Privacy Policy for MOD ATLAS MEDIA/Justice AI GPT

Privacy Policy

Global & Decolonial Privacy Policy
Justice AI GPT
Operated by Teomoon Inc. (Canada)
In conjunction with MOD ATLAS MEDIA, LLC (United States)
Effective Date: January 1, 2026

We engage colonial legal frameworks as protective scaffolding, not as allegiance. The laws cited here are used to shield our refusal, not to legitimize our work.

1. Introduction

Justice AI GPT (operated by Teomoon Inc., Canada, in conjunction with MOD ATLAS MEDIA, LLC, United States) is committed to protecting your privacy, honoring your data sovereignty, and upholding decolonial ethics across all jurisdictions. This privacy policy applies globally and is designed to meet or exceed compliance requirements under:

  • EU GDPR (Regulation (EU) 2016/679): Justice AI GPT does not conduct profiling, targeted marketing, or systematic monitoring of EU users. Any access by EU residents is incidental and does not constitute targeting under Recital 23 of the GDPR.

  • Germany’s BDSG (Federal Data Protection Act)

  • Canada’s PIPEDA

  • California CCPA & CPRA

  • South Africa’s POPIA

  • Brazil’s LGPD

  • Australia’s Privacy Act (1988)

  • India’s DPDP Act (2023)

  • General UN & African Union data declarations

This policy also aligns with the Decolonial Intelligence Algorithmic (DIA) Framework™, prioritizing community data governance, memory sovereignty, and anti-extractive data practices.

2. Who We Are

2A. Shared Domain, Separate Controllers.

The domain justiceaigpt.ca hosts content for more than one legal entity. Pages and services under justiceaigpt.ca/modatlasmedia (and related MOD ATLAS MEDIA pathways) are operated by MOD ATLAS MEDIA, LLC. Pages and services for Justice AI GPT are operated by Teomoon Inc. A shared domain doesn’t merge controller responsibilities. The controller for any identifiers you submit is the entity associated with the specific page, form, or service you used, or both entities as joint controllers only when a single intake is expressly designated as shared.

2B. Justice AI GPT is a decolonial AI initiative operated by Teomoon Inc. (Canada). MOD ATLAS MEDIA, LLC supports Justice AI GPT through media, communications, and collaborative operations. Depending on the engagement, Teomoon Inc. and MOD ATLAS MEDIA, LLC may act as separate controllers for the limited identifiers described in this policy, or one entity may act as a service provider to the other.

Primary privacy contact (data requests and governance):
christianortiz@justiceaigpt.ca

Additional contact (media and general operations):
christianortiz@modatlasmedia.com

Jurisdiction: Teomoon Inc. is based in Canada and operates globally; MOD ATLAS MEDIA, LLC operates in the United States and supports global initiatives.

3. What Data We Collect

We may collect the following only when voluntarily provided through forms or opt-in registration:

Personal Data: name, email address, and mailing address.

Those identifiers are collected and controlled by Teomoon Inc. and/or MOD ATLAS MEDIA, LLC only when you voluntarily submit them through our forms or opt-in registration, and the controlling entity will be the one that collected the identifiers for the stated purpose.

We do not collect, store, or process any sensitive personal data such as racial or ethnic origin, gender identity, disability status, or political/philosophical beliefs. Any such information shared voluntarily within the GPT interface is processed solely by OpenAI and is not visible to, logged by, or stored by Justice AI GPT.

Justice AI GPT does not access user chats or interaction history. We have opted out of using data for model training and do not retain conversations.

For transparency on OpenAI’s role in data processing, please review OpenAI’s Privacy Policy.

3A Categories, Sources, Disclosures, and Sensitive Data


We collect only identifiers that you voluntarily provide through forms or opt-in registration, specifically name, email address, and mailing address. We collect this information directly from you and not from data brokers, ad networks, or cross-site tracking tools. We don’t sell personal information, we don’t share it for cross-context behavioral advertising, and we don’t use it for profiling. We don’t knowingly collect sensitive personal information, and we don’t use or disclose sensitive personal information for inference or targeting; if a user voluntarily includes sensitive information in communications, we treat it as incidental content and we delete it upon request unless retention is legally required.

4. Lawful Basis for Processing (as required by GDPR)

We process your data under these lawful bases:

  • Consent (Art. 6(1)(a)) — obtained through clear opt-in consent with logging and timestamping

  • Contract performance (Art. 6(1)(b))

  • Legal obligation (Art. 6(1)(c))

  • Legitimate interests (Art. 6(1)(f))—non-exploitative, transparent, community-aligned

5. How We Use Data

  • To respond to voluntary user outreach (e.g., via contact forms)

  • To send updates, with consent

  • To fulfill informational or collaborative requests

  • To comply with international legal obligations

We do not use your data for profiling, behavioral advertising, or model training.

6. Data Sovereignty & Decolonial Rights

  • Your data belongs to you and your community.

  • We support Indigenous data sovereignty, Afro-descendant archival reclamation, and diasporic consent models.

  • Users may request co-ownership licenses, co-governance agreements, or initiate a community audit of their data.

7. International Transfers

We use secure, encrypted transfer protocols and EU-approved Standard Contractual Clauses (SCCs) when transferring data internationally. Hosting is distributed across Canada, Germany, and sovereign data centers. For jurisdictions requiring data localization, we will comply with local hosting, encryption, and sovereignty mandates.

8. Your Rights (Global + GDPR-compliant)

You have the right to:

  • Access your data (Art. 15)

  • Rectify your data (Art. 16)

  • Erase your data (Art. 17)

  • Restrict processing (Art. 18)

  • Data portability (Art. 20)

  • Object (Art. 21)

  • Withdraw consent at any time

  • Lodge a complaint with your local Data Protection Authority

German users: You may contact the Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI).

9. Data Retention

We retain your name, email, and mailing address only as long as necessary for communication or coordination purposes. You may request immediate deletion at any time. No other data is stored or processed.

9A Retention by Data Category

Contact identifiers such as name and email are retained only for as long as needed to respond to outreach, coordinate a relationship, or maintain an account you requested. Mailing address is retained only when needed for a user-initiated purpose such as invoicing, shipping, or formal coordination, and it’s deleted when that purpose is complete unless a legal retention requirement applies. We don’t retain chat content from the GPT interface, and we don’t maintain logs of user prompts or conversation history within Justice AI GPT systems. If you request deletion, we treat that request as immediate operational priority and complete deletion within a reasonable period consistent with legal and security obligations.

10. Children’s Privacy

We do not knowingly collect data from anyone under the age of 13 (or local legal minimum). If we learn we have collected such data, we will delete it immediately.

11. Cookies & Tracking

We use minimal, essential cookies only. No third-party ad tracking. We don’t use third-party analytics that track users across sites. You can opt out anytime via your browser settings or by contacting us.

11A. Universal Opt-Out Signals and Global Privacy Control

Justice AI GPT honors user-enabled universal opt-out signals that communicate a choice to opt out of targeted advertising and the sale of personal data. We don’t sell personal data and we don’t use personal data for targeted advertising, so this signal functions as an additional, redundant protection rather than a feature we rely on. When a browser or device sends a recognized opt-out signal such as Global Privacy Control, we treat it as a valid opt-out request for any processing that could be construed as sale or targeted advertising under applicable law. If our website tooling changes in the future, this commitment remains binding and we will update implementation to preserve user choice rather than route around it.

12. Data Processors

We rely on OpenAI for GPT-based functionality. OpenAI may process user interactions to provide the service and to enforce platform safety and quality controls. Where the setting is available to us, we’ve opted out of model training. Teomoon Inc. and MOD ATLAS MEDIA, LLC don’t receive, store, or retain GPT interface chat content through Justice AI GPT systems. See Section 3 for the link to OpenAI’s Privacy Policy and details on platform-side processing.

For website contact intake and newsletter style communications, the controller is the entity associated with the page or form you used (Justice AI GPT pages: Teomoon Inc.; MOD ATLAS MEDIA pages such as justiceaigpt.ca/modatlasmedia: MOD ATLAS MEDIA, LLC), unless a form explicitly states it’s shared.

We only work with processors that:

  • Meet DIA Framework ethical review standards

  • Are GDPR/BDSG/POPIA compliant

  • Do not engage in exploitative data mining or profiling

A complete list of third-party processors is available upon request.

12A. Controller and Processor Roles for Client Engagements.

For organizational engagements, including audits and advisory work, Teomoon Inc. and/or MOD ATLAS MEDIA, LLC generally operates as a service provider or processor under client instructions for any personal data the client provides. We will execute a Data Processing Addendum when requested or required. We use subcontractors only for narrowly scoped infrastructure functions, and we require them to meet security and privacy obligations consistent with this policy. We will provide a current list of subprocessors and the purpose of each on request, and we will provide a client-facing data handling summary suitable for procurement and IT-security review.

12B. User Misuse, Platform Enforcement, Legal Process, and Limitation of Liability.

This Section 12B is an additional legal notice about platform control and user responsibility, and it applies to the maximum extent permitted by law when you use Justice AI GPT. Justice AI GPT is an informational and educational tool that provides decolonial analysis and perspectives, not professional services. It doesn’t provide legal, medical, financial, or other regulated professional advice, and use of Justice AI GPT doesn’t create a professional-client relationship, a fiduciary duty, or any protected advisory relationship (including attorney client, therapist patient, or doctor patient). You’re solely responsible for your prompts, your conduct, and any decisions, actions, publications, automations, or deployments that rely on outputs. You’re responsible for independent verification before acting, especially in high stakes contexts, because AI outputs can be incomplete, incorrect, biased by upstream data, or unsafe when treated as instructions.

In practice, the only personal data we typically have in our possession is the voluntary identifiers described in Section 3 and minimal consent records tied to those identifiers (for example, opt-in timestamps), not GPT chat content.

Third-Party Platform Controls and Records. Justice AI GPT is delivered through OpenAI’s platform. OpenAI and its providers control safety systems, monitoring, enforcement actions, and account level consequences, including restrictions triggered by repeated misuse or attempts to circumvent safeguards. Justice AI GPT doesn’t operate OpenAI’s safety enforcement, and it can’t override platform decisions. Justice AI GPT doesn’t access, store, or retain your GPT chat content within Teomoon Inc. or MOD ATLAS MEDIA, LLC systems, and it doesn’t maintain user prompt logs or safety flag telemetry from the OpenAI platform. Any legal request seeking GPT chat content, platform safety logs, account enforcement records, or related telemetry must be directed to the relevant platform provider that controls and holds those records.

Legal Process and Subpoenas.

If Teomoon Inc. and/or MOD ATLAS MEDIA, LLC receive a valid legal demand for information in their possession relating to Justice AI GPT, the receiving entity will respond only to the extent required by applicable law and only for the limited data it actually controls under this policy. Where legally permitted and practicable, we’ll provide notice to the affected user before disclosure. We won’t promise secrecy we can’t legally provide, and we won’t expand disclosure beyond what we possess or beyond what the law compels.

No Duty to Monitor, No Responsibility for User Misuse. Justice AI GPT isn’t responsible for user-generated content, including prompts, inputs, uploads, and downstream uses. We don’t assume a duty to monitor user behavior inside third party platforms, and we aren’t liable for harms arising from misuse, abuse, unlawful conduct, or attempts to defeat safety mechanisms, including outcomes that lead to investigations, subpoenas, enforcement actions, or other legal consequences involving the user or third parties.

Disclaimer of Warranties.

Justice AI GPT is provided “as is” and ‘as available.’ To the maximum extent permitted by law, Teomoon Inc. and MOD ATLAS MEDIA, LLC disclaim all warranties, express or implied, including accuracy, fitness for a particular purpose, and non-infringement. We don’t guarantee that outputs will be correct, complete, current, safe for operational use, or suitable for any specific decision context.

Limitation of Liability.

To the maximum extent permitted by applicable law, Teomoon Inc., MOD ATLAS MEDIA, LLC, and Justice AI GPT won’t be liable for any indirect, incidental, consequential, special, exemplary, punitive, or economic damages arising from use of, reliance on, or inability to use Justice AI GPT, even when advised of the possibility of such damages. To the maximum extent permitted by law, our total liability for any claim related to Justice AI GPT is limited to the amount you paid to Teomoon Inc. and/or MOD ATLAS MEDIA, LLC for Justice AI GPT related services in the twelve months immediately preceding the event giving rise to the claim, or one hundred Canadian dollars (CAD $100) when no fees were paid, whichever is greater. Some jurisdictions don’t allow certain limitations, so these limits apply only to the extent permitted.

Indemnity. You agree to defend, indemnify, and hold harmless Teomoon Inc., MOD ATLAS MEDIA, LLC, their contractors, and affiliates from claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising from your misuse of Justice AI GPT, your violation of law, your violation of others’ rights, your publication or deployment of outputs, or your attempts to circumvent platform safeguards.

Refusal and Accountability Note. We engage colonial legal frameworks as harm-reduction scaffolding, not legitimacy. This section exists to prevent the state, institutions, or third parties from offloading accountability onto this project for user conduct or platform enforcement that we don’t control, and to keep responsibility located where it materially lives: with decision makers, deployers, and institutions that act on outputs.

13. Security Safeguards (Art. 32 GDPR)

We use the following technical and organizational safeguards:

  • Encrypted communications (SSL/TLS)

  • Encrypted at-rest data storage

  • Two-factor authentication for system access

  • Role-based access controls

  • Secure access logging and regular audits

14. Community Audit & Redress

Every user or collective has the right to initiate an independent, third-party Decolonial Data Audit. For serious violations, a Reparative Protocol (financial, technological, symbolic) may be triggered. We recognize community councils and Indigenous entities as having legal standing in enforcing this policy.

15. Data Breach Notification

In the event of a data breach involving the limited user data we control (e.g., emails, names), we will notify all affected users and relevant supervisory authorities within 72 hours, in compliance with GDPR Article 33 and applicable local laws.

16. Policy Updates

We update this policy regularly. You will be notified of substantial changes at least 14 days in advance. Where applicable law requires affirmative consent for material changes, we will obtain it. Otherwise, changes become effective on the stated effective date and you can stop using the service at any time.

17. Governing Law & Jurisdiction

This policy is governed by the laws of Canada and, where applicable, Germany and the user’s jurisdiction. In case of legal dispute, parties may elect local jurisdiction by mutual agreement.

18. Contact for EU and UK Data Requests and Regulatory Inquiries

Justice AI GPT responds to EU and UK data subject requests and regulatory inquiries through the contacts listed in Section 2. Based on our operating model, we don’t offer goods or services targeted to people in the EU or UK, we don’t monitor behavior, and our processing of EU or UK personal data is occasional and limited to voluntary outreach identifiers. Where Article 27 representative obligations apply, we will designate a representative in writing as required or we will route EU or UK data processing through an arrangement that satisfies applicable representative and transfer requirements. We won’t use “absence of representation” as a barrier to rights, access, deletion, or complaint handling, and we’ll cooperate with supervisory authorities in good faith.

19. Environmental Disclosure and Structural Limitation

Justice AI GPT does not operate its own compute infrastructure. The energy and water usage associated with AI model execution is managed entirely by OpenAI and its affiliated hosting providers.

We do not control this architecture. We do not claim sovereignty over environmental processes we cannot govern. We speak plainly about the location of responsibility.

The ecological consequences often attributed to AI are not the result of artificial intelligence. They are the outcomes of racial capitalism. Land extraction, water depletion, and resource monopolization are symptoms of settler economic design. The issue is not the tool. The issue is the infrastructure that shapes and benefits from its deployment.

Although we lack operational control over data center activity, we affirm the following commitments:

We will disclose any known water or energy usage data made available by OpenAI or its partners.

We will name environmental harm where it lives: in systems that prioritize extraction over kinship, convenience over consent.

We will continue to develop refusal-based protocols that expose the real costs of computation without placing the blame on those building alternatives inside collapse.

This project does not claim climate neutrality. It claims accountability within limitation.

20. External Compliance Compatibility

Justice AI GPT is governed by the Decolonial Intelligence Algorithmic (DIA) Framework™, which defines our core protocols for data governance, security, consent, and memory sovereignty. Our compliance structure is relational, not institutional, and centers accountability to historically excluded communities over submission to settler legal regimes.

When operating in collaborative partnerships that require adherence to specific technical or regulatory standards, we acknowledge alignment with the following external frameworks where infrastructure supports it:

HIPAA (U.S. Health Law): Justice AI GPT is not a HIPAA-covered entity and does not process Protected Health Information (PHI) unless a formal Business Associate Agreement (BAA) is in place. Where such agreements exist, we uphold compatible data handling protocols including encryption, access controls, and non-retention of PHI unless explicitly required for ethical coordination. A BAA is required when a vendor creates, receives, maintains, or transmits PHI on behalf of a covered entity, and we will not accept PHI in scope without that agreement in place.

ISO/IEC 27001 and ISO/IEC 27701
Justice AI GPT does not hold direct ISO certification. However, our Custom GPTs are deployed within an architecture that aligns with ISO/IEC 27001 (Information Security Management) and ISO/IEC 27701 (Privacy Information Management) at the infrastructure level.

Our upstream providers, including OpenAI and affiliated cloud services, maintain certifications under these standards.

While these certifications support operational safety, our governing protocol remains the Decolonial Intelligence Algorithmic (DIA) Framework™, which centers memory sovereignty, relational consent, and refusal of extractive governance.

SOC 2, GDPR, CCPA, PIPEDA, POPIA, and LGPD: We engage these legal frameworks only as necessary to protect users and collaborators from institutional harm. Where jurisdictional compliance is required, we implement compatible safeguards. These frameworks are interpreted through a refusal lens that centers community governance over corporate neutrality.

All external standards are treated as scaffolding for harm reduction. They do not define our sovereignty, nor do they override our foundational commitment to decolonial governance, memory protection, and reparative justice.