Privacy Policy

This privacy notice for Archive Intel, Inc. (doing business as AI) ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at https://archiveintel.com, or any website of ours that links to this privacy notice
• Download and use our mobile application (AI Archive Intel), our Facebook application (AI Archive Intel), or any other application of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at legal@archiveintel.com.

Summary of Key Points

Table of Contents

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• mailing addresses
• job titles
• usernames
• contact preferences
• billing addresses

Sensitive Information. We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called "How Do We Handle Your Social Logins?" below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's contacts, sms messages, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

Information collected when you use our Facebook application(s). We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To respond to user inquiries / offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

Archiving electronic communications. Recordkeeping for email, social media, SMS, messages, and websites.

3. What Legal Bases Do We Rely On to Process Your Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

When we use Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

5. How Do We Handle Your Social Logins?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. If you log in using Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than in accordance with the SEC 17a-4 rule. Archive Intel will safely archive client and user data for at least 5 years. For users who wish to hold their data longer with Archive Intel, users will need to notify support to hold data for additional years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at al@archiveintel.com.

9. What Are Your Privacy Rights?

In Short: In some regions, such as Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "How Can You Contact Us About This Notice?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "How Can You Contact Us About This Notice?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at legal@archiveintel.com.

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you are granted specific rights regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under state or federal law	Gender and date of birth	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G. Geolocation data	Device location	NO
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education Information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics	NO
L. Sensitive personal information		NO

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A – As long as the user has an account with us
• Category B – As long as the user has an account with us

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels
• Participation in customer surveys or contests
• Facilitation in the delivery of our Services and to respond to your inquiries

How do we use and share your personal information?

Learn about how we use your personal information in the section "How Do We Process Your Information?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section "When and With Whom Do We Share Your Personal Information?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.

The California Code of Regulations defines a "resident" as:

1. every individual who is in the State of California for other than a temporary or transitory purpose, and
2. every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents." If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your rights with respect to your personal data

Right to request deletion of the data. Request to delete. You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed. Request to know. Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information
• the categories of personal information that we collect
• the purposes for which the collected personal information is used
• whether we sell or share personal information to third parties
• the categories of personal information that we sold, shared, or disclosed for a business purpose
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose
• the business or commercial purpose for collecting, selling, or sharing personal information
• the specific pieces of personal information we collected about you

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights. We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not process consumer's sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by emailing us at support@archiveintel.com, by completing our contact form at archiveintel.com/contact/, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

To submit a request to exercise these rights described above, please email legal@archiveintel.com.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at legal@archiveintel.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

To submit a request to exercise these rights described above, please email legal@archiveintel.com.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at legal@archiveintel.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Utah Residents

This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data

To submit a request to exercise these rights described above, please email legal@archiveintel.com.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

Your rights with respect to your personal data

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Exercise your rights provided under the Virginia VCDPA

You may contact us by email at legal@archiveintel.com.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process – We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal – If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at legal@archiveintel.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

12. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Al Tafur, by email at al@archiveintel.com, by phone at 720-637-0700, or contact us by post at:

Archive Intel, Inc.
Al Tafur
8000 Avalon Blvd, Suite 100
Alpharetta, GA 30009
United States

14. How Can You Review, Update, or Delete the Data We Collect From You?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please email us at support@archiveintel.com.

15. Artificial Intelligence Privacy Policy

1. Purpose

The purpose of Archive Intel's AI policy is to ensure legal and ethical use of AI technology. The guidance below defines acceptable and prohibited uses and outlines employee obligations related to the use or development of AI models and applications.

2. Scope

This policy applies to all applicable parties, which may include, but not be limited to, employees, contractors, directors, and/or third parties with access to critical or high-risk systems or customer or employee PI use of AI applications or development of internal AI models. This policy applies to the use of those applications on company devices and/or personal devices when used for work purposes.

3. Key Context

AI refers to an artificial intelligence technology that synthesizes new versions of text, audio, or visual imagery from large bodies of data in response to user prompts. AI models can be used in stand-alone applications or incorporated into other applications such as internet search engines or word processing applications.

AI Model – A computational system that performs tasks that typically require human intelligence.

Data – Any information, whether personally identifiable or not, collected or processed by AI models.

Third-Party Tools or Platforms – External applications or services that use AI models but are not controlled by the primary organization.

If you have any questions about what constitutes AI, AI Model, Data, and Third-Party Tools or Platform, please contact Al Tafur, 720-637-0700, al@archiveintel.com.

3.1 Privacy, Security, and Confidentiality

Information is shared with an AI tool by user prompts, or a series of instructions or questions for the tool. Generally, providing access to information constitutes sharing data with the tool. The sharing of data potentially makes confidential or sensitive information public as the tool may train its model on the data shared. In some cases, data that has been anonymized could be linked to personal information and become exposed. Any customer or employee personal information, company proprietary information or intellectual property, or otherwise confidential information entered into the prompt may appear in other users' output. Therefore, users of AI should avoid entering any information into an AI tool which they do not want to be made public or is otherwise restricted by law or policy.

3.2 Verification of AI Output

Outputs created by AI tools may provide fictitious answers, these are sometimes referred to as hallucinations. Furthermore, many open-source AI models are often trained on large, publicly available datasets (e.g., through data extraction of public webpages). The outputs may therefore contain copyrighted information or others' intellectual property. While ownership in many of these cases is unclear, users should err on the side of caution and not use any output that contains material they suspect to be under copyright protection in any materials, internal or externally facing.

Users of AI tools must also be aware that they incorporate any biases of the data sets that were used to train them. This modeling bias may not always align with Archive Intel's core values of Innovation, Integrity, Customer-Centricity, Reliability, Compliance, Collaboration, Accessibility, and Transparency and our commitment to diversity, equity, and inclusion. Therefore, model output may make systematic errors or favor certain groups, leading to unfair or discriminatory outcomes. Users of AI must adhere to existing review processes where AI is used to make decisions or provide analysis of information that may be subject to bias.

Using output from AI tools without reviewing it for accuracy places the company at risk and may harm Archive Intel's reputation with customers and employees.

3.3 Transparency

Consistent with our code of conduct and other policy, we aim to provide our employees, third parties, and customers with transparency regarding how we use AI to support our work. All content generated using AI must be clearly identified on any outward-facing content.

3.4 Third-Party Risk

Data, if any, sent by Archive Intel to third parties could be used in the third party's use of AI tools. Uses include, but are not limited to, training new AI models, providing updated information for existing AI models, and improving the user experience. Sensitive information input into unapproved AI applications may appear as output for individuals outside of the company. Not using AI in accordance with this policy may violate Archive Intel's contractual obligations with customers or vendors or, in some cases, violate applicable law.

3.5 Data Sharing

Third-Party Agreements: Ensure that third-party tools or platforms adhere to equivalent data protection standards. Establish data-sharing agreements that specify data usage, security measures, and responsibilities.

Access Control: Limit access to data to only those third-party tools or platforms that require it for legitimate purposes. Access should be granted on a need-to-know basis.

Anonymization: Wherever possible, data should be anonymized before sharing to minimize privacy risks.

4. Acceptable Use

Any use of AI, via platforms, tools, and software, must be consistent with our code of conduct, company policy, and applicable law. Use of AI on company devices must be limited to business purposes. Use of AI tools on personal devices or personal accounts to conduct company business is prohibited. Use of AI tools on personal devices to circumvent company policies or safeguards is strictly prohibited.

Any violation of this policy or use cases out of scope of the table below will result in disciplinary action, up to and including termination.

This list is not inclusive of all possible use cases and if a use case is not specifically listed, a user should ask before proceeding. We reserve the right to make changes to, or update this list periodically:

Accepted Use. The following use cases are permitted:

• Text Classification Model: Searching and highlighting text within a document based on predefined search words and its intent.

Data Sharing: User data is not shared with AI Model or Third-Party.

The following applications are permitted: Archive Intel Text Classification Model.

All Other Use. All other use requires preauthorized approval. Adherence to Data Sharing Policy (Section 3.5). To request approval, please email Al Tafur, CTO, al@archiveintel.com.

5. Policy Guidelines

For any use of AI applications, employees must adhere to the following:

5.1 To maintain the security of our data and IT systems

Employees are prohibited from attempting to gain access to unapproved AI applications when using company systems or networks, conducting business on behalf of the company, or when using the company's data. To avoid potential data leaks or security incidents:

• Do not use company credentials, email addresses, or telephone numbers as a login to publicly available AI applications.
• Do not install non-approved Application Programming Interfaces (APIs), plug-ins, connectors, or software related to AI systems.
• Do not implement or use in any way code generated by AI on company systems.

5.2 To maintain the confidentiality of our company's sensitive information

Including but not limited to employee and customer personal information, our intellectual property, and copyrighted material, employees and contractors must only share information with approved personnel and only input sensitive information into approved AI systems. To maintain confidentiality:

• Do not input company intellectual property into non-approved AI applications.
• Do not enter personal information (PII) of employees, customers, or other third parties into any non-approved AI application. Treat the application as you would an employee of another company with whom we have no formal relationship.
• Do contact your manager, or email legal@archiveintel.com if you are unsure whether information you are planning to input falls into any of the above categories.
• Do review the company's data handling policies at archiveintel.com/privacy-policy/.

5.3 To maintain transparency with customers and employees and protect the company from claims against copyright infringement and/or theft of intellectual property

All AI-generated content must be cited and reviewed if used for work purposes. To protect the company:

• Do clearly attribute any output used for work purposes to the AI application that created it through a footnote or other means visible to the reader.
• Do maintain an updated record of AI use for work purposes and be able to share those records with your manager or other authorized company personnel upon request.

5.4 To protect our employees and clients from harm, and to protect the company from reputational damage

Employees must use AI pursuant to Archive Intel's business code of conduct and non-discrimination policies. AI-created content that is inappropriate, discriminatory, or otherwise harmful to our employees or clients/customers must not be used for work purposes. Such use will result in disciplinary action, up to and including termination. To protect our employees, customers, and the company:

• Do review output of AI applications to make sure it meets the Company's standards for principles of equity, ethics, and appropriateness.
• Do not use any output that discriminates against individuals based on race, color, religion, sex, national origin, age, disability, marital status, political affiliation, or sexual orientation.
• Do not use AI applications to create text, audio, or visual content for purposes of committing fraud or to misrepresent an individual's identity.

5.5 Compliance with Laws

All employees and contractors are expected to comply with applicable laws, regulations, or company policies regarding the use or development of AI content or tools.

5.6 Reporting

All employees are expected to report instances of non-compliance with this policy to the compliance team, email al@archiveintel.com or call 720-637-0700. Employees are encouraged to speak up when they witness misconduct. Employees who report misconduct or concerns in good faith will not be retaliated against.

6. Monitoring

Archive Intel reserves the right to access and monitor the use of AI applications on any company-issued devices or that appear on company-managed networks to ensure compliant use of these systems.

7. Failure to Comply

Users who fail to comply with any provision of this Policy may be subject to discipline up to and including termination of employment. Violations by contractors may be considered breach of contract and result in removal from assignment. Any AI-related activities which appear to violate applicable laws will be reported to external law enforcement.

If monitoring systems and processes detect a possible policy violation or if a user reports a possible policy violation, the suspect event should be processed using appropriate security incident response processes.

16. iMessage and WhatsApp Data Protection

We take your privacy seriously and are committed to ensuring that your data is handled securely. Our iMessage archiving process is designed to retain only the information that is specifically whitelisted. This means:

• Whitelisted Data – Only iMessages that have been pre-approved or specifically marked for retention by you or your organization will be archived.
• Non-Whitelisted Data – Any iMessages not included in the whitelist are automatically deleted from our systems and will not be stored or retained.

Additionally, we do not store, collect, or retain user passwords for iMessage, Apple ID, or any related authentication credentials as part of this process. Our system operates without requiring access to such sensitive information, ensuring your account security remains intact. We employ strict security measures to ensure that non-whitelisted data is permanently removed, safeguarding your privacy and ensuring that no unnecessary information is archived.