Privacy Policy

Effective: September 1, 2025

We at Accentrust Inc. ("Accentrust", "we", "our", "us") respect your privacy and are committed to protecting personal information we collect from or about you when you use our websites, products, and services, including Fabric, Guard, Studio, and Signals (collectively, the "Services").

This Privacy Policy does not apply to content we process solely on behalf of our enterprise customers under a subscription, pilot, or API agreement (e.g., data sent to Fabric within a customer's VPC). That processing is governed by the applicable Business Terms, Data Processing Addendum (DPA), and customer instructions.

For how we use training data to improve AI models and your choices, see "Model Improvement & Opt-Out" below.

1) Personal Data we collect

"Personal Data" means information that identifies or can reasonably be linked to an individual.

2) How we use Personal Data

We use Personal Data to:

• Provide and operate the Services (including responding to prompts, routing requests, and supporting features).
• Secure and protect the Services (fraud, abuse, vulnerability, incident response, and audit).
• Improve and develop the Services and conduct research (including evaluations, quality testing, and new features).
• Communicate with you (product updates, security notices, transactional emails, and—with consent where required—marketing).
• Comply with law and enforce our Terms of Use, Business Terms, and policies.

We may aggregate or de-identify Personal Data for analytics and research. We maintain de-identified data in that form and will not attempt to re-identify except as permitted by law.

3) Model improvement & opt-out

Unless your enterprise agreement or in-product setting says otherwise, we may use Content (your Inputs and the associated context/telemetry) to maintain, develop, and improve model quality, safety, and performance.

4) When we disclose Personal Data

We may disclose Personal Data as follows:

We do not sell Personal Data and do not share Personal Data for cross-context behavioral advertising as defined by U.S. state privacy laws.

5) Retention

We retain Personal Data only as long as necessary for the purposes above, to comply with law, resolve disputes, enforce agreements, and ensure safety. Retention periods vary by data type, legal requirements, and your settings (e.g., temporary sessions or workspace retention policies). When no longer needed, we delete or de-identify data consistent with our schedules.

6) Your privacy choices & rights

Your available rights depend on your location (e.g., PIPEDA/PIPA, CCPA/CPRA, GDPR). Subject to exceptions, you may request to:

• Access the Personal Data we hold about you;
• Correct inaccurate data;
• Delete data;
• Port data in a portable format;
• Restrict or Object to processing;
• Withdraw consent where we rely on consent;
• Appeal certain automated or rights-request decisions (where applicable).

You can exercise some controls in product. Otherwise, contact dsar@accentrust.com or privacy@accentrust.com. We may verify your identity and, where permitted, respond within the legally required time.

Authorized agents (US). You may use an agent with written permission; we may require identity verification.

Complaints. You may contact your local regulator (e.g., Office of the Information & Privacy Commissioner for BC, Office of the Privacy Commissioner of Canada, or your EEA/UK authority).

7) International data transfers

We operate in Canada and the United States, and may process data in other countries. Where required, we use appropriate transfer mechanisms (e.g., SCCs, UK IDTA, intra-group agreements) and apply the protections described in this Policy regardless of where data is processed.

8) Children

The Services are not directed to children under 13. We do not knowingly collect Personal Data from children under 13. Users under 18 must have parental/guardian permission. If you believe a child provided data, contact privacy@accentrust.com.

9) Security

We employ administrative, technical, and organizational measures designed to protect Personal Data, including encryption in transit and at rest, access controls, logging, and vulnerability management. No system is perfectly secure; you should use care when transmitting information online.

10) Communications, marketing & CASL

We comply with CASL for commercial electronic messages. You can unsubscribe from marketing at any time via email footer or by contacting privacy@accentrust.com. We will continue to send transactional or safety communications.

11) Additional U.S. state disclosures

Categories we collect may include identifiers (name, email, IP), commercial information (transactions), internet/network activity (usage logs), geolocation (approximate), professional info (role), and in limited cases payment data (processed by our payment provider).

We use and disclose these categories for the purposes and recipients described above.

Under CCPA/CPRA you may have the rights to know/access, delete, correct, and non-discrimination. We do not sell Personal Data and do not share it for cross-context behavioral advertising. Submit requests at dsar@accentrust.com.

12) Cookies & similar technologies

We use strictly necessary cookies (security, session), functional cookies (preferences), and analytics cookies. Manage preferences in our Cookie Notice (link) or your browser settings. Blocking some cookies may impact features.

13) Changes to this Policy

We may update this Policy from time to time. If changes materially affect you, we will provide at least 30 days' advance notice via email or in-product notice where required. The "Effective" date above reflects the latest version.