Effective Date:July 18, 2025

Introduction

This Privacy Policy (our “Privacy Policy”) describes how Translucent AI, Inc. (“we,” “our,” or “us”) collects, uses, and discloses personal information about you when you:

- visit our website at https://www.translucent.co (the “Website”); or

- access or use our hosted AI agent services, including any applications, user portals, and related services (the “Service”).

This Policy also applies to information we collect through email, text, and other electronic communications between you and us.

Please read this Policy carefully to understand how we handle your information. By using the Website or the Service, you agree to the terms of this Policy. If you do not agree with our policies and practices, do not use the Website or the Service

Information We Collect About You

We collect information about you from a variety of sources, depending on how you interact with us. This may include:

A. Information Collected from the Website:

When you visit or interact with our public-facing website(https://www.translucent.co), we may collect:

- Identifiers such as your name, email address, company name, and phone number if you submit them through a form;

- Communications such as emails or messages you send to us;

- Technical data including yourIP address, browser type, device identifiers, and usage data, collected automatically via cookies and similar technologies;

- Marketing and analytics data collected through tools like Google Analytics, HubSpot, and others.

B. Information Collected from the AI Agent Service

When you access or use our hosted AI agent services, we may collect:

- Account information such as login credentials, email address, and organization (if access is provisioned by an enterprise customer);

- User Content such as prompts, questions, uploaded documents, or other data you submit to the Service during your interactions;

- Usage data including time stamps, agent interactions, session metadata, and user behavior within theService;

- Technical information such asIP address, browser or client version, and log data to support security and diagnostics.

How WeCollect Information About You

We collect information about you in the following ways:

A. Information You Provide Directly

We collect personal information you voluntarily provide, such as:

- When you fill out forms or contact us through our Website;

- When you communicate with us via email, chat, or other channels;

- When you access the Service and submit prompts, questions, documents, or other content to an AI agent;

- When you log into an account provided by your employer or another organization.

B. Information Collected Automatically

We use various technologies to automatically collect certain data, including:

- Cookies and browser storage;

- Web beacons and tracking pixels in emails or on pages;

- Session and interaction logs from use of the AI agent platform;

- Device, browser, and network information such as IP address, browser type, operating system, and access times.

C. Information from Third Parties

We may receive information about you from:

- Analytics or marketing partners (e.g., Google Analytics, HubSpot);

- Enterprise customers who provision access to the Service on your behalf;

- Identity providers or authentication services if you log in through a federated or SSO system.

‍

How We UseYour Information

We use the information we collect for purposes consistent with the context in which it was provided or collected.This includes:

A. Use of Website Information

We may use information collected through our Website to

- Provide and maintain the Website and its features

- Respond to your inquiries or requests;

- Send you marketing or promotional communications (if permitted by law)

- Analyze site usage and improve Website performance

- Detect and prevent fraud or abuse.

B. Use of Information CollectedThrough the AI Agent Service

We may use personal information andUser Content collected through the Service to

- Provide and operate the AI agent functionality

Respond to your queries and generate outputs based on your inputs

- Improve the accuracy, safety, and performance of our models and system

- Analyze usage patterns and support enterprise-level reporting (where applicable)

- Diagnose service issues, ensure security, and monitor platform integrity

- Comply with legal obligations or protect our legal rights.

We may also use aggregated or de-identified information, which does not identify any individual, for research, analytics, and product development.

‍

Disclosure of Your Information

We may disclose your information to third parties in the following circumstances:

A. Service Providers and Subprocessors

We may share your information with trusted service providers who perform functions on our behalf, including:

- Hosting and infrastructure (e.g., Amazon Web Services

- AI model providers and inference platforms

- Analytics and monitoring providers

- Customer support and communication tools.

These third parties are contractually obligated to use your information only for the purposes of providing services to us and in accordance with this Policy.

B. Enterprise Customers (WhereApplicable)

If your access to the Service is provisioned by your employer or another organization (an “EnterpriseCustomer”), we may share usage data and other information about your interactions with the Service with that organization, subject to our contractual obligations with them.

C. Legal and Regulatory Disclosures

We may disclose your information if required to do so by law or if we believe in good faith that such disclosure is necessary to:

- Comply with a legal obligation, subpoena, or court order

- Prevent or investigate possible wrongdoing

- Protect our legal rights or those of others.

D. Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, in accordance with applicable law.

E. With Your Consent

We may share your information for any other purpose disclosed to you at the time of collection, with your consent.

‍

Your Choices and Controls

We strive to provide you with choices about how your personal information is collected, used, and shared. The mechanisms available to you may differ depending on whether you are interacting with our Website or accessing the AI Agent Service.

A. Website Tracking and Advertising

• Cookies and Tracking Technologies: You can configure your browser     to refuse all or some browser cookies, or to alert you when cookies are     being set. If you disable or refuse cookies, please note that some parts     of the Website may become inaccessible or not function properly.
• Marketing Communications: You can opt out of receiving promotional emails     from us by clicking the “unsubscribe” link in our messages or contacting     us at legal@translucent.co. This does not apply to administrative or     service-related emails.
• Interest-Based Advertising: We may work with advertising partners that use     cookies and similar technologies to show you interest-based ads. You can     opt out through industry tools such as the Digital Advertising Alliance or the Network     Advertising Initiative

B. Enterprise or AI Agent ServiceUsers

If your access to the Service was provisioned by your employer or another organization, some data controls (such as account deletion or usage visibility) may be managed by that organization.In such cases, please direct inquiries to your administrator or employer, orc ontact us if you need assistance.

C. Additional Controls

• Affiliate Marketing: If you receive promotional content from     Translucent’s partners or affiliates and wish to unsubscribe, use the link     provided in the communication or contact legal@translucent.co.
• Data Deletion and Corrections: You may contact us to request     correction or deletion of your personal information, subject to applicable     legal and contractual limitations (see Your Rights below).

‍

Promotions for Our Products and Services

‍We may use your contact information collected through the Website to send you updates, offers, or promotional communications about our products and services. You may opt out of receiving these communications at any time by following the unsubscribe link in our emails or contacting us at legal@translucent.co.

These communications do not apply to users accessing our AI Agent Service through an enterprise customer relationship, unless you have separately provided your consent.

‍

Your Rights

Depending on where you reside and how you interact with us, you may have the following rights regarding your personal information:

• Access – You have the right to request a copy of the personal information we hold about you.
• Correction – You may request that we correct any inaccurate or incomplete personal information.
• Deletion – You may request that we delete your personal information, subject to certain exceptions.
• Objection / Restriction – You may object to or request that we restrict certain processing of your personal information.
• Portability – Where applicable, you may request a copy of your personal information in a structured, machine-readable format.

If you wish to exercise any of these rights, please contact us at [legal@translucent.co]. We may need to verify your identity before fulfilling your request.

‍

AI Agent Service Users (EnterpriseProvisioned)

If your access to the Service is provided by an organization (e.g., your employer or healthcare provider), your information maybe controlled by that organization. In such cases, we may refer your request to the appropriate administrator or data controller, depending on our contractual relationship.

California Residents

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

• The  right to know what categories of personal information we collect, the     purposes for which we use it, and whether we disclose it to third parties;
• The right to opt out of the sale or sharing of your personal information     (note: we do not sell your personal information);
• The right to non-discrimination for exercising your privacy rights.

To exercise these rights, please contact us at legal@translucent.co.

‍

Do Not Track Signals

Some web browsers offer a “Do NotTrack” (DNT) signal or setting, which you can activate to indicate your preference that websites not track your online activity.

At this time, we do not respond toDNT signals or similar mechanisms because there is no industry-standard approach to interpreting them. We encourage you to use your browser’s privacy settings, cookie controls, and opt-out tools to manage your preferences.

‍

Data Security

We implement reasonable physical, technical, and administrative safeguards to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures are designed to provide a level of security appropriate to the nature of the data we collect and the risks associated with processing it.

While we strive to protect your information, no method of transmission over the internet or electronic storage is completely secure. Accordingly, we cannot guarantee the absolute security of your data.

If your access to the Service is provided by an enterprise customer, we may comply with additional security requirements as outlined in our agreement with that organization. Please contact your administrator for more information about enterprise-specific security protocols.

Children’s Privacy‍

Our Website and Services are not intended for, and may not be used by, individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without appropriate consent, we will take steps to delete such information as soon as possible.‍

‍

Storage of Personal Data in the United States

All of the information that you provide to us will be stored and processed in the United States. If you access the Website or Service from outside the United States, you understand that your information may be transferred to, stored in, and processed in the United States, where data protection laws may differ from those of your jurisdiction.

‍

Data Retention

We retain Personal Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. We may retain aggregated or de-identified information for business or research purposes.

‍

Changes to Our Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by updating the date at the top of this Policy and, where appropriate, providing additional notice (such as through the Service or by email).

We encourage you to review thisPolicy periodically to stay informed about how we collect, use, and protect your information.

‍

Contact Information

You may contact us through the contact information below.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Website.

‍

Translucent AI, Inc.

85 Fifth Avenue, 8th Floor

New York, NY 10003

Email: legal@translucent.co