Privacy Policy
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data.ai Privacy Policy for Mobile Applications (Phone
Guardian)
Last Updated February 15, 2022
Our Privacy Policy Has Recently Changed.
The privacy and security of your information is important to us. We have made changes to our Privacy Policy that
apply with respect to information that you provide on or after the date indicated in the “Last Updated” legend
above. These changes include:
1. Additional detail regarding what personal information and other information we collect from you, and how
we collect and use it;
2. Further descriptions of the parties with whom and for what purposes your information is shared; and3. What rights you have regarding your personal information.
To learn more, please review the full data.ai Privacy Policy for Mobile Applications below.

data.ai cares about the privacy of individuals who use our mobile application, Phone Guardian (“App”) and,
where applicable, its website at https://www.phoneguardianapp.com/ (“Site”) (together our “Services”).
As used herein, “data.ai,” or “us/we/our”, refers to data.ai Inc., a US company, acting by itself and/or throughentities that are legally part of the data.ai family of companies (the “Related Companies”). Those Related
Companies include, but are not limited to, data.ai Europe Limited, Mobidia Technology Inc., and Distimo B.V.
SummaryThis data.ai Privacy Policy for Mobile Applications (“Policy”) explains how the App collects information about you
and about how you use your mobile device, including information about the apps you use and websites you visit.
data.ai processes and safeguards information we obtain from and about you through our Services. The Policy
also explains your rights and choices with respect to your personal information, and how you can contact us if
you have any questions or concerns. No part of the Services is directed to children under the age of 16, nor do
we knowingly collect information from anyone under the age of 16. This Policy does not apply to other websites,
mobile applications and services provided by data.ai. Please visit the privacy policy for the respective website,
mobile application or service.
Your use of the Services is subject to this Policy and the Terms of Service accessible on the App or Site. If any
term of this Policy is unacceptable to you, please do not use the Services and do not provide yourpersonal information.

TABLE OF CONTENTS
1. HOW DATA.AI COLLECTS YOUR INFORMATION
2. HOW WE USE YOUR INFORMATION
3. HOW WE DISCLOSE YOUR INFORMATION
4. TRANSFERS TO OTHER COUNTRIES
5. DATA RETENTION
6. OUR COMMITMENT TO SECURITY
7. CHILDREN’S PRIVACY
8. DO NOT TRACK

9. YOUR RIGHTS AND CHOICES
10. THIRD-PARTY PLATFORMS
11. UPDATES TO THIS PRIVACY POLICY
12. HOW TO CONTACT US

1. How data.ai Collects Your Information
For the purpose of this Policy, “Personal Information” means any information relating to an identified or
identifiable individual. We obtain Personal Information relating to you from various sources described below.
If you do not provide Personal Information when requested, you may not be able to benefit from our Services ifthat information is necessary to provide you with the Services or if we are legally required to collect it. Where
applicable, we indicate whether and why you must provide us with your Personal Information, as well as theconsequences of failing to do so.
i. Personal Information Provided Directly by You

Communications
If you contact us directly, such as to request information, access the Services, or connect with Customer
Support, we may receive additional information about you, such as your name, email address, the content, date
and time of your message, and our reply. We also may receive information if you complete a survey, such as
demographic information (e.g., age, gender) and any other information you choose to provide.
ii. Information We Collect About You When You Use the Services
Depending on which mobile device operating system you use, we may collect the following information:

Device Information
We receive information about your device, which may include publisher identifiers, web browser type, operating
system version, device manufacturer and model, language and regional settings, and carrier or network.

App Usage Information
We receive information about your interactions with the App like the pages or other content you view, the dates
and times of your interactions, or how often you use our Services.

Location Data
We infer your location from information we collect (for example, your IP address indicates the general geographic
region from which you are connecting to the Internet). We aggregate and anonymize your location data at theregional level. We may use this aggregated location data in order to improve the Services and/or to provide
market research information for data.ai services.

Market Research Information
With your consent, we may collect information to create market research information (for example, which apps
and websites you use, how many people use a specific app or website, how much time is spent on an app or
website, and how many times a specific app is used). You can opt out of our collection of this information formarket research at any time through the Menu in the App settings. If you opt out of market research, you cancontinue to use the App and all of its functionality. For more information, please visit Market ResearchInformation in Section 2 below.

Event Information

We collect information about crash reports and other details about any errors you may encounter when using oraccessing the App (i.e., for example, lost connection to the Internet).

Mobile Application Providers
We may receive information about you from a Mobile Application Provider when you download the App from theapplication store (e.g., Apple iTunes, Google Play, etc.), such as your device information in order to provide youwith the correct version of the App.

Cookies
The Site
When you use our Site, we and our third-party service providers may collect information from you throughcookies, web beacons, web server logs, and similar technologies. A cookie is a small piece of text that is sent toa browser. Cookies may either be first or third-party cookies. First-party cookies are those that we place on yourcomputer or device through the Site; third-party cookies are cookies that another party places on your computeror device through our Site. For example, we use cookies to track user trends and patterns, such as the numberof visits to pages of our Site, and the journey of visitors through the Site. This helps us better understand andimprove areas of the Site that our users find valuable.
For more information on the cookies we use and how you can manage them, please access our “Cookie
Preference Center” or from your browser setting. Please note that if you disable functional cookies on yourbrowser, some parts of the Site may not work fully.

Online Advertising
We may partner with third-party advertising partners to manage our advertising on other online services. Ad
networks allow us to target our advertising to users through the use of behavioral and contextual advertising.
These third-party advertising partners collect and use this information subject to their own privacy policies.

The App
We do not use cookies in our App.
If you download our App by clicking one of our ads, we will collect data through advertising IDs, such as arandomly generated identifier (“IDFA”), which is an identifier that does not contain Personal Information. This
technology provides a unique identifier to your device to attribute, or measure, user interactions with ad
campaigns, installs, and in-app activity.
You have choices regarding how we collect and use information. For more information, please see “Your Rights
and Choices” Section 9 below.

2. How We Use Your Information
data.ai will use your information, including your Personal Information for the following purposes:

Providing and Improving the Services
To provide, enhance, improve, and personalize our Services. We also may send push notifications to yourdevice. You have choices with respect to the communications you receive from us. Please see “Your Rights andChoices” Section 9 below.

Analytics

To understand and analyze how you use our Services.

Communications
To communicate with you, including to respond to your inquiries and to send emails to an email address you
provide to us for customer-service or technical-support purposes.

Fraud Detection and Other Technical Issues
To detect, prevent, or otherwise address fraud, security or technical issues.

Legal
To comply with applicable federal, state, and other laws and regulations, and to protect the rights, property, or
safety of us or any other person, enforce our Terms of Service, or protect the content of the Services.

Market Research Information
If you have consented to our collection of information for market research, we will only share it in a way that does
not identify you (e.g., in an aggregated form). No Personal Information received is disclosed or sold to third
parties.

Other Reasons
We may use your Personal Information for any purpose where you have given your consent (where legallyrequired).
We only process your Personal Information based on a valid legal grounds in accordance with applicable law,
including but not limited to the EU General Data Protection Regulation (“GDPR”) when:
You have consented to the use of your Personal Information, for example, to receive marketing
communications or location tracking. You may withdraw any consent you previously provided to us
regarding the processing of your Personal Information, at any time and free of charge. We will apply yourpreferences going forward and this will not affect the lawfulness of the processing before your consent
withdrawal.
We need your Personal Information to provide you with the Services, including to respond to yourinquiries.
We have a legal obligation to use your Personal Information.
We or a third party have a legitimate interest in using your Personal Information. In particular, we have alegitimate interest in using your Personal Information to conduct business analytics, and otherwise
improve the safety, security, and performance of our Services.
We do not engage in general profiling or automated decision-making practices.

3. How We Disclose Your Information
Corporate Affiliates
data.ai may share Personal Information with our Related Companies in the ordinary course of business and forthe purposes of providing the services set forth in this Policy.

Service Providers
We may share your Personal Information with our vendors, service providers, and other third parties that perform
services on our behalf. This includes our data analytics service providers and customer-service support. Weenter into confidentiality and data processing terms with these providers to provide appropriate and suitablesafeguards for their processing of your Personal Information.

As Required by Law and Similar Disclosures
We may disclose Personal Information we have about you: (i) if we are required to do so by law, regulation, or
legal process, such as a court order or subpoena; (ii) in response to requests by government agencies, such as
law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to protect against or
respond to physical, financial or other harm, injury, or loss to property; or (iv) in connection with an investigationof suspected or actual unlawful activity.

Merger, Sale, or Other Asset Transfersdata.ai may disclose your Personal Information to a potential or actual acquirer, successor, or assignee as part ofany reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of
our business, assets or stock (including in bankruptcy or similar proceedings).

Aggregated Information
If you have consented to market research, we will aggregate your information with other information. We will only
share such information in an anonymized and aggregated manner with our Related Companies and for the
purpose of data.ai services or publicly. We do not sell your Personal Information.

Consent
data.ai may further disclose your Personal Information with your consent.

4. Transfers to Other Countries
The Services are provided from the United States and other locations, and we may transfer your Personal
Information to multiple countries throughout the world, including the United States, in accordance with applicable
local laws and regulations. These countries may not have the same high level of protection as the dataprotection laws in the country from which you initially provided the information.
We rely on appropriate and suitable safeguards including EU Standard Contractual Clauses to transfer Personal
Information to countries outside the EEA, United Kingdom or Switzerland where an adequate level of protection
is not already guaranteed. If you are located in the EU, EEA, the United Kingdom or Switzerland, we comply withapplicable data protection laws when transferring your Personal Information outside of these areas. In particular,
we may transfer your Personal Information to countries for which adequacy decisions have been issued; use
contractual protections, such as the European Commission’s Standard Contractual Clauses for the transfer of
Personal Information to our U.S. headquarters, other offices or third parties, or rely on third parties’ certification
to the EU-U.S. or Swiss-U.S. Privacy Shield frameworks, where applicable. You may contact us as specified in
the “How to Contact Us” Section 12 below to obtain a copy of the clauses, relevant data transfer agreements or
safeguards we use to transfer Personal Information outside of these countries/regions.

5. Data Retention
Personal Information will be stored and kept as long as needed to carry out the purposes described in this Policy
or as otherwise required by applicable law. Unless we are required or permitted by law to keep this information
for a longer period of time, when this information is no longer necessary to carry out the purposes for which we
process it, we will delete your Personal Information or keep it in a form that does not permit identifying you.
When determining the retention period, we take into account various criteria, such as the type of Services
requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with
our Services, the impact on the Services we provide if we delete some Personal Information from or about you,

mandatory retention periods provided by law and the statute of limitations, and our use of your information for
aggregated market research.

6. Our Commitment to Security
data.ai cares about the security of your information, and employs physical, technological and administrative
measures to protect the information you submit via the Services against loss, theft, and unauthorized access,use, disclosure or modification. However, we cannot ensure or warrant the security of any information you
transmit to us or guarantee that information on the Services may not be accessed, disclosed, altered or
destroyed. Electronic communications sent to or from the Services may not be secure. You should use caution
whenever submitting information online and take special care in deciding what information you send to us. If you
have reason to believe that your Personal Information is no longer secure, please notify us at the e-mail addressprovided in the “How to Contact Us” Section 12 below.

7. Children’s Privacy
We do not knowingly collect, maintain, or use Personal Information from children under 16 years of age, and nopart of the Services is directed to children under the age of 16. If you learn that your child has provided us with
Personal Information without your consent, then you may alert us at privacy@data.ai. If we learn that we havecollected any Personal Information from children under 16, then we will promptly take steps to delete suchinformation.

8. Do Not Track
Some web browsers incorporate a “Do Not Track” feature. Because there is not yet an accepted standard for
how to respond to Do Not Track signals, our Services do not currently respond to such signals. However, ourSite does not track you. If you want to restrict ads in general on your devices you may opt out from ad tracking
by enabling “Limit Ad Tracking” or “Opt Out of Ads Personalization” (as applicable to your device) in your device
settings.

9. Your Rights and Choices
i. Global Rights & Choices
We provide you with certain choices with respect to your Personal Information, our use of cookies, and marketing
activities, with respect to our Services:
Cookies. You can manage your preferences related to our use of cookies and similar technologies. Pleasesee our Cookie Preference Center for further information. Some of our advertising partners are membersof the Network Advertising Initiative or the Digital Advertising Alliance. If you do not wish to receive our ads
in our third-party advertising partners sites or platforms, please visit their opt-out pages to learn about how
you may opt out of receiving web-based personalized ads from member companies (or if located in theEuropean Union, click https://www.youronlinechoices.eu/. You can access any settings offered by yourmobile operating system to limit ad tracking, or you can install the AppChoices mobile app
https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en_AU to learn more about how
you may opt out of personalized ads in mobile apps. Please note you may continue to receive generic ads.
IDFA. You can reset the advertising identifier randomly assigned to your device at any time and can opt
out of personalized ads by enabling “Limit Ad Tracking” or “Opt Out of Ads Personalization” (as applicableto your device) in your device settings. When you disable “Limit Ad Tracking” or “Opt Out of Device
Personalization” (as applicable to your device), advertisers and their measurement solutions will receive ablank device ID in place of a device-specific ID.
Push notifications. You can opt out of receiving push notifications using your mobile application or device
settings. Opting out of push notifications may impact the functionality of our Services.

In addition, we provide all users with certain rights in connection with our processing of Personal Information
through the App:
Access. data.ai will provide you with access to your Personal Information, which includes the right toobtain confirmation from us as to whether Personal Information concerning you is being processed. Wherethat is the case, data.ai will provide you with access to your Personal Information and information related
to how it is processed.
Erasure. If you have opted into sharing market research information with us and you want to erase any
Personal Information that we receive, please go into the App settings and turn-off “Data Collection formarket research by data.ai”. When you turn this off, we will no longer collect this information for market
research and we will not be able to associate any of that information to you. For erasure requests related
to all of your Personal Information received by data.ai through the App, you can delete the App from yourdevice. If you delete the App from your device, we will no longer receive any of your information including
Personal Information, and we will no longer be able to identify you as a user of the App. If you would liketo request any information about the erasure of Personal Information received through our Supportchannels please submit a request at forgetme@data.ai.
Please note that we have the right to reject access or erasure requests that are unduly burdensome or repetitive,or that cannot be honored in light of legal obligations or ongoing disputes, or where retention is necessary to
enforce our agreements or protect our or another party’s rights, property, safety, or security, or other reasons
under the law.
If you have any questions about exercising your rights, please contact us using the information listed in the “Howto Contact Us” Section 12 below.
ii. For Residents in the EU, EEA, United Kingdom, and Switzerland
In addition to the global rights above, the GDPR, or other applicable laws, provide you with additional rights
regarding your Personal Information, as follows:
Rectify. You have the right to update or correct your Personal Information (e.g., your e-mail address) which
you submit for support cases. However, data.ai does not have an ability to rectify your Personal
Information collected through your use of the App. data.ai cannot rectify your Personal Information, it can
only delete your Personal Information which is collected through the App. As described in the “Erasure”
subsection above, above, once you have deleted the App, any Personal Information that you had provided
through the App is anonymized.
Data Portability. You may have the right to exercise your right to data portability to easily transfer your
Personal Information to another company.
Object. You may also object to the processing of your Personal Information under certain circumstances,including objecting to processing your Personal Information for direct marketing purposes or when it isdone based upon legitimate interest.
Restrict. You may restrict us from continuing to process your Personal Information under certain
circumstances (e.g., where you contest the accuracy of your Personal Information, for a period enabling
us to verify the accuracy of the Personal Information).
Consent Withdrawal. You may withdraw the consent that you might have given with respect to theprocessing of your Personal Information at any time with future effect.
Complaint. If you are not satisfied with data.ai’s response or believe that your Personal Information is not
being processed in accordance with the law, you may also have the right to lodge a complaint with thecompetent supervisory authority in your country of residence, place of work or where the incident took
place, or seek other remedies under applicable law. For more information on how to lodge a complaint in
the EU, please see https://edpb.europa.eu/about-edpb/board/members_en.
iii. For Residents of California
The California Consumer Privacy Act (“CCPA”) provides you with additional rights regarding your Personal
Information.

Collection of Personal Information

In the preceding twelve (12) months, we may have collected from you or from your use of the Services,
categories of Personal Information as defined under the CCPA, which includes the following:
Identifiers, such as your first and last name, e-mail address, unique personal identifier, online identifier,Internet Protocol, advertising identifiers and other similar identifiersProtected Classifications, such as your gender and age
Internet or Other Similar Network Activity, such as your browsing history, search history, and information
on your interaction with our Site
Geolocation data
Inferences Drawn from Personal Information, such as a profile reflecting your preferences, characteristics,
trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

PurposesIn the preceding twelve (12) months, we may have used and disclosed the categories of Personal Informationfrom the sources described in Sections 2 and 3, for business purposes, including:
Auditing consumer interactions, including, auditing compliance with this specification and other standards;
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, andprosecuting those responsible for that activity;
Debugging to identify and repair errors that impair existing intended functionality;
Providing services (including providing customer service, analytics or similar services on behalf of thebusiness or service provider);Undertaking internal research for technological development and demonstration (i.e., to develop new
products or features); andUndertaking activities to maintain the quality or safety of the Services and to improve, upgrade, or
enhance the Services.
We also may have used and disclosed the Personal Information we collect for commercial purposes to provide
you with our Services, as described in Sections 2 and 3 of this Policy above.

Disclosure of Personal Information
In the preceding twelve (12) months, we may have disclosed your Personal Information for a business purpose,including to the following categories of third parties:
Categories of Personal Information

Categories of Third Parties

Identifiers, such as your first and last name, addressand e-mail address

Our Related Companies
Customer service provider

Protected Classifications, such as your gender andage

Our Related Companies
Data analytics providers

Internet or Other Similar Network Activity, such as
your browsing history, search history, andinformation about your interaction with our Site

Our Related Companies
Data analytics providers

Geolocation data

Our Related Companies
Data analytics providers

Inferences Drawn from Personal Information, suchas a profile reflecting your preferencescharacteristics, trends, predispositions, behavior,
attitudes, intelligence, abilities and aptitudes

Our Related Companies
Data analytics providers

California Resident Privacy Rights
If you are a California resident, in addition to the rights described above under “Global Rights & Choices” above,
you have the following rights.
Right to Access Specific Information. You may request access to the specific pieces of Personal
Information we have collected, used, and disclosed about you in the twelve (12) months preceding yourrequest.
Right to Know Personal Information. You may request to know the categories of Personal Information we
have collected about you and the purposes for doing so; the categories of sources of that data; thecategories of third parties with whom we shared it for a business purpose and our purposes for doing so.
Right to Opt Out of Sale of Personal Information. The term “sale” is defined broadly under the California
Consumer Privacy Act. To the extent that “sale” under the CCPA is interpreted to include interest-based
advertising or other data uses described in the “Cookies” section above, we will comply with applicable law
as to those activities. To opt out of receiving interest-based advertising, you can exercise your choice byusing your account privacy settings, or the “Cookie Preference Center” link located at the footer of ourhomepage.
Non-Discrimination. We will not discriminate against you for exercising any of your privacy rights under
CCPA or applicable law, including by denying you Services, providing you a different level of Services, orsuggesting that you will receive a different level of quality of goods or services.

Verification and Authorized AgentTo exercise your rights, please follow the instructions above and the contact information in the “How to Contact
Us” Section 12 below. We will confirm receipt of your requests and respond within 30 calendar days, unlessadditional time is needed, in which case we will provide notice and an explanation of the reason. Also, torespond to your request to right to know and/or delete, we must verify your identity or authority to make therequest and confirm the Personal Information relates to you, or others. To do so, we collect your e-mail address
to verify your identity through the App. We also may contact you by e-mail (if you have provided it to us) to verify
your identity and ask you additional questions so that we can match your identity with the data we have aboutyou. In some instances, we may ask you to declare under penalty of perjury that you are the consumer whose
Personal Information is the subject of the request. If we cannot verify your identity, we may reject your request inwhole or in part.
You also may designate an authorized agent to make a request for you. To use an authorized agent, we may
require: (1) your signed permission designating the authorized agent; (2) evidence that the authorized agency
has power of attorney under the California Probate Code; or (3) proof that the authorized agent is registered with
the California Secretary of State and that you have authorized such authorized agent to be able to act on yourbehalf. We may deny a request from an authorized agent who does not submit sufficient proof.

10. Third-Party Platforms
Our Services may contain links, features, components or other interactive tools supplied by third parties, such as
the Facebook “Like” button. Please be aware that you are providing your Personal Information to these third
parties and not to data.ai. Such third parties may have information practices different than those set forth herein
and their use of cookies and similar technologies is not covered by this Policy. We do not have access to orcontrol over such third parties and encourage you to consult the privacy notices provided by those third parties.
PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY
APP/WEBSITE FOR FURTHER INFORMATION.

11. Updates to this Privacy Policy
We reserve the right to change this Policy at any time. We will post any adjustments to this Policy on this page,
and the revised version will be effective the date it is posted, which is identified at the top of the page. If wematerially change the ways in which we process your Personal Information previously collected from you, we will

notify you through our Services or any other means. We encourage you to review the Policy, which may be
updated from time to time. Your continued use of our Services after such amendments will be deemed youracknowledgement of these changes to this Policy.

12. How to Contact Us
If you have any questions or concerns about data.ai’s privacy practices or about this Policy, or would like toexercise your rights in relation to your Personal Information, you may:Contact data.ai via e-mail at: privacy@data.ai, orWrite us at:data.ai Inc. Legal Department
44 Montgomery Street, 3rd Floor
San Francisco, CA 94104
data.ai’s Data Protection Officer may be contacted via e-mail (dpo@data.ai) or at the following address:
data.ai Inc. Legal Department
ATTN: David Fuller
44 Montgomery Street, 3rd Floor
San Francisco, CA 94104
data.ai Inc. is the entity responsible (data controller) for the processing of your Personal Information.