Privacy Policy

Introduction

We at Zatomic AI, Inc. as well as our affiliates (collectively, "we," "us," or "our") respect your privacy and are committed to protecting it through our compliance with this Policy. This Policy describes the types of information we may collect from you or that you may provide to us, including when (i) you visit our website at https://www.zatomic.ai/ and any successor, subpage or subdomain thereof, as well as any other website where we post this Policy (collectively, our "Website"), and (ii) you access and use our proprietary software applications, corresponding APIs and associated technical support and other services (collectively, our "Software Offerings" and, together with the Website, our "Offerings") and our practices for collecting, using, maintaining, protecting and disclosing that information.

When This Policy Applies. This Policy applies to (i) any information that we collect on the Website or otherwise in connection with your use of the Website, including any information in any forms or messages submitted by you to us through our Website or using the contact information provided on our Website, (ii) any information collected when you interact with e-mail messages you receive from us, (iii) any information that we collect in connection with your use of our Software Offerings, and (iv) any other information we collect about you offline but that will be processed by automated means using our Website or Software Offerings. This Policy does not apply to any other information we collect by any other means.

When It Doesn't Apply. If you or your organization has contracted with us to access and use our Software Offerings under a written agreement other than our standard online Zatomic^TM Terms of Service, this Policy does not apply to any information collected or processed by us in connection with your or your company's use of such Software Offerings. In such cases, you will need to refer to our contract with you or your organization for information about our policies and practices for collecting and processing information in connection with your or your organization's use of such Software Offerings.

Important Information - Please Review Carefully. Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you can choose not to access or use our Offerings. By accessing or using our Offerings, except as described in the section above titled "When It Doesn't Apply", you agree to this Policy. This Policy may change from time to time. When we make changes to this Policy, we will post the updated Policy on our Website and update the Policy's "last modified" date. We will also provide notice of any material changes as explained in the section below titled "Changes to Our Privacy Policy". Your continued use of our Offerings after we make changes is deemed to be acceptance of those changes.

Information Collected About You and How It Is Collected

Personal Information We Collect - Generally. We may collect several types of information from and about users of our Offerings. This information may include information by which users may be personally identified or other information about a user to the extent maintained in personally-identifiable form (collectively "Personal Information"). Specifically, we (or our third-party service providers acting on our behalf) may collect the following from you:

• Personal identifiers and contact information, such as your name, e-mail address, telephone number (including mobile telephone number) and the IP Address or Mobile Device ID of the computer or device used to access and use our Offerings ("Identifiers").
• The name and contact information of your company or organization.
• Your or your company or organization's country or region.
• The Technical Information described in the section below titled "Traffic, Usage and Computer/Device Information".
• Information related to Internet or other similar network activity, including browsing history, search history and information on your interaction with our Offerings ("Internet Activity").
• Any other information (including Personal Information) you choose to provide to us, such as in any forms or messages submitted by you to us through our Website or using the contact information provided on our Website, or and any Personal Information that you choose to upload to or through our Software Offerings or otherwise provide to us in connection with our provision of our Software Offerings.

How We Collect Information. With the exception of your Technical Information and Internet Activity (which we or our third-party service providers collect automatically as you navigate through or interact with our Offerings, as described below in the section titled "Traffic, Usage and Computer/Device Information"), generally we collect Personal Information directly from you when you provide it or submit it to us directly such as in connection with registering to obtain additional information from us (such as by signing up to receive our e-newsletter or other marketing and promotional information about us or our products and services), purchasing a subscription to our Software Offerings, entering into a sweepstakes, contest, giveaway or other promotion related to our products and services, responding to a voluntary survey you have agreed to complete, contacting us for service inquiries or reporting a problem with one or more of our Offerings, otherwise submitting an inquiry to us using the contact methods provided on our Website or associated with our Software Offerings, or otherwise contacting us about our Offerings or our business.

Traffic, Usage and Computer/Device Information; Cookie Policy. Additionally, as you navigate through and interact with our Offerings or interact with the e-mails or other electronic messages we send to you, we or our third-party service providers may automatically collect certain traffic data, usage information and information about your computer equipment or mobile device, such as your browser and operating system, your wireless carrier, configuration data, clickstream analytics and your actions and patterns when you use our Offerings ("Technical Information"). The technologies we use for this automatic data collection may include cookies that are stored on the browser of your computer or mobile device, small embedded electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) and other types of embedded code. We collect this information to manage our content and improve users' use of our Offerings; to count and review the number of users of our Offerings and their usage patterns; to track key performance indicators such as pages accessed, frequency of access and other statistical information related to our Offerings (for example, recording the popularity of certain content and verifying system and server integrity); to identify the portion of users who access our Offerings via different web browsers; to recognize if a user is a return user of our Offerings; to store information about a user’s visits; to remember a user's preferences; and for similar purposes in connection with monitoring, operating, maintaining and improving our Offerings. Third parties may also collect Technical Information and other information on our behalf as further described in the sections below titled "Use of Google Analytics" and "Tracking and 'DO NOT TRACK'".

How We Use Your Information

Generally. We may use the information we collect about you or that you provide to us, including Personal Information, to:

• Provide our Offerings to you.
• Provide you with information you request from us.
• Authenticate or otherwise verify your identity in connection with your requests and inquiries via the Offerings or otherwise.
• Provide you with support and respond to your inquiries and support requests relating to our Offerings, including to investigate and address your concerns and to monitor and improve our responses.
• Update and maintain e-mail or mailing lists (such as our e-mail lists to receive newsletters or alerts by e-mail).
• Carry out the advertising, promotional and marketing purposes as described in the section below titled "Use of Personal Information for Marketing Purposes".
• Help maintain the safety, security and integrity of our Offerings, databases and other technology assets and our business.
• Register you for sweepstakes, contests, giveaways or other promotions.
• Develop and administer voluntary user surveys.
• Notify you about changes to our Offerings, products and services.
• With respect to pseudonymized, aggregated or de-identified information, fulfill the purposes described in the section below titled "Use and Disclosure of Pseudonymized, Aggregated or De-Identified Data".
• With respect to Technical Information, fulfill the purposes described in the section above titled "Traffic, Usage and Computer/Device Information".
• Respond to lawful requests for information through court orders, subpoenas, warrants and other legal processes or obligations.
• Enforce any contracts between you and us, including for billing and collection, or for the establishment, exercise or defense of legal claims.
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which information (including Personal Information) held by us is among the assets transferred.
• Fulfill any other purpose for which you provide the information.
• Serve any other purpose that we describe when you provide the information and for any other purpose with your consent.

Use of Personal Information for Marketing Purposes. We may use your information (including Personal Information) for advertising, promotional and other marketing purposes in various ways. This includes using your information (including Personal Information) to provide you with informational and promotional content and materials, including by e-mail, regarding the Offerings and our own products and services, such as advertising and promotional information about our products and services or information about special offers or promotions related to our products and services.

If you do not want us to use your information in this manner, see the section below titled "Your Rights and Choices" for more information about how to opt out of such uses.

Third-Party Sites and Services. Our Website may include links to blogs, social media and third-party websites. These third-party sites have their own privacy policies and terms of use and are not controlled by this Policy. You should carefully review any terms, conditions and policies of such third-party sites before visiting them or supplying them with any Personal Information. If you follow a link on our Website to any third-party site, any information you provide to that site will be governed by its own terms of use and privacy policy and not this Policy.

We are not responsible for the privacy or security of any information you provide to a third-party website or the information practices used by any third-party site, including those that are accessed via links to any third-party site from our Website. We make no representations, express or implied, concerning the accuracy, privacy, safety, security or the information practices of any third-party site. The inclusion of a link to a third-party site on our Website does not constitute any type of endorsement of the linked site by us. We are not responsible for any loss or damage you may sustain resulting from your use of any third-party website or any information you share with a third-party website.

Use and Disclosure of Pseudonymized, Aggregated or De-Identified Data. We may pseudonymize some Personal Information of users so that it can no longer be attributed to a particular, identifiable user without the use of other separately maintained information, or we may convert or combine some Personal Information of users into de-identified or aggregated data that does not disclose any of the Personal Information of any individual user. As an example, we may pseudonymize, de-identify or aggregate information provided by or collected about you and other visitors to our Website or users of our Software Offerings to generate aggregate trends or insights about the behavior of visitors to our Website or users of our Software Offerings generally that may be shared (including for commercial purposes) with third parties. You understand and agree that we may use and disclose to third parties any such pseudonymized, de-identified or aggregated data for any lawful purpose.

Tracking and "DO NOT TRACK". Tracking involves the use of cookies, web beacons or other embedded code or tracking technologies to collect, analyze and store information on a user's behavior over time on multiple sites, including information on the sites visited, products viewed, products purchased and other online interactions. Tracking information can be used to enable companies to make interest-based ("behavioral" or "targeted") advertising available to users on multiple sites that they visit.

Currently we do not (and we do not allow third parties to) collect Personal Information about your online activities over time and across third-party sites for tracking purposes when you use our Offerings. Because of this, our Offerings do not respond to any "do not track" signals sent by your computer, browser or mobile device, and if your computer, browser or mobile device sends a "do not track" signal to one or more of our Offerings, our Offerings will not treat you differently from users who do not send such signals.

For more information on how to disable certain tracking technologies, please visit the Network Advertising Initiative’s Consumer Opt-Out page at https://thenai.org/opt-out/ and the Digital Advertising Alliance's Consumer Assistance page at https://youradchoices.com/control.

Use of Google Analytics. We use Google Analytics to track and analyze certain traffic and usage statistics regarding the use of our Offerings, such as the number of visitors to our Offerings, how visitors are navigating to our Offerings, visitors' general geographic region information, how long individuals are visiting our Offerings, and information about the equipment individuals are using to access our Offerings (e.g., browser version and operating system). Google Analytics may use a Google Analytics cookie as part of this service, and we may share certain Personal Information with Google Analytics (such as an IP address) as part of this service. We use this traffic and usage information to make improvements to our Offerings and our own marketing and promotional efforts.

For more information, please review the following:

• Information about Google's use of cookies: https://policies.google.com/technologies/cookies?hl=en-US
• You can opt out of our use of certain Google Analytics features by updating the "Ads Settings" in your browser (www.adssettings.google.com/authenticated or mobile device (www.support.google.com/ads/answer/1660762#mob, by enabling the Google Analytics Opt-out Browser Add-on in your browser (https://tools.google.com/dlpage/gaoptout) or by visiting the Network Advertising Initiative's ("NAI") Consumer Opt-Out page (www.optout.networkadvertising.org/. Because those opt-out and preference control pages are specific to the individual browser used to visit it, and because those pages are not operated by us, we are unable to perform the opt-outs on your behalf.

Disclosure of Your Information

Generally. We may share your Personal Information with third parties in the following circumstances:

• We may disclose Personal Information to our affiliates or to any contractors and other service providers who need to know such information (or such contractors, service providers or other third parties may collect Personal Information directly from you on our behalf while you use our Offerings) to provide services to us that support our hosting, maintenance, operation and promotion of our Offerings and our permitted uses of Personal Information under this Policy. For example, we may use a third-party cloud-hosting infrastructure service provider (e.g., Amazon Web Services, Google Cloud or Microsoft Azure) to store certain of your Personal Information securely; we may use a customer relationship management and/or an e-mail marketing software solution offered by a third-party service provider to organize and track our communications with you; and we may use certain third-party website analytics service providers (such as Google Analytics, as described above in the sections titled "Use of Google Analytics").
• We may disclose Personal Information to a buyer or other successor to our business in the event of a sale of equity or assets, reorganization, merger or a similar corporate transaction, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, and in connection with any due diligence review with respect to any such proposed transaction.
• We may disclose Personal Information to comply with any court order, law or legal process, including to meet national security and law enforcement requirements and to respond to any government or regulatory request or audit.
• We may disclose Personal Information to enforce or apply any legal agreements between us and you, or if we believe disclosure is necessary or appropriate to protect the rights, property or safety of our customers or others.
• • We may also disclose your Personal Information for any purpose disclosed when the information is provided, and for any other purpose with your consent.

We may disclose Technical Information and all forms of Personal Information for each of the purposes described above, including but not limited to your Identifiers, Internet Activity.

No Sales of Personal Information. We do not sell, and in the past 12 months we have not sold, any Personal Information to third parties.

Your Rights and Choices

Generally. You have certain choices regarding the Personal Information you provide to us. You can set your browser to refuse all or some browser cookies. If you choose not to accept cookies, you may be unable to access certain parts or pages of our Offerings, or certain parts or features of our Offerings may not function properly.

If you do not wish to have your Personal Information used by us to contact you for marketing purposes, you can opt out (1) by sending us an e-mail with your request to hello@zatomic.ai or (2) with respect to marketing communications by e-mail, by clicking on the "Unsubscribe" or similar link in the most recent e-mail you received from us and by following the prompts that appear. This opt-out does not apply to information provided as a result of a purchase, customer service or support service inquiry or other informational or transactional communications (e.g., an order confirmation or response to a specific inquiry or request you have made to us).

Please also refer to the section above titled "Use of Google Analytics" for more information regarding opting out of certain Google Analytics features used on and in connection with our Offerings.

Accessing and Correcting Your Information: Generally. You can review, change and request the deletion of certain portions of your Personal Information by sending us an e-mail at hello@zatomic.ai to request access to any Personal Information that you have provided to us, or to request to correct or delete that Personal Information. Except as specifically described below in the sections titled "Canadian Users: Individual Access", "European Users: Your European Privacy Rights", the following will apply with respect to each such request:

• We will evaluate such requests on a case-by-case basis.
• In certain cases we cannot delete your Personal Information. For example, we cannot continue to maintain your account and/or your subscriptions without retaining certain portions of your Personal Information, so a request to delete certain forms of Personal Information may require the deletion of your account and cessation of services to you.
• We also may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Canadian Users: Individual Access. If you are a user accessing and using our Offerings from Canada then, upon your request, and subject to certain exceptions under applicable law, we will inform you of the existence, use, and disclosure of your Personal Information and give you access to that information, and you may challenge the accuracy and completeness of the information and have us amend it as appropriate. You may submit a request under this section by sending us an e-mail stating your request to hello@zatomic.ai. Regardless of the method you use to contact us, please indicate in your communication that you are making an individual access request under Canadian law.

California "Shine The Light" Disclosure. The California Civil Code permits California residents with whom we have an established business relationship to request that we provide a list of certain categories of Personal Information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an e-mail to hello@zatomic.ai. Please mention that you are making a "California Shine the Light" inquiry.

Nevada Residents: Sale Opt-Out Rights. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: hello@zatomic.ai. Please mention that you are making a "Nevada Sale Opt-Out Right" request. However, please know we do not currently sell data triggering that statute's opt-out requirements.

Users Outside of the United States

Generally. Our Offerings are hosted in the United States and are provided from the United States. It is possible that certain information will be stored on servers in multiple other countries on the "cloud" or other similar distributed hosting platforms. If you are accessing our Offerings from Canada, the United Kingdom, a country in the European Economic Area, Asia or any other jurisdiction with laws governing personal data collection, use and disclosure that differ from United States laws, please note that by using our Offerings and providing your Personal Information to us through our Offerings you are expressly and knowingly consenting to the transfer of your Personal Information from your home country to the United States and other jurisdictions as indicated above (where laws may differ from the laws of your jurisdiction) and you are expressly and knowingly consenting to our use of such Personal Information in accordance with this Policy.

European Users. If you are a user accessing and using our Offerings from one of the European Economic Area countries, Switzerland or the United Kingdom (collectively, the "European Countries" and such users the "European Users"), please read this section carefully for more information about our collection, processing and transfer of your Personal Information and your rights related to such activities.

1. Legal Basis for Processing. If you are a European User, we have the legal right to collect, process, use and retain your Personal Information ("European Personal Information") in the ways described in this Policy based on your consent, the need to use your European Personal Information to provide you with goods or services that you have requested, and/or our legitimate interests in furthering our existing relationship with you or preventing fraud. Accordingly, generally you have a contractual rather than a statutory obligation to provide such information. If you do not provide such information, you may be unable to use our Offerings and we may be unable to provide any products or services that you request.
2. Transfers of Your European Personal Information to the United States. In connection with our collection and use of your European Personal Information, we may transfer all or certain portions of your European Personal Information to our servers in the United States or our third-party service providers in the United States. Please note that the governing bodies in your jurisdiction have determined that the laws of the United States do not provide adequate protection for your European Personal Information. Accordingly, we are transferring your European Personal Information from your country to the United States based on your explicit consent, because the transfer is necessary for the performance of a contract between you and us or the implementation of pre-contractual measures taken at your request, because the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and another natural or legal person (e.g., your organization) and/or because the transfer is necessary for the establishment, exercise or defense or legal claims, and you acknowledge and agree that we may collect, use and disclose your European Personal Information, both before and after such transfer, in accordance with this Policy.
3. Storage of Your European Personal Information. We securely store your European Personal Information in distributed locations in the United States using our own servers or the servers of reputable, third-party service providers such as our cloud-hosted infrastructure service provider and other cloud-based software service providers. We will keep such information for no longer than necessary. The length of time we retain your European Personal Information will depend on any legal obligations we have (such as tax recording purposes), the nature of any contracts we have in place with you, the existence of your consent or our legitimate interests as a business.
4. Your European Privacy Rights. If you are a European User, you will have the following additional rights with respect to your European Personal Information (your "European Privacy Rights"):

   • If we intend to disclose your European Personal Information to any third party that will have the right to process your European Personal Information, we will enter into a contract with that third party that provides that your European Personal Information may be processed only for limited and specified purposes consistent with the consent that you have provided to us, and that the third party must provide the same level of protection for your European Personal Information that we are obligated to provide under this Policy. In addition, we will notify you if that third party will have the right to determine the purposes for which it will process your European Personal Information and the means it will use to process your European Personal Information (rather than just providing requested assistance to us in support of our permitted uses of your European Personal Information). In certain situations, we may be required to disclose your European Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
   • If we are processing your European Personal Information based on your consent, you may withdraw that consent at any time. Your withdrawal will not affect the lawfulness of our processing based on your consent before your withdrawal. If you withdraw your consent, we may not be able to provide our Offerings or our other products or services to you. We will advise you if this is the case at the time you withdraw your consent.
   • You may restrict our use and processing of your European Personal Information by sending us an e-mail stating your request to hello@zatomic.ai, if you have contested the accuracy of that information, if the processing is unlawful or if we no longer need such information for the purposes for which it was collected. We will then store your European Personal Information and process it only with your consent, or to establish, exercise or defend a legal claim or to protect the rights of others. The restriction with respect to information claimed to be inaccurate would end if we verify the accuracy of that contested information.
   • We do not collect, store or process sensitive information related to your racial or ethnic identity, political opinions, religious or philosophical beliefs, trade union membership, health (including genetic and biometric data), sex life or sexual orientation ("European Sensitive Information"). We will not use or disclose any of your European Sensitive Information without your explicit consent, subject to certain limited exceptions. Should we wish to make any such use or disclosure, we will notify you by e-mail and will request that you authorize such use or disclosure by responding to the e-mail with your explicit consent.
   • Upon our receipt of your request by e-mail at hello@zatomic.ai and our verification of your identity, we will advise you whether we are processing European Personal Information concerning you and, if so, will provide you with a copy of your European Personal Information being processed and certain information about the nature and purposes of the processing. You may correct, amend or delete any such European Personal Information that is inaccurate or incomplete. We will respond to all requests within a reasonable timeframe.
   • Upon your request by e-mail at hello@zatomic.ai and our verification of your identity, we will erase any of your European Personal Information that is no longer needed for the purpose for which it was collected or that is being used for direct marketing purposes, or if our use is based on your consent and you withdraw that consent. We will not erase such information, however, to the extent it is necessary for the establishment, exercise or defense of a legal claim or another exception applies under applicable law.
   • If we are using your European Personal Information on the basis of your consent and we change our Policy to permit any use or disclosure of your European Personal Information that is materially different than the uses for which it was originally collected or subsequently authorized by you, we will obtain your consent before we make such further uses of your European Personal Information.

Generally, you will not have to pay a fee to exercise any of your European Privacy Rights. We may, however, charge a reasonable fee if a request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in those circumstances.

We may need to request specific information from you to help us confirm your identity and to ensure your right to exercise your European Privacy Rights. This is a security measure to ensure that your European Personal Information is not disclosed to a person who does not have a right to receive it.

We try to respond to all legitimate requests related to European Privacy Rights within a reasonable timeframe. Occasionally, it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated of our progress.

A list of Supervisory Authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Children Under the Age of 18

Our Offerings are not intended for children under 18 years of age, and no one under the age of 18 may provide any information to us on or using our Offerings. We do not knowingly collect Personal Information from children under the age of 18. If you are under 18 years of age, do not use our Offerings or provide any information about yourself to us, including your name, address, telephone number, e-mail address, IP Address or Mobile Device ID, or any screen name or username you may use. If we learn we have collected or received Personal Information from a child under 18 years of age without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 18, please contact us at hello@zatomic.ai.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Our security and privacy policies are periodically reviewed and enhanced as necessary. While we strive to undertake such reasonable and necessary efforts to secure Personal Information provided to us, even such security measures do not guarantee the security of all Personal Information, and we cannot guarantee that the Personal Information we collect, use and retain will be protected in all circumstances, including those beyond our reasonable control.

Below is a non-exhaustive list of our security measures:

• All data is encrypted both in-transit and at-rest.
• We only use HTTPS, SSL, and TLS technologies and protocols for secure communication across our entire platform and between external systems.
• User passwords are securely stored using one-way hashing with unique salts.
• API keys are encrypted and masked, with each key stored using its own cryptographic vector.
• All customer data is segmented using unique account identifiers within a multi-tenant data store to prevent unauthorized cross-access.
• Our data is hosted in a private virtual network, accessible only by specific infrastructure components that require it for operation.
• Connection to our cloud environment is restricted to a secure VPN, with access tightly controlled and granted only to authorized personnel for necessary support functions.
• Any AI prompts, versions, or analyses stored within our system remain private to your account. We do not share stored prompts with any third parties, and they are never used for training AI models.

Changes to Our Privacy Policy

We post any changes we make to our Policy on this page. If we make material changes to how we collect and use Personal Information (including with respect to the categories of Personal Information we collect), we will notify you through a notice on the Website home page. The date this Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Policy to check for any changes. Please note that we will not collect additional categories of personal information beyond those disclosed in this Policy without providing additional notice to you, and we will not use your Personal Information for additional purposes beyond those disclosed in this Policy without providing notice.

Contact Information

To ask questions or to submit comments about this Policy and our privacy practices, you may contact us via e-mail at hello@zatomic.ai.