SWIRL CORP.

Privacy Policy

(Revised: March 2025)

This Privacy Policy for Swirl, Inc. ("Company," "we," "us," or "our") sets forth and describes the collection, storage, usage, and/or sharing (any, "process" or "processing") of your information when you use our applications and/or services (collectively, "Services"), such as when you:

• Visit our website at https://swirlaiconnect.com, or any website of Company that links to this privacy notice.
• Engage with us in other related ways, including any sales, marketing, or events.

This Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices as set forth in this Privacy Policy, please do not use or discontinue use of our Services. For any specific questions, please contact us by email at hello@swirlaiconnect.com or write to us at the address set forth in Section 11 below.

Frequently Asked Questions

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Swirl, Inc. and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information?

We do not process sensitive personal information.

Do we receive any information from third parties?

We do not receive any information from third parties.

How do we process your information?

We process your information when we have a valid legal reason to do so, and in any manner necessary to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention, and to comply with applicable laws, rules and regulations. We may also process your information for other purposes, with your consent.

In what situations and with which parties do we share personal information?

We may share personal information in specific situations and with specific third parties, consistent with how you interact with Swirl, Inc. and the Services, the choices you make, and the products and features you use. We may also share personal information with third parties for marketing and other Company business purposes.

How do we keep your information safe?

We have organizational and technical processes and procedures in place to protect your personal information, consistent with industry standards. However, 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. We make no explicit representations, commitments or guarantees regarding the protection of personal information.

How do you educate yourself about privacy or contact Company about privacy-related issued?

The easiest way to educate yourself is by visiting https://swirlaiconnect.com, or by contacting us directly. We will consider and act upon any request or communication, in accordance with applicable data protection laws, rules and regulations.

Terms and Conditions

1. Collection of Personal Information

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

The personal information that we collect depends on the context and extent 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 without limitation the following:

• names
• email addresses
• job titles

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 immediately upon the occurrence of such changes.

2. Processing and Deletion of Personal Information

We process and utilize your personal information for a variety of reasons, depending on how you interact with our Services, including without limitation:

• To facilitate creation, authentication and logins relating to your account, and to otherwise manage all user accounts and keep same in working order.
• To request feedback and to communicate with you about your use of our Services.
• To transmit and deliver marketing and promotional communications, in accordance with your designated marketing preferences. You can opt out of our marketing emails at any time.
• To transmit and deliver targeted and/or personalized content and advertising, including without limitation as tailored to your interests, location, and other characteristics.
• To save or protect your or any individual's vital interest, including without limitation to prevent harm (as determined in Company's sole and absolute discretion).

To request to review, update, or delete your personal information, please visit https://swirlaiconnect.com, contact us by email at hello@swirlaiconnect.com or write to us at the address set forth in Section 11 below.

3. Legal Rationale for Processing Personal Information; Privacy Rights Regarding Personal Information; Consent Rights/Processes

We only process your personal information when we believe it is necessary and when we believe we have a valid legal basis to do so under applicable laws rules regulations, which may include without limitation with your consent, as required to comply with laws, rules and regulations, to provide you with the Services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. If you have questions or comments about your personal information and/or your privacy rights, you may email us at hello@swirlaiconnect.com or write to us at the address set forth in Section 11 below.

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If you are located in the European Union and/or United Kingdom, this section may apply:

The European Union General Data Protection Regulation (GDPR) and the United Kingdom GDPR require us to explain the valid legal bases Company relies upon in order to process your personal information, as follows:

Consent.

We may process your information if you have given us permission (i.e., consent) to use your personal information. You can withdraw your consent at any time, but such withdrawal may impact your ability to use and access the Services.

Legitimate Interests.

We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, and when those interests do not outweigh your interests and fundamental rights and freedoms. For example only, we may process your personal information in order to:

• Send you or other users information about special offers and discounts on our products and services
• Develop and display personalized and relevant advertising content for you or other users
• Understand how you or our other users use our products and services generally, and the Services, so that we can improve user experience

Legal Obligations.

We may process your information where we believe it is necessary for compliance with our legal obligations, including without limitation to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or relating to disclose of your or other information as evidence in the context of any litigation or other proceeding in which we are involved.

Vital Interests.

We may process your information where we believe it is necessary to protect your vital interests or the vital interests of any other third-party, such as situations involving potential threats to the safety of any person (as determined in the discretion of Company).

If you are located in Canada, this section may apply:

We can and 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 without limitation, and by way of example only:

• In the interests of you or any other an individual, and where consent cannot be obtained in a timely way
• For investigations, and the prevention and detection of fraud
• For transactions conducted by the Company in the ordinary course of business and under certain applicable conditions
• If it is contained in a witness statement, and the collection/processing is necessary or required 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, in our discretion, that you or any other individual has been, is, or may be a victim of financial abuse
• If it is reasonable to expect the collection and use of information 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 of Canada
• 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 applicable laws, rules and regulations

If you are located in California, this section may apply:

Residents of California are granted specific rights regarding access to personal information, including without limitation under California Civil Code Section 1798.83 (also known as the "Shine The Light" law) the California Consumer Privacy Act of 2018 ("CCPA"), and other California laws, statutes, rules and regulations (all, collectively, "California Laws"). Among other rights, California Laws provide as follows:

Our users who are California residents have the right 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 by email at hello@swirlaiconnect.com or in writing to the address set forth in Section 11 below.

If you are under 18 years of age, reside in California, and have a registered account with and for the Services, you have the right to request removal of unwanted data that you publicly post with or on the Services. To request removal of such data, please email us at hello@swirlaiconnect.com or write to us at the address set forth in Section 11 below, and please include the email address associated with your account and a statement that you reside in California. In response and subsequent to receipt of your communication, we will make sure the data is not publicly displayed on the Services; provided, however, that you acknowledge and agree that some or all of the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

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/or (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.

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

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.
• Category I – 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, by phone or by mail, in the context of:

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

If you are using an authorized agent to exercise your right to opt out of the use or retention of personal information, we may deny such a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

You further acknowledge and Agree that:

(1) We may disclose your personal information with and to our service providers, pursuant to a written contract between us and each such service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by California Laws.

(2) 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.

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

You have the right to 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 applicable laws, rules and regulations, 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.

Depending on the circumstances and applicable laws, rules and regulations, under California Laws you do or may 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; and
• the specific pieces of personal information we collected about you.

In accordance with California Laws, 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.

We will not discriminate against you if you exercise your privacy rights under California Laws or the laws, statutes, rules and/or regulations of any other geographic locale. We do not process any sensitive consumer personal information.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the personal information in our system. These verification efforts require us to ask you to provide certain personal and other 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, in our sole discretion.

We will only use personal information provided in your request to verify your identity and/or your 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 in our discretion. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights which may apply to you, including without limitation under California Laws, include the following:

• 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 you may 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 your rights under California Laws, you can contact us by email at hello@swirlaiconnect.com, or by writing to us at the address set forth in Section 11 below, 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.

If you are located in Virginia, this section may apply:

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 the foregoing definition of "Consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with Company and our Services.

Company has not sold any personal data to third parties for business or commercial purposes. Company will not sell personal data in the future belonging to website visitors, users, and other consumers.

For any questions or concerns, you may contact us by email at hello@swirlaiconnect.com, by visiting https://swirlaiconnect.com, or by writing to us at the address set forth in Section 11 below.

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, including without limitation under the VDCPA. 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 deemed reasonably necessary in Company's discretion. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

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 hello@swirlaiconnect.com or write to us at the address set forth in Section 11 below. 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 Virginia Attorney General to submit a complaint.

Additional Location-Specific Privacy Rights

In some geographic regions (such as the European Economic Area (EEA), United Kingdom (UK), and Canada), you do or may have certain rights that do or may allow you greater access to, and greater control over, your personal information. These rights do or may include rights to: (i) request access and obtain a copy of your personal information; (ii) request rectification or erasure relating to your personal information; (iii) to restrict the processing of your personal information; and/or (iv) data portability, if applicable. 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 emailing us at hello@swirlaiconnect.com or writing to us at the address set forth in Section 11 below. We will consider and act upon any such request you make, in accordance with applicable data protection laws.

If you are located in the EEA or UK, and you believe we are unlawfully processing your personal information, you also have the right to complain to your EEA Member State data protection authority, or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Consent Rights; Opting Out

If we are relying on your consent to process your personal information (which may be express and/or implied consent, depending on the applicable laws, rules and regulations), you have the right to withdraw your consent at any time. You can do so by emailing us at hello@swirlaiconnect.com or writing to us at the address set forth in Section 11 below, or by updating your preferences within the Service application.

Please note that any withdrawal of consent will not affect the lawfulness of the processing of personal information before such withdrawal. Nor, when applicable laws, rules and/or regulations allow, will such consent withdrawal affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You can elect to unsubscribe from our marketing and promotional communications, at any time, by clicking on the "unsubscribe" link in any of the emails that we send to you, or by emailing us at hello@swirlaiconnect.com or writing to us at the address set forth in Section 11 below.

You will subsequently be removed from our marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. We make no representations regarding your receipt of communications, or the termination of same, from third-parties.

4. Account Information

If you would, at any time, like to review or change the information in your account, or terminate your account, you can email us at hello@swirlaiconnect.com or write to us at the address set forth in Section 11 below. Upon our receipt of any request to terminate your account, we will deactivate or delete your account and personal information from our active databases. However, you acknowledge that we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

5. Business Transfer - Sharing of Personal Information

You acknowledge and agree that we may share or transfer your personal information in connection with, or during negotiations of or relating to, any merger, consolidation, corporate reorganization, sale of company assets, financing, or acquisition of all or a portion of our business, with or to another company.

6. General Retention of Personal Information

We will keep and maintain your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by applicable laws, rules or regulations (including without limitation for or relating to tax, accounting, or other legal requirements). Company generally is not required to and does not keep or maintain personal information for longer than the period of time in which users have an account with us.

As such point when Company has no ongoing legitimate business need or reason to process or maintain 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. Security of Personal Information

We have implemented appropriate and reasonable industry-standard technical and organizational security measures, which are designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your personal information, no electronic transmission over the Internet or information storage technology is or can be guaranteed to be 100% secure. Accordingly, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will be unable to defeat our security, and will be fully and completely prevented from improperly collecting, accessing, stealing, or modifying your personal information. Although we will always implement commercially-reasonable efforts to protect your personal information, the 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. Collection of Information from Minors; Marketing to Minors

We do not knowingly solicit data from, or market to, persons under 18 years of age. By using the Services, you represent and warrant that you are at least 18 years of age, or that you are the parent or guardian of such a minor/dependent and you 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 improperly or without appropriate consent, 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 persons under 18 years of age, please email us at hello@swirlaiconnect.com or write to us at the address set forth in Section 11 below.

9. 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, which 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 relating to the Services. 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 Policy.

10. Updates to this Privacy Policy

We will or may unilaterally update this Privacy Policy from time to time, in our discretion, including without limitation as necessary to stay compliant with relevant laws, statutes, rules and regulations. Any updated version of this Privacy Policy 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 Policy, 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 Policy frequently, in order to be informed of how we are protecting your personal information.

11. Company Contact Information

If you have questions or comments about this Privacy Policy, please email us at hello@swirlaiconnect.com, or communicate with us by mail to the following address: Swirl, Inc., 235 Bear Hill Rd, Suite 201, Waltham, MA 02451, United States of America.