CONTESTRA PRIVACY POLICY

Last Updated: July 29, 2025

California Consumer Privacy Act ("CCPA") Notice at Collection

The following serves as our notice at collection ("Notice") of Personal Information. We collect personal information as detailed in this Notice and in our Privacy Policy below.

Categories of Personal Information collected:

• Automatically collected data: This includes IP address, device type, browser type, operating system, referring URLs, geographic location (country only), and data concerning pages viewed and the time you spend on each page, collected by cookies and other tracking tools, when you interact with our Websites and/or Services.
• Identifiers (including account credentials information): This includes your name, country, email address, phone number, username and password if you register an account with us. We may collect information from partners that verify your identity for account log-in purposes.
• Communication information: This includes your contact information and the context of the communication (to the extent considered Personal Information) when you send us an email or request, such as name of workplace and job title.
• Geolocation data: This means the device details, geolocation from where your device accesses our Websites and Services based on information like its IP address.
• Network and services activity information: This includes content data and how you interact with our Websites and Services, including your answers to general questions (e.g., your preferred language, purpose of usage of the Services), and content supplied through your interaction with our models (e.g., prompts, text, documents, and any other content and information uploaded, entered, or otherwise transmitted by you in connection with your use of the Services), feedback, answers to surveys or other comments sent to us.

Purposes for which the Personal Information is used:

• To provide you with the Services. We will use your Personal Information for the following purposes: (i) to allow you to create an account; and (ii) to administer and improve, enhance and develop our products and Services.
• To allow you to make use of our Website. We will use your Personal Information to allow you to make use of our Websites, including: (i) if you complete a Website form, (ii) to answer your questions and to allow you to communicate with us; (iii) to analyze your use of our Websites and to improve our Websites; and (iv) to customize your experience.
• For Administrative Purposes. Contestra uses your Personal Information (i) to respond to your questions, comments, and other requests, or information, including information about potential or future products and Services; (ii) to provide you with the Websites and the Services; (iii) for internal quality control purposes; and (iv) to generally administer the Websites and the Services.
• To Market and develop Contestra products and Services. We use information to market Contestra products and Services. Such use includes (i) notifying you about offers and services that may be of interest to you; (ii) adding you to our mailing list, send newsletters or other marketing communications; (iii) advertising Contestra products and Services and other-related offers for you; (iv) conducting market research; (v) developing, enhancing, improving and marketing new products and Services; (vi) to measure interest in our Websites, products and services; (vii) other purposes disclosed at the time you provide information; and (viii) as you otherwise consent.
• Security purposes. Some of the abovementioned Personal Information will be used: (i) for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; (ii) To prevent fraud, prohibited or illegal activities and to enforce our contracts with you; (iii) to identify and repair errors; to conduct audits (including bias audit); (iv) for security purposes; and (v) to comply with legal obligations and to protect the rights, privacy, and safety of our users, ours and/or third parties. Personal Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.
• De-identified and Aggregated Information Use. In certain cases, we may aggregate or de-identify your Personal Information and further use it, including, without limitation, to analyze and improve our Websites, as well as our products and Services (including through the use of artificial intelligence) and for research purposes.
• Cookies and Similar Technologies. We use cookies, analytic tools and other technologies to automatically collect information through, and to track users' movement in our Websites and the Services.

Sale or share of Personal Information: We do not "sell" or "share" Personal Data for cross-contextual behavioral advertising and we do not process Personal Information for "targeted advertising" purposes.

Retention periods: Your Personal Information will be stored until we proactively delete it, or you send a valid deletion request. Please note that in some circumstances we may store your Personal Information for longer periods of time. These circumstances include: (i) where we are required to do so, for example for compliance with legal and regulatory requirements in accordance with legal, regulatory, tax or accounting requirements, (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings, and/or (iv) in the form of Aggregated Information (as described below).

In order to ensure transparency and give you more control over your Personal Information, this privacy policy ("Privacy Policy") governs how we, Contestra (together, "Contestra", "we", "our" or "us") use, collect and store Personal Data we collect or receive from or about you ("you") such as in the following use cases:

1. When you make use of, or interact with, our websites (https://www.contestra.com/) ("Websites")
   1. When you contact us (e.g. customer support, need help, submit a request)
   2. When you subscribe to our distribution list(s) / newsletter(s)
2. When you download, access and/or make use of, or interact with our application programming interfaces, or associated software, websites, tools, developer services, data, UI and design or documentation (collectively, the "Services")
   1. When you download and make use of the Services
   2. When you contact us
3. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices and your rights in relation to personal data. "Personal Data" or "Personal Information" means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that some provisions only apply to individuals in certain jurisdictions. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or means of enforcement.

Table of contents:

1. What information we collect, why we collect it, and how it is used
2. Customer Information
3. How we protect and retain your Personal Data
4. How we share your Personal Data
5. Additional information regarding transfers of Personal Data
6. Your privacy rights
7. Use by children
8. Interaction with third party products
9. Analytic tools and other tracking technologies
10. Specific provisions applicable under California Consumer Privacy Act ("CCPA")
11. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Websites, Services or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Finally, please note that some of the above-mentioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits (including, without limitation, bias audits), and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.

2. CUSTOMER INFORMATION

2.1. For the avoidance of doubt, Contestra processes the Customer Information (defined below) on behalf of the applicable customer. Therefore, the customer is the party responsible for the security, integrity and authorized usage of Customer Information in the context of the services and for obtaining all the necessary consents and permissions and providing all notices required for the collection and usage of such Customer Information and honoring all data subject requests. Contestra has a contractual relationship with its customers. In the context of Contestra Services, customers can upload, add, input and/or receive to the Services (at the customer's sole discretion) information, including Personal Data ("Customer Information").

2.2. Customer Information is not regulated by this Privacy Policy, and this paragraph is provided only for transparency purposes. If you have any questions related to the Customer Information, please contact the customer directly.

2.3. Please note that, as part of providing our Services, the Personal Data will be processed, in whole or in part, by artificial intelligence (AI) systems.

3. HOW WE PROTECT AND RETAIN YOUR INFORMATION

3.1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information and items.

3.2. Retention of your Personal Data. Your Personal Data will be stored until we proactively delete it, or you send a valid deletion request. Please note that in some circumstances we may store your Personal Data for longer periods of time. These circumstances include: (i) where we are required to do so, for example for compliance with legal and regulatory requirements in accordance with legal, regulatory, tax or accounting requirements, (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings, and/or (iv) in the form of Aggregated Information.

4. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may share your Personal Data as follows:

4.1. With our corporate affiliates (e.g. parent and subsidiaries within our group) and/or partners;

4.2. With our vendors and service providers, including:

4.2.1. Email provider and email distribution
4.2.2. Website and product hosting
4.2.3. Payment processor
4.2.4. Customer engagement
4.2.5. Customer support
4.2.6. Product analytics
4.2.7. Website analytic tools
4.2.8. Serving and models Platforms
4.2.9. Business intelligence
4.2.10. Advertisement/marketing activities

4.3. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order. We may use or disclose Personal Data we collect in order to ensure that our users are complying with all applicable aspects of our policies;

4.4. We may disclose Personal Data with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;

4.5. We may use or disclose Personal Data to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations;

4.6. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;

4.7. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or

4.8. Where you have provided your consent to our sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

4.9. For more information, please contact us at [email protected].

5. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

5.1. Internal transfers: Transfers within the Contestra group will be covered by an internal processing agreement entered into by members of the Contestra group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.

5.2. External transfers: We process Personal Data on servers located outside of the EEA, Switzerland and the UK for the purposes described in this Privacy Policy. This includes processing and storing your Personal Data in our facilities and servers in the United States. While data protection law varies by country and some countries may not offer the same level of data protection as your country, we apply the below-mentioned protections to your Personal Data.

5.2.1. We will obtain contractual commitments from them to protect your Personal Data.
5.2.2. We will comply with the transfers rules under the GDPR, including, by implementing a transfer mechanism, for example, transferring Personal Data to a country declared adequate by the European Commission, executing Standard Contractual Clauses with the data recipient and/or relying on their Data Privacy Framework certification.

5.3. For more information, please contact us at [email protected].

6. YOUR PRIVACY RIGHTS

6.1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals depending on your location and applicable privacy law:

• You have the right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work, or place of alleged infringement) at any time, or before the relevant institutions in your place of residence. We kindly ask that you attempt to resolve any issues with us before contacting your local supervisory authority and/or relevant institution.
• You have a right to access Personal Data held about you;
• You have the right to request that we rectify or delete any Personal Data we hold that is inaccurate or misleading;
• You have the right to request the erasure/deletion of your Personal Data (e.g. from our records);
• You have the right to object to, or to request restriction of, the processing of your Personal Data;
• You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• You have the right to object to profiling;
• You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
• You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality; and
• You have the right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work, or place of alleged infringement) at any time, or before the relevant institutions in your place of residence. We kindly ask that you attempt to resolve any issues with us before contacting your local supervisory authority and/or relevant institution.

6.2. Data subject request process: You can exercise your rights by contacting us at [email protected]. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

6.3. Marketing emails – opt-out: You can unsubscribe from our marketing emails using the link found at the bottom of the email, and we will process your request within a reasonable time after receipt.

7. USE BY CHILDREN

We do not intentionally collect data from children under the age of eighteen (18). If you believe that we might have any such information, please contact us at [email protected]. Regardless, in the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it.

8. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a "Third Party Service"). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

9. ANALYTIC TOOLS AND OTHER TRACKING TECHNOLOGIES

• Google Analytics. Our Websites use a tool called "Google Analytics" to collect information about the use of the Websites. Google Analytics collects information such as how often users visit these Websites, what pages they visit, and what other websites they used prior to coming to these Websites. We use the information we obtain from Google Analytics to maintain and improve the Websites and our products. We do not combine the information collected through Google Analytics with Personal Data we collect. Google's ability to use and share information collected by Google Analytics about your visits to the Websites is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. You may prevent your data from being used by Google Analytics by using the Google Analytics opt-out.
• Log Files. We use log files to analyze trends, administer the Websites and Services, track users' movement around the Websites and Services, and gather demographic information.
• We reserve the right to remove or add new analytics tools.

10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA CONSUMER PRIVACY ACT

10.1. General. This Privacy Policy for California Residents supplements and is expressly made part of the information contained in this Privacy Policy, and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this Privacy Policy to comply with the California Consumer Privacy Act of 2018 and its amendments and regulations ("CCPA"). Any terms defined in the CCPA have the same meaning when used in this CCPA Privacy Policy.

10.2. Categories of Personal Information. Personal Information collected in the last 12 months is described in Section 1 above. If you have further questions with respect the collection, use, disclosure or sale of your Personal Information, please make your request by contacting us at [email protected].

10.3. Disclosure of Personal Information. We disclose Personal Information to third parties as described in Section 4 above.

10.4. Categories of sources. We obtain these categories of personal information listed above from the following categories of sources:

1. Directly from you. For example, when you make use of the Services.
2. Indirectly from you. For example, via any of our vendors and service providers, for example from observing your actions on our Services.

10.5. Your privacy rights.

10.5.1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to individuals protected by the CCPA:

1. You have the right to know what Personal Information is being collected about you, this includes the right to request that we disclose what Personal Information of yours we collect, use, disclose, and sell;
2. You have the right to request the erasure/deletion of your Personal Information (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
3. You have the right to know whether your Personal Information is sold or disclosed and to whom;
4. You have the right to restriction of, or object to, processing of your Personal Information, including the right to opt in or opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;
5. You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA;
6. You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in California). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution; and
7. If we decline to take action on one of your rights, applicable law may allow us to submit an appeal, this may be done by emailing us at [email protected].

10.5.2. Exercise your rights. You can exercise your rights by following the steps and options described in Section 6 above.

10.5.3. Non-Discrimination. If you decide to exercise your rights, you will not receive any discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. However, note that some features of our Websites and the Services will not function without your Personal Information. Unless permitted by the CCPA, we will not: (i) deny goods or services, (ii) charge different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, (iii) provide you with a different level or quality of goods or services, and (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

10.6. Sale or Share of Personal Information. We do not "sell" or "share" Personal Data for cross-contextual behavioral advertising and we do not process Personal Information for "targeted advertising" purposes.

10.7. Notice of financial incentives. We do not offer financial incentives for the collection of Personal Information. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program.

10.8. Our California Do Not Track Notice (Shine the Light). Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

11. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us – Contestra, as the data controller, at [email protected].