Privacy Policy

Effective Date June 5, 2026

This Privacy Policy describes how BrightAI Corporation (“BrightAI,” “we,” “us” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, marketing activities, mobile app, and other activities described in this Privacy Policy (collectively, the “Service”)).

This Privacy Policy does not apply to any information that we process on behalf of our business customers (such as businesses and other organizations) while providing BrightAI services to them and their employees. Our use of information that we process on behalf of our business customers is governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that enterprise customer.

Our websites, products, and services are designed for enterprise customers operating in their professional capacities. We do not offer products or services intended for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect in connection with our website, marketing activities and live events as pertaining to individuals in their business capacities, or as representatives of the relevant enterprise, and not in their individual capacities.

BrightAI may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section at the end of this Policy for additional information for individuals located in the European Economic Area, Switzerland or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly).

Index

Personal information we collect
How we use your personal information
How we share your personal information
Your choices
Retention
Other sites and services
Security
International data transfer
Children and teens
Changes to this Privacy Policy
How to contact us
Notice to European Users

Personal information we collect

Information you provide to us. Personal information you may provide to us includes:

Contact data, such as your first and last name, salutation, email address, mailing addresses, professional title and company name, and phone number (phone numbers are collected for two-factor authentication purposes and are not shared with third parties for marketing or promotional purposes.).
Profile data, such as the username and password that you may set to establish an online account on the Service, and any other information that you or your company add to your account profile. For example, BrightAI Opportunity Explorer allows you to add a profile photo or avatar, time zone and language preferences, and other professional information.
Communications data, based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Event registration data, such as your Contact data and any other information you provide when registering for a webinar or other event.
Other data, not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data,such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Communication interaction data, suchas your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Some of our automatic collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

Partners, such as marketing partners and event co-sponsors.

Service providers, that provide services on our behalf or help us operate the Service or our business.

Third-party linked services, such as your Apple, Google, Facebook, or other accounts, that you use to log into, or otherwise link with, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

provide and operate the Service and operate our business;
establish and maintain your profile on the Service;
enable security features of the Service, such as by sending you security codes and remembering devices from which you have previously logged in;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and
provide support for the Service, and respond to your requests, questions and feedback.

Service personalization. We may use your personal information to personalize the Service for you, which may include using your personal information to:

personalize your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate the Service.

SMS / Text Messaging. We may send text messages to mobile numbers you provide, with your consent. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All other categories of personal information exclude text messaging originator opt-in data and consent; that information will not be shared with any third parties.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Marketing. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Events, promotions and contests. We may use your personal information to:

administer promotions and contests
communicate with you about promotions or contests in which you participate
contact or market to you after collecting your personal information at an event.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information by removing information that makes the data identifiable to you. We will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Data sharing in the context of business transactions, we may share certain personal information in the context of actual or prospective business transactions – for more information, see How we share your personal information, below.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection).

Service providers. Third partiesthat provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Partners. Third partieswith whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of BrightAI, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of BrightAI as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choice

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below in the ‘Notice to European Users’.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Account Deletion. You may delete your account at any time through the account settings in the Service or by contacting privacy@bright.ai/. Upon account deletion, we will delete your personal information, subject to the Retention section below.

Cookies and other technologies. For information about our use of cookies and similar technologies and your options, see our Cookie Policy.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into webpages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile application or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Security

We employ technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users who are located in Europe can find additional information about data transfers below.

Children and teens

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or by other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgement that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you, please contact us via the method listed below.

Email: privacy@bright.ai

Mail:
BrightAI, Corporation
1001 Page Mill Rd, Bldg 3
Palo Alto, CA 94304
United States

U.S. State Privacy Rights Notice at Collection

Except as otherwise provided, this section applies to residents of California and other states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the “State Privacy Laws”).

This U.S. State Privacy Rights Notice at Collection is part of our full Privacy Policy.

This section describes how we collect, retain, use, disclose, sell and share for the purposes of targeted advertising personal information of residents of these states and the rights these users may have with respect to their personal information. Please note that not all rights listed below may be afforded to all individuals and that if your state does not afford you these rights, you may not be able to exercise these rights. In addition, we may not be able to process your access, correction or deletion request if you do not provide us with sufficient detail to allow us to confirm your identity and understand and respond to your request.

For purposes of this section, the term “personal information” means information that relates to an identified or identifiable natural person, or that is reasonably capable of being used to identify, contact, or precisely locate a natural person, household, or a particular computing system or device.

We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Your privacy rights. You may request to exercise the rights listed below. We will respond to your request in accordance with applicable law. We may decline to honor your request where an exception applies.

Right to know

You can request to know whether we process your personal information.
You can request the following information about how we have collected and used your personal information during the past 12 months and how we will continue to do so:
- The categories of personal information that we have collected.
- The categories of sources from which we collected personal information.
- The business or commercial purpose for collecting, selling, and/or sharing personal information for targeted advertising purposes.
- The categories of personal information that we sold or shared for targeted advertising purposes, and the categories of third parties to whom this information was sold or shared, categorized by the type of personal information for each type of third party.
- The categories of personal information that we disclosed for business purposes and the types of entities to whom this information was disclosed.

Access. You can request a portable copy of the personal information that we have collected about you.
Correction. You can ask us to correct inaccurate personal information that we have collected about you.
Deletion. You can ask us to delete the personal information that we have collected from or about you.
Revoke consent. You may have the right to revoke your consent to our processing of your personal information.

Opt-out.
- Opt-out of targeted advertising. We do not process your personal information for targeted advertising purposes.
- Opt-out of sale of your Personal Information. We do not sell your personal information. We do not sell personal information of minors under 18 years of age.
- Automated decision making. We do not use your personal information to engage in automated processing or profiling personal information to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements to make a decision that produces legal or similarly significant effects.

Sensitive Personal Information. We do not collect Sensitive Personal Information.
Nonretaliation. You are entitled to exercise the rights described above free from retaliation as prohibited by the State Privacy Laws.

Exercising your right to know, access, correction, and deletion. You may submit requests at this webform, calling us toll free at 1-866-467-8688, and enter 2444#, or via email to privacy@bright.ai.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Global Privacy Control. The Global Privacy Control is an opt-out preference signal that allows you to automatically exercise your right to opt-out of the sale or sharing for targeted advertising purposes of your personal information. Because we do not sell or share your personal information for targeted or cross-contextual advertising purposes, broadcasting the Global Privacy Control does not change how we process your personal information. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/.

Verification of Identity; Authorized agents. We may need to verify your identity to process your know, access, correction, or deletion requests and reserve the right to confirm your residency. We may need to request certain of your personal information, in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your personal information.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. Depending on the kind of request you have made, we may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Law rights on your behalf, the information we request to verify your identity, or confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. We have summarized the personal information we collect and may disclose, sell to or share with third parties by reference below to both the categories of personal information defined in the “Personal Information we collect,” “How we use your personal information,” and “How we share your personal information” sections of this Policy above and the categories of personal information specified in state law. This table describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

See our full Privacy Policy for descriptions of each entry in this table.

Personal Information (“PI”) we collect	California statutory category of PI	Business/commercial purpose for PI collection	Categories of third parties to whom we “disclose” PI for a business purpose
Contact data	Identifiers Customer records	Service delivery and operations Service improvement and analytics Direct Marketing Compliance and protection Analytics Corporate transactions	Affiliates Service providers Payment processors AI platforms Third parties designated by you Sponsor partners Professional advisors Authorities Counterparties and advisors/professionals in corporate transactions Other users and the public
Communications data	Commercial information Internet activity	Service delivery and operations Service improvement and analytics To create aggregated, de-identified and/or anonymized data Direct Marketing Compliance and protection Analytics Corporate transactions
Marketing Data	Commercial information Internet activity Inferences	Service delivery and operations Service improvement and analytics Direct Marketing Compliance and protection Analytics Corporate transactions
Device data	Identifiers Internet activity Geolocation data	Service delivery and operations Service improvement and analytics To create aggregated, de-identified and/or anonymized data Direct Marketing Compliance and protection Analytics Corporate transactions
Location Data (approximate)	Geolocation data	Service delivery and operations Service improvement and analytics To create aggregated, de-identified and/or anonymized data Direct Marketing Compliance and protection Analytics Corporate transactions
Communication interaction data	Commercial information Internet activity	Service delivery and operations Service improvement and analytics To create aggregated, de-identified and/or anonymized data Direct Marketing Compliance and protection Analytics Corporate transactions
Online activity data	Commercial information Internet activity	Service delivery and operations Service improvement and analytics To create aggregated, de-identified and/or anonymized data Direct Marketing Compliance and protection Analytics Corporate transactions
Tracking technology data	Identifiers Internet activity	Service delivery and operations Service improvement and analytics To create aggregated, de-identified and/or anonymized data Direct Marketing Compliance and protection Analytics Corporate transactions
Inferences from the above kinds of personal information	Inferences	Service delivery and operations Service improvement and analytics To create aggregated, de-identified and/or anonymized data Direct Marketing Compliance and protection Analytics Corporate transactions

Consumers under 18. We do not have actual knowledge that we have collected, sold, or shared the personal information of residents who are under 18 years of age.

Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale, as defined, of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email privacy@bright.ai.

Retention Period for Personal Information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, including Sensitive Personal Information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.

Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section, above.

Notice to European Users

General

Where this Notice to European users applies. The information provided in this “Notice to European Users” section applies only to individuals in the United Kingdom, Switzerland and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Controller. BrightAI is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”) and the Swiss Federal Act on Data Protection (as and where applicable, the “FADP”)). See the ‘How to contact us’ section above for our contact details.

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR and the FADP) – i.e., information about individuals from which they are either directly identified or can be identified.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:

Our Representative in the EU. Our EU representative appointed under the EU GDPR is EDPO. You can contact them:	Our Representative in the UK. Our UK representative appointed under the UK GDPR is EDPO. You can contact them:
– by using EDPO’s online request form: https://edpo.com/gdpr-data-request/ – by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium	– by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/ – by writing to EDPO UK Ltd, Unit 33, Waterside, Schooner Court, 44-48 Wharf Road, London, N1 7UX, United Kingdom
Our Representative in Switzerland. Our Swiss representative appointed under Swiss privacy laws is EDPO. You can contact them:
– by using EDPO Switzerland’s online request form: https://edpo.com/swiss-data-request/ – by writing to EDPO Switzerland at Rue de Lausanne 37, 1201 Geneva, Switzerland

Our legal basis for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to perform a contract we have entered into with you or are about to enter (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’.

Purpose	Categories of personal information involved	Legal basis
Service delivery and operations	Contact data Profile data Transactional data Communications data Marketing data Event registration data Device data Online activity data Communication interaction data Data from Third Party Sources	Contractual Necessity Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service, our business and associated IT services, systems and networks.
Service personalization	Profile data Communications data Device data Online activity data Communication interaction data Data from Third Party Sources	Legitimate Interests. We have a legitimate interest in providing you with a good service via the Service, which is personalized to you and that remembers your selections and preferences. Consent, in respect of any optional processing relevant to personalization (including processing directly associated with any optional cookies used for this purpose).
Service improvement and analytics	Profile data Communications data Device data Online activity data Communication interaction data Data from Third Party Sources	Legitimate Interests. We have a legitimate interest in providing you with a good service and analyzing how you use it so that we can improve it over time, as well as developing and growing our business. Consent, in respect of any optional cookies used for this purpose.
Direct marketing and events, promotions and contests	Contact data Communications data Event registration data Marketing data Data from Third Party Sources	Legitimate Interests. We have a legitimate interest in promoting our organization and sending marketing communications and organizing events, promotions and contests for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications or organizing events, promotions and contests.
Compliance and protection	Any and all data types relevant in the circumstances	Compliance with Law Legitimate Interests. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety. We also have a legitimate interest in ensuring the ongoing security and proper operation of our Service and associated IT services, systems, and networks.
To create aggregated, de-identified and/or anonymized data	Any and all data types relevant in the circumstances	Legitimate Interests. We have a legitimate interest in taking steps to preserve our users’ privacy as we research how they use our Service.
Data sharing in the context of business transactions	Any and all data types relevant in the circumstances	Legitimate Interests. We have a legitimate interest in pursuing and consummating actual or prospective corporate transactions and providing information to relevant third parties involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations).
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Other

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Your rights

General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information you have provided to us that we process based on Consent or Contractual Necessity.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we process your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by email to privacy@bright.ai. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your supervisory authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK – contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/
For users in Switzerland – contact information for the Swiss supervisory authority is below:

Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragte
Feldeggweg 1
CH – 3003 Bern

Data Processing outside Europe

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection.
- However, in these cases:
  - we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
  - in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

Personal information subject to the FADP is transferred to the following countries:

EU Member States (transfer mechanism: adequacy decision);
U.S. (transfer mechanism: EU standard contract clauses (including the Swiss Annex) [and Swiss-U.S. Data Privacy Framework (as applicable)];
UK (transfer mechanism: adequacy decision).

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at privacy@bright.ai.

Notice of Certification under the Data Privacy Framework (“DPF Notice”)

Effective as of June 5, 2026

BrightAI complies with the (i) EU-U.S. Data Privacy Framework (EU-U.S. DPF), (ii) the UK Extension to the EU-U.S. DPF, and (iii) the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) (collectively, the “Data Privacy Framework”) as set forth by the U.S. Department of Commerce. BrightAI has certified to the U.S. Department of Commerce that BrightAI adheres (i) to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal information received from the EU in reliance on the EU-U.S. DPF, and (ii) from the UK (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF, and (iii) to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal information received from Switzerland in reliance on the Swiss-U.S. DPF (collectively, the “DPF Principles”). If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles (as applicable) shall govern. To learn more about the Data Privacy Framework, and to view our certification, please visit the Data Privacy Framework website.

Data processed and purposes of data processing: BrightAI may collect, use, and disclose categories of personal information received in reliance on the Data Privacy Framework for the purposes described in this Privacy Policy, including the sections entitled “Personal information we collect” and “How we use your personal information.”

Third parties who may receive personal information: BrightAI uses a limited number of third parties to assist BrightAI in providing our services to customers. The types of third parties with which BrightAI may share personal information received in reliance on the Data Privacy Framework and for which purposes are set out in the section of this Privacy Policy entitled “How we share your personal information.”

If recipients to whom BrightAI has disclosed personal information in reliance upon the Data Privacy Framework process it in a manner that does not comply with the DPF Principles, BrightAI may be accountable, unless BrightAI proves that BrightAI is not responsible for the event giving rise to the damage.

Inquiries and complaints: In compliance with the Data Privacy Framework, BrightAI commits to resolve DPF Principles-related complaints about our collection or use of your personal information. EEA, UK and Swiss individuals with inquiries or complaints regarding our handling of personal information received in reliance on the Data Privacy Framework should first contact us by email at privacy@bright.ai, or please write to the following address:

BrightAI Corporation
1001 Page Mill Rd, Bldg 3
Palo Alto, CA 94304
United States

In compliance with the Data Privacy Framework, BrightAI commits to refer unresolved complaints concerning our handling of personal information received in reliance on the Data Privacy Framework to BBB National Programs, Inc., an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit DPF Services Dispute Resolution Process page for more information or to file a complaint. The services of BBB National Programs, Inc. are provided at no cost to you.

Additionally, under certain conditions, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. For more information on this option, please see the Data Privacy Framework website: Annex I

Your rights to access, to limit use, and to limit disclosure: Depending upon the context in which BrightAI processes personal information received in reliance upon the Data Privacy Framework, EEA, UK and Swiss individuals may have rights to access personal information about them, and choices to limit the use and disclosure of their personal information. With our Data Privacy Framework self-certification, BrightAI has committed to respect those rights. Please submit a written request to exercise your rights or choices to the contact information provided in this Privacy Policy (see the section entitled “How to contact us”). BrightAI may request specific information from you to confirm your identity in an effort to respond to your request.

U.S. Federal Trade Commission enforcement: With respect to personal information received or transferred pursuant to the Data Privacy Framework, the U.S. Federal Trade Commission has jurisdiction over BrightAI’s compliance with the Data Privacy Framework.

Compelled disclosure: BrightAI may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

BrightAI may amend this DPF Notice on the Data Privacy Framework from time to time consistent with Data Privacy Framework requirements.