This GDPR Compliance Notice is directed at Users who are habitually resident in the European Economic Area (EEA), the United Kingdom, or Switzerland. It supplements the Privacy Policy and is issued pursuant to the General Data Protection Regulation (EU) 2016/679 and the UK GDPR.
Article I
GDPR Applicability and Stance
The Offline Advantage
The Ivory Index is architecturally designed to process student data exclusively on the User's local device. Where this architecture operates as intended, certain GDPR obligations are materially reduced in scope — specifically those concerning server-side data transfers, cross-border data flows, and processor-side breach notification, as these obligations presuppose that a controller or processor holds data on infrastructure it controls. GDPR questions may nonetheless arise in relation to the Software as a tool that determines the means and purposes of on-device processing, and IECC does not represent that GDPR obligations are entirely absent. This notice addresses those obligations to the extent they apply.
1.1AOArose acknowledges the applicability of the GDPR and UK GDPR to the extent it processes personal data of EEA and UK residents in connection with the website ivory.aoarose.com and direct communications.
1.2The Ivory Index is operated by IECC or its designated operating entity, with intended domicile in India. IECC's formal registration is subject to finalisation upon commercial launch. AOArose does not operate a European establishment, does not target EEA residents as a primary audience, and does not systematically monitor EEA individuals. AOArose voluntarily applies GDPR-equivalent standards as a matter of best practice pending formal launch and jurisdictional registration.
Article II
Data Controller Details
| Field | Detail |
|---|---|
| Controller Name | Imperial Eminence Cyberguard Corporation (IECC) |
| Operated under | AOArose · A Division of Voidreign Institute |
| Contact | legal@imperialecc.com |
| Privacy Contact | IECC Privacy Team — legal@imperialecc.com (Note: IECC does not formally designate a Data Protection Officer at this stage. The Privacy Contact is the point of contact for all data protection enquiries and exercises of data subject rights.) |
| EU/UK Representative | To be appointed upon triggering of Article 27 GDPR obligations |
| Supervisory Authority | Relevant national DPA in the User's jurisdiction (e.g., ICO for UK) |
Article III
Legal Bases for Processing
3.1Contractual necessity (Article 6(1)(b) GDPR): Processing of contact emails and correspondence is necessary to respond to your enquiry and to perform our obligations under the Terms of Service.
3.2Legitimate interests (Article 6(1)(f) GDPR): We process minimal contact data in our legitimate interest of operating and improving the Software and responding to user support requests, provided such interests are not overridden by your fundamental rights and freedoms.
3.3Local device processing: All personal data entered into The Ivory Index is processed on your device under your own control. AOArose is not the controller of this data. You are the sole controller of your own local data.
Article IV
International Data Transfers
4.1Where any personal data (such as contact emails) is received by AOArose or IECC, such data is handled under AOArose's commitment to GDPR-equivalent standards. As pre-launch digital structures with intended domicile in India, AOArose and IECC are not subject to a formal adequacy decision framework. Any such transfer is made on the basis of AOArose's voluntary application of data minimisation, purpose limitation, and storage limitation safeguards equivalent in effect to GDPR Chapter V requirements.
4.2Upon formal incorporation and launch, AOArose will review and update its international transfer mechanisms and, where required, implement Standard Contractual Clauses or seek an applicable adequacy finding for its registered jurisdiction.
Article V
Your GDPR Rights
5.1Under the GDPR you have the right to: (a) Access your personal data held by AOArose (Article 15); (b) Rectification of inaccurate data (Article 16); (c) Erasure ("right to be forgotten") (Article 17); (d) Restriction of processing (Article 18); (e) Data portability in a structured, machine-readable format (Article 20); (f) Object to processing based on legitimate interests (Article 21); (g) Withdraw consent at any time where processing is based on consent; (h) Lodge a complaint with your national supervisory authority.
5.2To exercise any right, contact legal@imperialecc.com. We will respond within one (1) calendar month of receiving your verified request, as required by Article 12(3) GDPR.
5.3We will not charge a fee for exercising your rights unless the request is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee or refuse to act, providing written reasons.
Article VI
Special Category Data
6.1The Software may store data that constitutes special category data under Article 9 GDPR (e.g., financial information, disability status, nationality) in your local ~/.theivorry/ directory. As AOArose does not receive or access this data, Article 9 safeguards are the User's own responsibility at the device level. AOArose recommends full-disk encryption for all devices running The Ivory Index.