PRIVACY NOTICE

This Privacy Notice describes how Poseidon AI, Inc. (“we”, “us”, “our”) collects, uses and discloses information about you when you use our websites, data contribution platform, NUMO mobile application or otherwise interact with us where this Privacy Notice is posted (collectively, the “Services”). For the purposes of this Privacy Notice, we are the data controller, and “you” and “your” means you as the user of the Services.

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not understand or agree to this Privacy Notice, please do not use or access the Services.

1. CHANGES TO THIS PRIVACY NOTICE

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to how we use or disclose information we collect, we will use reasonable efforts to notify you as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

2. COLLECTION AND USE OF INFORMATION

When you use or access the Services, we collect certain categories of information about you from a variety of sources. In addition to the specific uses discussed below, we may use this information to provide and improve the Services and to maintain our business relationship, as a matter of our legitimate interests, including by enhancing the safety and security of our Services, providing customer support, complying with applicable legal obligations, enforcing any applicable terms of use, and protecting our rights and the rights of our employees, users or other individuals.

To the extent required by applicable data protection laws, we process your personal information on the legal bases specified below. Where the laws in your jurisdiction do not recognize the legal basis of legitimate interest or another legal basis specified below for a particular purpose, you consent to the processing of your personal information for that purpose by consenting to the processing in this Privacy Notice.

Some of the categories of personal information specified below may be considered sensitive personal information under applicable law, and you consent to the collection of such information.

Information You Provide to Us

Some features of the Services may require you to directly provide certain information, including information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services may include but is not limited to:

• Basic contact details, such as name and email address. We use this information where necessary to perform our contract with you to create, maintain and secure your account and provide the Services.
• Professional Information. We may collect information about your professional experience and job history to perform our contract with you and for our legitimate interests in providing our services.
• Payment related information, such as your blockchain wallet address, which we or a third party provider may collect to compensate you, as required to perform our contract with you.
• Account and profile information, such as your username, gender, age, language, and nationality. We collect account login information to maintain your account, as required to perform our contract with you. We collect broader profile information with your authorization in order to perform our contract with you or, to the extent required by applicable data protection laws, with your consent.
• Audio and Video Recordings, and other content that you choose to submit to us through the Services, including without limitation any documentation, files, texts, videos, photos, audio files or any other information. We may collect such content with your authorization in order to perform our contract with you and because it is in our legitimate interests to provide and improve our services. Content you submit may be licensed to third party AI companies who may use it for purposes including voice and visual AI model training.
• Any other information you choose to provide us when using the Services or include in communications with us, for example, when sending a message through the Services, because it is necessary for us to perform our contract with you.

Information Collected Automatically

We and third parties may also use cookies, pixels or other tracking technologies (“Tracking Technologies”) to automatically collect certain information about your interactions with the Services. This information is collected and used with your consent (where consent is required under applicable laws) and in our legitimate interests to run analytics and measure and better understand user interaction with the Service, provide and secure the Services and we may permit third parties to use the below information for such purposes. Such information includes:

• Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.
• Location information, such as approximate location based on IP address.
• Other information regarding your interaction with the Services, such as browser type, log data, date and time stamps, clickstream data (e.g., page requests, page views, how much time is spent on a page, content viewed or interacted with).

For further information on the use of Tracking Technologies and your choices, see the section below, Cookies and Other Tracking Technologies.

Information Collected From Other Sources

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. Such information may include categories of information collected from outside sources that are specific to the Services. Sources from which we currently collect information include:

Google Sign-In. If you choose to create an account or sign in using Google, we receive basic account profile information from Google, including your name and email address, to authenticate your identity and create or access your account.

Stripe Connect. If you choose to enroll in our payout program, our payment partner Stripe may collect identity verification and Know Your Customer (KYC) information, including government-issued identification and bank account details, to verify your identity and facilitate payments to you. This information is collected and processed by Stripe in accordance with Stripe's own privacy policy and terms of service. We receive confirmation of verification status and the information necessary to process payments.

Other sources. From time to time we may receive information about you from additional third party sources, including authentication providers, payment processors, identity verification services, and analytics providers, to the extent necessary to provide and improve the Services. We will update this section as new sources are added.

Any information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for any third party’s policies or practices. For more information, see the section below, Third Party Websites and Links.

Deidentified Information

We may, in our legitimate interests, deidentify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you (or we may collect information that has already been deidentified or anonymized), and we may use such deidentified or anonymized information for any purpose. This includes publishing anonymized or deidentified samples of contributed content publicly on open data platforms and research repositories for the purposes of advancing AI research and development. Any data published publicly in this manner will have undergone a deidentification process designed to remove personal identifiers before publication. Where we publish content that has not been fully anonymized or deidentified, we will obtain your explicit prior consent before doing so.

3. COOKIES AND OTHER TRACKING TECHNOLOGIES

As described above, we and third parties use Tracking Technologies to collect certain information about your interactions with the Services. Most browsers accept Tracking Technologies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete certain Tracking Technologies from your browser; however, blocking or deleting cookies may cause some of the Services, including login features and general functionality, to work incorrectly.

Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of your information when you visit various websites. Like many websites, our website is not designed to respond to such signals, and we do not use or disclose your information in any way that would legally require us to recognize opt-out preference signals. For users of our mobile application, we use similar tracking technologies including device identifiers and embedded analytics SDKs to collect the information described above. The cookie opt-out mechanisms described in this section may not apply to mobile app tracking — to limit tracking on your mobile device please review your device settings for options to limit ad tracking and data collection.

4. BIOMETRIC INFORMATION

Some of our Services may involve the collection of content from which biometric data may be derived and collected for multimodal AI model training purposes. We collect such content only with your explicit prior consent, obtained separately from your general consent to this Privacy Notice through a dedicated in-app consent mechanism presented at the time of the relevant task.

We may license such content to third party AI companies who may use it to extract biometric identifiers including facial geometry and voiceprints for the purposes of training, testing, and improving AI models. We will not license content collected for biometric purposes without your explicit prior consent.

We retain content collected for biometric purposes for no longer than 3 years following your last interaction with the Services, after which it will be permanently and securely destroyed. We do not sell, lease, or otherwise profit from your biometric information except as expressly described in this section and consented to by you.

Residents of certain states including Illinois, Texas, and Washington have additional rights regarding biometric information. To exercise your rights or withdraw consent regarding biometric data collection please contact us at [email protected].

5. DISCLOSURE OF YOUR INFORMATION

We may disclose your information for legitimate purposes subject to this Privacy Notice, including:

• Our affiliates or others within our corporate group, in accordance with our contract with you and as a matter of our legitimate interests to efficiently provide the Services.
• Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, customer relationship management, marketing communications, web analytics, payment networks, and payment processing.
• Third parties, including our business customers and third parties to whom we license submitted content with your authorization, and who may use this information for their own business purposes, including for the purposes of training AI models. We do this as necessary for the performance of a contract, or in our legitimate interest to provide you with access to the Services, or with your consent (where consent is required by applicable laws).
• Open data platforms and research repositories, where we may publish anonymized or deidentified samples of your contributed content for the purposes of AI research, model development, and dataset transparency, or where with your explicit separate opt-in consent we may publish non-anonymized samples of your contributed content as part of publicly available datasets. Any non-anonymized content published publicly will only be shared with your explicit prior consent obtained separately at the task level. You may withdraw consent for future publications at any time by contacting [email protected], though we cannot guarantee removal from datasets already downloaded by third parties prior to withdrawal.
• Professional advisors, such as auditors, law firms, or accounting firms, as necessary and a matter of our legitimate interests to run a successful and compliant business and assess, protect, enforce and defend our rights and to comply with our legal and regulatory obligations.
• Third parties in connection with or anticipation of an asset sale, merger, bankruptcy, or other business transaction, as a matter of our legitimate interests to run a successful and efficient business.
• As needed to comply with applicable law or any obligations thereunder or in our legitimate interests to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of use, to detect and protect against fraudulent or illegal activity, and to ensure the safety and security of our business, employees, and users.

6. THIRD-PARTY WEBSITES AND MATERIALS

We may provide links to third-party websites or platforms, and display, or make available content, data, applications or materials from third parties. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms, or the accuracy, completeness or reliability of third-party materials. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

7. CHILDREN’S PRIVACY

Our Services are not intended for children, and we do not seek or knowingly collect any personal information about children. If we become aware that we have unknowingly collected information about a child, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the below information to request that it be deleted. By children, we mean users under the age of 18 years old, or in the case of a region where the minimum age for processing personal information differs, such different age.

8. DATA SECURITY AND RETENTION

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee security. Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.

We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements (such as those with you and with our business customers), prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products.

9. DATA TRANSFERS

We are based in the United States. If you are using the Services from outside the United States, please be aware that the information we collect from you may be transferred to, stored, accessed from and/or otherwise processed in the United States or other countries outside your country of residence, including countries in which our service providers or other third parties described in Section ‎4 are located, for the purposes described in this Privacy Notice.

By using the Services and acknowledging this Privacy Notice, you consent to the transfer of your personal information to service providers and third parties, which may include the cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, to the jurisdictions specified above.

10. ADDITIONAL RIGHTS FOR RESIDENTS OF CERTAIN JURISDICTIONS

Depending on where you live, you may have additional rights regarding your personal information beyond those described in the Privacy Rights section above. This section provides additional information for residents of certain jurisdictions.

Korea

If you are a resident of the Republic of Korea, the following applies in accordance with Korea's Personal Information Protection Act ("PIPA"). Poseidon AI, Inc. is the data controller for your personal information. We collect and use your personal information for the purposes described in this Privacy Notice. Where we license your submitted content to third parties including for AI training purposes, we will obtain your consent prior to doing so. We retain your personal information for no longer than [X years] following termination of your use of the Services, unless a longer period is required by law. Your personal information may be transferred to and processed in the United States and other countries outside Korea, and by using the Services you consent to such transfer. You have the right to access, correct, delete, and suspend processing of your personal information, and to withdraw consent at any time. You may also lodge a complaint with Korea's Personal Information Protection Commission (PIPC) at www.pipc.go.kr.

California

If you are a California resident, the following applies in accordance with the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"). We collect the categories of personal information described in this Privacy Notice, including identifiers, commercial information, internet activity information, geolocation data, audio and visual content, and professional information. We do not sell your personal information. You have the right to know what personal information we collect and how it is used, to request deletion of your personal information, to correct inaccurate personal information, and to be free from discrimination for exercising these rights. To exercise your California privacy rights please contact us at [email protected].

European Economic Area and United Kingdom

If you are a resident of the European Economic Area or United Kingdom, the following applies in accordance with the General Data Protection Regulation ("GDPR") and applicable UK data protection law. We process your personal information on the following legal bases: performance of a contract with you, our legitimate interests in providing and improving the Services, compliance with legal obligations, and where required, your consent. Where we transfer your personal information outside the EEA or UK we will ensure appropriate safeguards are in place including Standard Contractual Clauses or other mechanisms permitted under applicable law. In addition to the rights described in the Privacy Rights section above, you have the right to lodge a complaint with your local data protection supervisory authority.

India

If you are a resident of India, the following applies in accordance with India's Digital Personal Data Protection Act, 2023 ("DPDPA"). In addition to the rights described in the Privacy Rights section above, you have the right to nominate another individual to exercise your data rights on your behalf in the event of your death or incapacity. To exercise your rights or submit a grievance please contact us at [email protected].

11. PRIVACY RIGHTS

Depending on where you live, you may have certain rights in relation to your personal information, which may include the ones set out below. However, please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law.

• Access / Know: You may have the right to request access to the personal information we hold about you, and to obtain details about how we use and share your information, and with whom we share or have shared it in the past.
• Deletion / Erasure: You may have the right to request that we delete the personal information we hold about you.
• Correction: You may have the right to request that we correct the inaccurate personal information we hold about you.
• Portability: You may have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party in a structured and commonly used format.
• Restriction of Processing: You may have the right to require us to stop, suspend or restrict our processing of personal information we hold about you.
• Objection: You may have the right to object to our processing of your personal information. You may also have the right to object to the processing of your personal information through automated means, including profiling.
• Opt-Out of Marketing: You may opt out of marketing at any time by using the unsubscribe / opt-out instructions provided in our communications to you. If you opt out, we may still send you transactional or administrative messages, such as emails about your account.
• Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent at any time. However, please note that if you withdraw your consent, we may not be able to deliver the expected service.
• Right to complain: You may have the right to file a complaint with the relevant regulator.

Depending on where you live, you may also have additional rights, such as the right to be indemnified for any damages you sustained due to inaccurate or unlawfully obtained data.

To make a request described in this Section, please email us at [email protected].

We will not discriminate against you for exercising any of these rights. Further information may be needed to verify your identity before exercising these rights. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. If we deny your request, you may appeal our decision by contacting us through the methods described in Section 11. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal. You may also have the right to complain to your local data protection authority about how we process your personal information. Of course, we hope you will contact us first so we can resolve any issues.

12. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Notice, please contact us as [email protected].

13. LANGUAGE

Except as otherwise prescribed by applicable law, in the event of any inconsistency between the English language version and local language version of this Privacy Notice, the English language version will prevail.