RedBrick AI Privacy Policy
1. Introduction
Zantula, Inc. and its corporate affiliates RedBrick AI, and Venturebay AI(“Company”, “we”, “us”, “RedBrick AI”) is a software platform for creating andmanaging computer vision training data. Our clients use the RedBrick AI
platform to automate, structure, and qualify their labeling efforts.
This Privacy Policy (“Policy”) describes how the Company collects, uses, anddiscloses information associated with an identified or identifiable individual(“Personal Data”), your rights and choices, as well as how you can contact us withprivacy-related inquiries.
Data privacy is at the core of everything RedBrick AI builds and maintains, and
RedBrick AI has implemented comprehensive measures to ensure that all
Personal Data is managed in a safe and secure manner.
​This Policy applies to all activities conducted on RedBrick AI’s platform (the“Service”), app.redbrickai.com (the “Web Application”), and other RedBrick AI
websites (collectively, the “Websites”) and other interactions (e.g., customer
service inquiries, error reports, etc.) you may have with RedBrick AI.
This Policy does not apply to any third-party applications or software that
integrate with the Service (“Third-Party Services”), or any other third-party
products, services or businesses who will provide their services under their own
terms of service and privacy policy. In addition, a separate agreement governsdelivery, access and use of the Service (the “Terms of Service”), including theprocessing of data such as messages, files or other content submitted throughService accounts (collectively, “Customer Data”).
The organization (i.e., your employer or another entity or person) that enteredinto the Terms of Service (“Customer”) controls its instance of the Service (its“Workspace”) and any associated Customer Data and/or Personal Data(collectively, “Data”).

If you do not agree with this Policy, then do not access or use the Service,
Websites or any other aspect of RedBrick AI’s business.
For the avoidance of doubt, this is the only privacy policy that applies to
RedBrick AI.

1.1 Relevant Terms
For the purposes of this Policy:● “Authorized User” - an individual that has registered an account on
RedBrick AI.
● “Company” (also “we”, “us”) - refers to the corporate entity RedBrick AI.
● “Customer” - an individual or organization that has entered into acontractual agreement with the Company.
● “Customer Data” - all information provided by Customers or collected by
the Company, including Personal Data (e.g. email addresses, IP addresses)
and other information (e.g. anonymized error logs, the name of aBusiness, a dummy image used for resolving a support query).
● “Customer Label Data" - annotations and associated information, such as
which individual labeled the data.
● ”Customer MetaData" - data that is generated as a result of using ourService, which includes information on the usage of our Service.
● “Customer Visual Assets” - raw image/video data owned and/or managed
by RedBrick AI Customers.
● “Data” - Personal Data and Customer Data
● “External Storage Methods” - any Customer data storage method or
third-party storage method outside of RedBrick AI’s infrastructure.
● “Legitimate Interests” - business interests that serve as a justification fordata processing activities.
● “Hybrid Cloud Storage” - a storage configuration in which the Customer
has granted RedBrick AI explicit permission to store and/or route
Customer Visual Assets and Customer Label Data on Company servers.
● “Personal Data” - any information that relates to an identified or
identifiable individual.
● “Policy” - the RedBrick AI Privacy Policy.
● “Service” - the RedBrick AI Web Application and related tools.

● “Subprocessor” - a third-party data processor that also has access tocertain types of Personal and Customer Data.
● “Web

Application”-

theCompany

softwarehostedathttps://app.redbrickai.com.
● “Websites” - all web properties owned and maintained by RedBrick AI
and/or its Affiliates.
● “Workspace” - the instance of the Service on the Web Application that is
managed by the Customer.

2. Collection of Personal Information
We collect a limited amount of Personal Data, receive information directly fromthe Customer, and receive information related to a Customer's usage of ourservices through Third-Party Services.
You have choices about whether you visit and/or utilize our Sites and Service.
However, some parts of the Service may become inaccessible if you do notprovide certain Personal Data. For example, you must provide a valid email
address in order to create an account on RedBrick AI.
You provide us with Personal Data about yourself or others when you:● Register or log in to your account● Edit your user profile● Contact customer support (or CC colleagues in your query)● Comment on our blog
● Participate in surveys● Opt in to receiving product updates● Extend user invitations to an existing RedBrick Organization
The different kinds of information we collect are enumerated below.
● Workspace and Account Information: to register an account on the
RedBrick AI platform, the Customer must provide their full name, email
address, and a password, as well as join an existing Organization.
● Usage Information:

o Services metadata: when a registered user (“Authorized User”)
interacts with the Services, metadata is generated that provides
additional context about the way that an Authorized User utilizes
the Service. For example, RedBrick AI uses a Third-Party Service tolog whether or not a customer has opened a response to a support
email.
o Log data: like the vast majority of websites and technology services
delivered over the Internet, we automatically collect information
when you access or use our Websites or Service and record it in log
files. This log data may include your Internet Protocol (IP) address,
your browser type and settings, the date and time the Service wasused, information about browser configuration and plugins, andyour language preferences.
o Device information: RedBrick AI collects information about devices
accessing the Service, including type of device, what operating
system is used, and browser settings.
o Location information: we receive information from you, ourCustomers and other third parties that helps us approximate yourlocation. We may, for example, use a business address submitted
by your employer (who listed your registered place of business
when establishing a contract with RedBrick AI) or an IP address
received from your browser or device to determine approximate
location to assist with localization, troubleshooting, or for security
purposes.
● Third-Party Service Information: we collect information on ourCustomers from certain Third-Party Services for a variety of purposes. Fora full list of the services RedBrick AI collaborates and exchanges data with,please see Section 4.1. below.
● Cookie Information: RedBrick AI uses essential cookies, non-essential
cookies and similar technologies to collect information from ourCustomers and website visitors. For a detailed overview of how we use
these cookies, as well as how to opt out of them, please see our Cookie
Policy.
● Additional Information provided to RedBrick AI: We also receive
Customer Data when submitted to our Websites or in other ways, such as
responses or opinions you provide during surveys, feedback you provide
about our products or services, information you provide if you apply for ajob with RedBrick AI, request support, interact with our social media
accounts or otherwise communicate with RedBrick AI.

3. Use of Personal Data
In general, and subject to applicable law, including consent (as required), we may
use your Personal Data to provide, fix, and improve our Service, develop new
Services, and market our companies and their products and Service. Examples
of how we use the Personal Data we process include, but are not limited to, thefollowing:● Create your account and manage your relationship with us (e.g.,communicating with you, providing you with requested information).
●

Create and review data about our users and how they use our Service.

●

Test changes in our Service and develop new features and products.

●

Fix problems you may have with our Service, including answering support
questions, customer education and training, and resolving disputes.

●

Manage the Service platform, including support systems and security.

●

Prevent, investigate and respond to fraud, unauthorized access to or useof our Service, breaches of terms and policies, or other wrongful behavior.

●

Comply with legal obligations.

●

Meet legal retention periods.

●

Establish, exercise, or defend our rights in legal claims.

●

Send you records of our relationship, including for purchases or otherevents.

●Collect payment for the Service you request.

3.1 Lawful Basis for Processing Your Personal Information
We collect or process Personal Data only where we have your consent to do so,in instances where the Personal Data is required to execute our contractual
obligations with you, or where the processing is in our legitimate interests andnot overridden by your data protection interests or fundamental rights andfreedoms.
Contractual Obligations

In certain circumstances, we may be required to access or process your Personal
Data in order to comply with the obligations defined in our Terms of Service.
These activities are primarily associated with the provision of technical support
services to the Customer and the maintenance of Customer accounts.
We use Workspace and Account Information, Usage information, Cookie
Information, Third-Party Service Information, and Additional Information
provided to RedBrick AI when fulfilling our contractual obligations.
Compliance With A Legal Obligation
RedBrick AI processes Data when we comply with a legal obligation including, forexample, to access, preserve or disclose certain information if there is a valid
legal request from a regulator, law enforcement or others. For example, aproduction order from law enforcement to provide information in relation to an
investigation, such as your IP address.
We use Workspace and Account Information, Usage information, Cookie
Information, Third-Party Service Information, and Additional Information
provided to RedBrick AI for compliance with a legal obligation.
Legitimate Interests
We rely on our legitimate interests or the legitimate interests of a third party
where they are not outweighed by your interests or fundamental rights andfreedoms ("legitimate interests").
We use Workspace and Account Information, Usage information, Cookie
Information, Third-Party Service Information, and Additional Information
provided to RedBrick AI for the following legitimate interests:● To provide, update, maintain and protect our Service, Websites and business.
This includes the use of Data to support delivery of the Service underTerms of Service, prevent or address service errors, security or technicalissues, analyze and monitor usage, trends and other activities, or at an
Authorized User’s request.
○ It is in our and your interests to provide, update, maintain andprotect our Service, Websites, and business.

● To develop and provide additional features.
RedBrick AI endeavors to make the Service as useful as possible for
Authorized Users. For example, we may:
■ make Services or third-party service suggestions based on
historical use and predictive models;■ identify organizational trends and insights;■ customize a Service experience; or■ create new productivity features and products.
○ It is in our interest and in the interest of Customers and Authorized
Users to continuously improve and develop the Service andcustomer support we provide.
● To investigate and help prevent security issues and abuse.
We may use a variety of tools such as device fingerprinting to prevent
issues and abuse. We may process, including in an automated fashion,
Data to better understand how RedBrick AI is used or to prevent spam orabuse.
○ It is in our interest to keep the Service secure and to detect,prevent, and address abuse, as well as investigate and take action
in respect of suspicious activity on the Service.
● To aggregate or de-identify information.
In some cases, we aggregate or de-identify information we haveassociated with you and use the resulting information, for example, toimprove the Service.
○ It is in our interest to research and improve the Service;○ It is in the interests of Customers and Authorized Users to practicedata minimization and privacy by design in respect of theirinformation.
● Share information with others including law enforcement and to respond tolegal requests.
○ It is in our interest and the interest of the general public to prevent
and address fraud, unauthorized use of RedBrick AI, violations ofour terms or other harmful or illegal activity; to protect ourselves,
our users or others, including as part of investigations or regulatory

enquiries; or to prevent death or imminent bodily harm.
● Transfer, store or process your information outside the European Economic
Area.
As the Websites and Service operate globally, with Customers around theworld, we need to share information we collect globally. We carry out
necessary transfers outside the European Economic Area, including to
India and the United States, to provide, update, maintain and protect our
Services, Websites and business.
For more information, review Section 8.3. below.
○ It is in our and your interests to provide, update, maintain andprotect our Service, Websites and business.
We use Workspace and Account Information, Usage information, Cookie
Information, Third-Party Service Information, and Additional Information
provided to RedBrick AI for the following legitimate interests:● To communicate with you by responding to your requests, comments andquestions.
If you contact us, we may use your Data to respond.
○ It is in our, our Customers’ and Authorized Users’ interests tofacilitate communication (for example, to answer questions from
Customers).
● To send service emails and other communications.
For example, we may:
○ send you service, technical and other administrative emails,
messages, and other types of communications; or○ contact you to inform you about changes in our Service, ourServices offerings, and important Service-related notices, such as
security and fraud notices. These communications are consideredpart of the Service and you may not opt out of them. It is in ourCustomers

andAuthorized

Users’

interests

toaddress

service-related issues.
We use Workspace, Account Information and Usage Information for thefollowing legitimate interests:

● For billing, account management and other administrative matters.
RedBrick AI may need to contact you for invoicing, account management,
and similar reasons and we use account data to administer accounts andkeep track of billing and payments.
○ It is in our interest to facilitate the effective provision andadministration of the Websites and Service.
We use Workspace and account information, Usage Information, Cookie
information, Third-Party Services Information, Third-Party data, and Additional
information provided to Slack for the following legitimate interests:● To send marketing emails and other communications.
We sometimes send emails about new product features, promotional
communications or other news about RedBrick AI. Inasmuch as these aremarketing messages, you can control whether you receive them. If you
have additional questions about a message you have received from
RedBrick AI, please get in touch through the contact mechanisms
described below.
○ It is in our interest to promote the Websites and Service and send
our direct marketing.

4. Sharing and Disclosure of Personal Information
We limit access to your Personal Data to our employees and consultants who
have both a legitimate legal basis to process it and a clear, relevant need to doso.
If we share your Data with other parties (such as developers, service providers,domain registrars, and reselling partners), we will ensure that they have
implemented appropriate security measures and have a valid reason forprocessing your Data.
Subject to applicable law, including consent (as required), we may share
Personal Data as follows:● Service Providers. We share your Personal Data with service providers
we use to support our Service. These companies provide services like

intelligent analytics, advertising, authentication systems, bill collection,
fraud detection, and customer support. We have contracts with ourservice providers that address the safeguarding and proper use of your
Personal Data. For a full list of our Third-Party Services, please see Section
4.1. below.
● Affiliates. We may share your Personal Data with other companies undercommon ownership or control with RedBrick AI. These companies use
your Personal Data as described in this Policy.
●

Public or Government Authorities. We may share your Personal Data tocomply with our legal obligations, regulations, or contracts, or to respondto a court order, administrative, or judicial process, such as a subpoena,
government audit, or search warrant where we are legally compelled to
do so. We also may share your information when there are threats to thephysical safety of any person, violations of RedBrick AI policies or otheragreements, or to protect the legal rights of third parties, including our
employees, users, or the public.

●

Corporate Transactions. Your Personal Data may be disclosed ortransferred to relevant third parties in the event of, or as part of the due
diligence for, any proposed or actual

reorganization, sale, merger,

consolidation, joint venture, assignment, transfer, or other disposition of
all or part of our business, assets, or stock (including in connection withany bankruptcy or similar proceeding). If a corporate transaction occurs,
we will provide notification of any changes to the control of yourinformation, as well as choices you may have.
●

Consent. We may share your Personal Data in other ways if you haveasked us to do so or have given consent. For example, with your consent,
we could post a user testimonial that would identify you.

Your Personal Data may also be shared as described below:● Other RedBrick AI Authorized Users. When you allow others to access,use, or edit content in your Workspace, we share that content with them.
For example, if you add an Authorized User to an annotation project, we
make the contents of that project available to them.
● Third Parties. When you create an account on RedBrick AI using an email
address that you own, the authentication information associated withyour account is stored in a database.

● Public Information.
● User-Generated Content. When you comment on our blogs orwithin a Workspace, this information may also be read, collected,
and used by others.
● Your Employer or Organization. When you create an account or userrole with an email address assigned to you as an employee, contractor or
member of an organization (e.g., yourname@youremployer.com), thatorganization (if it is a RedBrick AI Customer) can find your account andtake certain actions that may affect your account.

4.1 Third-Party Services
We share certain Data with a select number of data processors (each, a“Subprocessor”) for the specific purposes outlined below.
Each Subprocessor that we share Data with is responsible for maintaining its
privacy notice and practices related to the use and protection of Personal Data.
RedBrick AI requires Subprocessors acting on our behalf or with whom we share
Personal Data to also ensure appropriate security measures under relevant
industry standards.
RedBrick AI will always ensure that any Subprocessors with whom we share Data
are subject to privacy and security obligations consistent with this Policy andapplicable laws.
Service Provider

Processing Operation

Amazon Web Services

Identity Management, IaaS

Checkr

Employee Background Checks

Deel

Workforce Management

DocuSign

Electronic Signature and Contract
Solution

GitHubCode Version Control andCollaboration

GoogleWeb Analytics, Email Communication

Hubspot

Marketing, Sales, and Customer
Outreach

LaunchNotes

Business Communication

LinearProject Management and Ticket
Tracking

PostHog

Product Analytics

SentryError Monitoring and Logging

Slack

Team Communication and
Collaboration,
Direct Support for Customers using
Enterprise-level service

StripePayment Processing

Vanta

Security and Compliance

Zendesk

Customer Support

5. Your Choices and Rights
In accordance with global and local data protection and privacy laws, you havecertain rights related to the collection and processing of your personal
information.
To exercise any of the following rights, please contact us directly at
contact@redbrickai.com.
● You can access and review Personal Data associated with your account.
● You also can request the following information: how we collect and use
your Personal Data and why; the categories of Personal Data involved; thecategories of recipients of your Personal Data; how we received your
Personal Data and its source; our business purpose for using your
Personal Data; and how long we use or store your Personal Data or themanner in which we determine relevant retention periods.
○ EU Citizens and other persons residing in the EU and/or EEA may
also contact our EU Representative (see Section 8.5.) directly tosubmit a Subject Access Request.

● You can correct information about you that you feel is inaccurate or
incomplete.
● In certain circumstances, you have the right to request to have your
Personal Data erased without undue delay, object to or restrict theprocessing of your Personal Data, or export your Personal Data to
another controller.
● Where we rely on your consent to process your personal information, youhave the right to decline consent and/or, if provided, to withdraw
consent at any time. This will not affect the lawfulness of processing prior
to the withdrawal of your consent.
● You can request that your Personal Data no longer be used for direct
marketing purposes.
For all other inquiries regarding the collection, use, storage, or processing ofyour Personal Data, please reach out to us at contact@redbrickai.com.

6. Data Privacy Strategy
As stated above, best practices for data collection, maintenance, and security areat the core of RedBrick AI’s vision and mission. The subsections below provide acomprehensive overview of how various data are moved, stored, and processedby RedBrick AI’s systems.

6.1. How We Handle Customer Data
Our preferred strategy to ensure the privacy of raw image/volume data(“Customer Visual Assets”) and segmentation data (“Customer Label Data”) is tocompletely decouple customer data storage from the RedBrick AI platform.
RedBrick AI can be integrated with a variety of storage methods that exist
outside of our infrastructure (“External Storage Methods”), which allows
Customers to have complete control over the level of privacy and security
protocols that are appropriate for their application, as well as leveragecommonly utilized third-party solutions.
RedBrick AI does not store or route data through Company servers unless we
receive explicit consent from a Customer to do so or a Customer utilizes ourDirect Upload feature. In these cases, all data will be stored in a U.S.-based AWS
S3 bucket (“Hybrid Cloud Storage”). For more information, please see Section 3.3
of our Terms of Service.
If you or your organization has specific privacy and security needs, the RedBrickAI team is always happy to cooperate with Customers to ensure the proper
implementation of custom requirements.
Technical Overview
To make the Customer Visual Assets accessible on RedBrick AI, Customers are
required to upload a list of file paths or URLs to the Web Application. Thesepaths or URLs act as a reference to the individual data points in the storage
method, allowing the Customer’s browser to request the Customer Visual Assets
and/or Customer Label Data as needed.
Whether Customer Visual Assets and/or Customer Label Data are stored in partor fully on the cloud, the data transfer only occurs between a Customer’sbrowser and the data storage method.
To accommodate a variety of Customer requirements, Customer Visual Assets
and Customer Label Data can be stored using any of the following storage
methods:● Third-party cloud storage (Amazon S3, Azure, Google Cloud Storage)● Hybrid cloud storage (Amazon S3)● On-premises storage
The specifics of the data flows for each of the three data storage methods iscovered in the sections below.

6.2. Third-Party Cloud Storage and Flow
RedBrick AI currently supports data storage on Amazon S3, Azure Blob and
Google Cloud Storage.

In order to integrate an external cloud storage solution to the RedBrick AI
platform, certain information and permissions associated with the storage
method will have to be provided. Our documentation provides a comprehensive
overview of how to configure the integration for each of the above three cloudservice providers.
When an Authorized User logs into the RedBrick AI platform and visits a page
where the Customer Visual Assets and/or Customer Label Data needs to be
displayed, the Customer's browser retrieves a pre-signed URL from the RedBrickAI backend. This pre-signed URL, which is only valid for several minutes, allows
the Authorized User’s browser to request the data directly from the Customer’sstorage method.
This flow ensures data never gets routed via RedBrick AI servers (with the
exception of Hybrid Cloud Storage implementations), and authentication isproperly handled using pre-signed URLs.

6.3. Hybrid Cloud Storage and Flow
When a Customer has requested to use Hybrid Cloud Storage or utilized the
Direct Upload feature to transfer data from their local machine to Company
servers, all data will be stored in a U.S.-based AWS S3 Bucket managed by
RedBrick AI.
The procedure for requesting and displaying Customer Visual Assets andCustomer Label Data in the browser is identical to the process outlined in
Section 6.2. above.

6.4. On-premises Storage and Flow
RedBrick AI can be used with Customer Visual Assets and/or Customer Label
Data stored on-premises and accessible only over a private network.
On-premises storage gives a Customer complete control over their data privacy
flows, including who can access the data and how it can be accessed.

Once an Authorized User visits a page where data needs to be displayed, thebrowser requests the data directly from the on-premises servers (using the
URLs/_le paths uploaded during data import). This flow ensures that data is only
moving from the on-premises storage to the browser.
On-premises storage methods can be configured to be as private as a Customer
desires. Requests to the on-premises server can be restricted to specific IP
addresses or specific file paths on the server.
Furthermore, the RedBrick AI team is happy to work with our Customers tocomplywithspecific

security

concerns

and

make

modifications(e.g.

configurations to use pre-signed URLs) to abide by company-specific protocols.

6.5. How We Handle Label Data and Metadata
Customer Label Data and Customer Metadata generated during the use of ourservices is securely transmitted over SSL, stored by RedBrick AI on Amazon
DynamoDB, and encrypted with industry-standard AES-256 encryption.

7. Internal Data and Network Security Department
RedBrick AI strives to develop, implement, and maintain the highest level of data
security and protection practices. Pursuant to this, our Company has a dedicatedinternal department dedicated to data and network security. Some of thefunctions of this department are highlighted below:● To ensure that RedBrick AI complies with this Policy.
● To conduct a quarterly review of the Company’s data security posture andprotocols.
● To review and update Company’s data security and protection practices,
as applicable on at least a quarterly basis, with the goal of remaining
up-to-date with various technological developments in regards to data
security and privacy.
● To ensure compliance with relevant data protection laws and regulations● To ensure the highest possible standard of data safety.

7.1. Standard Operating Procedures
The RedBrick AI may formulate separate Standard Operating Procedures (SOP’s)for the Internal Data and Network Security Department. These procedures will
not be covered under this Policy. However, these SOPs would follow the global
industry standards and practices with regards to data protection.

7.2. Data Retention
We retain all Data for as long as is required for the purposes stated in Section
3.1. of this Policy.
When we no longer have a need to process your information based on the legal
bases outlined above, we will delete, anonymize, or isolate your information as
appropriate.

8. RedBrick AI and GDPR
RedBrick AI is committed to maintaining continued compliance with thepractices and standards outlined in the General Data Protection Regulation, as
well as helping its Customer understand and, where applicable, comply with thislaw.

8.1. Identifying the Controller and Processor
If European data protection law applies and where RedBrick AI acts as a data
controller, our lawful basis for collecting and using the Personal Data describedin this Policy will depend on the type of Personal Data concerned, as well as thecontext in which we collect or use it.
Note that in situations where RedBrick AI acts as a processor, it is our Customer
who determines the appropriate legal basis associated with processing activities,
and queries about the applicable lawful basis should be directed to them.

8.2. GDPR Compliance
RedBrick AI has implemented a wide range of policies, practices, and proceduresin order to be fully compliant with GDPR. Some examples include:● a dedicated GDPR Compliance Policy, which outlines internal proceduresfor improved data protection practices, an incident response plan,
procedures for Data Subject Access Requests, among other things.
● the designation of a Data Protection Officer (see Section 8.4.).
● the designation of a Local EU Representative (see Section 8.5.).
● the designation of a Lead Supervisory Authority (see Section 8.6.).
● the establishment of GDPR-specific employee training, to be completed
annually.
● investments into our security infrastructure● a completed Data Protection Impact Assessment.
●

Supportforinternational

datatransfers

byexecutingStandard

Contractual Clauses through our updated Data Processing Addendum,
which is available to all Customers.
We also monitor the guidance around GDPR compliance from privacy-related
regulatory

bodies,andupdateour

product

featuresandcontractual

commitments accordingly.

8.3. International Data Transfers
We may transfer your Personal Data to countries other than the one in which
you live, including transfers to the United States. To the extent that Personal
Data is transferred abroad, RedBrick AI will ensure compliance with therequirements of the applicable laws in the respective jurisdiction in line with ourobligations.
In particular, we offer the following safeguards if RedBrick AI transfers Personal
Data from jurisdictions with differing data protection laws:● European Commission’s Standard Contractual Clauses. RedBrick AI
uses Standard Contractual Clauses approved by the European

Commission for transfers to, among others, India and the United States.
RedBrick AI will transfer your Personal Data to facilitate the provision of
the Services. A copy of our standard data processing addendum,
incorporating the Standard Contractual Clauses, is available on our
Website, and a copy of the executed version of the Standard Contractual
Clauses may be obtained by contacting us as described in Section 8.4.
below.

8.4. Data Protection Officer
For data or compliance-related inquiries, you can contact RedBrick AI’s Data
Protection Officer at contact@redbrickai.com.

8.5. Local EU Representative
Adam Brogden
EU - Ireland Representative
INSTANT EU GDPR REPRESENTATIVE LIMITED
contact@gdprlocal.com+ 353 15 549 700
Office 2 12A Lower Main Street, Lucan Co.
Dublin K78 X5P8
Ireland
Subject Access Requests can be submitted directly to the EU Representativehere.

8.6. Lead Supervisory Authority
RedBrick AI’s Lead Supervisory Authority is:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2

D02 RD28
Ireland
The Data Protection Commission recommends the use of its online contact form
when submitting an inquiry.

8.7. F.A.S.T.
The Fast Automated Segmentation Tool (F.A.S.T.) is an interactive segmentation tool thatis specifically designed for radiology images and can be enabled for RedBrick AI
Organizations both globally (i.e. Organization-wide) or at the Project level.
F.A.S.T. is powered by the Segment Anything Model (SAM), which is developed by MetaAI.
We firmly believe that it is imperative to have a clear understanding of the SAM's
encoder-decoder architecture to explicate the privacy and security features of RedBrick
AI's F.A.S.T.
RedBrick AI's F.A.S.T. performs image encoding (i.e. the process of converting
pixel/voxel data into a vector format suitable for machine learning) on the
RedBrick AI servers, which are located in the United States.
In plain terms, when using F.A.S.T., your image pixel/voxel data is transferred as a PNG
image of a single slice, as captured with default Windowing settings. The derived PNG
image is only used for computing embeddings and does not get stored after
computation is complete.
Please note that no spatial information, UIDs, or other DICOM headers are stored ortransmitted as part of this process.
Once the embeddings are calculated on the server side, F.A.S.T. is run in the browser
through user prompts and the mask is decoded in the browser. This provides you withthe ability to create segmentation masks interactively in real time.
By requesting access to and utilizing F.A.S.T., you agree to the following:-

to permit the transfer of your image data to RedBrick AI’s U.S.-based servers forembedding computation;-

to not use the F.A.S.T. feature on any data that has PHI burned into the image(such as ultrasounds), as our organizations do not have a HIPAA BAA in place;9. Children’s Privacy
RedBrick AI does not permit individuals under the age of 16 to use our Service or
Websites, to the extent prohibited by applicable law.
If you suspect that we have unlawfully received or collected Personal Data
regarding any individuals under the age of 16, please reach out tocontact@redbrickai.com and we will take steps to delete the information.

10. Clauses Specific to California Residents
To the extent, you are a consumer as defined under the California Consumer
Privacy Act of 2018 (“CCPA”) and RedBrick AI is a business as defined under
CCPA, the following applies to you:
Subject to the provisions of the CCPA, you have the right to request in themanner provided herein, for the following:
1. Right to request for information about the:● Categories of Personal Information● Specific pieces of Personal Information.
● Categories of sources from which the Personal Information iscollected.
● Businessorcommercial

purposeforcollecting

Personal

Information.
● Categories of third parties with whom the business shares Personal
Information.
2. Right to request for deletion of any Personal Information
If you seek to exercise the foregoing rights to access or delete Personal
Information which constitutes ‘personal information’ as defined in CCPA, pleasecontact us at contact@redbrickai.com.

By writing to us, you agree to receive communication from us seeking
information from you in order to verify you to be the consumer from whom wehave collected the Personal Information from and such other information asreasonably required to enable us to honor your request.

11. Changes To Privacy Policy
We may update this Policy at any time to reflect evolving standards of dataprotection and security protocols. Any and all such changes will be considered to
be in effect immediately after being posted on RedBrick AI’s web site. We reserve
the right to update or change our Privacy Policy at any time and you should
check this Privacy Policy periodically.
Your continued use of the Service and Websites after we post any modifications
to the Privacy Policy on this page will constitute your acknowledgment of themodifications and your consent to abide and be bound by the modified Privacy
Policy.
If we make any material changes to this Privacy Policy, we will notify you either
through the email address you have provided us, or by placing a prominent
notice on our website.

12. Contact Us
If you have any questions or complaints regarding this Policy, please reach out
to us at contact@redbrickai.com.