example the EU–US Data Privacy Framework, where the provider is certified), or
- the European Commission's Standard Contractual Clauses plus supplementary safeguards.
You can request details of the transfer mechanism used for a specific provider.
8. Cookies
We use:
- Essential cookies — login, session, security. Always active.
- Analytics cookies — how the product and site are used.
- Marketing cookies — measuring campaigns and ads.
Non-essential cookies are set only after consent. You can change or withdraw consent via the cookie banner or your browser settings.
9. Your rights
Under GDPR you have the right to:
- access your personal data
- correct inaccurate data
- request erasure
- restrict or object to processing, including profiling and direct marketing
- receive your data in a portable format
- withdraw consent
- not be subject to solely automated decisions with legal or similarly significant effects — SixWings does not make such decisions about individuals
To exercise any right, email info@sixwings.ai. We respond within one month. We may ask you to verify your identity.
You can complain to the Lithuanian State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija), L. Sapiegos g. 17, Vilnius — ada.lt — or to the supervisory authority where you live.
10. Security
Measures include encryption in transit, access controls and least-privilege permissions, hashed credentials, logging and monitoring, vendor due diligence, and backups. No system is perfectly secure. We will notify affected users and the supervisory authority of a personal data breach where GDPR requires it.
11. Children
SixWings is a B2B product and is not intended for anyone under 16. We do not knowingly collect their data.
12. Changes
We may update this policy. Material changes will be notified by email or in-app at least 14 days before taking effect. The "Last updated" date always reflects the current version.
13. Contact
MB dimartec (SixWings)
V. Nagevičiaus g. 3, LT-08237 Vilnius, Lithuania
Company code 305594435
info@sixwings.ai
