WEBSITE & SERVICE PRIVACY POLICY

Last Revision: May 2026

For client-specific legal documentation, such as contracts and agreements, please contact legal@intelocate.com.

1.  Overview

This Privacy Policy covers how Spinmetry Inc. d/b/a Intelocate ("Company", "we", "us") collects, uses, and protects personal information provided by users via the Intelocate website, tools, products, and services ("Service"). This policy applies to all users globally, including those in Canada, the United States, the United Kingdom, the European Economic Area, and Ireland.

2.  Regulatory Compliance

We comply with applicable privacy and data protection laws across all jurisdictions in which we operate:

• Canada (PIPEDA): We comply with the Personal Information Protection and Electronic Documents Act and applicable provincial privacy laws.

• UK & European Economic Area (GDPR / UK GDPR): For users in the EEA and UK, we process personal information under the following legal bases: (a) Performance of a Contract — processing necessary to provide the Service; (b) Legitimate Interests — improving platform security, user experience, and AI-powered insights; and (c) Compliance with Law — meeting our legal and regulatory obligations.

• United States — FERPA: For educational institution customers, Company acts as a "school official" with a legitimate educational interest. We process student data solely to deliver the Service and in compliance with the Family Educational Rights and Privacy Act (FERPA).

• United States — State Privacy Laws: We comply with applicable US state privacy laws across all states in which we operate, including the California Consumer Privacy Act (CCPA). We do not sell or share personal information for cross-context behavioral advertising.

3.  Data Collection

• Website: We collect IP addresses via cookies to record visits and improve our website functionality. You may opt out through your browser settings.

• Services: We collect names, email addresses, job titles, and contact numbers to deliver the Service and manage your account. We also collect emails and communications exchanged on our platform.

• AI Features: When using AI-powered features, we process inputs, natural language prompts, query parameters, and the resulting AI-generated summaries, analytics, and reports ("AI Processing Data").

4.  AI-Powered Features & Locally Hosted Models

Intelocate provides AI-powered capabilities designed to help users query, analyze, and generate insights from operational data within their environment.

• Hybrid Infrastructure: AI Features are powered by a combination of third-party providers and Company-operated infrastructure running locally hosted models. Where locally hosted models are used, data remains within Company's controlled environment.

• No Training Guarantee: We do not use Customer Data — including prompts, outputs, logs, or embeddings — to train, fine-tune, or improve any AI model, whether operated by Company or a third party.

• No Commercial Use: Customer Data processed by AI is used solely to deliver the Service and is never used for unrelated commercial purposes.

• Sensitive Data Prohibition: Users must not submit sensitive personal data — such as government-issued ID numbers, passwords, financial account details, or medical records — through AI prompts or queries. Any such submission is at the user's sole risk and Company bears no responsibility for its security or confidentiality.

• Subprocessors: A current list of third-party AI providers is maintained at intelocate.com/legal/ai-subprocessors.

5.  Data Transfers, Security & Retention

• International Transfers: We do not rely on the EU-US Privacy Shield. All international data transfers are protected by Standard Contractual Clauses (SCCs) or equivalent mechanisms approved by applicable data protection authorities.

• Security: We maintain administrative, physical, and technical safeguards appropriate to the level of sensitivity of the information we process. All AI-processed data is transmitted over encrypted connections and subject to the same security obligations as all other Customer Data.

• Retention: We retain your personal information only for as long as you have an active account with Intelocate. Upon account termination, we will either return your data to you or delete it, as you request, within a specified period, in accordance with the MSA in place.

6.  How We Share Information

Intelocate only shares personal information with third-party contractors and AI subprocessors engaged to assist us in providing our services and only for that purpose. We ensure all such providers comply with applicable data protection standards and this Privacy Policy. We do not sell personal information to third parties.

7.  Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Right to Access / Correct: You may access or correct your personal information at any time.

• Right to Erasure: You may request that we delete your personal information.

• Right to Portability: You may request a copy of your data in a structured, machine-readable format.

• Right to Object: You may object to the processing of your data for legitimate interests or direct marketing.

• Right to Restrict Processing: You may request that we restrict the processing of your personal information in certain circumstances.

To exercise any of these rights, contact us at legal@intelocate.com.

8.  Contact

Intelocate's Dedicated Privacy Coordinator

Email: legal@intelocate.com

Should your concerns remain unaddressed, you may contact the Data Protection Authority in your country or the Office of the Privacy Commissioner of Canada.

This policy was last revised in May 2026. We will notify users of any material changes by updating the date at the top of this page.