Privacy Policy (Document 01)
Effective date: 1 February 2026 · Controller: 7EulerianStrategies Ltd.
This Privacy Policy describes how 7EulerianStrategies Ltd. (“7EulerianStrategies”, “we”, “us”, “our”) processes personal data in connection with the VIRGIL autonomous compliance automation platform, related websites, and associated services.
Who we are
Eulerian Holdings Ltd. is a company registered in United Kingdom with registered office at 6 Mitchell Close, Slough, SL19DY and company number 16551691. For many of our services we act as a data controller for business contact and account data, and as a data processor when processing transaction, KYC, AML, and compliance data on behalf of FCA-authorised fintechs, EMIs, BaaS operators, and regulated firms.
Contact for privacy enquiries: mitual@7eulerianstrategies.com / teghvir@7eulerianstrategies.com
Data we process
- Account & contact data — name, role, business email and phone, employer, and access permissions.
- Platform & usage data — login timestamps, IP address, device/browser information, feature usage, configuration and workflow data, support history.
- Compliance, transaction, and AML data — transaction records, KYC artefacts, SAR drafts, regulatory submissions, and audit evidence supplied by our customers under data processor arrangements.
- Cookie & analytics data — online identifiers, website interaction data, cookie preferences (see Cookie Policy).
Purposes and legal bases
- Provide and operate VIRGIL and related compliance automation services (contract, legitimate interests).
- Secure and monitor the platform (legitimate interests, legal obligations).
- Improve our products using aggregated or anonymised insights (legitimate interests, consent where required).
- Manage sales, marketing, and client relationships (consent or legitimate interests, subject to opt–out).
- Meet legal, regulatory, and audit requirements (legal obligations, legitimate interests).
Terms of Service (Document 02)
Effective date: 1 February 2026
These Terms govern access to and use of the VIRGIL platform, APIs, and related compliance automation services provided by 7EulerianStrategies Ltd. to business customers.
AI, agents, and outputs
VIRGIL uses an agentic AI engine with four consensus agents to generate risk scores, AML alerts, SAR drafts, and audit evidence packs. These Outputs support but do not replace professional judgment in compliance, AML, and regulatory decisions. MLRO sign-off remains the responsibility of the designated individual under FCA MLRO Rules.
Limitations and liability
VIRGIL is provided “as is” and “as available” to the extent permitted by law. We do not guarantee that all regulatory obligations, AML anomalies, or compliance risks will be detected, or that Outputs will be error–free.
Security Practices Overview (Document 04)
Effective date: 1 February 2026
Data protection and hosting
- Encryption in transit via TLS for all public–facing endpoints.
- Encryption at rest (e.g. AES–256) for databases and storage containing Customer Data.
- Multi–region hosting options to support UK and EU clients with jurisdiction-specific data residency requirements.
Cookie Policy
Effective date: 1 February 2026
We use cookies and similar technologies on VIRGIL websites and web applications to operate the site, improve performance, and support business–to–business analytics and marketing.
Types of cookies
- Strictly necessary — required for sign–in, security, and core functionality.
- Performance & analytics — help us understand usage and improve experience.
- Functionality — remember preferences such as language and region.
- B2B marketing — limited use to understand which organisations engage with our content.
Sub–Processors & Data Processing Addendum
Effective date: 1 February 2026
Sub–processors list
The following third–party sub–processors process personal data on our behalf. This list is current as of 1 February 2026 and is updated whenever sub–processors are added or changed.
| Sub–Processor |
Service |
Data Processed |
Location |
Safeguard |
| Formspree Inc. |
Contact form handling |
Name, work email, company, enquiry content |
US |
SCCs / Formspree DPA |
| Web3Forms |
Newsletter subscription handling |
Email address, consent timestamp |
US |
SCCs / Web3Forms ToS |
| Cloudflare Inc. |
CDN, DDoS protection, Web Analytics |
IP address (anonymised), page view data |
US / Global |
SCCs / Cloudflare DPA |
| Sentry (Functional Software Inc.) |
Error and performance monitoring |
Error context (PII scrubbed before transmission) |
US / EU region available |
SCCs / Sentry DPA |
| GitHub Inc. (Microsoft) |
Source code and legal document version control |
No personal data (code repository only) |
US |
GitHub DPA / SCCs |
To request notification of sub–processor changes or to receive the full sub–processor DPA schedule, contact mitual@7eulerianstrategies.com / teghvir@7eulerianstrategies.com.
Data Processing Addendum (DPA)
- DPA template (download) — contact mitual@7eulerianstrategies.com / teghvir@7eulerianstrategies.com to request the standard DPA template for your jurisdiction (GDPR / UK GDPR).
- Signed DPA on request — eligible customers may request a countersigned DPA. We aim to return executed DPAs within 5 business days.