PRIVACY POLICY

This privacy policy describes how Modella AI, Inc (“we”, “our” or “us”) collects, uses, discloses, and otherwise processes your personal information when you use our website, applications, and/or services (collectively, “Services”). This policy is effective as of 1/31/2024.

Personal Information We Collect

We collect personal information relating to you as follows:

Personal Information You Provide:

• Contact and account information such as your first and last name, email address, password, and phone number.
• Content and metadata of any messages that you send using the Services.
• Communications that we exchange with you, including when you apply for employment with us, respond to our surveys or contact us with questions, feedback or otherwise.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Personal Information We Receive Automatically From Your Use of the Services:

• Log data such as information that your browser or device automatically sends when you use our Services.
• Device data such as your device’s operating system, manufacturer and model, browser type, device identifiers, IP address, and general location information such as city, state or geographic area.
• Usage Data such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.
• Error data when you or your device experiences an error, such as the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.
• Cookies: We use cookies to operate and administer our Services, and improve your experience. A “cookie” is a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website.
• Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.

How We Use Information We Collect

We use personal information for the following purposes or as otherwise described at the time of collection:

• To provide, administer, maintain and/or analyze the Services;
• To improve, monitor, personalize, and protect our Services;
• To develop new programs and services;
• To communicate with you about our Services
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
• To prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our IT systems, architecture, and networks;

Research and development. We may use personal information for research and development purposes where it is in our legitimate business interests, including to analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to:

• Protect our, your, or others’ rights, privacy, safety, or property
• Audit our internal processes for compliance with legal and contractual requirements and internal policies.
• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

How We Share Information

We do not sell or share your personal information with third-parties for interest-based advertising purposes. We may disclose your personal information as described below:

• With third party service providers if needed to maintain our services. Service providers are restricted from using information other than to provide services on our behalf.
• To comply with legal obligations, enforce our terms, or protect rights and safety.
• In connection with a merger, sale, or acquisition if Modella AI, Inc is involved in such a transaction.
• With other users and third parties you share information with. Certain features allow you to display or share information with other users or third parties. For example, you may share Devin AI conversations with other users via shared links. Be sure you trust any user or third party with whom you share information.

Your Rights

Subject to applicable law, and depending on where you reside, you have rights regarding your personal information. For example, you may have the right to:

• Access your Personal Information and information relating to how it is processed.
• Delete your Personal Information from our records.
• Rectify or update your Personal Information.
• Transfer your Personal Information to a third party (right to data portability).
• Restrict how we process your Personal Information.
• Withdraw your consent—where we rely on consent as the legal basis for processing at any time.
• Object to how we process your Personal Information.
• Lodge a complaint with your local data protection authority.

Security and Retention

Ensuring the integrity of your data is a major priority for us. We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, these measures are not a guarantee of absolute security and you acknowledge and accept that your use of our Services is ultimately at your own risk.

We’ll retain your personal information for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain personal information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.

Third-Party Websites and Services

Our Services may contain links to other websites not operated or controlled by Modella AI, Inc, including social media services ( “Third-Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

International users

By using our Service, you understand and acknowledge that your personal information will be processed and stored in our facilities and servers in the United States and may be disclosed to our service providers and affiliates in other jurisdictions.

Changes to This Policy

We are continuing to iterate on our Services, and this Privacy Policy will need to be updated. Please be aware that we reserve the right to modify this Privacy Policy at any time.

When we do so and unless required by law to provide an alternative notice, we will post an updated version on this page. If you choose to continue your use of our Services after such a revision, you consent to be governed by the amended Privacy Policy.

Contact Information

You can email us at info@modella.ai if you have any questions or concerns not already addressed in this Privacy Policy.