• Identity and Contact Data: Such as name, email address, and phone number,collected during account registration or when requesting information about our Services.
• Payment Information: Collected when purchasing access to Esapiens’products and services.
• Inputs and OOOutputs: Our AI services allow you to prompt the Services in a variety of media including but not limited to the format oftext, files and documents, photos and images, and other materials alongwith the metadata and other information contained therein (“Prompts”or "Inputs"), which generate responses (“Outputs”or “Completions”) based on your Inputs. If you include personal data in your Inputs, we will collect that information and this information may be reproduced in your Outputs.
• Feedback onyour use of our Services: Information providedwhen giving feedback or rating outputs in response to inputs.
• Communication Information: Details collected during user communications,including names, contact information, and message content.

• Device and Connection Information: In line with your device or browser permissions, your device or browser automatically transmits information to us regarding the installation, access, or utilization of our Services. This encompasses details such as your device category, operating system specifics,browser particulars and web page referrers, mobile network, connectivity specifics, mobile operator or internet service provider (ISP), time zone configuration, IP address (including geolocation data derived from your IP address), identifiers (including device or advertising identifiers, probabilistic identifiers, and other unique personal or online identifiers).
• UsageInformation: We gather data on how you interact with the Services, including access dates and times, browsing history, search activity, details about clicked links, viewed pages, and other insights into your utilization of the Services, as well as technological aspectsaspect searchearch activityspertaining to the devices through which you access the Services.
• Log andTroubleshooting Information: We compile data on theperformance of our Services during your usage. This includes log files. Inthe event of an error experienced by you or your device, we may collectdata regarding the error, its occurrence time, the feature in use, theapplication's state at the time of the error, and any correspondingcommunications or content.
• Cookies& Similar Technologies: Both we and our serviceproviders employ cookies, scripts, or akin technologies (“cookies”) toadminister the Services and gather information concerning you and yourengagement with the Services. These technologies aid in identifying you,tailoring your experience, suggesting additional products or services, andassessing the Services' usage to enhance their utility to you. Forcomprehensive insights into our utilization of these technologies, as wellas your opt-out mechanisms and alternative choices, please refer to ourCookie Policy.

Personal data received indirectly for model training:

Esapiens obtains personal data from third-party sources to train our models, with measures taken to minimize privacy impacts on individuals.

We maintain severs around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks relating to the transfer of data.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

Some U.S. state privacy laws require specific disclosures.

This Privacy Policy is designed to help you understand how esapiens handles your information:

• We explain the categories of information esapiens collects and the sources of that information.
• We explain the purposes for which esapiens collect and uses information .
• We explain when esapiens may disclose information. esapiens does not sell your personal information. esapiens also does not “share” your personal information as that term is defined in the California Consumer Privacy Act (CCPA).
• We explain how esapiens retains information . You can also learn more about how esapiens anonymizes data. As described here, when esapiens anonymizes data to protect your privacy, we maintain policies and technical measures to avoid re-identifying that information.

U.S. state privacy laws also provide the right to request information about how esapiens collects, uses, and discloses your information. And they give you the right to access your information, sometimes in a portable format; correct your information; and to request that esapiens delete that information. Many of these laws also provide the right to opt out of certain forms of profiling and targeted advertising. They also provide the right to not be discriminated against for exercising these privacy rights. Additionally, the CCPA treats certain kinds of information, like health data, as sensitive; when users provide this information, esapiens only uses it for purposes permitted by the CCPA, like to provide services that are requested and expected by our users.

The Washington My Health My Data Act and Nevada Senate Bill 370 provide specific rights, in addition to those rights above, that apply to health information. When you provide this information, esapiens only processes it with your consent and allows you to withdraw your consent.

When you use these tools, we’ll validate your request by verifying that you’re signed in to your esapiens Account. If you have questions or requests related to your rights under U.S. state privacy laws, you (or your authorized agent) can also contact esapiens. And if you disagree with the decision on your request, you can ask esapiens to reconsider it by responding to our email.

Some U.S. state privacy laws also require a description of data practices using specific categories. This table uses these categories to organize the information in this Privacy Policy.

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We will exclusively utilize your personal data when permitted by law. Typically, we rely on the following grounds according to European data protection laws (our “Legal Bases”):

• Where necessary to fulfill a contract with you: For instance, we process Identity and Contact Data, Inputs, Outputs, and Payment Information to deliver Services to you. In cases where no contract exists, such as withend users of our Commercial Services, we instead rely on our legitimate interests.
• Where necessary for our legitimate interests (or those of a third party) and your interests and rights do not outweigh ours: Our legitimate interests encompass:

1. Providing, maintaining, and improving our products and services;
2. Research and development, including developing new products and features;
3. Marketing our products and services;
4. Detecting, preventing and enforcing violations of our terms including misuse of services, fraud, abuse, and other trust and safety protocols;
5. Protecting our rights and the rights of others.

• Where you have given us your consent. You have the right to withdraw your consent at any time.
• Where we are obligated to comply with legal requirements.

Where we are obligated to comply with legal requirements. We will refrain from using your Inputs or Outputs to train our models, except in scenarios where: (1) your conversations are flagged for Trust & Safety review (in such cases, we may employ or analyze them to enhance our ability to detect and enforce our Acceptable Use Policy, including model training for our Trust and Safety team, consistent with Esapiens’s safety mission), or (2) you have explicitly reported the materials to us (e.g., via our feedback mechanisms), or (3) by otherwise explicitly opting in to training.

We use your personal data for the following purposes:

Esapiens will disclose personal data to the following categories of third parties for the purposes explained in this Policy:

• Affiliates & corporate partners:
  Esapiens shares the categories of personal data described above among its affiliates and related entities.
• Service providers & business partners:
  Esapiensmay reveal the categories of personal data described above with serviceproviders and business partners for various business purposes, includingwebsite and data hosting, ensuring compliance with industry standards,research, auditing, and data processing.

Esapiens may also disclose personal data in the following circumstances:

• As part of a significant corporate event:
  Esapiens is involved in a merger, corporate transaction, bankruptcy, orother situation involving the transfer of business assets, Esapiens willdisclose your personal data as part of these corporate transactions.
• Third-Party Websites and Services:
  Our Services may involve integrationswith, or may direct you to, websites, apps, and services managed by thirdparties. By interacting with these third parties, you are providinginformation directly to the third party and not Esapiens and subject to thethird party’s privacy policy. If you access third-party services, such associal media sites or other sites linked through the Services (e.g., ifyou follow a link to our Twitter account), these will be able to collectpersonal data about you, including information about your activity on theServices. If we link to a site or service via our Services, you shouldread their data usage policies or other documentation. Our linking toanother site or service doesn’t mean we endorse it or speak for that thirdparty.
• To comply with regulatory or legalrequirements, safety and to enforce our terms:
  We may divulge personal data togovernmental regulatory authorities as required by law, including for taxor accounting purposes, in response to their requests for such information or to assist in investigations. We may also divulge personal data to thirdparties in connection with claims, disputes, or litigation, when otherwiserequired by law, or if we determine its disclosure is necessary to protectthe health and safety of you or any other person, to protect against fraud or credit risk, or to enforce our legal rights or contractual commitmentsthat you have made.
• With an individuals’ consent:
  Esapiens will otherwise disclose personal data when an individual gives us permission or directs us todisclose this information.

You can find information on our list about the third parties Esapiens engages to help us process personal data provided to us where Esapiens acts as a data processor, such as with respect to personal data we receive, process, store, or host when you use Esapiens's AI services as or through a commercial customer.

Subject to applicable law and depending on where you reside, you may have some rights regarding your personal data, as described further below. Esapiens will not discriminate based on the exercising of privacy rights you may have.

To exercise your rights, you or an authorized agent may submit a request by emailing us at privacy@Esapiens.com. After we receive your request, we may verify it by requesting information sufficient to confirm your identity. You may also have the right to appeal requests that we deny by emailing privacy@Esapiens.com.

• Right to know:
  You may have the right to know what personal data Esapiens processes about you, including the categories of personal data, the categories of sources from which it is collected, the business or commercial purposes for collection, and the categories of third parties to whom we disclose it.
• Access &data portability:
  You may have the right to request a copy of the personal data Esapiens processes about you, subject to certain exceptions. In certain cases and subject to applicable law, you have the right to port your information.
• Deletion:
  You may have the right to request that we delete personal data collected from you and retained, subject to certain exceptions.
• Correction:
  You may have the right to request that we correct inaccurate personal data Esapiensretains about you, subject to certain exceptions. Please note that we cannot guarantee the factual accuracy of Outputs. If Outputs contain factually inaccurate personal data relating to you, you can submit acorrection request and we will make a reasonable effort to correct this information—but, but due to the technical complexity of our large language models, it may not always be possible for us to do so.
• Objection：
  You may have a right to object to processing of your personal data, including profilingconducted on grounds of public or legitimate interest. We will no longer process the personal data in case of such objection unless we demonstrate compellingg legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise or defense of legal claims. If we use your information for direct marketing, you can object and opt out of future direct marketing messages using the unsubscribe link in such communications.
• Restriction: You
  have the right to restrict our processing of your personal data in certain circumstances.
• Withdrawalof consent:
  Where Esapiens’s processing of your personal data is based on consent, per the table in Section 2 above, you have the right to withdraw your consent. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
• Automateddecision-making:
  Esapiens does not engage in decision makingbased solely on automated processing or profiling in a manner whichproduces a legal effect (i.e., impacts your legal rights) or significantlyaffects you in a similar way (e.g., significantly affects your financialcircumstances or ability to access essential goods or services).
• Sale &targeted Esapiens marketing of its products and services:
  Esapiens does not “sell” your personal data as that term is defined by applicablelaws and regulations. If we share your personal data for targeted advertising to promote our products and services in the future, you can opt-out and we will honor global privacy controls.

When you access our website or services, your personal data may be transferred to our servers in the United States, or to other countries outside the United States. This transfer may occur either through direct provision of your personal data to us or through a transfer made by us or a third party (the latter being referred to as a “Transfer”).

Where information is transferred outside the EEA or the UK, we ensure it benefits from an adequate level of data protection by relying on:

• Adequacydecisions:
  These decisions are issued by the EuropeanCommission under Article 45 of the GDPR (or equivalent decisions underother laws), recognizing that a country provides an adequate level of dataprotection. We transfer your information to some countries with adequacydecisions, such as those listed here under the “Collection of PersonalData” section.
• Standardcontractual clauses:
  The European Commission has approvedcontractual clauses under Article 46 GDPR that allows companies in the EEAto transfer data outside the EEA. These (and their approved equivalent forthe UK and Switzerland) are called standard contractual clauses. We relyon standard contractual clauses to transfer information as described in“Collection of Personal Data” to certain affiliates and third parties incountries without an adequacy decision.

In certain situations, we may rely on derogations provided for under applicable data protection law to transfer information to a third country.

Esapiens retains your personal data for as long as reasonably necessary for the purposes and criteria outlined in this Privacy Policy and further explained in our support center.

Aggregated or De-Identified Information

We may process personal data in an aggregated or de-identified form to analyze the effectiveness of our services, conduct research, study user behavior, and train our AI models. For example:

• When yousubmit feedback and grant us permission, we dissociate inputs and outputsfrom your user ID to use them for training and improving our models.
• If oursystems flag inputs or outputs for potentially violating our AcceptableUse Policy, we dissociate the content from your user ID to train our trustand safety classification models and internal generative models. However,we may re-identify the materials to enforce our Acceptable Use Policy withthe responsible user if necessary.
• To enhanceuser experience, we may analyze and aggregate general user behavior andusage data. This information does not identify individual users.

Our services are not directed towards, and we do not knowingly collect, sell, or share any information about, individuals under the age of 18. If you become aware that an individual under the age of 18 has provided any personal data to us while using our services, please email us at XX, and we will investigate the matter and, if appropriate, delete the personal data.

Esapiens may update this Privacy Policy periodically. We will inform you of any substantial alterations to this Privacy Policy, as appropriate, and revise the Effective Date at the top of XX. We encourage you to review that page for updates when you access the Services.

If you have any questions or concerns about these Terms or our Services, please contact us at:

Silicon Sapiens, LLC 808 Travis St Suite 1406, Houston, Texas 77002

Email: admin@esapiens.ai