Privacy Policy

This Policy is issued by each of the Controller entities listed in Section (O) below (together, “Hayden AI”, “we”, “us” and “our”) and is addressed to individuals outside our organization with whom we interact, including personnel of current or potential customers, visitors to our Sites, users of our Apps, other users of our services, personnel of vendors, applicants for employment, and visitors to our premises (together, “you”). Defined terms used in this Policy are explained in Section (P) below.

This Policy is limited to processing activities in respect of which we are a controller. Where we act as a processor on behalf of a third party controller, please review the privacy policy of that controller.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

This Policy was last updated on April 30, 2025

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

• Data provided to us:We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).
• Data collected and processed by our AI-powered camera system:Personal Data may be collected from the onboard camera system managed by us, to the extent that we act as a controller in respect of such collection of Personal Data.
• Data we obtain in person:We obtain Personal Data during meetings, at trade shows, during visits from sales or marketing representatives, or at events we attend.
• Relationship data:We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to your employer).
• Data you make public:We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
• Site data:We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
• Content and advertising information:If you interact with any third party content or advertising on a Site or in an App (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
• Third party information:We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

We also create Personal Data about you in certain circumstances, such as records of your interactions with us. We may also combine Personal Data from any of our Sites, Apps, or services, including where those data are collected from different devices or sources.

We Process the following categories of Personal Data about you:

• Personal details: given name(s); preferred name; video footage; and photograph.
• Contact / ID details: correspondence address; telephone number; email address; vehicle license plate details; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
• Correspondence: records and copies of your correspondence if you contact us.
• Professional details: your CV; records of your expertise; professional history; practicing details and qualification details; information about your experience; participation in meetings, seminars, advisory boards and conferences; information about your professional relationship with other individuals or institutions; language abilities; and other professional skills.
• Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
• Visitor logs: records of visits to our premises.
• Consent records: records of any consents you have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent).
• Purchase details:: records of purchases and prices.
• Payment details:: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card 'valid from' date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
• Data relating to our Sites and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; location data; platform usage metrics; username; password; security login details; and aggregate statistical information.
• Employer details:  where you interact with us in your capacity as an employee of a third party; and the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part); any touchscreen interactions; and information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message.
• Cookie data: we collect information via cookies and similar technologies. Please see our Cookie Policy for more details.
• Security information: your password(s); login attempt details; security settings; and other security-related information.
• Views and opinions: responses to surveys, responses to testing, any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

• Compliance with applicable law:We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
• Detection and prevention of crime:We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
• Establishment, exercise or defense of legal claims:We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defense of legal claims; or
• Consent:We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

The purposes for which we Process the categories of Personal Data identified in Section (D) above, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

We disclose Personal Data to other entities within the Hayden AI group, for legitimate business purposes and the operation of our Sites, Apps, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to: you and, where appropriate, your appointed representatives;

• accountants, auditors, consultants, lawyers and other outside professional advisors to Hayden AI, subject to binding contractual obligations of confidentiality;

• third party Processors (such as payment services providers; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);

• any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal claims or compliance with applicable law;

• any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

• an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Data is transferred to one or more third parties as one of our business assets; and

• any relevant third party provider, where our Sites or our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

International Transfers: Our servers and data centers are located in the United States (US). If you choose to access our Sites, our Apps, or our services from outside the US, then you should know that you are transferring your Personal Data outside of your region and into the US for storage and processing. We may also transfer your Personal Data from the US to other countries or regions in connection with the storage and processing of data, fulfilling your requests, and operating our services. You should know that each region can have its own privacy and data security laws, some of which may be less stringent as compared to those of your own region. If you are located in the European Union (EU), the United Kingdom (UK), or Switzerland, then the countries we may transfer your Personal Data to, including the US, may not have data protection laws as comprehensive as those in your own country. To ensure your Personal Data is protected, and that we comply with the applicable data protection laws, we have implemented the following measures:

• EU-US Data Privacy Framework. We comply with the EU-US Data Privacy Framework (“EU-US DPF”), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (“Swiss-US DPF”) for the purposes of processing data received from the EU, UK, and Switzerland. Please see the section 'US Data Privacy Framework Notice' in this Privacy Policy for more information.
• Standard Contractual Clauses. We use the Standard Contractual Clauses (SCCs) for transfers of Personal Data to us, and also for transfer of Personal Data to third-party service providers. These clauses require the recipients to protect the Personal Data they receive in accordance with European data protection laws and regulations. Details of our use of SCCs can be provided upon request.
• Derogations. In certain circumstances we may transfer Personal Data based on the derogations contained in Article 49 of the General Data Protection Regulation (GDPR).
• Supplementary Measures. In addition to the SCCs, we may use contractual, technical, and organizational measures to further protect your Personal Data.
• Adequacy Decisions. Where applicable, we may rely on adequacy decisions provided by the European Commission under Article 45 of the GDPR to transfer your Personal Data outside of the EU, the UK, or Switzerland.

US Data Privacy Framework Notice: We comply with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF as set forth by the US Department of Commerce. Hayden AI has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (“EU-US DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF. Hayden AI has certified to the US Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (“Swiss-US DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF. If there is any conflict between the terms in this privacy policy and the EU-US DPF and UK Extension to the EU-US DPF Principles and/or the Swiss-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

To help protect your Personal Data, we use commercially reasonable steps to protect the data that we collect, including your Personal Data. The reasonable steps include protecting this data against accidental loss, unauthorized use, disclosure, and restricting access to Personal Data by our staff. Our Sites, our Apps, and our services are hosted by a third-party hosting company that we have determined maintains adequate security controls and utilizes TLS encryption for all internet communication with our Sites, our Apps, and our services. We also require all staff that administer and develop our Sites, our Apps, and our services to follow industry-standard controls, including strong passwords, the use of anti-virus and anti-malware software, disk encryption, and other best practices.

We use various third party processors to enable us to provide our Sites, our Apps, and our services, and as part of our vendor due-diligence, we review the security controls these processors have in place and ensure they meet industry standards appropriate for the type of data we collect.

You should keep in mind, however, that our Sites, our Apps, and our services utilize software, hardware, and networks, which from time to time require maintenance and experience problems beyond our control. Note that no data transmission over the public internet or encryption method can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information that you provide to us. You transmit information to us at your own risk.

We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up-to-date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:

1. we will retain Personal Data in a form that permits identification only for as long as:
   1. we maintain an ongoing relationship with you (e.g., where you have an account on the Data Portal, or are a you are lawfully included in our mailing list and have not unsubscribed); or
   2. your Personal Data are necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

plus:

2. the duration of:
   1. any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and
   2. an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

and:

3. in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the relevant Personal Data; or
• anonymize the relevant Personal Data.

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
  • erasure of your Relevant Personal Data; or
  • restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (i.e., in relation to the UK, the Information Commissioner's Office (https://ico.org.uk/) or in relation to the EU, the Data Protection Authority for EU Member State in which you live, or in which you work, or in which the alleged infringement occurred (see the list here: https://edpb.europa.eu/about-edpb/about-edpb/members_en)).

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the Contact / ID details provided in Section (O) below. Please note that:

• in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps, or services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, Apps, or services. If we provide Sites, Apps, or services to you, we may send or display information to you regarding our Sites, Apps, or services, upcoming promotions and other information that may be of interest to you, including by using the Contact / ID details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

We allow you to opt out of receiving marketing communications from us as described in this section, and also at the time you sign up and create an account. Even if you opt out, we may continue to send you administrative emails, including, for example, periodic updates to this Privacy Policy, security, support, and maintenance advisories, and welcome emails to verify your email address provided when your account was created.

If you receive marketing emails from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving marketing emails from us, and any other promotional communications that we may send to you from time to time (e.g., by postal mail) by sending your request to us by email at privacy@hayden.ai or by writing to us at the address given in the 'Contacting Us' section of this Privacy Policy.

Please be aware that if you opt out of receiving marketing emails from us, it may take up to ten business days for us to process your opt-out request, and you may receive marketing emails from us during that period. Additionally, even after you opt out of receiving marketing messages from us, you will continue to receive administrative and transactional messages from us regarding your use of our Sites, our Apps, and our services.

Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. Our Sites, Apps, and services are not directed to users under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If we learn that we have collected Personal Data from a child under the age of 18 on our Services, we will delete that information without undue delay. If you believe that we may have collected any such Personal Data, please notify us at privacy@hayden.ai

For the purposes of this Policy, the relevant Controllers are:

Alternatively, you may contact us using our online Contact Us form.