The Official Site Of NAIT (Native AI Teams)

Privacy Policy & Terms of Service

Last updated: July 12, 2026

1. Data controller

The data controller is x321 (NAIT — Native AI Teams), operator of x321.org, pl.x321.org and x321.app (“we”). For any personal-data matter, contact us at contact@x321.org.

2. Scope of this policy

This policy covers: (a) our websites, (b) our apps for the Shopify platform — Smart Spin Wheel and Lead Popup, (c) our custom software development services.

3. What we process on our websites and why

  • Contact form — name, e-mail address, subject and message. Purpose: responding to your inquiry and follow-up correspondence. Legal basis: Art. 6(1)(b) or (f) GDPR.
  • Comments — the comment text, form data, IP address and browser identifier (spam protection). Legal basis: Art. 6(1)(f) GDPR.
  • Server logs — IP address, browser identifier, requested URLs. Purpose: security and diagnostics. Legal basis: Art. 6(1)(f) GDPR.
  • Analytics (Google Analytics 4) — _ga/_gid cookies and site-usage data. Loaded only after you consent in the consent manager. Legal basis: Art. 6(1)(a) GDPR.
  • Embedded content (YouTube) — loaded only after consent; once loaded, the provider may collect data under its own privacy policy.

4. Consent management (cookies)

We use the Klaro consent manager. Analytics and external content are off by default and only run after you opt in. You can change or withdraw your decision at any time by reopening the privacy settings dialog on this site.

5. Shopify apps (Smart Spin Wheel, Lead Popup)

For data processed by our Shopify apps we generally act as a processor on behalf of the merchant (store owner), who remains the controller of their customers’ data.

  • Store data — store domain, account data required for the app to function, configuration. Purpose: providing and billing the service.
  • Store customers’ data — e.g. e-mail addresses submitted through a spin wheel or popup. We process them solely to operate the app and make them available to the merchant; we never use them for our own marketing and never sell them.
  • Shopify GDPR requests — we honour the mandatory customers/data_request, customers/redact and shop/redact webhooks. Customer data is erased on request; store data is erased no later than 30 days after receiving shop/redact following uninstallation.

6. Custom software services

We process client and contact-person data as needed to prepare proposals and perform contracts (Art. 6(1)(b) GDPR) and for accounting obligations required by law (Art. 6(1)(c) GDPR). Data entrusted to us within client projects is processed under the applicable data-processing agreements.

7. Recipients and transfers outside the EEA

Data may be processed by our service providers: hosting (Hostinger), Google (Google Analytics 4) and Shopify (app platform) — only to the extent described above. For providers outside the European Economic Area (e.g. Google LLC, Shopify Inc.), transfers rely on an adequacy decision (EU–US Data Privacy Framework) or standard contractual clauses.

8. Retention periods

  • Contact-form correspondence — up to 24 months after the matter is closed.
  • Analytics data — up to 14 months (Google Analytics 4 settings).
  • Shopify app data — for as long as the app is installed, plus up to 30 days after uninstallation.
  • Server logs — per the hosting provider’s retention policy.

9. Your rights

You have the right to access, rectify, erase and port your data, to restrict or object to its processing, and to withdraw consent at any time (without affecting the lawfulness of processing before withdrawal). You may also lodge a complaint with your supervisory authority. Send requests to contact@x321.org.

10. Terms of service

  1. This site presents our business (SaaS products, Shopify apps, software development services) together with editorial and news content.
  2. Using the site is free of charge and requires no registration. Individual products (including our Shopify apps) are governed by their own terms.
  3. Content published on this site is protected by copyright; copying or redistribution requires our consent.
  4. Site content is informational and does not constitute professional advice; we accept no liability for consequences of its use.
  5. Some links are affiliate links — they cost you nothing and help support the platform.
  6. Contact for all matters: contact@x321.org.

11. Changes to this policy

We may update this policy as our products and services evolve. The current version is always available at this address, together with its last-updated date.