Privacy Policy Hayden AI

(A) This Policy

This Policy explains how we Process Personal data. This Policy may be amended or updated from time to time, so please check it regularly for updates.

This Policy is issued by each of the Controller entities listed in Section (O) below (together, “ Hayden AI”, “ we”, “ us” and “ our”) and is addressed to individuals outside our organization with whom we interact, including personnel of current or potential customers, visitors to our Sites, users of our Apps, other users of our services, personnel of vendors, applicants for employment, and visitors to our premises (together, “ you”). Defined terms used in this Policy are explained in Section (P) below.

This Policy is limited to processing activities in respect of which we are a controller. Where we act as a processor on behalf of a third party controller, please review the privacy policy of that controller.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

This Policy was last updated on April 30, 2025

(B) Collection of Personal Data

We collect or obtain Personal Data: when those data are provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you are an employee of a customer or vendor); when you make Personal Data public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Apps; when you visit our Sites; when you register to use any of our Sites, Apps, or services; or when you interact with any third party content or advertising on a Site or in an App.

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

• Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).
• Data collected and processed by our AI-powered camera system: Personal Data may be collected from the onboard camera system managed by us, to the extent that we act as a controller in respect of such collection of Personal Data.
• Data we obtain in person: We obtain Personal Data during meetings, at trade shows, during visits from sales or marketing representatives, or at events we attend.
• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to your employer).
• Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
• Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
• Content and advertising information: If you interact with any third party content or advertising on a Site or in an App (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
• Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

(C) Creation of Personal Data

We create Personal Data about you (e.g., records of your interactions with us). We also create Personal Data about you in certain circumstances, such as records of your interactions with us. We may also combine Personal Data from any of our Sites, Apps, or services, including where those data are collected from different devices or sources.

(D) Categories of Personal Data we Process

We Process: your personal details (e.g., your name); your Contact / ID details (e.g., your address); your professional details (e.g., your CV); records of surveys or testing in which you have participated; demographic data (e.g., your age); visitor logs for our premises; records of your consents; payment details (e.g., your billing address); information about our Sites and Apps (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.

We Process the following categories of Personal Data about you:

• Personal details: given name(s); preferred name; video footage; and photograph.
• Contact / ID details: correspondence address; telephone number; email address; vehicle license plate details; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
• Correspondence: records and copies of your correspondence if you contact us.
• Professional details: your CV; records of your expertise; professional history; practicing details and qualification details; information about your experience; participation in meetings, seminars, advisory boards and conferences; information about your professional relationship with other individuals or institutions; language abilities; and other professional skills.
• Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
• Visitor logs: records of visits to our premises.
• Consent records: records of any consents you have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent).
• Purchase details: records of purchases and prices.
• Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card 'valid from' date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
• Data relating to our Sites and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; location data; platform usage metrics; username; password; security login details; and aggregate statistical information.
• Employer details: where you interact with us in your capacity as an employee of a third party; and the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part); any touchscreen interactions; and information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message.
• Cookie data: we collect information via cookies and similar technologies. Please see our Cookie Policy for more details.
• Security information: your password(s); login attempt details; security settings; and other security-related information.
• Views and opinions: responses to surveys, responses to testing, any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

(E) Sensitive Personal Data

We do not seek to collect or otherwise Process Sensitive Personal Data. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

(F) Purposes of Processing and legal bases for Processing

We Process Personal Data for the following purposes: providing our Sites, Apps, and services to you; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, Apps, and services; fraud prevention; establishment, exercise and defense of legal claims; and recruitment and job applications.

The purposes for which we Process the categories of Personal Data identified in Section (D) above, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

(G) Disclosure of Personal Data to third parties

We disclose Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites or our Apps.

We disclose Personal Data to other entities within the Hayden AI group, for legitimate business purposes and the operation of our Sites, Apps, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to: you and, where appropriate, your appointed representatives;

• accountants, auditors, consultants, lawyers and other outside professional advisors to Hayden AI, subject to binding contractual obligations of confidentiality;

• third party Processors (such as payment services providers; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);

• any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal claims or compliance with applicable law;

• any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

• an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Data is transferred to one or more third parties as one of our business assets; and

• any relevant third party provider, where our Sites or our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

(H) International transfer of Personal Data

We transfer Personal Data to recipients in other countries. Where we transfer Personal Data from the UK or the EEA we rely on various data transfer mechanisms to fulfil our obligations under applicable law, depending on the circumstances.

International Transfers: Our servers and data centers are located in the United States (US). If you choose to access our Sites, our Apps, or our services from outside the US, then you should know that you are transferring your Personal Data outside of your region and into the US for storage and processing. We may also transfer your Personal Data from the US to other countries or regions in connection with the storage and processing of data, fulfilling your requests, and operating our services. You should know that each region can have its own privacy and data security laws, some of which may be less stringent as compared to those of your own region. If you are located in the European Union (EU), the United Kingdom (UK), or Switzerland, then the countries we may transfer your Personal Data to, including the US, may not have data protection laws as comprehensive as those in your own country. To ensure your Personal Data is protected, and that we comply with the applicable data protection laws, we have implemented the following measures:

• EU-US Data Privacy Framework. We comply with the EU-US Data Privacy Framework (“ EU-US DPF”), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (“ Swiss-US DPF”) for the purposes of processing data received from the EU, UK, and Switzerland. Please see the section 'US Data Privacy Framework Notice' in this Privacy Policy for more information.
• Standard Contractual Clauses. We use the Standard Contractual Clauses (SCCs) for transfers of Personal Data to us, and also for transfer of Personal Data to third-party service providers. These clauses require the recipients to protect the Personal Data they receive in accordance with European data protection laws and regulations. Details of our use of SCCs can be provided upon request.
• Derogations. In certain circumstances we may transfer Personal Data based on the derogations contained in Article 49 of the General Data Protection Regulation (GDPR).
• Supplementary Measures. In addition to the SCCs, we may use contractual, technical, and organizational measures to further protect your Personal Data.
• Adequacy Decisions. Where applicable, we may rely on adequacy decisions provided by the European Commission under Article 45 of the GDPR to transfer your Personal Data outside of the EU, the UK, or Switzerland.

US Data Privacy Framework Notice: We comply with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF as set forth by the US Department of Commerce. Hayden AI has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (“ EU-US DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF. Hayden AI has certified to the US Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (“ Swiss-US DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF.

(I) Data security

We implement commercially reasonable security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.

To help protect your Personal Data, we use commercially reasonable steps to protect the data that we collect, including your Personal Data. The reasonable steps include protecting this data against accidental loss, unauthorized use, disclosure, and restricting access to Personal Data by our staff. Our Sites, our Apps, and our services are hosted by a third-party hosting company that we have determined maintains adequate security controls and utilizes TLS encryption for all internet communication with our Sites, our Apps, and our services. We also require all staff that administer and develop our Sites, our Apps, and our services to follow industry-standard controls, including strong passwords, the use of anti-virus and anti-malware software, disk encryption, and other best practices.

You should keep in mind, however, that our Sites, our Apps, and our services utilize software, hardware, and networks, which from time to time require maintenance and experience problems beyond our control. Note that no data transmission over the public internet or encryption method can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information that you provide to us. You transmit information to us at your own risk.

(J) Data accuracy

We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.

(K) Data minimization

We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.

(L) Data retention

We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed in connection with a lawful purpose.

(M) Your legal rights

Subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities.

(N) Direct marketing

We Process Personal Data to contact you with information regarding Sites, Apps, or services that may be of interest to you. You may unsubscribe for free at any time.

(O) Children

Our Sites, Apps, and services are not directed to users under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent.

(P) Details of Controllers

For the purposes of this Policy, the relevant Controllers are:

(Q) U.S. Data Privacy Framework

Hayden AI Technologies, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) (collectively, the “DPF”).

• Disputes Resolution: In compliance with the DPF, Hayden AI Technologies, Inc. commits to resolve complaints about its collection and use of the personal data received in reliance on the DPF.
• Onward Transfers Liability: Hayden AI Technologies, Inc. remains liable under the DPF Principles if third-party agents or service providers to whom we transfer personal data process such data in a manner inconsistent with those Principles.

To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

(R) California Privacy Notice

This section describes how we collect, use, and share the Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”) and the rights these users may have with respect to their Personal Information.

Categories of personal information we collect and disclose: In the preceding 12 months, we have collected the following categories of personal information, as defined by the CCPA, and referencing the categories described in the 'What information do we collect' section of this Privacy Policy.

Purposes for our collection of your information: We may use your personal information for the purposes described in the " How do we use your personal information" section of this Privacy Policy and for the following business purposes specified in the CCPA:

• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, internal business analytics, or providing similar services on behalf of the business or service provider;
• Auditing related to counting ad impressions to unique visitors, verifying the effectiveness and quality of ad impressions, and auditing compliance;
• Helping to ensure the security and integrity of our Websites and Services;
• Debugging to identify and repair errors that impair the functionality of our Websites and Services;
• Providing advertising and marketing services that do not include cross-context behavioral advertising;
• Undertaking internal research for internal product development purposes; and
• Undertaking activities to verify or maintain the quality or safety of our Websites and Services.

We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers, and/or for purposes subject to the right to limit under the CCPA.

Sales and Sharing: Under the CCPA, “sales” and “sharing” are broadly defined, respectively, and include disclosing or making available personal information in exchange for monetary or other valuable consideration, or for purposes of cross-context behavioral advertising. We do not disclose, sell, or otherwise make available personal information in exchange for monetary compensation.