Privacy Policy

1. Definitions

For purposes of this Policy, capitalized terms shall have the meanings set forth in this Section 1 or as otherwise defined herein. Other capitalized terms used but not defined herein shall have the meanings ascribed to them in the Terms of Service.

1.1 "Account" means a registered account on the Service, including without limitation founder accounts, contractor accounts, customer records, administrative accounts, and any other category of access established by Company from time to time in its sole and absolute discretion.

1.2 "Aggregated and De-Identified Information" means information relating to a group or category of Users, or information that has been modified to remove direct and indirect identifiers, such that the information cannot reasonably be used to infer information about, or otherwise be linked to, any particular natural person or household.

1.3 "Authorized Agent" means a natural person or entity authorized in writing by a Consumer to act on such Consumer's behalf in submitting a request under Applicable Privacy Laws.

1.4 "Consumer" means a natural person who is a California resident, Virginia resident, Colorado resident, Connecticut resident, Utah resident, Texas resident, or resident of any other U.S. jurisdiction whose Applicable Privacy Laws confer rights on natural persons by reason of such residency, in each case as such terms are defined under the applicable jurisdiction's Applicable Privacy Laws.

1.5 "Personal Information" means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person, household, device, or User account, and includes "personally identifiable information," "personal information," "nonpublic personal information," and any analogous terms as such terms are defined under Applicable Privacy Laws. Personal Information does not include Aggregated and De-Identified Information or publicly available information as such term is defined under Applicable Privacy Laws.

1.6 "Sensitive Personal Information" means the categories of Personal Information designated as "sensitive," "sensitive personal information," "sensitive data," or analogous terms under Applicable Privacy Laws, including without limitation government-issued identifiers, financial-account credentials, precise geolocation, racial or ethnic origin, religious beliefs, health information, sex-life or sexual-orientation information, genetic data, biometric data processed for the purpose of uniquely identifying a natural person, and the contents of non-public communications.

1.7 "Service Provider" means any third party that processes Personal Information on behalf of Company for one or more business purposes pursuant to a written contract that satisfies the requirements of Applicable Privacy Laws, and includes "service providers," "contractors," "processors," "subprocessors," and analogous terms as defined under Applicable Privacy Laws.

1.8 "Third Party" means a natural person or entity that is not Company, a Service Provider, or a User.

1.9 "Tracking Technologies" has the meaning set forth in Section 12.

2. Notice at Collection

In accordance with California Privacy Law and analogous provisions of Applicable Privacy Laws, this Section 2, together with the disclosures set forth elsewhere in this Policy, constitutes notice at or before the point of collection of the categories of Personal Information to be collected, the purposes for which such Personal Information is collected, used, or disclosed, the length of time Company intends to retain such categories of Personal Information, and the categories of Sensitive Personal Information, if any, to be collected. The categories of Personal Information Company collects, the categories of sources from which such Personal Information is collected, the business and commercial purposes for which such Personal Information is collected, used, and disclosed, and the categories of recipients to whom such Personal Information is disclosed are set forth in Sections 3 through 9 of this Policy. Retention is addressed in Section 13.

3. Categories of Personal Information Collected

In the twelve (12) months preceding the Last Updated date above, and on an ongoing basis, Company has collected, and may continue to collect, the following categories of Personal Information about Users, as such categories are defined under California Privacy Law and analogous provisions of Applicable Privacy Laws:

(a) Identifiers, including without limitation real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, telephone number, signature, and similar identifiers;

(b) Categories of Personal Information described in Cal. Civ. Code § 1798.80(e), including without limitation name, signature, address, telephone number, employment information, and financial-account information, which categories may overlap with Identifiers;

(c) Characteristics of protected classifications under California or federal law, only to the extent voluntarily provided by Users;

(d) Commercial Information, including without limitation records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;

(e) Internet or Other Electronic Network Activity Information, including without limitation browsing history, search history, and information regarding a User's interaction with the Service, including without limitation tap events, button activations, page views, session durations, and clickstream data;

(f) Geolocation Data, in approximate (non-precise) form unless precise geolocation is voluntarily provided by the User;

(g) Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information, only to the extent voluntarily provided by Users (e.g., profile photographs);

(h) Professional or Employment-Related Information, including without limitation business name, business role, and related information voluntarily provided;

(i) Inferences drawn from any of the foregoing categories to create a profile reflecting User preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and

(j) Sensitive Personal Information, only to the extent voluntarily provided by Users and only as further described in Section 6.

The specific pieces of Personal Information collected by Company within each of the foregoing categories are further described elsewhere in this Policy.

4. Sources of Personal Information

Company collects Personal Information from the following categories of sources:

(a) Directly from Users, including without limitation through registration forms, account-management interfaces, profile-editing tools, communications channels, and any other input mechanism provided through the Service;

(b) Automatically through Tracking Technologies, as further described in Section 12, including server logs, client-side instrumentation, cookies, web beacons, pixel tags, and similar tools;

(c) From Other Users, including without limitation when one User adds another User to a contact list, contractor record, customer record, or network within the Service, when one User shares Personal Information about another User in connection with the Service, or when two or more Users are connected to a User's activity on the Service and one such User shares Personal Information about another User as further described in Section 7;

(d) From Service Providers, including without limitation our payment processor, hosting provider, identity-verification providers, fraud-prevention vendors, analytics providers, and email-delivery providers; and

(e) From publicly available sources, social media platforms, data brokers, and other Third Parties, in each case to the extent permitted by Applicable Privacy Laws.

5. Purposes of Processing

Company processes Personal Information for the purposes set forth below, in each case as permitted by Applicable Privacy Laws.

The purposes for which Company processes Personal Information include, without limitation:

(a) to provide, operate, maintain, secure, support, and improve the Service and any feature thereof;

(b) to process Account registrations, authenticate Users, and manage Accounts;

(c) to process transactions, including without limitation payments, refunds, and subscription billing;

(d) to facilitate communications between and among Users and to enable User-to-User functionality;

(e) to send transactional, administrative, or account-related communications, including without limitation service announcements, security alerts, billing notices, and support messages;

(f) to send marketing, promotional, or commercial communications, subject to Applicable Privacy Laws and Your opt-out rights;

(g) to personalize, customize, and tailor Your experience of the Service;

(h) to monitor, measure, analyze, and report on usage, trends, and performance of the Service;

(i) to research, design, develop, test, deploy, train, and improve features, products, models, and algorithms, including without limitation analytics, machine-learning, artificial intelligence, recommendation, classification, and similar data-driven features;

(j) to detect, prevent, investigate, document, mitigate, and address fraud, abuse, security incidents, violations of the Terms of Service, violations of Applicable Privacy Laws, and other unlawful, harmful, or unauthorized conduct;

(k) to enforce, exercise, defend, or establish legal claims, rights, or remedies of Company or any Third Party;

(l) to comply with Applicable Privacy Laws, legal process, governmental requests, audit obligations, and other legal or regulatory requirements;

(m) to protect the rights, property, safety, security, or operational continuity of Company, its Affiliates, its Service Providers, its Users, or the public;

(n) for any other purpose disclosed to You at or before the point of collection of the relevant Personal Information, or otherwise with Your consent; and

(o) for any purpose compatible with the purposes set forth above, in each case as permitted by Applicable Privacy Laws.

6. Sensitive Personal Information

Company does not knowingly collect Sensitive Personal Information except where a User voluntarily elects to provide such information. Company does not use or disclose Sensitive Personal Information for purposes other than those set forth in Cal. Civ. Code § 1798.121(a) and analogous provisions of Applicable Privacy Laws, and Consumers may exercise applicable rights to limit such use and disclosure as provided in Sections 17 and 18.

7. Personal Information Disclosed; Categories of Recipients

Subject to Applicable Privacy Laws, Company may disclose each of the categories of Personal Information described in Section 3 to one or more of the following categories of recipients, in each case for one or more of the business or commercial purposes described in Section 5:

(a) Other Users. The Service is designed and intended to facilitate connections, communications, transactions, and other interactions among founders, contractors, customers, and other Users. Personal Information that You submit to, generate within, or otherwise make available through the Service may be visible, accessible, or otherwise made available to other Users with whom You interact, including without limitation founders You engage with through the Service. Without limiting the generality of the foregoing, where two or more founders are connected to a User's activity on the Service, including without limitation by reason of mutual participation in each other's networks, such founders may share, exchange, disclose, or otherwise make available Personal Information about such User with or to one another in furtherance of the Service. The categories and items of Personal Information disclosed in any such User-to-User sharing, the recipients thereof, and the timing of any such disclosure are determined by the User who originated the underlying interaction, subject in each case to the controls, review processes, and approval workflows provided within the Service from time to time.

(b) Service Providers. Company may disclose Personal Information to Service Providers that perform services on behalf of Company, including without limitation services related to payment processing, hosting and infrastructure, database management, authentication, email and message delivery, email forwarding, analytics, customer support, fraud prevention, identity verification, marketing, communications, and any other services reasonably necessary or appropriate for the operation, support, or improvement of the Service. Service Providers are contractually obligated to process Personal Information solely for the purposes for which such Personal Information was disclosed to them and in accordance with the confidentiality, security, and data-protection requirements imposed by Applicable Privacy Laws.

(c) Legal, Regulatory, and Governmental Authorities. Company may disclose Personal Information to law-enforcement agencies, regulatory authorities, courts, arbitral tribunals, or other governmental, judicial, or quasi-judicial bodies (i) in response to a subpoena, warrant, court order, civil investigative demand, or other valid legal process; (ii) in connection with any investigation by any such authority; (iii) to comply with Applicable Privacy Laws or any other applicable law; (iv) to investigate, prevent, document, or take action regarding suspected or actual unlawful, fraudulent, or harmful conduct; or (v) where Company determines, in its sole and absolute discretion, that such disclosure is necessary, appropriate, or advisable to protect the rights, property, safety, security, or operational continuity of Company, its Affiliates, its Service Providers, its Users, or any other Person.

(d) Business Transactions. In the event of, or in connection with, any actual or proposed merger, acquisition, consolidation, reorganization, divestiture, joint venture, financing, sale of all or substantially all of Company's assets or equity, change of control, or similar corporate transaction, or any insolvency, bankruptcy, receivership, dissolution, or analogous proceeding, Personal Information may be transferred, assigned, or otherwise made available to the prospective counterparty, successor entity, acquirer, transferee, trustee, receiver, or other recipient as part of, in preparation for, or in contemplation of any such transaction or proceeding, in each case subject to applicable confidentiality protections.

(e) Affiliates. Company may disclose Personal Information to its Affiliates for purposes consistent with this Policy.

(f) Professional Advisors. Company may disclose Personal Information to its professional advisors, including without limitation attorneys, accountants, auditors, insurers, consultants, and similar advisors, in connection with the operation, management, governance, audit, insurance coverage, financing, sale, or protection of Company's business.

(g) Other Third Parties with Your Consent or at Your Direction. Company may disclose Personal Information to any other Third Party with Your consent or at Your direction.

(h) As Required or Permitted by Applicable Privacy Laws. Company may disclose Personal Information as otherwise required, permitted, or authorized under Applicable Privacy Laws.

8. Service Providers, Contractors, and Third Parties

Without limitation of Section 7, Company's Service Providers currently include, among others, Stripe, Inc. (payment processing), Supabase, Inc. (database and authentication infrastructure), Vercel Inc. (application hosting and edge infrastructure), Resend, Inc. (transactional email delivery), and ImprovMX SAS (email forwarding). The list of Service Providers is subject to change from time to time in Company's sole discretion, and the foregoing list is provided for illustrative purposes only and shall not be construed as a complete or current enumeration. Each Service Provider processes Personal Information in accordance with such Service Provider's own privacy policy and pursuant to a written contract with Company satisfying the requirements of Applicable Privacy Laws.

9. Sale or Sharing of Personal Information

Company does not "sell" Personal Information in exchange for monetary consideration within the meaning of California Privacy Law. Without limiting the generality of the foregoing, the disclosures of Personal Information described in Section 7 may, depending on the characterization adopted by the applicable regulator or court, be deemed to constitute a "sale," "sharing," "targeted advertising," "cross-context behavioral advertising," or analogous concept under one or more Applicable Privacy Laws. To the extent any such characterization applies, Consumers may exercise applicable opt-out rights as described in Sections 17 through 19. Company has not knowingly sold or shared the Personal Information of Consumers under sixteen (16) years of age.

10. Automated Decision-Making and Profiling

Company does not currently engage in solely automated decision-making, including profiling, that produces legal or similarly significant effects concerning Users within the meaning of any Applicable Privacy Laws. To the extent Company introduces such processing in the future, Company will provide additional disclosures and, where required by Applicable Privacy Laws, obtain Your consent or otherwise afford You applicable rights.

11. Aggregated and De-Identified Information

Notwithstanding anything to the contrary in this Policy, Company may aggregate, anonymize, or de-identify Personal Information such that it constitutes Aggregated and De-Identified Information, and may use, process, retain, modify, combine, and disclose such Aggregated and De-Identified Information for any lawful purpose, including without limitation analytics, research and development, product development, model training, marketing, and disclosure to Third Parties, in each case without further notice to or consent from any User. Aggregated and De-Identified Information is not Personal Information for purposes of this Policy or Applicable Privacy Laws. Company commits to maintain Aggregated and De-Identified Information in such form and to refrain from attempting to re-identify such information except as permitted under Applicable Privacy Laws.

12. Cookies, Tracking Technologies, and Similar Tools

Company and its Service Providers use cookies, web beacons, pixel tags, software development kits, server logs, fingerprinting techniques, local-storage objects, and other tracking, identification, or instrumentation technologies (collectively, "Tracking Technologies") to operate the Service, authenticate Users, remember preferences, analyze usage, deliver communications, and for other purposes consistent with this Policy. The categories of Tracking Technologies used include, without limitation: (a) strictly necessary Tracking Technologies, which are required for the operation of the Service; (b) functionality Tracking Technologies, which enable Company to remember Your preferences and customize Your experience; (c) analytics Tracking Technologies, which help Company understand how Users interact with the Service; and (d) performance Tracking Technologies, which collect information regarding Service performance and diagnostic data. You may control or block Tracking Technologies through Your browser settings, device controls, or, where available, in-Service controls; provided, however, that doing so may prevent or impair Your use of certain features of the Service. Company does not currently respond to "Do Not Track" signals transmitted by browsers because no industry-standard specification for such signals has been finalized.

13. Data Retention and Deletion

Company retains Personal Information for so long as is reasonably necessary to provide the Service, fulfill the purposes set forth in Section 5, comply with legal, regulatory, accounting, audit, tax, and reporting obligations, resolve disputes, prevent fraud or abuse, enforce agreements, and pursue legitimate business purposes. Retention periods are determined by reference to factors including, without limitation, the nature and sensitivity of the Personal Information, the purposes for which it is processed, applicable legal and regulatory requirements, contractual obligations, statutes of limitations, and operational and business needs. When Personal Information is no longer required, Company will delete, destroy, anonymize, or de-identify such Personal Information in accordance with Company's data-retention practices and Applicable Privacy Laws, except where retention is required or permitted by law.

14. Information Security Measures

Company maintains administrative, technical, organizational, and physical safeguards designed to protect Personal Information against unauthorized or unlawful processing, accidental loss, destruction, damage, alteration, or disclosure. Notwithstanding the foregoing, no method of transmission over the Internet, no electronic storage system, and no security measure is impenetrable, and Company makes no representation, warranty, or guarantee that Personal Information will be protected against unauthorized access, use, disclosure, alteration, or destruction under all circumstances. To the maximum extent permitted by Applicable Privacy Laws, You acknowledge and agree that You provide Personal Information at Your own risk.

15. Data Processing Location

Company is headquartered in and operates from the United States, and Personal Information collected by Company is primarily processed and stored in the United States. The Service is offered to, and intended for, residents of the United States only as described above. Certain of Company's Service Providers (including without limitation those identified in Section 8) may operate or process data on infrastructure located outside the United States; Service Providers are contractually obligated to handle Personal Information in accordance with Applicable Privacy Laws. By using the Service, You acknowledge and consent, to the maximum extent permitted by Applicable Privacy Laws, that Personal Information will be processed in the United States and that Service Providers may use infrastructure located outside the United States.

16. Your Privacy Rights — General

Subject to Applicable Privacy Laws and the further provisions of Sections 17 through 19, You may have certain rights with respect to Your Personal Information, including without limitation: (i) the right of access; (ii) the right to correction; (iii) the right to deletion; (iv) the right to portability; (v) the right to opt out of "sale," "sharing," "targeted advertising," "cross-context behavioral advertising," or analogous processing; (vi) the right to limit use and disclosure of Sensitive Personal Information; (vii) the right to opt out of profiling that produces legal or similarly significant effects; and (viii) the right not to be subject to unlawful discrimination or retaliation for exercising any such right.

17. California Residents — Additional Rights

If You are a California resident, You may have additional rights under California Privacy Law, including without limitation the rights to: (a) know the categories and specific pieces of Personal Information Company has collected about You, the categories of sources from which such Personal Information was collected, the business or commercial purposes for collection, and the categories of Third Parties to whom such Personal Information has been disclosed; (b) request deletion of Personal Information, subject to applicable exceptions; (c) request correction of inaccurate Personal Information; (d) opt out of the "sale" or "sharing" of Personal Information; (e) limit the use and disclosure of Sensitive Personal Information to those purposes set forth in Cal. Civ. Code § 1798.121(a); and (f) be free from unlawful discrimination or retaliation for exercising any such rights. Company shall respond to verifiable consumer requests within the time periods required by California Privacy Law. Section 20 addresses the limited "Shine the Light" rights under Cal. Civ. Code § 1798.83.

18. Virginia, Colorado, Connecticut, Utah, Texas, and Other State-Law Rights

If You are a resident of Virginia, Colorado, Connecticut, Utah, Texas, or any other U.S. state with comprehensive privacy legislation in effect, You may have additional rights under such state's Applicable Privacy Laws, including without limitation rights of access, correction, deletion, portability, opt-out of sale, opt-out of targeted advertising, opt-out of profiling that produces legal or similarly significant effects, and the right to appeal a denial of such requests. Company shall respond to verifiable requests within the time periods required by the applicable state law.

19. Exercising Your Rights; Verification; Authorized Agents

To exercise any right described in Sections 16 through 18, please contact Company at hello@gotagai.com. Company may require verification of Your identity before fulfilling any such request, and the level of verification required may vary based on the sensitivity of the Personal Information involved and the nature of the request. Company may request additional information from You to verify Your identity or the authority of any Authorized Agent acting on Your behalf. Where You designate an Authorized Agent, Company may require: (a) written authorization signed by You; (b) verification of Your identity directly with Company; and (c) confirmation of the Authorized Agent's authority. Company may decline to fulfill any request to the extent permitted or required by Applicable Privacy Laws. Company shall not unlawfully discriminate against any User for exercising any right described herein.

20. California "Shine the Light"

California Civil Code § 1798.83 ("Shine the Light") permits Users who are California residents to request information regarding Company's disclosure of Personal Information to Third Parties for such Third Parties' direct marketing purposes. Company does not currently make such disclosures. To make a Shine the Light request, contact Company at hello@gotagai.com.

21. Nevada Residents

Pursuant to Nev. Rev. Stat. § 603A.340, Nevada residents may submit a request directing Company not to make any "sale" of certain covered information collected about them. Company does not currently sell such covered information within the meaning of Nev. Rev. Stat. § 603A. To submit such a request, contact Company at hello@gotagai.com.

22. Children's Privacy

The Service is not directed to, and Company does not knowingly collect, solicit, or process Personal Information from, children under the age of thirteen (13). If Company becomes aware that it has collected Personal Information from a child under the age of thirteen (13) without verified parental consent in accordance with the Children's Online Privacy Protection Act of 1998, 15 U.S.C. § 6501 et seq. ("COPPA"), Company will take reasonable steps to delete such Personal Information. If You believe Company has collected Personal Information from a child under the age of thirteen (13), please contact Company immediately at hello@gotagai.com.

23. Third-Party Links, Integrations, and Content

The Service may contain links to, integrations with, or content provided by Third Parties not owned or operated by Company. This Policy does not apply to such Third-Party websites, applications, services, integrations, or content, and Company is not responsible or liable for any such Third-Party content, privacy practices, or terms of use. Company encourages You to review the privacy policies and terms of any Third-Party services with which You interact.

24. Changes to This Policy

Company may amend, modify, supplement, or replace this Policy at any time and from time to time in its sole discretion. When Company makes such changes, Company will revise the "Last Updated" date at the top of this Policy. If Company makes material changes, Company may provide additional notice (such as by email, in-Service notification, or by posting a notice on the Service) where required by Applicable Privacy Laws. Your continued access to or use of the Service following the effective date of any such update constitutes Your acceptance of the updated Policy. If You do not agree to the updated Policy, You must discontinue use of the Service.

25. No Waiver; Severability; Interpretation

No waiver by Company of any provision of this Policy shall be effective unless in writing and signed by an authorized representative of Company. No failure or delay by Company in exercising any right under this Policy shall operate as a waiver thereof, nor shall any single or partial exercise of any right preclude any other or further exercise thereof. If any provision of this Policy is held to be invalid, illegal, or unenforceable in any respect, such invalidity, illegality, or unenforceability shall not affect any other provision hereof, and this Policy shall be construed as if such invalid, illegal, or unenforceable provision had been modified to the minimum extent necessary to render it valid, legal, and enforceable, or, if such modification is not possible, severed herefrom. Section headings are for convenience of reference only and shall not affect the construction or interpretation of this Policy. The words "include," "includes," and "including" shall be deemed to be followed by the phrase "without limitation." References to "Sections" are to Sections of this Policy unless otherwise specified.

26. Governing Law; Venue

This Policy and any disputes, claims, or controversies arising out of, relating to, or in connection with this Policy, the Service, or any Personal Information processed hereunder shall be governed by and construed in accordance with the laws of the State of Florida, without regard to its conflict-of-laws principles. Any action, suit, or proceeding arising out of, relating to, or in connection with this Policy or the Service shall be brought exclusively in the state or federal courts of competent jurisdiction located in Palm Beach County, Florida, and each party irrevocably submits to the personal jurisdiction and exclusive venue of such courts and waives any objection based on forum non conveniens or any other ground. Nothing in this Section 26 shall limit any class-action waiver, arbitration provision, or analogous provision contained in the Terms of Service, which provisions are incorporated herein by reference to the extent applicable.

27. Survival

The provisions of Sections 1, 6, 9, 11, 14, 15, 19, 24 through 27, and 28, together with any other provision that by its nature is intended to survive, shall survive any termination, expiration, or modification of this Policy or of Your use of the Service.

28. Contact Information

For questions, comments, concerns, requests, or complaints regarding this Policy, Company's privacy practices, or to exercise any right described herein, please contact:

Agai Networks LLC

Attention: Privacy

11860 Sanbourn Court, West Palm Beach, Florida 33412

hello@gotagai.com