CORTICO CORPORATION PRIVACY POLICY

Effective date: August 30, 2023

At Cortico and Fora (operated by Cortico), we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal information. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Cortico’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Privacy Policy by clicking here. If you have a disability, you may access this Privacy Policy in an alternative format by contacting help@cortico.ai.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Categories of Personal Data We Collect

The chart in this section details the categories of Personal Data that we collect and have collected over the past 12 months:

Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• “You”
  • When you provide such information directly to us.
  • When Personal Data about you is automatically collected in connection with your use of our Services (see the subsection titled “Information Collected Automatically” below).
• “Third Parties”
  • Third parties that provide us with Personal Data about you. Third Parties that share your Personal Data with us include:
    • Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
    • Community Partners. For example, we partner with third party community organizations to offer programming events.

Information Collected Automatically

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at https://google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

How We Use Your Personal Data

We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:

• To meet or fulfill the reason you provided the information to us.
• To communicate with you about the Services, including Service announcements, updates or offers.
• To provide support and assistance for the Services.
• To create and manage your Account or other user profiles.
• To personalize website content and communications based on your preferences, to respond to user inquiries and fulfill user requests.
• To improve and develop the Services, including testing, research, analysis and product development.
• To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.
• To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at help@cortico.ai.

How We Share Your Personal Data

Categories of Third Parties with Whom We Share Personal Data

We disclose your Personal Data as indicated in the chart above to the following categories of other parties:

• “Service Providers”
  • These are third parties that help us provide our Services, including security and fraud prevention providers, hosting and other technology and communications providers, analytics providers, and staff augmentation and contract personnel.
• “Community Partners”
  • These are third party community organizations that we partner with to offer programming events. If you attend a programming event that is organized with a community partner, we may ask for your consent to share your contact information with that partner.

Your Personal Data may also be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

Disclosures of Personal Data for a Business Purpose

We disclose your Personal Data to service providers and other parties for the following business purposes:

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
• Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling reservations, verifying customer information, providing analytic services, providing transcription services, or providing similar services on behalf of the business or service provider.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture (or that was manufactured for us) or control.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at help@cortico.ai.

We may collect Personal Data from children under 18; if that data is shared by their parent or legal guardian and in accordance with the Children’s Online Privacy Protection Act (“COPPA”). We do not knowingly collect or solicit personally identifiable information from children under 18 without obtaining verifiable consent from that child’s parent or guardian, except for the limited amount of personally identifiable information we need to collect in order to obtain parental consent (“Required Information”). Until we have received parental consent, we will only use Required Information for the purpose of obtaining parental consent. If we learn we have collected Personal Data from a child under 18, without parental or legal guardian consent, we will delete that information as quickly as possible. If you are a parent or legal guardian of a child that has used Fora, or if you believe that a child under 18 may have provided us Personal Data, please contact us at help@cortico.ai.

User Protection

We will not authorize Fora Content, and information derived from Fora Content, to be used by, or knowingly displayed, distributed, or otherwise made available to:

1. Any public sector entity (or any entities providing services to such entities) for surveillance purposes, including but not limited to:
   • investigating or tracking Fora users or their Fora Content; and,
   • tracking, alerting, or other monitoring of sensitive events (including but not limited to protests, rallies, or community organizing meetings);
2. Any public sector entity (or any entities providing services to such entities) whose primary function or mission includes conducting surveillance or gathering intelligence;
3. Any entity for the purposes of conducting or providing surveillance, analyses or research that isolates a group of individuals or any single individual for any unlawful or discriminatory purpose or in a manner that would be inconsistent with our users’ reasonable expectations of privacy;
4. Any entity to target, segment, or profile individuals based on health (including pregnancy), negative financial status or condition, political affiliation or beliefs, racial or ethnic origin, religious or philosophical affiliation or beliefs, sex life or sexual orientation, trade union membership, data relating to any alleged or actual commission of a crime, or any other sensitive categories of personal information prohibited by law;
5. Any entity that you reasonably believe will use such data to violate the Universal Declaration of Human Rights, including without limitation Articles 12, 18, or 19.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at help@cortico.ai.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.
• If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. To submit a request related to access, modification or deletion of your information, you can contact us through one of the points of contact at the bottom of this Privacy Policy or, if you are logged into your Cortico account, you can manage your privacy settings and other account features here. Please note that it may take a bit of time for privacy settings to be fully reflected throughout our systems. Under the CCPA, this right to deletion is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

• Right to Access: If you are a California resident, you have the right to request (up to twice per year), access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.
• Right to Delete: If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions as mentioned above.
• Right to Opt Out of Sale of Personal Information: If you are a California resident, you have the right to opt out of the sale of your personal information to third parties.

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, including your email address used for fora.io and the date and location of the conversation you participated in (if applicable) and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

• Call us at: 617-404-9812
• Email us at: help@cortico.ai

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Personal Data Sales Opt-Out and Opt-In

We will not sell your Personal Data, and have not done so over the last 12 months.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at help@cortico.ai.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at help@cortico.ai with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.