At Aspectium LLC ("Aspectium", "our", "us" or "we"), we value your privacy and are committed to being fair, accountable, and transparent in how we handle your personal information. Our Privacy Policy outlines how we collect and use your personal information when you use our websites, products, applications, and other services (our "Services"). It also describes your privacy rights.

We recommend that you read this Privacy Policy in full so you understand how we process your personal information. However, to make it easier for you to access a particular section of this Privacy Policy, you can click the relevant link below to jump to that section:

Aspectium is a U.S.-based company.

We use your personal information for a variety of purposes, including:

• To process payments and manage purchases, subscriptions, or account-linked entitlements: We may process payment and transaction-related information in relation to paid plans, subscriptions, refunds, taxes, and account-linked entitlements, as applicable.
• To provide and maintain our Services: We use your personal information to provide and maintain our Services, including authentication, account management, shared sign-in, website-managed features, and support flows.
• To administer required acceptance of our terms and related service access: We may use acceptance records and related browser, device, installation, or account-linked identifiers to record assent to our terms, enable access where acceptance is required before use, associate an installation with an account after sign-in, and support security, fraud prevention, troubleshooting, and enforcement of our agreements.
• To provide support and assistance in relation to our Services, including to communicate with you and respond to your enquiries: We use your personal information to troubleshoot and diagnose problems, provide customer care and support services.
• To operate AI features you request: We may process submitted content and related account, entitlement, authorization, and usage information to provide AI-enabled features, return the resulting output, and support related security, troubleshooting, and quota enforcement.
• To develop and improve our Services: We may use account information, support records, optional telemetry, feedback, and User Content submitted to Aspectium-managed features to troubleshoot issues, improve existing features, and develop new features or services.
• To ensure the security and integrity of our Services: We process your information to protect the security of the Services and our systems, and to detect and prevent fraud, unauthorized use, unlawful activity, and other misuses of our Services by reviewing your activity and User Content, investigating suspicious activity, and enforcing our terms and policies.
• To comply with our legal obligations: We process your personal information where necessary to comply with applicable laws, regulations, court orders, legal processes, or lawful requests from public authorities.
• To protect our rights, safety, and the integrity of our Services: We may process your personal information where necessary to protect our rights or property, protect the safety of our users or others, prevent or address misuse or abuse of the Services, pursue available remedies, limit our damages, and enforce our agreements, policies, and terms.
• For our internal business operations: We may use your personal information for recordkeeping, debugging, service planning, internal reporting, and operating and expanding our business activities.

If we need to use your personal information for a new purpose that is materially different from the purposes described in this Privacy Policy, we will update this Privacy Policy or otherwise provide notice as required by applicable law.

We do not share your personal information with third parties, other than as follows:

• With our contracted vendors, service providers, and consultants: To assist in providing the Services to you or performing business operations, we may provide personal information to service providers that help us operate, secure, support, or host the Services, to payment and transaction providers, and to AI or LLM providers when you use AI-enabled features.
• In connection with business transfers: In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company. If required by applicable laws, we will use reasonable efforts to notify you of any transfer of personal information to an unaffiliated third party.
• To comply with our legal obligations: To comply with applicable laws, regulations, lawful requests, legal process, court orders, or requests from public authorities.
• To protect rights, safety, and the integrity of our Services: To protect the rights or property of Aspectium and others, enforce our agreements, policies, and terms, investigate or respond to misuse or abuse of the Services, or in an emergency, protect the personal safety of Aspectium, its customers, or any person.
• With our related companies and internal systems: We may disclose personal information to our related companies or internal systems to the extent such sharing is necessary for customer management, customer support, technical operations, account management, subscription entitlements, or the purposes described above.

We may also create, use, and disclose anonymized, aggregated, and de-identified data where permitted by law, including for analysis, reporting, security, and product improvement, so long as that information does not identify you.

Except as described in this Privacy Policy, we do not sell or rent your personal information and do not share it with third parties for their own direct marketing purposes.

We may use your personal information to send first-party service-related, account, support, subscription, legal, and product-update communications, and to send or display first-party upgrade or promotional content for Aspectium products and services. Where required by applicable law, we will send promotional communications only with the required consent, and you can opt out of promotional emails at any time by using the unsubscribe method included in the message or by contacting us. We may still send you non-promotional communications relating to your account, transactions, support, subscriptions, legal notices, or ongoing use of the Services. We do not share your personal information with third parties for their direct marketing purposes.

Aspectium takes reasonable precautions to safeguard your personal information, including through use of appropriate organizational and technical measures to help safeguard your personal information against accidental or unlawful destruction, loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

However, no security measure or modality of data transmission over the internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security. As such, you acknowledge and accept that we cannot guarantee the security of your personal information and that any such transmission of your personal information to us is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites and online accounts after your sessions.

We retain your personal information where we have an ongoing legitimate business need to do so (e.g., to provide you with Services you have requested or to comply with applicable legal requirements). In certain circumstances, we will need to keep your information for legal reasons after our contractual relationship has ended. The specific retention periods depend on the nature of the information, why it is collected and processed, and any applicable legal requirements.

Opportunity Workspace Cloud accounts and data: You may cancel an account-deletion request within seven days after making it. When the deletion is completed, we remove the account and associated Cloud data from active systems. Residual copies may remain in routine backups for up to 30 additional days before they are deleted through the backup-retention cycle. We may delete an inactive Cloud account and its associated Cloud data after 36 consecutive months of inactivity. These timeframes do not apply to data we need to retain for legal obligations, security incidents, fraud prevention, or the establishment, exercise, or defense of legal claims.

Desktop data: Core Desktop data and local backup files remain on your device and are not retained by Aspectium unless you separately provide them to us, such as through a support request or an individual AI-processing request.

AI processing: We may retain AI inputs, outputs, and related processing metadata for up to 30 days to troubleshoot and maintain the security and reliability of AI processing.

For example, we may retain your personal information:

• when we have a legal obligation to do so (e.g., if we receive a court order, we would retain your information for longer than our usual retention periods);
• to deal with and resolve requests and complaints (e.g., if there is an ongoing complaint about you);
• to protect the safety, security, and integrity of our business and the Services, as well as to protect our rights and property and those of others (e.g., if we detect misuse of our Services or otherwise detect unusual activity on your account or in your interactions with us); and
• for litigation or regulatory matters (e.g., we would retain your information if there was an ongoing legal claim and the information was relevant to the claim).

This section describes current Opportunity Workspace data practices. The applicable offer, a more specific statement in this Privacy Policy, and Section 10, Important application-level terms in the Terms of Service control if they conflict with this section.

Cloud data. Cloud workspace data is stored on Aspectium Cloud, including routine backup copies. Browser storage may contain session, preference, and cached information. Earlier or deleted record content may remain in audit history and backups, subject to Section 7, Retention of your personal information.

Desktop data. Desktop data and backup files remain on your device unless you separately provide content to Aspectium. Local record history and unencrypted backup files may retain earlier or deleted content.

Temporary session data. Sandbox data is held in memory and is not saved to your Cloud or Desktop workspace or included in backups. It is cleared when the application is reloaded or closed, or when you sign out or switch accounts.

AI processing. Content submitted for AI processing may be sent to Aspectium services and a third-party LLM service provider. This does not transmit the full local Desktop data set. Section 7, Retention of your personal information describes AI-processing retention.

Our Services may contain or let you open links to third-party websites or services that are not operated by us, including user-entered external websites or other third-party resources. These links are provided for your reference and convenience only. This Privacy Policy only applies to the personal information that we collect or receive, and we are not responsible for personal information collected directly by third parties.

Third-party websites have their own terms and conditions and privacy policies, and you should read them carefully before submitting any personal information to those websites. We do not endorse, and are not responsible or liable for, the content of such third-party websites or their terms, conditions, or policies.

Our Services are not directed at children under the age of 13, and we do not knowingly collect any personal information from them. You must be at least 16 years old to use the Services on your own behalf, as described in Section 2(g), Age requirements in the Terms of Service.

If you are under the age of 16, please do not attempt to register for or otherwise use our Services on your own behalf. If we learn that we have inadvertently obtained personal information about a child under the age of 13 via our Services, or from any other source, then we will delete that information as soon as possible.

Please contact us if you are aware that we may have inadvertently collected personal information from a child under the age of 13.

Depending on where you are located and subject to applicable legal exceptions, you may have certain rights in relation to your personal information. For more information on rights that may apply under applicable U.S. privacy laws, please see Section 13, Additional information for U.S. residents.

Aspectium does not currently offer paid Services to consumers located in the European Economic Area ("EEA"), the United Kingdom, or Switzerland. If personal information from individuals located in those regions is nevertheless processed in connection with access to free Services, our website, required records of assent, security or fraud-prevention activity, or essential cookies and similar browser-side technologies, the following additional information applies to that limited processing.

Controller. Aspectium LLC is the controller of personal information covered by this Privacy Policy, unless otherwise specified.

Limited legal bases. For the limited processing described in this section, we generally rely on:

• Legitimate interests: Where necessary to operate, secure, and protect our website and related systems, maintain required records of assent, prevent fraud or abuse, troubleshoot issues, enforce our terms, and protect our rights and the rights of others.
• Legal obligation: Where necessary to comply with applicable law, legal process, lawful requests, or related recordkeeping obligations.

International transfers. Aspectium is based in the United States, and personal information covered by this Privacy Policy may be processed in the United States or other jurisdictions outside your country of residence. Where applicable, we will handle such cross-border processing in accordance with applicable data protection laws.

If you would like more information about cross-border processing of your personal information, please contact us.

Your rights. Subject to applicable legal exceptions, you may have rights in relation to your personal information, including rights to request access, correction, deletion, restriction, objection to certain processing, and, where applicable, data portability. Where processing is based on consent, you may withdraw that consent at any time for future processing. You may also have the right to lodge a complaint with the relevant supervisory authority or data protection regulator in the place where you live or work, or where you believe a violation has occurred.

If you wish to exercise any of these rights or have questions about this limited processing, please contact us. We may need to verify your identity before responding to your request.

Collection of your personal information. You can find a list of the categories of personal information that we collect in Section 2, Collection of your personal information. The chart below provides additional details regarding the categories of personal information that we collect and have collected over the past 12 months. For details about our collection, use, and disclosure of your personal information, see Section 2, Collection of your personal information, Section 3, How we use your personal information (our purposes), and Section 4, Sharing of your personal information.

Certain categories of personal information described above, such as precise geolocation if you voluntarily provide it or other information that may be treated as sensitive personal information under certain state privacy laws, may be subject to additional protections. Where applicable, we collect and process such information only for purposes permitted by law or with your consent. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you, and we have not "sold" or "shared" (as those terms are defined under U.S. privacy laws) personal information. We also do not knowingly sell or share the personal information of individuals under the age of 18.

For more information on how your information is disclosed, please see Section 4, Sharing of your personal information. As stated in Section 5, Marketing, we do not share your personal information with third parties for their direct marketing purposes.

As stated in Section 7, Retention of your personal information, we typically retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

For details regarding the sources from which we obtain personal information, please see Section 2, Collection of your personal information. We collect and use personal information for the business or commercial purposes described in Section 3, How we use your personal information (our purposes).

Your rights. Depending on the U.S. privacy law that applies to you and subject to certain exceptions, you may have the following rights:

• The right to submit certain privacy requests through an Authorized Agent.
• The right to request deletion of your personal information.
• The right to be free from discrimination for exercising the rights afforded to you under applicable privacy laws.
• The right to appeal a decision we make about your rights request.

Exercising your rights: To exercise your rights under applicable U.S. privacy laws, please submit a request by contacting us. Once you have submitted your request, we will respond within the time frame permitted by applicable privacy laws.

Verification: In order to protect your personal information, your ability to exercise some of the rights detailed in this Privacy Policy may be subject to your ability to verify that you are the person about whom your request pertains. We may require you to provide information sufficient to verify your identity and request. If we suspect fraudulent or malicious activity, we may ask you to supply additional information to allow us to verify your identity.

Authorized Agents: To exercise your rights using an Authorized Agent (as defined under applicable law), you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. We reserve the right to deny a request from an Authorized Agent that does not submit proof that they have been authorized by you to act on your behalf.

Appeals: If we refuse to take action on a request within a reasonable period of time after receiving your request, you may appeal our decision by contacting us. In such an appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to the rights and obligations afforded to you under applicable law. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.

Browser privacy signals: Some browsers and browser extensions may offer privacy preferences or signals, such as "Do Not Track" settings or similar browser-based privacy signals. Unless required by applicable law, we do not respond to such signals by changing our data collection, use, or disclosure practices.

We may update our Privacy Policy from time to time. If we make any changes, we will post an amended version and change the "Last Modified" date above. Where appropriate, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.

If you continue to use the Services after an updated Privacy Policy becomes effective, the updated Privacy Policy will apply to your continued use of the Services.

If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact us by mail or using the following contact details:

For privacy inquiries worldwide: