We at Venture Autopilot and our affiliates are committed to protecting your privacy. This Privacy Policy applies to the personal information and data collected by Venture Autopilot when you interact with our websites, product and services, and any other sites or services that link to this Privacy Policy. This includes when you:

• interact with us on our websites or through other channels (for example, by communicating with us or attending one of our events);
• use our product and services (including the Venture Autopilot Subscription Service); and
• when you use any other websites or services that link to this Privacy Policy

This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. This Privacy Policy also describes your choices and rights with respect to your Personal Data, including your rights of access and correction of your Personal Data. For the purposes of this Privacy Policy, "Personal Data" means any information relating to an identified or identifiable individual. If you do not agree with this Privacy Policy, you should not use our websites, product and services, or any other sites or services that link to this Privacy Policy.

Venture Autopilot customers may collect and manage Personal Data when using our product and services, or what we may refer to as the Subscription Service. "Subscription Service" is defined in the Venture Autopilot Customer Terms of Service and means all of our web-based applications, tools and platforms that you have subscribed to under an Order Form or that we otherwise make available to you, and are developed, operated, and maintained by us, accessible via https://ventureautopilot.com or another designated URL, and any ancillary products and services, including website hosting, that we provide to you. When you use the Subscription Service, Venture Autopilot processes Personal Data as a processor under the direction of our customers. Our customers, as data controllers, are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to collecting their customers’ Personal Data using the Subscription Service. Please see Section 1.b "Information We Process on Behalf of our Customers When They Use the Subscription Service" and Section 1.c "Information We Collect and Process When You Use the Subscription Service".

We update this Privacy Policy from time to time and we encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email notification, or if you subscribe to our Venture Autopilot product and services, through the Notification app in your Venture Autopilot account. Terms not otherwise defined in this Privacy Policy will have the meaning as set forth in the Venture Autopilot Customer Terms of Service.

If you have any questions about this Privacy Policy or to exercise the privacy rights and choices we offer please contact us at creighton@ventureautopilot.com.

The Venture Autopilot product is managed by The Creighton Group, Inc, a Delaware C-Corp.

1. What Information We Collect and Process

a. Information You Provide to Venture Autopilot

When you interact with us via our websites or any sites or services that link to this Privacy Policy or use the Subscription Service, we may collect Personal Data and other information from you, as further described below.

When You Visit Our Websites

We collect Personal Data from you when you submit web forms or interact with our websites, for example by subscribing to a Venture Autopilot blog, signing up for a webinar, subscribing to one of our services or requesting customer support. We may ask for your email address, first and last name, job title, and other similar business information. You are free to explore some of our websites without providing any Personal Data about yourself.

Event Information

When you register for a Venture Autopilot event, we collect information such as name, address, phone number, and email address. We use this information to communicate with you and in some cases facilitate your registration. Additionally, we may share your registration data with service providers of events in order to provide event information and improve your experience for future Venture Autopilot events.

Account and User Information

We collect Personal Data when you sign-up for a Venture Autopilot account, create or modify user information, set preferences, or provide any other related information to access or utilize our Subscription Service.

Payment Information

We collect payment and billing information when you register for paid products or services. For example, we may ask you to provide a billing address, or a billing contact for your Venture Autopilot account. If you give us payment information, we use it solely as authorized by you in accordance with this Privacy Policy.

You may also provide payment information, such as a credit card number or bank account numbers, when purchasing products or services. We use secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.

Customer Testimonials

We post customer testimonials and comments on our websites, which may contain Personal Data. We obtain each customer's consent via email or through other agreements between customers and Venture Autopilot prior to posting the customer's name and testimonial.

b. Information We Process on Behalf of Customers When They Use the Subscription Service

Our product, or the Subscription Service, allows our customers to create and share marketing, sales and customer service content. When customers use our product, they may collect Personal Data such as first and last name, email address, physical address, phone number, or other information about you. We call the information that our customers submit or collect via the product ‘Customer Data’ under our Customer Terms of Service.

We do not control the content of our customers' webpages or the types of Personal Data that our customers may choose to collect or manage using the Subscription Service. We store our customers' information on our service providers' servers but process it as a processor under our customers’ instructions and in accordance with our Customer Terms of Service, which prohibit us from using the information except as necessary to provide and improve the Subscription Service and as required by law.

Our customers control and are responsible for correcting, deleting or updating the information they process using the Subscription Service and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to Venture Autopilot for processing purposes.

c. Information We Collect and Process When You Use the Subscription Service

Usage Data

We collect usage data when you or your users in your Venture Autopilot account interact with the Subscription Service. Usage data includes metrics and information regarding your use and interaction with the Subscription Service such as what product features you use the most, when an object (like a ticket) is opened and closed, and how often certain features (like workflows) are triggered in your account.

We engage third party providers to collect usage data. For more information about how we protect your information with these service providers, please see Section 3 "How We Share Personal Data."

Mobile

When you access or use the Subscription Service via our mobile applications, we automatically collect information such as your device model and version, operating system, or device identifiers.

Third Party Integrations

You may connect third party integrations to your Venture Autopilot account, which may ask for certain permissions to access data or send information to your Venture Autopilot account. It is your responsibility to review any third party integrations you authorize. We may collect information about what types of integrations you use in your Venture Autopilot account.

Any permission(s) granted by you, grants these third parties access to your data, which may include (but is not limited to) granting third party applications access to view, store, and modify your Venture Autopilot account data. We are not responsible for the practices of third party integrations, so please carefully review the permissions you grant to third party applications.

Gmail Integration

If you use the Gmail integration or choose to integrate any other Google Workspace application with Venture Autopilot, you will be asked to give us access to information from your Gmail or Google account. You can learn more via the in-app notice when you connect to Gmail. As a reminder, knowledge base articles are for your information only, they are not incorporated into these terms.

By using the Gmail integration with the Subscription Service you will grant the Subscription Service access to information associated with your account, including contacts, emails, calendar, distribution lists, subject lines, and URLs of tracked links from your email, if you use the email tracking functionality. In addition, the Subscription Service will be able to read, modify, create, and send emails from your connected Gmail account. The Subscription Service will scan the content of your emails to identify which emails you have elected to track in order to provide you with the notifications feature. The Subscription Service will store replies, outgoing mail, email headers, subject line, distribution lists, aliases, time sent, and email bodies. Your email may contain sensitive information, such as names of your contacts, your private communications, or financial or medical information. You understand that the correspondences you track will be visible to other users on your Subscription team.

If you connect your Gmail account via IMAP (or Generic Inbox Connection), the Subscription Service will have access only to email address, password, server information, email metadata, and message bodies. Additionally, connecting your Gmail account via IMAP does not require you to connect any other Google Workspace applications.

Additional Limits on Use of Your Google User Data

Venture Autopilot's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Google Calendar Integration

The Subscription Service will have access to both your Google Calendar and any other calendar you access via Google in order to power our Meetings tool, and allow you to associate events with contacts in your Venture Autopilot account. The Subscription Service will have the ability to: create or change your calendars, and update individual calendar events.

Google Drive Integration

As part of connecting your Google Drive, the Subscription Service will be able to: see your files, upload and download your files, and store file contents and titles. The Subscription Service uses these permissions to power the features of our Composer and Collect tools, allowing you to create drafts of blog posts in Drive and then upload directly for publishing.

YouTube Integration

If you are a Venture Autopilot Customer and choose to use the YouTube integration with your Venture Autopilot Subscription Services, you will be asked to give us access to information from your YouTube account and have the option to link your accounts.

By using the YouTube integration with the Subscription Service you grant the Venture Autopilot Subscription Service access to information associated with your YouTube account. The Subscription Service will scan the content of your YouTube to identify content you have elected to track in order to provide you with features in the Subscription Services. The Subscription Service will store information from your YouTube account. You understand that the information from your YouTube Account you track in the Subscription Services may be visible to other Users within your Venture Autopilot Account.

Your use of Venture Autopilot’s YouTube integration is subject to the YouTube Terms of Service available at https://www.youtube.com/t/terms and the Google Privacy Policy available at http://www.google.com/policies/privacy.

In addition to the typical data deletion functionality supported in the Subscription Services, Customers may have the option to revoke the YouTube integration from your Venture Autopilot account, in the Google security settings page at https://security.google.com/settings/security/permissions.

AI/ML Model Usage and Google Workspace Data

• Google Analytics and YouTube Data: We may use data from Google Analytics and YouTube to train specific AI/ML models for improving personalized experiences on our platform. This data will be used solely for this purpose.
• Google Workspace Data: Venture Autopilot does not use Google Workspace API data for training generalized AI or machine learning models. Google Workspace data is primarily used for generating specific outputs and tasks, rather than reading or training models. If we were to use Google Workspace data for AI/ML model training, it would be for specific, personalized models that serve individual users, and not for generalized AI purposes.
• Third-Party AI Tools: We do not transfer any Google user data, including Google Workspace data, to third-party AI tools for training generalized or non-personalized AI/ML models.

We are in full compliance with the Workspace API user data policy and the Google Workspace API Policy Protections for Generative AI. If any changes are made to our data usage practices, we will update our privacy policy accordingly.

d. Information We Collect From Other Sources

Venture Autopilot Partners

We may receive information about you or other users of your Venture Autopilot account from our global network of partners. We may receive this data from our deal and lead registration process through our partners.

We may also collect information about you through our partner co-marketing partnerships. For example, you may sign up to a webinar or download a white paper published by Venture Autopilot and a Venture Autopilot co-marketing partner. For more information about how we share data with our partners, review the "Partners" subsection of the "How We Share Personal Data" provision of this privacy policy.

Third Parties

We may receive information from third party service providers, from related companies, and from our business and solution partners.

Personal Data from Different Sources

We may combine the personal information we collect from you with personal information we receive from other sources, such as third party providers of business information and publicly available sources (like social media platforms). This may include physical mail addresses, job titles, email addresses, phone numbers, IP addresses, and social media profiles. This helps us to update and improve our records, identify new customers, create more personalized advertising, suggest products and services that may interest you, deliver personalized communications and promote events. The collection of your Personal Data by these other third party providers is governed by the provider’s privacy policy.

Log Files

Like most websites and technology services delivered over the Internet, we automatically collect and store information about your computer hardware and software when you visit our websites, use our product and services, or visit other sites or services that link to this Privacy Policy. This information can include your IP address, browser type, domain names, internet service provider (ISP), and the files viewed on our websites (e.g., HTML pages, graphics, etc.), the files viewed on our, or our customer’s websites (if those websites are hosted on Venture Autopilot e.g. HTML pages or, graphics etc), your operating system, access times and referring website addresses.

When you use the Subscription Service, we collect and store the categories of information listed above in logs in the following instances, subject to the customer’s implementation settings:

• When a Venture Autopilot user logs into their account and accesses tools in the Venture Autopilot Platform;
• When an individual visits a customer’s website, if the website is hosted by the Venture Autopilot product; or
• When an individual visits a customer’s website, if the customer’s website is self-hosted, if the customer uses our plug-ins, and the customer uses Venture Autopilot scripts and content (such as embedded forms).

Buttons, tools, and content from other companies

Our websites may include features and widgets (such as the share and/or "like" button or interactive mini-programs) that run on our websites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. These features and widgets are either hosted by a third party or hosted directly on our websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

We have implemented Google reCAPTCHA Enterprise on certain products and services to prevent malicious software from engaging in abusive activities on our websites. You can learn more about data collected by Google and what this data is used for in Google's Privacy Policy. Additional information on Google services and products is available in Google's Terms of Service.

Other Venture Autopilot Companies

We may receive information about you from other companies that are owned or operated by Venture Autopilot.

2. How We Use Personal Data

a. To Communicate with You About the Product and Services

We use the account information you provide to Venture Autopilot when signing up for the Subscription Service and Trends services to send you transactional emails or in-app notification about billing, account management, and other administrative matters. We may also send you updates regarding our Customer Terms of Service or other legal agreements, and may also communicate with you about security incidents via email or in-app notification.

We use your information to provide customer support, such as resolving technical issues you encounter and analyzing product outages or bugs.

If you use the Venture Autopilot mobile applications, we may send you push notifications from time to time in order to update you about events and promotions. If you no longer wish to receive such communications, you may turn them off at the device level.

b. To Provide the Subscription Service

We use your account information and Customer Data to provide the product and services to you. For example, we use the email address you provide when signing up for the product to create your user account, and we use your payment information to process payments for paid use of the Subscription Service. We also use this information to authenticate you when you log in and to provide customer support.

c. To Improve and Develop Our Product and Services

We collect usage data about how you or your users interact with our product and services. We use this data to develop and improve our products and services. For example, we use usage data to assess trends and usage across the product to help us determine what new features or integrations our users may be interested in.

We use Customer Data for machine learning that supports certain products and development of features and functionality with the Subscription Service and similar products and services. For example, machine learning helps power the business card scanner tool if you use our mobile apps and allows for easier imports of data into your Venture Autopilot account. You may opt-out of having your Customer Data used for machine learning by emailing creighton@ventureautopilot.com.

We may publish data about how our product and services are being used across our customer base. When we share statistical information externally in this way, the data will be aggregated and we will not identify individual users or customers. For example, we may publish blog posts on trends or insights into how users are interacting with our product.

d. To Secure and Protect our Product and Venture Autopilot Users

We use your account information to investigate and help prevent security incidents. We may also use this information to meet legal requirements. We use your information to verify user accounts, new product sign-ups, and to detect and prevent product abuse.

We use log files to provide general statistics regarding use of the websites by you, including how you use our websites, what country you are logging in from (for analytics, export control and regulatory purposes) and to help improve the navigation experience. Your IP addresses are also collected and logged for security and debugging purposes, for example to track access patterns, investigate security events and incidents. For these purposes we do link this automatically-collected data to other personal data provided by you such as name, email address, address, and phone number.

e. To Market and Promote the Subscription Service

We use the information you provide to Venture Autopilot to market and promote the products, services, and other offerings. For example, we use the information, like your email or physical address, to send information or Venture Autopilot content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business.

You may opt out of receiving this promotional content by following the instructions contained in each communication that we send to you or by contacting us at creighton@ventureautopilot.com. If you unsubscribe from our marketing lists, we will continue to contact you regarding administrative matters, and to respond to your requests.

We may also reach out to you via telephone to ask about other Venture Autopilot products or services you may be interested in. If you have a call scheduled with a Venture Autopilot representative, we may record and transcribe the call. You will be notified prior to the call that the call is being recorded, and you will be offered an opportunity to opt-out of having the call recorded.

Where required by law, we will only send marketing communications with your consent. Otherwise, we will market and advertise our products and services on the basis of our legitimate business interests.

We receive information from third party service providers and other sources such as third party providers of business information and publicly available sources. We may receive and use this information from these service providers and other sources in combination with other information we collect through other means described in this Privacy Policy for the purposes of providing you with updates and an improved Subscription Service, like personalized communications, event promotion, and tailoring the websites or product to improve user experience.

f. Other Purposes if We Obtain Your Consent

We share your data with third parties when you give us consent to do so.

g. Legal Basis for Processing Personal Data (EEA and UK visitors only)

Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

3. How We Share Personal Data

a. Service Providers

We may share Personal Data with our third party service providers to support our websites, products, and services. For example, we use service providers for data hosting, application development, marketing, sales support and customer support. We may need to share your information with service providers to provide information about products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis on your use of the Subscription Service or interactions on our websites, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information in this way, we explicitly require the third party service providers to acknowledge and adhere to our privacy and data protection policies and standards.

b. Partners

We may share data with trusted Venture Autopilot partners to contact you based on your request to receive such communications, help us perform statistical analysis, provide sales support, or provide customer support. Partners are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your data.

We also partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you. When you engage with these co-marketing partners, we will tell you who we are sharing data with, and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications. These co-marketing partners are required to adhere to our privacy and data protection policies.

c. Corporate Events

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Venture Autopilot on the websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.

d. Public Forums

Our websites may offer publicly accessible message boards, blogs, and community forums (e.g. Venture Autopilot Community). Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums (including profile information associated with the account you use to post the information) it may be read, collected and used by any member of the public who accesses these websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you may disclose in this way. We will correct or delete any information you have posted on the websites if you so request, as described in Section 7 "Your Privacy Rights and Choices" below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.

e. Compelled Disclosure

We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process. If you use the Subscription Service, Customer Data is considered Confidential Information and you should review the Confidentiality terms in the Customer Terms of Service for more information.

4. How We Transfer Personal Data Internationally

a. International Transfers within the Venture Autopilot Group

To facilitate our global operations, we may transfer information to other Venture Autopilot Affiliates where we have operations for the purposes described in this policy.

This Privacy Policy will apply even if we transfer Personal Data to other countries. We have taken appropriate safeguards to require that your Personal Data will remain protected wherever it is transferred. When we share Personal Data of individuals in the European Economic Area ("EEA"), Switzerland or the United Kingdom ("UK") within and among Venture Autopilot’s Affiliates, we rely upon the Standard Contractual Clauses (approved by the European Commission and Swiss authorities) and UK Addendum to the Standard Contractual Clauses (approved by the UK authorities) where required, as well as additional safeguards where appropriate (such as commercial industry standard secure encryption methods to protect customer data at rest and in transit, TLS for Venture Autopilot hosted sites, web application firewall protection, and other appropriate contractual and organizational measures).

b. International Transfers to Third Parties

Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share Personal Data of individuals in the EEA, Switzerland or UK with third parties, we use a variety of legal mechanisms to safeguard the transfer including the European Commission-approved Data Privacy Framework Standard Contractual Clauses, as well as additional safeguards where appropriate. For transfers to or from the United Kingdom, we make use of the UK Addendum. For transfers to or from Canada, we make use of the standard contractual clauses. With respect to personal data received from or transferred to Canada, Venture Autopilot is subject to the regulatory enforcement powers of the Office of the Privacy Commissioner of Canada. Please contact us if you need more information about the legal mechanisms we rely on to transfer personal data outside the EEA, Switzerland, Canada, and UK.

5. How We Store and Secure Personal Data

a. Data Storage and Security

We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures.

b. Retention of Personal Data

How long we keep information we collect about you depends on the type of information and how we collect and store it. After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the section "Privacy Rights and Choices" below.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Venture Autopilot account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

The data our customers process in connection with the Subscription Service is retained according to the Venture Autopilot Customer Terms of Service.

6. Cookies and Similar Technologies

a. Cookies

When you visit our websites, sign up for a Venture Autopilot account, attend a Venture Autopilot virtual event, or request more information about Venture Autopilot, we collect information automatically using tracking technologies, like cookies and tracking pixels. Venture Autopilot and our partners use cookies or similar technologies (such as web beacons and JavaScript) to analyze trends, administer the website, monitor how visitors navigate around the websites, and to gather demographic information about our user base as a whole.

b. Advertising

We partner with third party ad networks to display advertising on our website or to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by using these services: https://optout.networkadvertising.org/ or https://optout.aboutads.info/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising you will continue to receive generic ads.

7. Your Privacy Rights and Choices

a. Personal Data Requests

You have the following data protection rights:

• Access, Correction or Deletion. You can request access, correction, updates or deletion of your Personal Data.
• Objection. You can object to our processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data.
• Withdraw Consent. If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
• Complaint. You have the right to complain to a data protection authority about our collection and use of your Personal Data. Contact details for data protection authorities in the EEA are available here.

We do not sell personal information.

To exercise any of these rights:

• for Venture Autopilot, including our websites and product or services, please email creighton@ventureautopilot.com;
• for all Venture Autopilot brands write to us by mail at The Creighton Group, Inc., 4041 S. Harvard Blvd Los Angeles, CA USA, Attn: Privacy and Data Protection Officer.

Please note that to protect personal information, we may verify your identity by a method appropriate to the type of request you are making. Depending on where you reside, you may be entitled to empower an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of the action we have taken. In some instances, your rights may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

If you are a customer, prospect, or otherwise interact with a Venture Autopilot customer that uses our Subscription Service and would like to access, correct, amend or delete your data controlled by the customer, please contact the relevant customer directly. Venture Autopilot acts as a processor for our customers and will work with our customers to fulfill these requests when applicable.

b. Anti-Spam Policy

We prohibit use of the Subscription Service to send unsolicited commercial email in violation of applicable laws, and require the inclusion in every email sent using the Subscription Service of an "opt-out" mechanism and other required information. We require all of our customers to agree to adhere to the Acceptable Use Policy at all times, and any violations of the Acceptable Use Policy by a customer can result in immediate suspension or termination of the Subscription Service.

c. To Unsubscribe From Our Communications

You may unsubscribe from our marketing communications through one of the following methods:

• by clicking on the "unsubscribe" link located on the bottom of our emails;
• updating your communication preferences;
• for all Venture Autopilot brands write to us by mail at The Creighton Group, Inc., 4041 S. Harvard Blvd Los Angeles, CA USA, Attn: Privacy and Data Protection Officer.

Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service.

d. To Unsubscribe From Our Customers' Communications

Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. Individuals who interact with a Venture Autopilot customer can unsubscribe from our customers' marketing communications by clicking on the "unsubscribe" link located on the bottom of their emails, or by contacting them directly.

8. California Privacy Rights

a. Applicability

This section applies only to California consumers. For purposes of this section "Personal Information" has the meaning given in the California Consumer Privacy Act (“CCPA”). It describes how we collect, use, and share California consumers' Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act ("CCPA") requires businesses to disclose whether they sell Personal Information. Venture Autopilot is a business, and does not sell Personal Information. We may share Personal Information with authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Information.

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.

b. How We Collect, Use, and Share your Personal Information

We have collected the following statutory categories of Personal Information in the past twelve (12) months:

• Identifiers, such as name, email address, mailing address, and phone number. We collect this information directly from you or from third party sources.
• Commercial information, such as subscription records. We collect this information directly from you.
• Internet or network information, such as browsing and search history. We collect this information directly from your device.
• Geolocation data, such as IP address. We collect this information from your device.
• Financial information, such as Payment Information or financial account numbers in the process of providing you with a subscription. We collect this information from you.
• Inferences.
• Other Personal Information, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the Subscription Service.

The business and commercial purposes for which we collect this information are described in Section 2 of this Privacy Policy. The categories of third parties to whom we "disclose" this information for a business purpose are described in Section 3 of this Privacy Policy. The period of time for which we retain this information is described in Section 5 of this Privacy Policy.

c. Your California Rights

You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.

• The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months.
• The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
• The right of correction means that you have the right to request that we correct any inaccurate personal information that we maintain about you.
• The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
• Venture Autopilot does not sell or share Personal Information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018).

d. How to Exercise your California Rights

You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your Personal Information.

Please use the contact details below, or see Section 7 "Your Privacy Rights and Choices" above, if you would like to:

• Access this policy in an alternative format;
• Exercise your rights;
• Learn more about your rights or our privacy practices; or
• Designate an authorized agent to make a request on your behalf.

9. Data Protection Officer

If you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format you may also contact us by email or by postal mail for all Venture Autopilot brands at:

Creighton Taylor

creighton@ventureautopilot.com

The Creighton Group, Inc.

4041 S. Harvard Blvd

Los Angeles, CA USA

10. Other Important Privacy Information

a. We Never Sell Personal Data

We will never sell your Personal Data to any third party.

b. Information About Children

The websites, products, and services are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect Personal Data about children under 16. If you believe that we have collected Personal Data about a child under 16, please contact us by emailing creighton@ventureautopilot.com, so that we may delete the information.

c. Third Party Dispute Resolution

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at creighton@ventureautopilot.com.

d. Third Party Artificial Intelligence (AI) Models

Third-Party Models Utilized

Venture Autopilot utilizes the OpenAI API, Mistral API, Claude API, and the Gemini API as needed. The specific model chosen depends on factors such as cost, speed, and accuracy relevant to the business use case.

Data Shared With Third-Party Models

The data shared with these third-party AI models pertains to the growth marketing of the business. Inputs may include product descriptions, pricing, customer personas, brand guides, customer feedback, product analytics data, and campaign performance data.

Purpose of Data Sharing

The purpose of sharing this data is to enable the AI models to generate useful growth marketing insights and suggest refinements to ongoing strategies and tactics. Examples of generated insights include market analyses, email templates, and pitch decks. Examples of suggested refinements include A/B test setups, improved messaging, and user experience enhancements.

Responsible and Ethical Use of Models

Venture Autopilot is committed to the responsible and ethical use of data with third-party AI models. We prioritize transparency by clearly explaining how data is used and how the AI models operate. Businesses must provide explicit consent for their data to be used with these models, ensuring they are fully informed. We are dedicated to mitigating potential biases in the AI models to ensure fair and equitable outcomes for all users. To uphold data minimization principles, we share only the minimum amount of data necessary for the models to function effectively. Regular audits are conducted to ensure compliance with ethical standards and relevant regulations. Furthermore, we respect user rights, allowing businesses to access, correct, or delete their data at any time. Through these measures, we demonstrate our commitment to ethical AI practices and the protection of user data.

User Consent

Data is only fed into models upon the explicit consent of the user.

For example, for generating market analysis, you would explicitly approve this task. Similarly, for ongoing use of the models, your explicit consent to do so will be requested.

Opting Out of Models

Businesses have the option to opt out of data sharing with third-party AI models at any time. To do so, please contact us at creighton@ventureautopilot.com.