Privacy Policy

At Answir Inc. (“Answir“, “we“, “our“, or “us“), protecting the privacy and security of our users and customers is one of our highest priorities. We believe transparency is fundamental to building trust, particularly when artificial intelligence is used to help organizations communicate with investors, customers, employees and other stakeholders.

This Privacy Policy explains how Answir collects, uses, stores, protects and shares information when individuals:

• visit our websites;
• interact with an Answir-powered AI assistant;
• create an account;
• communicate with us;
• attend demonstrations, webinars or events;
• subscribe to newsletters or marketing communications;
• request customer support; or
• otherwise use any products, services or applications offered by Answir (collectively, the “Services“).

This Privacy Policy also explains your rights regarding your information and the choices available to you.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

ABOUT ANSWIR

Answir is an enterprise artificial intelligence platform that enables organizations to deploy customized AI assistants trained on authorized information provided or approved by each customer.

Depending upon a customer’s configuration, Answir may answer questions using information contained within:

• public regulatory filings;
• corporate websites;
• investor presentations;
• news releases;
• frequently asked questions;
• internal documentation;
• customer-provided knowledge bases;
• policies and procedures;
• training materials;
• product documentation; or
• other information sources authorized by the customer.

Each customer controls the information made available to its own Answir assistant.

Unless expressly authorized by the applicable customer or required by law, information associated with one customer is not made available to another customer.

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to information collected through:

• www.answir.ai;
• customer-specific Answir deployments;
• embedded website assistants;
• mobile-compatible interfaces;
• voice-enabled interactions;
• customer support;
• online demonstrations;
• webinars;
• conferences;
• marketing campaigns;
• surveys;
• social media interactions;
• email communications;
• live chat;
• callback requests;
• application programming interfaces (APIs); and
• any future Answir products or services that expressly reference this Privacy Policy.

This Privacy Policy does not apply to third-party websites, applications or services that are not owned or controlled by Answir, even where those services may be linked from our website or integrated into our platform.

DEFINITIONS

For purposes of this Privacy Policy, the following terms have the meanings set out below:

“Account”

An electronic account created to access certain features or functionality of the Services.

“Administrator”

An individual authorized by a Customer to configure, manage or administer the Customer’s Answir deployment, including user permissions, knowledge sources, reporting, analytics and other administrative settings.

“AI Assistant”

A customized artificial intelligence-powered conversational interface provided through the Services that is configured to answer questions and provide information using customer-authorized content, approved data sources and applicable system instructions.

“AI-Generated Response”

Any response, summary, recommendation, translation, analysis or other output generated by the Services using artificial intelligence technologies.

“Answir”, “we”, “our”, or “us”

Answir Inc., together with its affiliates, successors and permitted assigns.

“Communications”

Any interaction between a User and Answir, including emails, forms, chat messages, support requests, surveys, demonstrations, webinars, voice interactions and other communications.

“Conversation”

A series of one or more interactions between a User and an AI Assistant, including prompts, responses, uploaded content and related metadata.

“Conversation Analytics”

Information generated from Conversations for reporting, operational insights, trend analysis, product improvement, customer reporting or other legitimate business purposes, including but not limited to conversation counts, engagement metrics, response times, satisfaction ratings, frequently discussed topics and sentiment analysis.

“Customer”

Any organization, business, government entity, non-profit organization or other legal entity that licenses, subscribes to or otherwise uses the Services.

“Customer Content”

Information, documents, data, images, knowledge bases, presentations, policies, procedures, regulatory filings, training materials, product information or other content provided, uploaded or authorized by a Customer for use within the Services.

“Customer Organization”

The specific organization whose Answir AI Assistant a User is interacting with.

“Knowledge Base”

The collection of documents, information, structured data and other content made available by or on behalf of a Customer for retrieval and use by its AI Assistant.

“Live Multi-User Q&A Event”

A feature that enables multiple participants to submit questions and interact simultaneously with an AI Assistant and, where configured, authorized human moderators or representatives.

“Personal Information”

Information about an identifiable individual or information that may reasonably be used, alone or in combination with other information, to identify an individual, as defined by applicable privacy legislation.

“Processing”

Any operation performed on information, whether automated or manual, including collecting, recording, organizing, structuring, storing, adapting, retrieving, using, disclosing, transmitting, analyzing, combining, deleting or otherwise handling information.

“Services”

All products, software, websites, applications, APIs, embedded AI Assistants, administrator portals, analytics dashboards, voice features, integrations and related services provided by Answir that reference this Privacy Policy.

“Subprocessor” or “Sub-processor”

A third-party service provider engaged by Answir to assist in providing, supporting or securing the Services by processing information on Answir’s behalf under contractual confidentiality and data protection obligations.

“User”

Any individual who accesses, visits or otherwise interacts with the Services, including investors, analysts, employees, customers, suppliers, partners, media representatives, administrators and other authorized users.

“Voice Features”

Optional accessibility features that enable Users to interact with the Services using speech-to-text, text-to-speech or other voice-enabled technologies.

OUR PRIVACY PRINCIPLES

At Answir, we believe privacy, security and transparency are fundamental to earning and maintaining the trust of our customers and their stakeholders. These principles guide how we design, develop and operate our Services.

Transparency

We strive to clearly explain what information we collect, why we collect it, how it is used and the choices available to our users. We believe individuals should understand how their information is handled when interacting with artificial intelligence.

Customer Control

Our customers determine how their Answir deployments are configured, including the knowledge sources used by their AI assistants, administrator permissions, retention settings and many other operational controls. We believe organizations should remain in control of their own information.

Data Segregation

Answir is designed so that each customer’s information remains logically separated from that of other customers. Information authorized for one customer is not intentionally used to answer questions on behalf of another customer unless expressly authorized or required by law.

Privacy by Design

Privacy considerations are incorporated throughout the design, development and operation of our platform. We seek to minimize unnecessary data collection, limit access to information based on legitimate business needs and implement safeguards appropriate to the sensitivity of the information we process.

Security by Design

Protecting customer information is a foundational element of our platform architecture. We continually evaluate and improve our administrative, technical and organizational safeguards to support the confidentiality, integrity and availability of the Services.

Responsible Artificial Intelligence

Artificial intelligence is intended to assist, not replace, human judgment.

Our AI technology is designed to help users discover and understand information more efficiently while recognizing that important financial, legal, regulatory, business and other significant decisions should continue to involve appropriate human oversight and professional judgment.

We continually evaluate our AI systems to improve accuracy, reliability, transparency and user experience while seeking to reduce errors and unintended outcomes.

Accessibility

We believe information should be accessible to as many people as reasonably possible.

Accordingly, Answir continues to develop accessibility features, including multilingual support, voice interactions and other technologies, to help users interact with information in ways that best meet their individual needs.

Continuous Improvement

Technology, privacy expectations and artificial intelligence continue to evolve rapidly.

We are committed to continually improving our platform, privacy practices, security controls and governance processes so that our customers and users benefit from advancements in technology while maintaining appropriate protections for their information.

Accountability

Privacy and security are shared responsibilities.

Answir maintains internal policies, governance processes and accountability measures intended to support responsible information management. We also encourage our customers and users to play an active role in protecting their own information by using strong authentication practices, safeguarding account credentials and exercising good cybersecurity habits.

Building Trust

Ultimately, our goal is to earn trust – not simply through legal compliance, but through responsible stewardship of information.

We believe organizations should be able to deploy artificial intelligence with confidence, knowing that transparency, privacy, security and customer control remain central to how Answir is designed and operated.

INFORMATION WE COLLECT

The information we collect depends on how you interact with Answir, the Services you use, the preferences you select and the configuration established by the organization whose Answir assistant you are interacting with.

We collect the following categories of information.

1. INFORMATION YOU VOLUNTARILY PROVIDE

You may choose to provide us with information directly, including:

Contact Information

Examples include:

• name;
• email address;
• telephone number;
• mailing address;
• employer;
• company name;
• organization;
• job title;
• department;
• country;
• province or state;
• preferred language; and
• other information you voluntarily provide.

Account Information

If you create an account, we may collect:

• username;
• password (stored using secure cryptographic methods);
• authentication credentials;
• profile photo (if provided);
• notification preferences;
• communication preferences;
• account settings; and
• administrative permissions.

Customer Profile Information

Depending on how a customer configures their Answir assistant, you may voluntarily provide additional information such as:

• investor type;
• shareholder status;
• analyst affiliation;
• media affiliation;
• supplier information;
• customer status;
• employee status;
• organization represented;
• reason for inquiry;
• areas of interest;
• preferred communication style or persona;
• accessibility preferences; or
• other optional profile information.

Providing this information is generally optional unless required by a customer organization for a specific service.

Communications

We collect information you provide when you:

• submit questions;
• participate in conversations;
• request demonstrations;
• contact support;
• submit surveys;
• leave feedback;
• provide testimonials;
• complete forms;
• request information;
• subscribe to newsletters;
• register for webinars;
• participate in promotional campaigns; or
• otherwise communicate with us.

Communications may include text, uploaded files, voice input (where enabled), images or other information voluntarily submitted.

2. AI CONVERSATION INFORMATION

One of the primary functions of Answir is facilitating conversations between users and AI assistants.

Accordingly, we may collect information relating to those interactions, including:

• questions submitted;
• prompts entered;
• AI-generated responses;
• follow-up questions;
• conversation timestamps;
• session identifiers;
• interaction duration;
• conversation length;
• conversation summaries;
• user feedback;
• satisfaction ratings;
• “thumbs up” and “thumbs down” responses;
• requests for clarification;
• requests for escalation;
• requests for live human assistance;
• callback requests;
• live chat requests;
• accessibility preferences selected during the conversation;
• language selections;
• communication persona selections; and
• other interaction metadata generated during use of the Services.

Depending on the configuration selected by a customer organization, conversations may be retained for customer reporting, quality assurance, analytics, compliance, training, customer support or other legitimate business purposes described in this Privacy Policy.

3. INFORMATION UPLOADED TO THE PLATFORM

Customers or users may upload information including:

• documents;
• presentations;
• PDFs;
• spreadsheets;
• policies;
• manuals;
• financial reports;
• regulatory filings;
• knowledge base articles;
• product documentation;
• frequently asked questions;
• multimedia files;
• images; and
• other content intended to improve the knowledge available to an Answir assistant.

Ownership of uploaded customer content remains subject to the applicable agreement between Answir and the customer.

4. INFORMATION COLLECTED AUTOMATICALLY

When you access or interact with our Services, we and our authorized service providers may automatically collect certain technical and usage information about your device and your interactions with the Services.

This information helps us maintain the security, reliability, performance and usability of the Services.

Depending upon your device, browser and customer configuration, we may collect information including:

Device Information

Examples include:

• IP address;
• browser type and version;
• operating system;
• device type;
• device model;
• screen resolution;
• browser language;
• time zone;
• unique device identifiers;
• network connection type; and
• diagnostic information.

Usage Information

Examples include:

• pages visited;
• features accessed;
• buttons clicked;
• searches performed;
• session duration;
• navigation paths;
• referral sources;
• entry and exit pages;
• interaction frequency;
• return visits;
• timestamps;
• feature adoption;
• response times;
• error logs; and
• crash reports.

Approximate Location Information

We may estimate your approximate geographic location using information such as your IP address.

Approximate location information may include:

• country;
• province or state;
• metropolitan area;
• city; or
• approximate geographic region.

We do not intentionally collect precise GPS location information unless explicitly enabled for a specific Service or feature with your permission.

5. COOKIES AND SIMILAR TECHNOLOGIES

Like most modern software platforms, Answir uses cookies and similar technologies to improve the functionality, security and performance of our Services.

These technologies may include:

• cookies;
• browser storage;
• session identifiers;
• web beacons;
• pixels;
• tags;
• software development kits (SDKs);
• application logs; and
• similar technologies.

Cookies help us:

• authenticate users;
• remember preferences;
• maintain secure sessions;
• improve website performance;
• understand feature usage;
• measure website traffic;
• improve user experience;
• prevent fraud;
• diagnose technical issues; and
• support analytics.

Certain cookies are necessary for the Services to function correctly and cannot be disabled without affecting core functionality.

Where required by applicable law, we will obtain your consent before placing non-essential cookies on your device.

You may manage cookie preferences through your browser settings or any cookie management tools made available on our website. Please note that disabling certain cookies may affect the availability or functionality of portions of the Services.

6. VOICE, ACCESSIBILITY AND COMMUNICATION PREFERENCES

Answir is designed to improve accessibility for users with varying communication preferences and abilities.

Where enabled by a customer organization, users may choose to interact with Answir using accessibility features including:

• speech-to-text;
• text-to-speech;
• multilingual conversations;
• translated responses;
• accessibility settings;
• communication personas;
• preferred languages; and
• other accessibility features introduced from time to time.

When voice functionality is used, spoken words may be converted into text for processing by the platform.

Likewise, AI-generated text responses may be converted into synthesized speech.

Voice interactions may generate the same types of interaction records described elsewhere in this Privacy Policy, including conversation history, timestamps, interaction metadata and user feedback.

Unless otherwise disclosed for a particular Service, Answir does not use voice recordings to build publicly available AI models.

HOW WE COLLECT INFORMATION

We collect information from several different sources depending upon how you interact with the Services.

Information You Provide Directly

We collect information directly from you when you:

• visit our website;
• create an account;
• register for demonstrations;
• request information;
• communicate with us;
• subscribe to newsletters;
• participate in surveys;
• contact customer support;
• submit forms;
• upload documents;
• interact with an AI assistant;
• request a callback;
• initiate a live chat;
• participate in a Live Multi-User Q&A Event;
• provide feedback; or
• otherwise communicate with us.

Information Collected Automatically

We automatically collect certain information using the technologies described above whenever you:

• browse our website;
• access customer deployments;
• interact with AI assistants;
• use embedded widgets;
• access administrator dashboards;
• utilize APIs;
• interact with accessibility features; or
• otherwise use the Services.

Information Provided by Customer Organizations

Organizations using Answir may provide information necessary to configure their deployment, including:

• company information;
• branding;
• organizational structure;
• approved knowledge sources;
• authorized documents;
• investor relations materials;
• product information;
• employee resources;
• support documentation;
• policies;
• administrator permissions;
• notification settings;
• escalation rules; and
• other customer-authorized information.

Customers remain responsible for ensuring they have the necessary rights to provide such information to Answir.

Information from Third Parties

We may receive information from third parties including:

• cloud infrastructure providers;
• authentication providers;
• payment processors;
• marketing platforms;
• analytics providers;
• customer relationship management systems;
• fraud prevention services;
• publicly available regulatory databases;
• stock market data providers;
• customer-authorized third-party integrations;
• event registration platforms;
• social media platforms;
• customer support platforms; and
• other vendors that assist us in operating the Services.

We only use such information for purposes consistent with this Privacy Policy and applicable agreements.

ARTIFICIAL INTELLIGENCE PROCESSING

Artificial intelligence is a core component of the Answir platform.

When you interact with an Answir assistant, your questions and related information may be processed using artificial intelligence technologies in order to generate responses.

Depending upon the customer’s configuration, AI-generated responses may incorporate information from:

• customer-authorized knowledge bases;
• public regulatory filings;
• corporate websites;
• news releases;
• presentations;
• internal documentation;
• uploaded documents;
• frequently asked questions;
• structured databases;
• financial information;
• market data;
• customer-provided content; and
• other information sources authorized by the customer.

AI-generated responses are produced automatically and may occasionally contain inaccuracies, omissions or outdated information.

Users should independently verify important information before making financial, legal, investment, business or other significant decisions.

Official company disclosures, regulatory filings and other authoritative documents remain the definitive source of information.

AI MODEL PROVIDERS

To deliver the Services, Answir may utilize artificial intelligence technologies provided by trusted third-party providers under contractual obligations regarding confidentiality, security and data protection.

These providers may process prompts, uploaded information and related interaction data solely for the purpose of generating responses or supporting functionality requested by Answir.

Where commercially and contractually available, Answir seeks to use services that do not permit customer information to be used to train publicly available AI models without authorization.

Answir continually evaluates available AI technologies and may introduce, replace or enhance underlying AI models in order to improve the quality, accuracy, security and performance of the Services.

The specific AI technologies used may change over time without requiring amendment to this Privacy Policy, provided such changes remain consistent with the purposes described herein.

CUSTOMER KNOWLEDGE BASES AND DATA SEGREGATION

One of Answir’s foundational design principles is customer-specific information management.

Each customer organization controls the information made available to its own Answir assistant.

Unless expressly authorized by the applicable customer or required by law:

• customer knowledge bases remain logically segregated;
• one customer’s information is not made available to another customer;
• customer-authorized content is processed only for the benefit of that customer;
• administrator permissions control access to customer information; and
• customer data is handled in accordance with applicable agreements and security controls.

Answir does not intentionally combine confidential customer knowledge bases into a shared repository for answering questions on behalf of unrelated customer organizations.

HOW WE USE INFORMATION

We use the information we collect for legitimate business purposes consistent with this Privacy Policy, our agreements with customers, applicable law, and the services requested by users.

Depending on how the Services are configured, we may use information to:

Provide the Services

• provide access to the Services;
• authenticate users;
• create and manage accounts;
• respond to questions submitted through Answir;
• generate AI-assisted responses;
• deliver customer-authorized information;
• remember conversation context during active sessions;
• facilitate multilingual conversations;
• provide voice-enabled interactions;
• enable accessibility features;
• personalize user experiences;
• provide customer support;
• process callback requests;
• facilitate live chat requests;
• support Live Multi-User Q&A Events;
• deliver notifications requested by users;
• administer customer deployments;
• maintain customer knowledge bases; and
• provide requested products and services.

Improve the Platform

We continually improve Answir to enhance its usefulness, security and accuracy.

Accordingly, we may use information to:

• improve AI response quality;
• improve search relevance;
• improve answer accuracy;
• evaluate response consistency;
• identify knowledge gaps;
• improve accessibility;
• improve multilingual capabilities;
• improve user interfaces;
• improve administrator tools;
• improve reporting capabilities;
• improve platform reliability;
• reduce response latency;
• improve system performance;
• improve security controls;
• improve feature usability;
• troubleshoot technical issues;
• identify software defects;
• test new features;
• evaluate beta functionality; and
• support future product development.

Customer Communications

We may use information to:

• respond to inquiries;
• communicate regarding support requests;
• notify users regarding account activity;
• provide service announcements;
• communicate security notices;
• send requested newsletters;
• provide educational resources;
• invite participation in webinars;
• administer events;
• conduct surveys;
• collect product feedback;
• communicate feature updates; and
• provide marketing communications where permitted by law or with your consent.

Users may opt out of marketing communications at any time. Transactional or service-related communications may continue where necessary to provide the Services.

Business Operations

We may also use information to:

• administer our business;
• maintain contractual relationships;
• process payments;
• manage subscriptions;
• prevent fraud;
• investigate abuse;
• protect the Services;
• enforce our agreements;
• comply with legal obligations;
• resolve disputes;
• establish legal claims;
• defend legal claims;
• conduct audits;
• maintain business records;
• support accounting activities;
• perform internal reporting;
• comply with regulatory requirements; and
• protect the rights, safety and property of Answir, our customers and our users.

CONVERSATION ANALYTICS AND PLATFORM INSIGHTS

One of the core benefits of the Answir platform is its ability to generate insights from user interactions.

Depending upon the customer’s configuration, Answir may analyze interactions to generate operational, engagement and customer experience metrics.

Examples may include:

• total conversations;
• total prompts submitted;
• conversation duration;
• average response times;
• interaction frequency;
• repeat visitor statistics;
• feature adoption;
• most frequently asked questions;
• popular topics;
• keyword trends;
• user satisfaction metrics;
• thumbs up/down trends;
• conversation completion rates;
• escalation frequency;
• callback requests;
• live chat requests;
• geographic trends based on approximate location;
• preferred languages;
• accessibility feature usage;
• communication persona selections; and
• other aggregated engagement metrics.

These analytics help customer organizations better understand the information needs of their stakeholders and improve future communications.

Unless otherwise disclosed or authorized, analytics are presented in a manner consistent with applicable privacy laws and customer agreements.

CONVERSATION SENTIMENT ANALYSIS

Where enabled by a customer organization, Answir may analyze the overall tone or sentiment of conversations using artificial intelligence.

Sentiment analysis is intended to help organizations better understand trends across user interactions and improve customer service, investor engagement, employee communications and related functions.

Depending upon customer configuration, sentiment analysis may include:

• conversation-level sentiment;
• individual interaction sentiment;
• positive and negative trends;
• emerging concerns;
• recurring themes;
• stakeholder satisfaction indicators;
• engagement quality metrics; and
• other analytical insights generated using artificial intelligence.

Sentiment analysis is intended as an analytical tool only and should not be interpreted as an objective assessment of any individual’s emotions, intentions or state of mind.

CONVERSATION SUMMARIES AND AI-GENERATED INSIGHTS

To improve usability and reporting, Answir may automatically generate summaries or insights based on conversations.

Examples include:

• conversation summaries;
• topic summaries;
• recurring questions;
• emerging themes;
• suggested knowledge base improvements;
• frequently requested information;
• customer support trends;
• investor relations trends;
• employee communication trends; and
• other AI-generated analytical outputs.

These summaries are intended to assist customer organizations in understanding overall communication trends and improving future interactions.

CONVERSATION ALERTS AND NOTIFICATIONS

Certain customers may choose to enable automated conversation alerts.

When enabled, Answir may automatically notify authorized administrators when predefined conditions occur.

Examples include:

• highly positive interactions;
• highly negative interactions;
• repeated requests for assistance;
• unresolved questions;
• compliance-related concerns;
• unusually high conversation activity;
• technical issues;
• recurring topics identified by AI;
• significant changes in conversation sentiment; or
• other customer-configured alert conditions.

Alert thresholds and recipients are determined by the applicable customer organization.

HUMAN ASSISTANCE FEATURES

Although Answir utilizes artificial intelligence to provide immediate responses, certain customer organizations may also offer human assistance.

Depending upon customer configuration, users may request:

• a live chat with a customer representative;
• a telephone callback;
• an email response;
• follow-up by a designated representative;
• assistance from customer support personnel;
• escalation of unresolved questions; or
• other forms of human assistance.

When a user requests human assistance, relevant information necessary to fulfill that request, including contact information, conversation history and the nature of the request, may be shared with the applicable customer organization.

LIVE MULTI-USER Q&A EVENTS

Certain customer organizations may utilize Answir to facilitate moderated Live Multi-User Q&A Events.

During these events, information may be collected relating to:

• questions submitted;
• participant interactions;
• timestamps;
• moderation actions;
• event analytics;
• audience engagement;
• accessibility preferences;
• polling responses (where applicable); and
• related event information.

Depending upon customer configuration, questions and responses may be visible to moderators or other participants as part of the event experience.

Organizations utilizing this functionality remain responsible for determining how event content is presented, retained and managed.

ADMINISTRATOR DASHBOARDS

Authorized customer administrators may have access to dashboards designed to assist in managing their Answir deployment.

Depending upon customer permissions, dashboards may include:

• conversation statistics;
• engagement metrics;
• conversation histories;
• user feedback;
• analytics;
• sentiment summaries;
• feature usage;
• callback requests;
• live chat requests;
• accessibility statistics;
• knowledge base utilization;
• administrative logs;
• platform health information; and
• other reporting tools.

Customer organizations determine which individuals are granted administrative access within their own deployment.

Answir recommends that customers grant administrative access only to individuals with a legitimate business need.

AI QUALITY ASSURANCE

To maintain and improve the quality of the Services, Answir may use information to:

• evaluate response accuracy;
• identify incomplete answers;
• improve retrieval quality;
• reduce hallucinations;
• improve citation quality;
• identify outdated content;
• improve customer knowledge bases;
• improve prompt routing;
• enhance security;
• evaluate feature performance;
• improve accessibility;
• improve multilingual capabilities; and
• maintain overall platform reliability.

Where commercially and contractually available, Answir seeks to utilize AI services that do not use customer information to train publicly available artificial intelligence models without authorization.

HOW WE SHARE INFORMATION

Answir does not sell personal information to third parties for monetary consideration.

We share information only as necessary to operate the Services, fulfill customer requests, comply with legal obligations, protect our rights, or as otherwise described in this Privacy Policy.

Depending upon the Services being used, information may be shared with the following categories of recipients.

Customer Organizations

When you interact with an Answir assistant deployed by an organization, information relating to your interaction may be shared with that organization.

Depending upon the customer’s configuration and applicable permissions, customer representatives may have access to information including:

• conversation history;
• questions submitted;
• AI-generated responses;
• uploaded files;
• satisfaction ratings;
• callback requests;
• live chat requests;
• conversation summaries;
• analytics;
• sentiment analysis;
• event participation;
• administrator reports; and
• other information generated through your use of that customer’s deployment.

The customer organization is responsible for its own handling of information it receives through the Services.

Where Answir processes personal information solely on behalf of a customer, Answir generally acts as a service provider, processor or equivalent role under applicable privacy laws, while the customer remains responsible for determining the purposes and means of processing.

Service Providers and Subprocessors

We engage carefully selected third-party service providers to support the operation of the Services.

Depending upon the Services being used, these providers may perform functions including:

• cloud hosting;
• infrastructure management;
• data storage;
• authentication;
• payment processing;
• email delivery;
• customer support;
• monitoring;
• analytics;
• artificial intelligence processing;
• cybersecurity;
• fraud prevention;
• software development;
• logging;
• performance monitoring;
• document processing;
• accessibility services;
• translation;
• telecommunications;
• and other operational services.

These providers are contractually required to process information only for authorized purposes and to maintain appropriate security and confidentiality safeguards.

Professional Advisors

We may share information with our:

• legal counsel;
• auditors;
• accountants;
• insurers;
• financial advisors;
• compliance consultants; and
• other professional advisors,

where reasonably necessary to protect our legitimate interests or comply with applicable legal obligations.

Business Partners

Where authorized by a customer or user, we may share limited information with trusted business partners for purposes including:

• integrations requested by customers;
• jointly delivered services;
• implementation support;
• reseller or distributor relationships;
• customer onboarding;
• training services; or
• technical support.

Such sharing is limited to information reasonably necessary to provide the requested services.

Legal Requirements

We may disclose information where we reasonably believe disclosure is necessary to:

• comply with applicable laws;
• respond to court orders;
• comply with subpoenas;
• cooperate with regulatory authorities;
• respond to lawful governmental requests;
• investigate fraud;
• investigate security incidents;
• enforce our agreements;
• protect our rights;
• protect customer rights;
• protect user safety;
• protect the integrity of the Services; or
• prevent unlawful activity.

Whenever appropriate and legally permissible, we may notify the affected customer before disclosing customer information.

Corporate Transactions

If Answir participates in:

• a merger;
• acquisition;
• financing;
• investment;
• corporate restructuring;
• sale of assets;
• bankruptcy;
• receivership; or
• similar transaction,

information may be transferred as part of that transaction, subject to applicable confidentiality obligations and applicable law.

Any successor organization will remain subject to obligations substantially consistent with this Privacy Policy unless users are notified otherwise.

INTERNATIONAL DATA TRANSFERS

Answir is headquartered in Canada but may provide Services to customers located throughout the world.

Accordingly, information may be processed or stored in Canada or other jurisdictions where Answir, its customers or its authorized service providers operate.

These jurisdictions may have privacy laws that differ from those applicable in your country of residence.

Where personal information is transferred internationally, Answir takes reasonable steps to ensure appropriate safeguards are implemented consistent with applicable privacy legislation.

These safeguards may include:

• contractual data protection provisions;
• vendor security assessments;
• technical safeguards;
• organizational safeguards;
• encryption;
• access controls; and
• other appropriate measures.

SECURITY OF YOUR INFORMATION

Protecting customer and user information is fundamental to Answir’s business.

We maintain a comprehensive information security program designed to protect the confidentiality, integrity and availability of information entrusted to us.

Our security program includes administrative, technical and physical safeguards appropriate to the nature of the information processed and the risks involved.

Depending upon the Services provided, these safeguards may include:

• encryption in transit;
• encryption at rest where appropriate;
• multi-factor authentication;
• role-based access controls;
• least-privilege access principles;
• administrator authentication;
• network security monitoring;
• vulnerability management;
• secure software development practices;
• logging and monitoring;
• security incident response procedures;
• backup and recovery processes;
• business continuity planning;
• employee confidentiality obligations;
• security awareness training;
• vendor risk management;
• access reviews;
• password management controls; and
• regular security improvements.

No method of electronic transmission or storage can be guaranteed to be completely secure.

Accordingly, while we strive to use commercially reasonable safeguards, we cannot guarantee absolute security.

CUSTOMER DATA ISOLATION

Answir has been designed with customer-specific information segregation as a foundational architectural principle.

Subject to customer configuration and applicable agreements:

• customer knowledge bases are logically isolated;
• customer AI assistants operate independently;
• customer-authorized documents are processed separately;
• administrator permissions are customer-specific;
• customer analytics remain customer-specific;
• conversation histories remain associated with the applicable deployment; and
• information is not intentionally shared across unrelated customer organizations.

This customer-specific architecture helps reduce the risk of unauthorized access and supports enterprise privacy and security requirements.

DATA RETENTION

We retain information only for as long as reasonably necessary to:

• provide the Services;
• fulfill contractual obligations;
• comply with legal requirements;
• maintain appropriate business records;
• resolve disputes;
• enforce agreements;
• improve the Services;
• support security investigations; or
• fulfill other legitimate business purposes described in this Privacy Policy.

Retention periods may vary depending upon:

• customer configuration;
• subscription level;
• contractual requirements;
• applicable law;
• litigation holds;
• regulatory obligations;
• technical requirements; and
• operational needs.

Customers may have the ability to configure certain retention settings within their own Answir deployment, subject to technical limitations and applicable agreements.

DELETION OF INFORMATION

Users may request correction or deletion of certain personal information, subject to applicable law and contractual obligations.

Where Answir processes information solely on behalf of a customer organization, requests relating to conversation history or customer-controlled information should generally be directed to the applicable customer.

Following expiration or termination of customer agreements, Answir will retain or securely delete customer information in accordance with applicable contractual commitments, legal obligations and documented retention procedures.

Backup systems may temporarily retain encrypted copies of information until those backups are overwritten or securely destroyed in accordance with normal operational practices.

BUSINESS CONTINUITY AND DISASTER RECOVERY

To promote the reliability and resilience of the Services, Answir maintains business continuity and disaster recovery practices appropriate to the nature of its operations.

These practices may include:

• encrypted backups;
• infrastructure redundancy;
• disaster recovery planning;
• system monitoring;
• incident response procedures;
• recovery testing;
• change management processes; and
• continuity planning.

These measures are intended to reduce the impact of unexpected disruptions while supporting the continued availability and integrity of the Services.

SECURITY INCIDENTS

If Answir becomes aware of a confirmed security incident involving personal information under its control, we will investigate the incident promptly and take appropriate steps to contain, assess and remediate the issue.

Where required by applicable law or contractual obligations, we will notify affected customers and, where appropriate, relevant regulatory authorities or affected individuals within the timeframes prescribed by law.

YOUR PRIVACY RIGHTS

Depending on your place of residence and applicable privacy laws, you may have certain rights regarding your personal information.

Subject to applicable legal limitations, these rights may include the ability to:

• access personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of certain personal information;
• request restriction of certain processing activities;
• object to certain processing activities;
• withdraw consent where processing is based upon consent;
• request portability of certain personal information;
• request information regarding how your information has been used;
• request information regarding disclosures of your information; and
• submit complaints to applicable privacy regulators.

The availability of these rights varies depending upon applicable law.

Customer-Controlled Information

Many Answir deployments are operated on behalf of customer organizations.

Where Answir processes personal information solely on behalf of a customer organization, that customer generally determines:

• why information is collected;
• how information is used;
• how long information is retained; and
• how privacy requests are handled.

Accordingly, if your request relates to information collected while interacting with an Answir assistant operated by one of our customers, we may direct you to submit your request to that customer.

Where appropriate, we will cooperate with our customers in responding to such requests.

EXERCISING YOUR RIGHTS

To submit a privacy request, you may contact Answir using the contact information provided at the end of this Privacy Policy.

To protect your privacy and the security of your information, we may request information necessary to verify your identity before fulfilling your request.

In certain circumstances, we may decline or limit requests where permitted or required by applicable law, including where fulfilling a request would:

• adversely affect the rights of another individual;
• interfere with legal obligations;
• compromise security;
• reveal confidential business information;
• interfere with ongoing investigations; or
• otherwise be prohibited by law.

MARKETING COMMUNICATIONS

Where permitted by applicable law, Answir may send newsletters, product announcements, educational content, event invitations and other marketing communications.

You may unsubscribe from marketing communications at any time by:

• selecting the unsubscribe link included in our emails;
• updating your communication preferences where available; or
• contacting us directly.

Please note that even if you opt out of marketing communications, we may continue to send important service-related communications, including:

• account notifications;
• security notices;
• billing information;
• contractual notices;
• support communications;
• product updates affecting your account; and
• other operational communications necessary to provide the Services.

COOKIE PREFERENCES

Where required by applicable law, users may manage cookie preferences through the cookie management tools provided on our website.

Most web browsers also permit users to:

• delete cookies;
• block cookies;
• receive notifications when cookies are placed; or
• limit certain categories of tracking technologies.

Please note that disabling certain cookies may reduce the functionality of portions of the Services.

CHILDREN’S PRIVACY

The Services are intended for business and professional use.

Answir does not knowingly collect personal information from children under the age required by applicable law without appropriate authorization.

If you believe a child has provided personal information to Answir without appropriate authorization, please contact us promptly so that we may investigate and take appropriate action.

THIRD-PARTY WEBSITES AND SERVICES

Our Services may contain links to third-party websites, applications or services.

Those third parties operate independently from Answir and maintain their own privacy policies and practices.

Answir is not responsible for the privacy, security or content of third-party websites or services.

We encourage users to review the privacy policies of any third-party websites or services they choose to access.

ARTIFICIAL INTELLIGENCE LIMITATIONS

Artificial intelligence is intended to assist users by providing timely access to information.

However, AI-generated responses may occasionally contain inaccuracies, omissions, ambiguities or outdated information.

Accordingly:

• AI-generated responses should not be considered a substitute for professional judgment;
• official company disclosures remain the authoritative source of information regarding customer organizations;
• users should independently verify important information before making financial, investment, legal, accounting, tax, medical or other significant decisions; and
• Answir does not guarantee the completeness, accuracy or suitability of AI-generated responses for every purpose.

Organizations using Answir remain responsible for the information they make available to their AI assistants.

CONTINUOUS IMPROVEMENT

Answir is continually improving its Services.

Accordingly, we may periodically introduce:

• new features;
• enhanced accessibility capabilities;
• improved analytics;
• additional reporting tools;
• expanded integrations;
• enhanced AI models;
• improved security controls;
• new customer configuration options; and
• other product enhancements.

Such improvements may result in additional categories of information being processed, provided such processing remains consistent with this Privacy Policy, applicable agreements and applicable law.

Where required by law, we will provide additional notice or obtain consent before processing information for materially different purposes.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

• changes in applicable law;
• new products or services;
• improvements to the Services;
• changes in technology;
• evolving privacy practices;
• regulatory guidance; or
• other operational or business developments.

When we make material changes, we will revise the “Last Updated” date at the beginning of this Privacy Policy.

Where required by applicable law, we will also provide additional notice or obtain consent before such changes become effective.

Your continued use of the Services after the effective date of an updated Privacy Policy constitutes acknowledgment of the revised Privacy Policy to the extent permitted by applicable law.

GOVERNING PRIVACY LAWS

Answir is headquartered in Alberta, Canada.

This Privacy Policy has been developed with consideration for applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Alberta’s Personal Information Protection Act (PIPA), together with internationally recognized privacy principles.

Where required, Answir also seeks to support compliance with other applicable privacy laws, including the General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and similar legislation applicable to our customers and users.

Nothing in this Privacy Policy limits any rights that users may have under applicable privacy legislation.

CONTACT US

If you have questions about this Privacy Policy, our privacy practices or your personal information, please contact us:

Answir Inc.

Attn: Privacy Officer

Tel: 1-844-ANSWIR-1

Email: [email protected]

Website: https://www.answir.ai

If your inquiry relates to a customer organization using Answir, please identify that organization when contacting us so that we can direct your request appropriately.