PRIVACY POLICY

Last updated May 21, 2024

This privacy notice for BarnacleAI, operated by BarnacleAI PTE LTD, and subsidiaries, affiliates, licensees, and/or licensors of BarnacleAI PTE LTD including BarnacleAI Inc ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

- Visit our website at https://barnacleai.com, or any website of ours that links to this privacy policy;
- Download and use our mobile application (BarnacleAI), or any other application of ours that links to this privacy policy;
- Engage with us in other related ways, including any sales, marketing, or events.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us.
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

- Names;
- Email addresses;
- Gender;
- Date of birth;
- Mailing addresses;
- Phone numbers;
- Nationality;
- Device ID;
- Transactional information;
- Profile Image.

Application Data. If you use our application(s), we may also collect the following information if you choose to provide us with access or permission:

- Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
- Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.
- Push Notifications. We may request to send you push notifications regarding your account or certain features of the application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.
- Profile Picture Data. Our app allows users to upload a profile picture for personalization purposes. We collect and process this image data solely for the purpose of displaying the user's chosen profile picture within the app. We do not store or retain users' personal images on our servers beyond the time necessary for processing and displaying them as profile pictures. We do not share users' profile pictures with any third parties, nor do we use the images for any purpose other than the user's intended display within the app. To ensure the privacy and security of users' image data, we employ industry-standard encryption methods and access control mechanisms. In accordance with applicable data protection laws, such as the General Data Protection Regulation (GDPR) in the EU and the California Consumer Privacy Act (CCPA) in the US, users have the right to access, correct, and delete their personal data, as well as the right to object to data processing. Users can remove, update, or replace their profile pictures at any time within the app. If you wish to exercise any of your rights or have any questions or concerns about our handling of profile picture data, please contact us at support@barnacleai.com.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. WHY DO WE PROCESS YOUR PERSONAL INFORMATION?

We use the personal information for the following purposes:


- Collected information is primarily needed to maintain the security and operation of our application, for troubleshooting, and for our internal analytics and reporting purposes.
- User experience. We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
- Communicate with you. We use your personal information to communicate with you in relation to BarnacleAI Services.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, such as with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:

- Consent. When we ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to the processing of your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop processing your data for that purpose.
- Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
- For investigations and fraud detection and prevention;
- For business transactions provided certain conditions are met;
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
- For identifying injured, ill, or deceased persons and communicating with next of kin;
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
- If the collection is solely for journalistic, artistic, or literary purposes;
- If the information is publicly available and is specified by the regulations.

4. COOKIES AND OTHER IDENTIFIERS

We use cookies and similar tools to enhance your user experience, provide our services, and understand how customers use our services so we can make improvements. Depending on applicable laws in the region you are located in, the cookie banner on your browser will tell you how to accept or refuse cookies.

5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

Information about our users is an important part of our business, and we are not in the business of selling our users' personal information to others. BarnacleAI shares users' personal information only as described below and with the subsidiaries or affiliates of BarnacleAI that are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.

- Third-party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analyzing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk. These third-party service providers only have access to personal information needed to perform their functions further; they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws.
- Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the user consents otherwise). Also, in the unlikely event that BarnacleAI or substantially all of its assets are acquired, user information will be one of the transferred assets.
- Protection of BarnacleAI and others: We release account and other personal information when we believe release is appropriate to comply with thelaw; enforce or apply our Conditions of Use and other agreements; or protect the rights, property, or safety of BarnacleAI, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
- At your option: Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

6. DATA SECURITY, INTEGRITY, AND RETENTION

We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. However, we cannot guarantee that our security measures will absolutely prevent unauthorized access to your personal information. It is also important for you to protect against unauthorized access to your password and to your computers, devices, and applications. Be sure to sign off when you finish using a shared computer. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or application, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We retain your personal information for as long as necessary to fulfil the purposes for which we collect it, except if required otherwise by law. For example, we may retain your information to comply with applicable legal, tax, or accounting requirements.

7. YOUR RIGHTS

Depending on applicable law, you may have the right to:

- Access: You may request information about our processing of your personal information and access to the personal information which we hold about you.
- Rectify: You may request the correction of your personal information where it is inaccurate, incomplete, or outdated.
- Delete: You may request the deletion of your personal information under certain circumstances, such as where the processing is based on your consent and you withdraw that consent.
- Restrict: You may request that we restrict the processing of your personal information under certain circumstances, such as where you contest the accuracy of that personal information or you object to us.
- Object: You may object to our processing of your personal information based on our legitimate interests, at any time. You may also object to our processing of your personal information for direct marketing purposes.
- Data Portability: You may request to receive your personal information in a structured, commonly used, and machine-readable format, and to have us transfer your personal information to another data controller where technically feasible.
You can exercise any of these rights by contacting us at support@barnacleai.com. We will process your request in accordance with applicable data protection laws.

8. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

9. HOW TO CONTACT US

If you have questions or concerns about this Privacy Policy or our practices, you may contact us by email at support@barnacleai.com
Thank you for trusting BarnacleAI with your personal information.