AdaIR ("AdaIR," "we," "us," or "our") provides AI-powered software that supports investor relations and capital markets communication for our enterprise customers. This Privacy Policy explains how we collect, use, disclose, and protect information when you visit www.adair.ai (the "Website"), request a demo, communicate with us, or use the AdaIR platform and related services (collectively, the "Services").

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

1. Scope of This Policy

This Policy applies to:

• Visitors to www.adair.ai and any subdomains we operate.

• Prospective customers who request a demo, sign up for updates, or otherwise communicate with us.

• Authorized users of the AdaIR platform acting on behalf of a customer organization (our "Customers").

Customer Content and Personal Data Processed on Behalf of Customers. When our Customers use the Services, they may submit or upload data—including transcripts, prepared remarks, financial disclosures, investor communications, and other materials—that may contain personal data ("Customer Content"). With respect to Customer Content, AdaIR acts as a processor (or service provider) on behalf of the Customer, who is the controller (or business). Our handling of Customer Content is governed by the agreement between AdaIR and the relevant Customer. If you are an end user of the Services through a Customer, please direct privacy inquiries to that Customer in the first instance.

2. Information We Collect

We collect information in the following ways.

2.1 Information You Provide Directly

• Contact and account information: name, business email address, job title, company name, phone number, and similar information you provide when you request a demo, contact us, subscribe to communications, or create an account.

• Communications: the contents of emails, demo conversations, support requests, and other messages you send us.

• Marketing preferences: your subscription and unsubscribe choices.

2.2 Customer Content Processed Through the Services

When authorized users access the platform, AdaIR processes the materials they submit, which may include earnings call transcripts, scripts and prepared remarks, Q&A preparation materials, investor questions and feedback, public disclosures, and other IR-related content. This material may incidentally contain personal data about employees, investors, analysts, or other individuals.

2.3 Information We Collect Automatically

When you interact with the Website or Services, we and our service providers may automatically collect:

• Device and connection data: IP address, browser type and version, operating system, device identifiers, and language settings.

• Usage data: pages viewed, links clicked, referring/exit pages, timestamps, session duration, and other interaction data.

• Cookies and similar technologies: see Section 7 below.

2.4 Information from Third Parties

We may receive information about you from third parties, such as:

• Business contact databases and enrichment providers.

• Analytics, advertising, and marketing platforms.

• Public sources, including company websites, LinkedIn, and SEC or other regulatory filings.

• Referrals from existing Customers or partners.

3. How We Use Information

We use the information we collect for the following purposes:

• Providing and operating the Services, including authenticating users, enabling platform features, and providing customer support.

• Communicating with you, including responding to inquiries, scheduling demos, and sending administrative messages.

• Marketing and business development, including sending information about AdaIR, events, and product updates (where permitted by law).

• Improving and developing our Services, including analyzing usage patterns, debugging, testing, and developing new features.

• Training and improving AI models, only as expressly permitted by our agreements with Customers, and—where applicable—using de-identified, aggregated, or anonymized data. We do not use a Customer's confidential content to train models that benefit other Customers unless that Customer has expressly authorized it.

• Security, fraud prevention, and integrity of the Services, including detecting and responding to unauthorized access or misuse.

• Legal and compliance purposes, including complying with applicable laws, responding to lawful requests, and enforcing our terms.

4. Legal Bases for Processing (EEA, UK, and Similar Jurisdictions)

Where the EU or UK General Data Protection Regulation ("GDPR") applies, we rely on the following legal bases:

• Performance of a contract — to provide the Services to you or your organization.

• Legitimate interests — to operate, improve, secure, and market our Services in a manner proportionate to your privacy interests.

• Consent — where required, such as for certain marketing communications or cookies. You may withdraw consent at any time.

• Legal obligation — to comply with applicable laws and regulatory requirements.

5. How We Share Information

We do not sell personal information. We share information only as described below.

• Service providers and subprocessors. We engage third parties to provide hosting, cloud infrastructure, analytics, customer support, communications, payment processing, and AI model infrastructure. These providers are bound by contractual obligations to protect the information and use it only for the purposes we specify. A current list of subprocessors used to deliver the platform is available to Customers upon request.

• Customers and authorized users. Customer Content is accessible to the Customer organization that submitted it and to its authorized users in accordance with the Customer's internal permissions.

• Corporate transactions. In connection with a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred to the relevant counterparty, subject to confidentiality protections.

• Legal and safety reasons. We may disclose information when we believe in good faith that disclosure is necessary to comply with a legal obligation, respond to lawful requests, protect the rights, property, or safety of AdaIR, our Customers, or others, or enforce our agreements.

• With your consent or direction.

Material Non-Public Information

The AdaIR platform may be used in connection with material non-public information ("MNPI") and other sensitive financial content. We design our Services, contractual commitments, and internal controls to support our Customers' compliance with applicable securities laws, including Regulation FD. We do not use, disclose, or trade on Customer Content for any purpose other than delivering and improving the Services as authorized.

6. AI Processing

The Services use machine learning and large language model technologies to summarize, analyze, draft, and generate content. We have implemented the following safeguards:

• Customer-isolated processing. Customer Content is processed within environments and configurations established for that Customer. We use logical access controls to prevent one Customer's content from being exposed to another.

• No training on Customer Content by default. We do not use Customer Content to train foundation models or to improve generally available models that serve other Customers without the Customer's express authorization.

• Subprocessor safeguards. Where we use third-party model providers, we contract for enterprise-grade terms that prohibit those providers from using Customer Content to train their general-purpose models.

• Human oversight. AI-generated outputs are intended to support, not replace, human review. Customers remain responsible for verifying the accuracy and appropriateness of any output before use in regulated communications.

7. Cookies and Tracking Technologies

We and our service providers use cookies, pixels, and similar technologies on the Website to operate the site, remember preferences, measure performance, and—where permitted—deliver marketing.

You can control cookies through your browser settings and, where available, through the cookie banner or preferences center on our Website. Blocking certain cookies may affect Website functionality. We honor Global Privacy Control (GPC) signals where required by law.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. Retention of Customer Content is governed by our agreements with the relevant Customer. When information is no longer needed, we delete, anonymize, or aggregate it.

9. Security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, disclosure, alteration, and destruction. These include encryption in transit and at rest, access controls based on least privilege, monitoring and logging, secure software development practices, and regular security reviews. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. International Data Transfers

AdaIR is based in the United States. If you access the Services from outside the United States, your information may be transferred to, processed, and stored in the United States or other jurisdictions where we or our service providers operate. We rely on appropriate transfer mechanisms—such as the Standard Contractual Clauses—where required by law.

11. Your Rights and Choices

Depending on your location, you may have the following rights with respect to your personal information:

• Access the personal information we hold about you.

• Correct inaccurate or incomplete information.

• Delete personal information, subject to certain exceptions.

• Object to or restrict certain processing.

• Data portability, where applicable.

• Withdraw consent for processing based on consent.

• Opt out of marketing communications by using the unsubscribe link in any marketing email or by contacting us.

• Lodge a complaint with your local data protection authority.

To exercise these rights, contact us using the details in Section 14. We will verify your request and respond within the timeframes required by applicable law. If your request concerns Customer Content, we may direct you to the relevant Customer.

Notice for California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act, as amended ("CCPA"), including the right to know, delete, correct, and limit the use of sensitive personal information, and the right to non-discrimination. We do not "sell" personal information or "share" it for cross-context behavioral advertising as those terms are defined under the CCPA.

12. Children's Privacy

The Services are intended for business users and are not directed to children. We do not knowingly collect personal information from individuals under 16. If you believe a child has provided us with personal information, please contact us so we can take appropriate action.

13. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by posting the updated Policy on the Website and updating the "Last Updated" date above. For significant changes, we may provide additional notice (such as by email).

14. Contact Us

If you have questions, comments, or requests regarding this Policy or our privacy practices, please contact us at privacy@adair.ai. 

If you are an authorized user of the Services through a Customer organization, you may also direct inquiries to that organization's privacy contact.

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit our Privacy Request page.