Last updated: January 31, 2023

This Privacy Policy describes Our policies and procedures on the collection, use and

disclosure of Your information when You use the Service and tells You about Your

privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service,

You agree to the collection and use of information in accordance with this Privacy

Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the

following conditions. The following definitions shall have the same meaning regardless

of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

•

Account means a unique account created for You to access our Service or parts

of our Service.

•

Affiliate means an entity that controls, is controlled by or is under common

control with a party, where "control" means ownership of 50% or more of the

shares, equity interest or other securities entitled to vote for election of directors

or other managing authority.

•

Company (referred to as either "the Company", "We", "Us" or "Our" in this

Agreement) refers to ITHENA, 4470 Cox Rd, #275, Richmond, VA, USA 23060.

•

Cookies are small files that are placed on Your computer, mobile device or any

other device by a website, containing the details of Your browsing history on that

website among its many uses.

•

Country refers to: Virginia, United States

•

Device means any device that can access the Service such as a computer, a

cellphone or a digital tablet.

•

Personal Data is any information that relates to an identified or identifiable

individual.

•

Service Provider means any natural or legal person who processes the data on

behalf of the Company. It refers to third-party companies or individuals employed

by the Company to facilitate the Service, to provide the Service on behalf of the

Company, to perform services related to the Service or to assist the Company in

analyzing how the Service is used.

•

Usage Data refers to data collected automatically, either generated by the use of

the Service or from the Service infrastructure itself (for example, the duration of a

page visit).

•

Website refers to all ITHENA products.

•

You means the individual accessing or using the Service, or the company, or

other legal entity on behalf of which such individual is accessing or using the

Service, as applicable.

Collecting and Using Your

Personal Data

Types of Data Collected

Personal Data

While using Our Service, we may ask You to provide Us with certain personally

identifiable information that can be used to contact or identify You. Personally

identifiable information may include, but is not limited to:

•

Email address

•

First name and last name

•

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address

(e.g. IP address), browser type, browser version, the pages of our Service that You visit,

the time and date of Your visit, the time spent on those pages, unique device identifiers

and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain

information automatically, including, but not limited to, the type of mobile device You

use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile

operating system, the type of mobile Internet browser You use, unique device identifiers

and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our

Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service

and store certain information. Tracking technologies used are beacons, tags, and

scripts to collect and track information and to improve and analyze Our Service. The

technologies We use may include:

•

Cookies or Browser Cookies. A cookie is a small file placed on Your Device.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie

is being sent. However, if You do not accept Cookies, You may not be able to

use some parts of our Service. Unless you have adjusted Your browser setting

so that it will refuse Cookies, our Service may use Cookies.

•

Web Beacons. Certain sections of our Service and our emails may contain small

electronic files known as web beacons (also referred to as clear gifs, pixel tags,

and single-pixel gifs) that permit the Company, for example, to count users who

have visited those pages or opened an email and for other related website

statistics (for example, recording the popularity of a certain section and verifying

system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your

personal computer or mobile device when You go offline, while Session Cookies are

deleted as soon as You close Your web browser. Learn more about cookies on

the Privacy Policies website article.

We use both Session and Persistent Cookies for the purposes set out below:

•

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available

through the Website and to enable You to use some of its features. They help to

authenticate users and prevent fraudulent use of user accounts. Without these

Cookies, the services that You have asked for cannot be provided, and We only

use these Cookies to provide You with those services.

•

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on

the Website.

•

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use

the Website, such as remembering your login details or language preference.

The purpose of these Cookies is to provide You with a more personal experience

and to avoid You having to re-enter your preferences every time You use the

Website.

For more information about the cookies we use and your choices regarding cookies,

please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

•

To provide and maintain our Service, including to monitor the usage of our

Service.

•

To manage Your Account: to manage Your registration as a user of the

Service. The Personal Data You provide can give You access to different

functionalities of the Service that are available to You as a registered user.

•

For the performance of a contract: the development, compliance and

undertaking of the purchase contract for the products, items or services You

have purchased or of any other contract with Us through the Service.

•

To contact You: To contact You by email, telephone calls, SMS, or other

equivalent forms of electronic communication, such as a mobile application's

push notifications regarding updates or informative communications related to

the functionalities, products or contracted services, including the security

updates, when necessary or reasonable for their implementation.

•

To provide You with news, special offers and general information about other

goods, services and events which we offer that are similar to those that you have

already purchased or enquired about unless You have opted not to receive such

information.

•

To manage Your requests: To attend and manage Your requests to Us.

•

For business transfers: We may use Your information to evaluate or conduct a

merger, divestiture, restructuring, reorganization, dissolution, or other sale or

transfer of some or all of Our assets, whether as a going concern or as part of

bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us

about our Service users is among the assets transferred.

•

For other purposes: We may use Your information for other purposes, such as

data analysis, identifying usage trends, determining the effectiveness of our

promotional campaigns and to evaluate and improve our Service, products,

services, marketing and your experience.

We may share Your personal information in the following situations:

•

With Service Providers: We may share Your personal information with Service

Providers to monitor and analyze the use of our Service, to contact You.

•

For business transfers: We may share or transfer Your personal 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.

•

With Affiliates: We may share Your information with Our affiliates, in which case

we will require those affiliates to honor this Privacy Policy. Affiliates include Our

parent company and any other subsidiaries, joint venture partners or other

companies that We control or that are under common control with Us.

•

With business partners: We may share Your information with Our business

partners to offer You certain products, services or promotions.

•

With other users: when You share personal information or otherwise interact in

the public areas with other users, such information may be viewed by all users

and may be publicly distributed outside.

•

With Your consent: We may disclose Your personal information for any other

purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the

purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the

extent necessary to comply with our legal obligations (for example, if we are required to

retain your data to comply with applicable laws), resolve disputes, and enforce our legal

agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is

generally retained for a shorter period of time, except when this data is used to

strengthen the security or to improve the functionality of Our Service, or We are legally

obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating

offices and in any other places where the parties involved in the processing are located.

It means that this information may be transferred to — and maintained on — computers

located outside of Your state, province, country or other governmental jurisdiction where

the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information

represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is

treated securely and in accordance with this Privacy Policy and no transfer of Your

Personal Data will take place to an organization or a country unless there are adequate

controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that

We have collected about You.

Our Service may give You the ability to delete certain information about You from within

the Service.

You may update, amend, or delete Your information at any time by signing in to Your

Account, if you have one, and visiting the account settings section that allows you to

manage Your personal information. You may also contact Us to request access to,

correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a

legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data

may be transferred. We will provide notice before Your Personal Data is transferred and

becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal

Data if required to do so by law or in response to valid requests by public authorities

(e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action

is necessary to:

•

Comply with a legal obligation

•

Protect and defend the rights or property of the Company

•

Prevent or investigate possible wrongdoing in connection with the Service

•

Protect the personal safety of Users of the Service or the public

•

Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of

transmission over the Internet, or method of electronic storage is 100% secure. While

We strive to use commercially acceptable means to protect Your Personal Data, We

cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect

personally identifiable information from anyone under the age of 13. If You are a parent

or guardian and You are aware that Your child has provided Us with Personal Data,

please contact Us. If We become aware that We have collected Personal Data from

anyone under the age of 13 without verification of parental consent, We take steps to

remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your

country requires consent from a parent, We may require Your parent's consent before

We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click

on a third party link, You will be directed to that third party's site. We strongly advise

You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies

or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes

by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the

change becoming effective and update the "Last updated" date at the top of this Privacy

Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to

this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, You can contact us:

•

By email: request@ithena.ai