Privacy Policy

Effective Date: October 28, 2025

Last Updated: October 28, 2025

1. Introduction

Ciphero AI Technologies, Inc. ("Ciphero," "we," "us," or "our") is committed to protecting the privacy and security of your information. This Privacy Policy describes how we collect, use, disclose, and protect information when you use our software, platform, and related services (collectively, the "Services").

This Privacy Policy applies to information we collect through our Services, our website, and any other interactions you have with us. By using our Services, you consent to the data practices described in this Privacy Policy.

2. Information We Collect

2.1 Information You Provide Directly

Account Information:

When you create an account, we collect:

  • Business name and contact information
  • Name, email address, and phone number of authorized users
  • Job title and department
  • Billing address and payment information
  • Company size and industry

Customer Data:

Information you upload or input into our Services for analysis, including:

  • Security logs and event data
  • Network traffic information
  • System configurations
  • Threat intelligence data
  • Any other data you choose to analyze using our Services

Communications:

When you contact us, we collect:

  • Inquiry details and support requests
  • Feedback and survey responses
  • Communication preferences

2.2 Information Collected Automatically

Usage Data:

We automatically collect information about how you use our Services:

  • Features accessed and actions taken
  • Frequency and duration of use
  • Performance metrics and error reports
  • Search queries within the platform

Technical Information:

When you access our Services, we collect:

  • IP address and approximate location
  • Browser type and version
  • Operating system
  • Device identifiers
  • Access times and referring URLs
  • Cookie and similar tracking technologies data

2.3 Information from Third Parties

We may receive information about you from:

  • Third-party security intelligence feeds (with your consent)
  • Business partners and resellers
  • Public sources and databases
  • Service providers that help us verify identity and prevent fraud

3. HOW WE USE YOUR INFORMATION

3.1 Service Delivery

We use your information to:

  • Provide, maintain, and improve our Services
  • Process and analyze your security data
  • Generate reports and insights
  • Respond to your requests and provide customer support
  • Send service-related notifications and alerts

3.2 Business Operations

We use your information for:

  • Billing, accounting, and payment processing
  • Verifying identity and preventing fraud
  • Monitoring and ensuring platform security
  • Conducting research and development
  • Improving our algorithms and AI models

3.3 Legal and Compliance

We use your information to:

  • Comply with legal obligations
  • Enforce our Terms of Service
  • Protect our rights and property
  • Respond to legal requests and prevent harm

3.4 Marketing and Communications

With your consent, we may use your information to:

  • Send promotional materials and newsletters
  • Inform you about new features and services
  • Conduct customer satisfaction surveys

4. HOW WE SHARE YOUR INFORMATION

4.1 Service Providers

We share information with third-party service providers that help us operate our business, including:

  • Cloud hosting and infrastructure providers
  • Payment processors
  • Analytics providers
  • Customer support tools
  • Security and compliance auditors

4.2 Business Transfers

If we are involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction.

4.3 Legal Requirements

We may disclose information when required to:

  • Comply with applicable laws and regulations
  • Respond to lawful requests from public authorities
  • Protect our rights, privacy, safety, or property
  • Prevent or investigate suspected fraud or security issues

4.4 Consent

We may share your information with your explicit consent or at your direction.

4.5 Aggregated Information

We may share aggregated, anonymized information that cannot identify you for research, marketing, or other purposes.

5. DATA RETENTION

5.1 Retention Period

We retain your information for as long as necessary to:

  • Provide the Services you have requested
  • Comply with legal and regulatory requirements
  • Resolve disputes and enforce agreements
  • Maintain business records for analysis and auditing

5.2 Deletion

When retention is no longer necessary, we will securely delete or anonymize your information in accordance with our data retention policies and applicable law.

6. DATA SECURITY

6.1 Security Measures

We implement comprehensive security measures including:

  • Encryption of data in transit and at rest
  • Multi-factor authentication
  • Regular security assessments and penetration testing
  • Employee training on data protection
  • Incident response procedures

6.2 Compliance Standards

We maintain compliance with:

  • SOC 2 Type II
  • ISO 27001

6.3 Security Incidents

In the event of a data breach affecting your personal information, we will notify you in accordance with applicable law and our incident response procedures.

7. YOUR RIGHTS AND CHOICES

7.1 Access and Portability

You have the right to request access to your personal information and receive a copy in a portable format.

7.2 Correction

You may request correction of inaccurate or incomplete personal information we hold about you.

7.3 Deletion

You may request deletion of your personal information, subject to legal and contractual obligations.

7.4 Opt-Out

You can opt-out of:

  • Marketing communications (via unsubscribe link or contacting us)
  • Certain cookies and tracking technologies
  • Sharing of information with third parties for their marketing purposes

7.5 Do Not Track

We do not currently respond to Do Not Track browser signals.

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 Types of Cookies We Use

  • Essential Cookies: Required for Service functionality
  • Performance Cookies: Help us understand Service usage
  • Analytics Cookies: Provide insights into user behavior
  • Marketing Cookies: Used with your consent for promotional purposes

8.2 Managing Cookies

You can control cookies through your browser settings. Note that disabling certain cookies may affect Service functionality.

8.3 Third-Party Analytics

We use analytics services like Google Analytics to improve our Services. These providers have their own privacy policies.

9. INTERNATIONAL DATA TRANSFERS

9.1 Cross-Border Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place for such transfers.

9.2 Privacy Shield and Standard Contractual Clauses

Where applicable, we rely on appropriate legal mechanisms such as Standard Contractual Clauses for international data transfers.

10. CALIFORNIA PRIVACY RIGHTS

10.1 California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:

  • Right to know what personal information we collect
  • Right to delete personal information
  • Right to opt-out of sale of personal information (we do not sell personal information)
  • Right to non-discrimination

10.2 Shine the Light

California residents may request information about disclosure of personal information to third parties for direct marketing purposes.

11. EUROPEAN DATA PROTECTION RIGHTS

11.1 GDPR Rights

If you are in the European Economic Area, you have rights under the General Data Protection Regulation (GDPR), including:

  • Right to access, correct, or delete your data
  • Right to restrict or object to processing
  • Right to data portability
  • Right to withdraw consent
  • Right to lodge a complaint with supervisory authorities

11.2 Legal Basis

We process personal data based on:

  • Contract performance
  • Legal obligations
  • Legitimate interests
  • Your consent

12. CHILDREN'S PRIVACY

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we learn we have collected information from a child under 18, we will delete that information promptly.

13. THIRD-PARTY LINKS

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of material changes by:

  • Posting the updated Policy on our website
  • Sending notice to your registered email address
  • Displaying a prominent notice within the Services

Your continued use of the Services after changes constitutes acceptance of the updated Privacy Policy.

15. DATA PROTECTION OFFICER

For privacy-related inquiries or to exercise your rights, please contact our Data Protection Officer at:

Data Protection Officer

Ciphero AI Technologies, Inc.

99 Wall Street #1148

New York, NY 10005

Email: contact@cipheroai.org

16. CONTACT INFORMATION

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Ciphero AI Technologies, Inc.

99 Wall Street #1148

New York, NY 10005

Email: contact@cipheroai.org

17. COMPLAINT RESOLUTION

If you have concerns about our privacy practices that we have not adequately resolved, you may:

  • Contact your local data protection authority
  • File a complaint with the relevant supervisory authority
  • Seek other remedies available under applicable law

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to our collection, use, and disclosure of your information as described herein.