Conifer Labs, Inc

Privacy Policy

Effective Date: March 23, 2026

Conifer Labs, Inc, a Delaware corporation (“Company,” “we,” “us,” or “our”), provides this Privacy Policy to describe how we collect, use, disclose, and otherwise process personal information in connection with our public-facing websites, landing pages, marketing pages, events, webinars, communications, and any related online services that link to this Privacy Policy (collectively, the “Site”).

This Privacy Policy is intended to provide a comprehensive public-facing notice for visitors to our Site, prospective customers, business contacts, and others who interact with us through the Site.

If we later offer a hosted platform, free trial, community edition, or other product experience, our processing of information through those offerings may be governed by separate product terms, privacy notices, and customer agreements.

1. Scope

This Privacy Policy applies to personal information we collect when you:

* visit or use the Site; * request a demo or more information; * contact us; * register for an event, webinar, or mailing list; * download reports, white papers, or other materials; * communicate with our sales, marketing, or business teams; or * otherwise interact with us in a business context through the Site.

This Privacy Policy does not apply to:

* information we process on behalf of customers in providing our products or services, where the applicable customer agreement or product privacy notice governs; * applicant, employee, contractor, or other workforce data subject to separate notices; or * third-party websites, services, or applications that are not operated by us.

2. Personal Information We Collect

Depending on how you interact with us, we may collect the following categories of personal information:

Contact and professional information

Such as your name, business email address, telephone number, employer, job title, department, and business location.

Inquiry and communications information

Such as the contents of demo requests, contact forms, emails, event registrations, survey responses, webinar participation, and other communications with us.

Business and commercial context information

Such as your company name, company size, industry, purchase interest, technology environment, or other information you choose to provide in connection with your interest in our offerings.

Device, network, and usage information

Such as IP address, browser type, device type, operating system, language settings, referring URLs, pages viewed, links clicked, dates and times of access, and similar interaction data.

Cookie and similar technology information

Such as information collected through cookies, pixels, local storage, tags, and similar technologies used for Site operation, security, performance measurement, and limited analytics. Please see our Cookie Notice for more detail.

Event, subscription, and preference information

Such as newsletter sign-up status, event attendance, content download history, communication preferences, and inferred interest in our products or services based on your interactions with us.

Information from third parties

We may receive business contact information and related professional information from publicly available sources, event or marketing partners, referral sources, analytics providers, or service providers that support our business operations, where permitted by applicable law.

Sensitive personal information

We do not intend to collect sensitive personal information through the Site. Please do not submit sensitive personal information through the Site unless we specifically request it and it is appropriate to do so.

3. How We Collect Personal Information

We collect personal information:

* directly from you, such as when you fill out a form, request a demo, register for an event, or communicate with us; * automatically when you use the Site, including through cookies and similar technologies; * from service providers and business partners that support analytics, communications, event management, CRM, security, and related operations; and * from publicly available or other lawful third-party sources.

4. How We Use Personal Information

We may use personal information for the following purposes:

* to operate, maintain, secure, and improve the Site; * to respond to your requests, questions, and communications; * to provide demos, product information, and requested materials; * to communicate with you about our products, services, events, newsletters, and other business or marketing communications, subject to applicable law; * to manage relationships with prospective customers, partners, and other business contacts; * to analyze Site usage, performance, and engagement; * to personalize Site content and communications based on your interactions with us; * to detect, prevent, investigate, and respond to fraud, abuse, security incidents, and other unlawful or harmful activity; * to comply with legal obligations and enforce our legal rights; * to support internal business operations, audits, reporting, and corporate transactions; * to create aggregated, deidentified, or anonymized information; and * to use aggregated, deidentified, anonymized, and, where permitted by applicable law, personal information for security operations, analytics, service improvement, benchmarking, research, and the development, testing, validation, and improvement of automated, machine learning, and artificial intelligence-enabled tools, subject to applicable law and our internal privacy, security, and AI governance processes.

We do not use personal information submitted through the Site to make solely automated decisions that produce legal or similarly significant effects about individuals through the Site.

5. Legal Bases for Processing Under GDPR and Similar Laws

If the GDPR, UK GDPR, or similar law applies to our processing, we process personal data on one or more of the following legal bases:

* Legitimate interests, including operating and securing the Site, responding to business inquiries, managing prospective customer relationships, improving our Site and services, conducting analytics, preventing fraud, and supporting internal product and service development; * Consent, where required by law, including for certain cookies and certain marketing communications; * Steps taken at your request before entering into a contract, including responding to demo requests and commercial inquiries; and * Compliance with legal obligations, where processing is necessary to satisfy legal or regulatory requirements.

6. Cookies and Similar Technologies

We and our service providers may use cookies and similar technologies for the following purposes:

* operating the Site; * maintaining security and integrity; * remembering user preferences; * measuring traffic and Site performance; and * understanding how visitors use the Site.

We aim to maintain a narrow website data stack centered on Site operation, security, consent management, and limited analytics.

Where required by applicable law, we obtain consent before using non-essential cookies or similar technologies.

You can manage cookies through your browser settings and, where available, our cookie banner or preference center. Please see our Cookie Notice for additional details.

7. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients:

* affiliates and subsidiaries; * service providers that support hosting, infrastructure, security, analytics, communications, CRM, event management, and similar business functions; * professional advisors, such as auditors, lawyers, insurers, and consultants; * regulators, law enforcement, courts, and other parties where required by law or where necessary to protect rights, safety, and security; and * actual or prospective counterparties and advisors in connection with a merger, acquisition, financing, restructuring, asset sale, or other corporate transaction.

We may also disclose personal information with your direction or consent.

8. Sale, Sharing, and Targeted Advertising

We do not sell personal information for money.

We do not currently use the Site for cross-context behavioral advertising or retargeting based on personal information collected across nonaffiliated websites.

We currently aim to maintain a minimal adtech footprint and a narrow analytics stack. If we later implement advertising, retargeting, or similar technologies that trigger opt-out rights under applicable law, we will update this Privacy Policy and our Cookie Notice and provide any notices or controls required by law.

9. Aggregated, Deidentified, Anonymized, and AI-Related Use

We may aggregate, deidentify, or anonymize personal information so that it can no longer reasonably be used to identify an individual or household, and we may use and disclose such information for lawful business purposes, including security and fraud prevention, analytics, product development, service improvement, benchmarking, industry reporting, research, and the development, training, testing, validation, and improvement of automated systems, machine learning models, and other artificial intelligence-enabled tools.

Where we rely on deidentified or anonymized information, we will maintain measures designed to prevent reidentification and will not attempt to reidentify such information except as permitted by applicable law to test and verify our deidentification processes.

We may also use personal information, where permitted by applicable law, for product improvement, security operations, fraud detection, service optimization, internal analytics, and to develop, train, test, validate, or improve features and tools that use automation, machine learning, or artificial intelligence. Where those activities involve personal information, we will process such information subject to this Privacy Policy, our internal data governance and AI governance processes, and applicable legal requirements, including requirements relating to transparency, lawful basis, data minimization, security, and, where applicable, risk assessments, human oversight, and individual rights.

10. International Transfers

We are headquartered in the United States and may transfer, store, and process personal information in the United States and other countries where we or our service providers operate.

Where required by applicable law, we use an appropriate transfer mechanism for personal data transferred outside the EEA, UK, or Switzerland, such as adequacy decisions, Standard Contractual Clauses, the UK International Data Transfer Addendum, or another lawful mechanism.

If you are a customer or prospective customer and require a data processing agreement or information about our international transfer safeguards, please contact \[PRIVACY EMAIL\] or your Company representative.

11. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

* respond to inquiries and provide requested information; * maintain records of business interactions; * operate, improve, and secure the Site; * support sales, marketing, and business development activities; * comply with legal, accounting, and reporting obligations; * resolve disputes; and * establish, exercise, or defend legal claims.

Retention periods vary depending on the nature of the information, the context in which it was collected, and applicable legal requirements.

12. Your Privacy Rights

Depending on your jurisdiction and subject to applicable exceptions and verification requirements, you may have the right to:

* confirm whether we process your personal information; * access your personal information; * correct inaccuracies in your personal information; * delete your personal information; * obtain a portable copy of your personal information; * opt out of sale, sharing, targeted advertising, or certain profiling, where applicable; * object to certain processing; * withdraw consent where processing is based on consent; and * appeal a denial of your request, where applicable.

We will not discriminate against you for exercising privacy rights provided by applicable law.

13. California Privacy Rights

If you are a California resident, California law may provide you with the right to:

* know the categories and specific pieces of personal information we have collected about you; * know the categories of sources from which personal information is collected; * know the business or commercial purposes for collecting, using, and disclosing personal information; * know the categories of third parties to whom we disclose personal information; * request deletion of personal information; * request correction of inaccurate personal information; * opt out of sale or sharing of personal information, if applicable; and * not be discriminated against for exercising your rights.

We do not currently sell personal information for money and do not currently use the Site for cross-context behavioral advertising or retargeting in a manner intended to constitute “sharing” under California law.

If we process sensitive personal information, we use it only as permitted by applicable law unless we provide additional notice and choices.

14. Delaware and Other U.S. State Privacy Rights

Residents of Delaware and certain other states may have rights to access, correct, delete, and obtain a copy of their personal data, and to opt out of certain processing such as targeted advertising, sale of personal data, or certain profiling, subject to statutory thresholds, exemptions, and verification requirements.

Where required by applicable law, we provide secure and reliable means for individuals to submit privacy rights requests and will not require you to create a new account solely to submit a request.

15. EEA, UK, and Swiss Privacy Rights

If you are located in the EEA, UK, or Switzerland, and applicable law applies, you may have the right to:

* request access to your personal data; * request correction of inaccurate personal data; * request deletion of your personal data; * request restriction of processing; * object to our processing, including processing based on legitimate interests and direct marketing; * receive your personal data in a portable format; * withdraw consent at any time where processing is based on consent; and * lodge a complaint with the competent supervisory authority.

16. How to Exercise Your Rights

You may submit a privacy request by contacting us at:

Email: privacy@coniferlabs.ai

Please specify the right you want to exercise and provide enough information for us to verify your request.

We may need to verify your identity before fulfilling a request. You may also designate an authorized agent to make a request on your behalf where permitted by law.

If we deny your request and applicable law provides an appeal right, you may appeal by emailing privacy@coniferlabs.ai with the subject line “Privacy Rights Appeal.”

17. Security

We use administrative, technical, and physical safeguards designed to protect personal information appropriate to the nature of the information and the risks involved. No method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

18. Children’s Privacy

The Site is intended for business use and is not directed to children. We do not knowingly collect personal information from children through the Site. If you believe a child has provided personal information to us through the Site, contact us and we will take appropriate steps.

19. Third-Party Links and Services

The Site may contain links to third-party websites, services, or content. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of those third parties before providing information to them.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will post the updated version on the Site and revise the Effective Date above. Your continued use of the Site after the updated Privacy Policy becomes effective is subject to the revised Privacy Policy.

21. Contact Us

CONIFER LABS, INC Email: privacy@coniferlabs.ai Website: conifer.ai