Privacy Notice

Mynd.ai recognizes that protecting the security and privacy of your personal data is important. This Privacy Notice explains how we collect, store, use, disclose and transfer (hereinafter “Process”) your personal data.

The trust you have in Mynd.ai’s solutions is the foundation of who we are as a company. That trust is why protecting the privacy and security of your personal data is so important to Mynd.ai. We want you to know that:

Mynd.ai is committed to protecting your personal information;
Mynd.ai will not sell any of your personal information to third parties;
Mynd.ai will abide by privacy laws and regulations as applicable around the world; and
Mynd.ai will use reasonable security measures to protect your personal information.

We promise to Process your personal information in a manner that is always lawful, fair and transparent. We also promise to provide you with choice and control over the use of your personal information in accordance with prevailing laws and obligations.

For purposes of ensuring compliance with data protection and data privacy laws around the world, including the General Data Protection Regulation (GDPR) for European Union (“EU”) residents and the Data Protection Act 2018 for residents of The United Kingdom of Great Britain and Northern Ireland (“UK”), Mynd.ai has appointed a Data Protection Officer to continually monitor and improve the safety and security of the personal information collected and Processed by Mynd.ai.

For more details about our privacy practices, or for questions and concerns, please contact our Data Protection Officer via email at privacy@Mynd.ai

Our EU Data Representative is: Our UK Contact Information is:

Promethean Poland sp. z o.o Promethean Limited

Attention: Legal Promethean House

Grabarska 1 st., 50-079 Lower Philips Road

Wrocław, Poland Blackburn, BB1 5TH

Attention: Legal

Our contact information for the U.S. and all other countries is: privacy@Mynd.ai

Please note that the personal data we Process about you depends on the context of your interactions with us, the products, services and features that you use, your location, and applicable law.

1. Processing of Personal Data Relating To Use Of Our Website.

When visiting our website we may Process the following categories of personal data:

● Your contact information, such as full name, work address, work telephone number, work mobile phone number and work email address;

● Organizational information including your company or school name and your job title or role;

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● Further personal data that you provide by filling in forms we may, from time to time, make available on our website; and

● Information Processed based upon your interaction with our website including, for example, your device identifier, information on your operating system, and the information accessed during your visit as well as the date and time of your visit and any request you may submit to us.

We Process your personal data for the following purposes:

● To administer and provide our website;

● If applicable, to verify your identity;

● To answer and fulfill your requests or instructions;

● To provide you with access to specific information;

● To contact you with information concerning our products and services or to send you marketing or other information;

● As reasonably necessary, to establish or preserve any legal claim or defense, to prevent fraud or other illegal activities, including attacks on our information technology systems; and

● For any other lawful purposes.

When we collect personal data, we will endeavor to minimize the personal data collected to only the limited amount of personal data we need for our purposes. We will only Process your personal data when we have one or more of the following lawful basis for Processing your personal data:

● Our Processing is necessary for the performance of a contract or to take steps prior to entering into a contract;

● Our Processing is necessary for compliance with a legal obligation;

● Our Processing is necessary to protect the vital interest of you or another natural person;

● Our Processing is necessary for the performance of a task carried out in the public interest;

● Our Processing is necessary for the purposes of our legitimate interests or the legitimate interests of a third-party; or

● You have given consent to the Processing.

PLEASE NOTE THAT PRODUCTS OR SERVICES OFFERED BY MYND.AI SUBSIDIARY COMPANIES HAVE THEIR OWN PRIVACY TERMS. IF YOU ARE USING ANY PRODUCT OR SERVICE OFFERED BY ANY MYND.AI SUBSIDIARY COMPANY, PLEASE SEE THE PRIVACY POLICY FOR THE APPLICABLE PRODUCT OR SERVICE FOR THE PRIVACY TERMS APPLICABLE TO THAT SPECIFIC PRODUCT OR SERVICE.

2. Sharing of Personal Data

Please note that we may share personal data collected by Mynd.ai with our subsidiary companies provided, however, use of such personal data by any Mynd.ai subsidiary company will be in compliance with the terms of this Privacy Notice and the terms of the Mynd.ai IntraGroup Agreement for Data Transfers which contains the European Commission approved standard contractual clauses for the transfer of personal data.

If you visit the website of any of our subsidiary companies, of if you use any of the products, applications or services made available by any of our subsidiary companies, please see the Privacy Policy applicable to each website, product, application or service for specific information relating to the Processing of your personal data by each of our subsidiary companies and their respective products, applications or services.

Except as provided for herein, we will not sell or share your personal data with third parties for their marketing purposes or advertisements unless you give us your consent to do so.

We may share your personal data with certain trusted third-party companies and individuals to perform tasks on our behalf, but strictly for the purpose of carrying out their work for us, for example, to help us provide the website, to enhance the website, to increase the website’s functionality and user friendliness, to provide customer support, to improve your experience on the website, to respond to your inquiries or questions, or to provide you with information regarding our company or the products or services provided by our subsidiary companies. Unless we tell you differently, these trusted third-party companies do not have any right to use your personal data beyond what is necessary to assist us with providing you the best possible service. To the extent we share personal data with any third party, we require them to comply with the requirements of a data processor under the EU’s General Data Protection Regulation.

Please also note that we may disclose your personal data if

● Mynd.ai or substantially all of its assets are acquired by a third party, in which case personal data held by Mynd.ai will be included among the transferred assets;

● required by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence;

● we determine that, for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate; or

● we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or other users.

3. Where We Process Your Personal Information

We maintain servers in hosting facilities located in the United States.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data that you transmit to Mynd.ai. Any transmission of personal data to Mynd.ai is, therefore, at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.

4. Retention periods

We will erase, delete or otherwise de-identify personal data we Process when we determine that such personal data is no longer necessary for the purpose(s) the personal data was collected for, in accordance with any policies or procedures we may adopt relating to the retention of personal data, or to comply with legal obligations (such as retention obligations under applicable laws).

5. Rights relating to our Processing of your personal data

The data protection laws in the jurisdiction in which you reside may entitle you to specific rights in relation to your personal data.

In particular, and subject to the legal requirements, you may be entitled to

● obtain from us confirmation as to whether or not we are Processing your personal data;

● access to your personal data if we are Processing your personal data;

● the correction of inaccurate personal data concerning you;

● erasure of your personal data that we are Processing;

● restriction of the Processing regarding your personal data;

● data portability concerning personal data that you actively provided;

● object, on grounds relating to your particular situation, to our further Processing of personal data; and

● withdraw your consent to our Processing of your personal data.

If you wish to contact us with regards to any of your privacy rights, please contact us at privacy@mynd.ai.

6. Cookies and Similar Technologies

Like most websites, we use cookies and other standard Internet technologies.

A cookie is a small text file that is placed on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, for example so you don’t have to re-enter such information whenever you come back to the website or browse from one page to another. A cookie can be classified by its lifespan and the domain to which it belongs. By lifespan, a cookie is either a:

● Session cookie which is erased when the user closes the browser; or

● Persistent cookie which remains on the user’s computer/device for a pre-defined period.

As for the domain to which it belongs, there are either:

● First-party cookies which are set by the web server of the visited page and share the same domain; or

● Third-party cookies stored by a different domain to the visited page’s domain. This can happen when the webpage references a file, such as JavaScript, located outside its domain.

We may use cookies for the following purposes:

● Capture and store your preferences, account settings, and, if applicable, certain login information (mainly for convenience, verification, and account security);

● Compile statistics and analytics about your use of and interaction with our website;

● Gather demographic information about the visitors to our website; and

● To perform other similar lawful functions.

We share with you the cookies that we place and we respect your election to allow or deny the use of cookies other than cookies that are necessary for the proper functioning of our website. If you prefer, you can change your browser to prevent cookies or, at any time, you can review and update your preferences to allow or deny cookies. Please note, however, that by blocking or deleting cookies, you may not be able to take full advantage of the website features.

7. Children

We understand the importance of taking extra precautions to protect the privacy and safety of children. This website is not intended for children or persons under the age of eighteen (18). Specifically, we do not knowingly collect, use, or process personal data from children under the age of eighteen (18). If you are under the age of eighteen (18), please do enter any personal data into our website for any reason.

If we ever learn that we have collected the personal data of a child without parental consent when parental consent is required, or without other lawful authorization, we will take steps to delete the information as soon as possible. If you know that we have inadvertently collected any personal data about a child without the required parental consent or authorization, please contact us at privacy@Mynd.ai.

8. Do Not Track (DNT)

Mynd.ai does not track its users over time or across third party websites to provide targeted advertising, and therefore, does not respond to Do Not Track (DNT) signals.

9. Links to Other Sites

Our website may, from time to time, contain links to and from the websites and services of third parties. Please note that Mynd.ai does not operate, manage or control the websites, services, or personal data Processing of any such third parties and Mynd.ai does not accept any responsibility for the processing of personal data by any such third party. Please carefully review the Privacy Notice, Terms of Use and Cookie Policy of each third party, as applicable, prior to clicking on any link to such third party’s website or service or allowing such third party to Process your personal data.

10. Changes to Our Privacy Notice and Contact Information

Any changes we may make to our Privacy Notice in the future will be posted on this page. Please check this page from time to time to take notice of any changes we make, as they are legally binding on you.

Questions, comments, and requests regarding this Privacy Notice should be addressed to privacy@Mynd.ai

November 16, 2023