This Privacy Policy describes how we collect, use, share and protect your personal data when you use our websites, applications, and other services that link to this Privacy Policy (collectively, the "Services").

Verdent AI, Inc. ("Verdent", "we" or "us") is the data controller responsible for processing your personal data as described in this Privacy Policy, in accordance with applicable data protection laws.

We collect the following categories of personal data:

We collect personal data if you create an account to use our Services or communicate with us. This includes:

1. Account Information: Verdent collects identifiers, such as your username and email address, when you sign up for a Verdent account or request information about our Services.

• When you sign up through Google: We collect your Google user ID (sub), full name, and email address.
• When you sign up through GitHub: We collect your GitHub user ID, username, and email address.
• When you sign up through Email: We collect your email address and a password that you create for your Verdent account.

2. Input and Output: We collect the content you input into the Services, including interactions with the large language model (LLM) and other AI-powered features. We also collect output generated by the Services in response. This data may be stored as part of your user history and associated with your Verdent account.

3. Code Repository Information: We do not access your code repositories unless you explicitly enable code indexing. If enabled, we store only embeddings for indexing purposes, not the original plaintext code. Additionally, embedding data that remains unused for a designated period will automatically expire and be deleted.

4. Purchase Information: If you access paid features or subscriptions, we may collect payment-related information, as necessary to complete the transaction.

5. Communication Information: If you communicate with us, including to provide feedback or suggestions ("Feedback"), we collect your name, contact information, and the content of any messages you send.

6. Other Information You Provide: We collect other information that you may provide to us, such as when you participate in events or surveys.

When you use the Services, we also receive certain technical data automatically. This includes:

1. Device and Network Information: Your device or browser automatically sends us information about when and how you install, access, or use our Services. This information may include unique identifiers and internet activity information regarding your interactions with the Services. This information may depend on your settings and the type of device you use to access the Services.

2. Log Information: We collect information about how our Services are performing, including your unique identifiers, error logs and other internet activity information regarding your interactions with the Services.

3. Usage Data: We collect information about your use of the Services, including internet activity information regarding your interaction with the Services, as well as technology on the devices you use to access the Services.

4. Cookies & Similar Technologies: We and our service providers utilize cookies, pixels, scripts, or similar technologies to operate and manage the Services and improve your experience. These technologies help us to recognize you, customize or personalize your experience, market additional products or services to you, and analyze and optimize your use of the Services, for example, to help maintain your preferences. You can control cookies through your browser settings and other tools.

Verdent does not knowingly collect sensitive or special category personal data, such as genetic data, biometric data for the purposes of uniquely identifying a natural person, health information, or religious information—unless explicitly required for testing purposes and subject to appropriate safeguards, including obtaining explicit consent where required by applicable law.

Verdent does not knowingly collect personal data from individuals under the age of 18, or under the age of majority in your jurisdiction, nor do we direct our Services or content to such individuals. If you are under the age of 18, or under the age of majority in your jurisdiction, please do not use our Services or provide any personal data.

If we learn or have reason to suspect that a user is under the age of 18, or under the age of majority in your jurisdiction, we will investigate and, if appropriate, delete the personal data and/or the account.

We may utilize personal data for the following purposes:

To deliver and maintain the Services, including optional functionalities that boost capabilities and user experience;

To establish, oversee, and manage your account—this includes facilitating payment processes and addressing your inquiries;

To enhance and evolve the Services, as well as conduct research; this encompasses debugging and pinpointing or fixing issues that hinder functionality;

To engage with you, such as sending updates, details about the Services, and event-related information;

To fend off, identify, and probe into fraud, misuse, security incidents, and breaches of our Terms of Services;

To adhere to legal duties and safeguard the rights, safety, privacy, and assets of users, us, or third parties;

To look into and resolve disputes or security-related matters.

Your Input and Output will not be used for model training unless you have provided your explicit consent. We may aggregate or de-identify personal data so that it no longer identifies you and use this information for the purposes described above, such as to analyze the way our Services are being used, to improve and add features to them, and to conduct research. We will maintain and use de-identified information in de-identified form and not attempt to reidentify the information, unless required by law.

We store your personal data on servers located within the United States.

If you access the Services from outside the U.S., your personal data may be transferred to and processed in the United States or other jurisdictions. Any such transfers are conducted in accordance with applicable data protection laws, and where required, appropriate safeguards are implemented to protect your data.

We retain your personal data only for as long as necessary to operate the Services effectively and to support legitimate business needs, including legal compliance, security, dispute resolution, and enforcement of our agreements.

The appropriate retention period varies depending on the purpose for which the personal data was collected, its sensitivity, potential risks associated with its use or exposure, and any applicable legal requirements.

When personal data is no longer needed, we will follow procedures to delete, erase, de-identify, or anonymize it in compliance with applicable laws.

We may share your Personal Data in the following circumstances:

1. Service Providers and Business Partners: We may disclose personal data to third-party vendors and service providers that support our operations and help us deliver the Services.

2. Business Transfers: In the event of a merger, acquisition, restructuring, bankruptcy, or other corporate transaction, personal data may be disclosed to counterparties and advisers as part of due diligence or transferred as part of the transaction.

3. Affiliates: We may share personal data with affiliates, meaning an entity that controls, is controlled by, or is under common control with, us. They may use personal data in a manner consistent with this Privacy Policy.

4. Legal Compliance and Protection of Rights: We may share your personal data with government authorities, regulators, or other third parties, if we believe in good faith that such disclosure is necessary: (i) comply with legal obligations or respond to lawful requests; (ii) protect or defend our rights, property, or safety, or those of others; (iii) detect or prevent fraud or other illegal activity; (iv) protect the safety, security, and integrity of our products, employees, users, or the public, or (v) protect against legal liability.

5. Third-Party Services and Integrations: The Services may include links or integrations with third-party websites, applications, or platforms. If you choose to interact with them, your personal data may be disclosed to those third parties and will be governed by their respective terms and privacy policies. Our integration with such third parties does not imply our endorsement or control over their practices.

6. Other Users and Third Parties You Share Information With: Some features of the Services may allow you to share Input, Output, or other content with other users or third-party platforms. Any information you choose to share is subject to those parties' own terms and privacy policies.

7. With Your Consent: We may share your information for other purposes pursuant to your consent or at your direction.

We take reasonable measures to protect your information from unauthorized access, use, or disclosure. However, no method of transmission over the internet, or method of electronic storage, is completely secure.

The Services may, from time to time, contain links to policies, functionality, or content maintained by third parties that we do not control. We are not responsible for, and make no representations regarding, such third-party policies or practices.

We may update this Privacy Policy from time to time. When we do, we will publish an updated version and effective date on this page, unless another type of notice is required by applicable law.

We recommend that you review the Privacy Policy from time to time to stay informed of our privacy practices. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

If you have any questions, comments, or requests regarding this Privacy Policy, please contact us at: hi@verdent.ai.

Some jurisdictions require specific disclosures regarding how we handle your personal data. The table below supplements this Privacy Policy by providing additional details about the purpose of data collection, type of data collected, and legal basis. For more information, see "WHAT INFORMATION DO WE COLLECT FROM YOU?", "HOW DO WE USE YOUR INFORMATION?", "HOW DO WE STORE YOUR INFORMATION?" and "HOW DO WE SHARE YOUR INFORMATION?" above.

1. Legal bases for processing. We use your personal data when we have a "legal basis" to do so. Our legal bases for processing your personal data described in this Privacy Policy are described in the table below.

2. Cross-Border Transfer of Personal Data. To support our global operations:

• We may store the personal data described in the "WHAT INFORMATION DO WE COLLECT FROM YOU?" section in servers located in the United States.

• Certain entities in our Corporate Group which are located outside the country where the data was collected may be given limited remote access to your personal data so they can provide certain functions, as described in the Our Corporate Group section in "How We Share Your Information".

• We may share the information as identified in "WHAT INFORMATION DO WE COLLECT FROM YOU?" with service providers and other third party entities located outside your country or region of residence, as described in "How We Share Your Information".

• When we transfer your personal data outside of the EEA, the UK, or Switzerland, we ensure it benefits from an adequate level of data protection by relying on adequacy decisions or standard contractual clauses. Further detail is provided below:

Adequacy decisions. These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognize that a country offers an adequate level of data protection.

Standard contractual clauses. The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses.

If you wish to enquire further about these safeguards, please contact us at: hi@verdent.ai.

3. Your rights

• The right to request confirmation of whether we process your personal data and access to a copy of the personal data retained by us.

• The right to request to update or request deletion of your personal data or restrict processing of your personal data.

• Where processing of your personal data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or to have your personal data transmitted directly to another company, where technically feasible.

• Where the processing of your personal data is based on your consent, the right to withdraw your consent at any time. Withdrawing your consent will not impact the lawfulness of any processing activities that have taken place before such withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

• The right not to be subject to any automatic individual decisions, including profiling, which produces legal effects on you or similarly significantly affects you unless we have your consent, this is authorised by European Union or local law, or this is necessary for the performance of a contract.

• The right to object to processing of your personal data on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing.

• You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.

• The right to opt-out of marketing communications at any time. If you choose to opt out of marketing communications, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations.

• The right to complain to a supervisory authority about our collection and use of your personal data. For more information, please contact your local supervisory authority at the contact details https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm (for the EU) and https://ico.org.uk/make-a-complaint/data-protection-complaints/ (for the UK). Certain supervisory authorities will require that you exhaust our own internal complaints process before looking into your complaint.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details. To exercise any of your rights, contact us at: hi@verdent.ai.

1. Data Retention: We retain your personal data only for as long as necessary to operate the Services effectively and to support legitimate business needs, including legal compliance, security, dispute resolution, and enforcement of our agreements. For data subject to statutory retention periods under applicable laws, we store such data, where applicable, in compliance with the following requirements, including but not limited to:

Act on Consumer Protection in Electronic Commerce

• Records on cancellation of orders, payment for purchased item, and the supply of goods or service: 5 years.

• Records on the handling of consumer complaints or dispute resolution: 3 years.

• Records on advertisements and labeling: 6 months.

Protection of Communications Secrets Act

• Records of computer communications, internet log data, and data tracing access location: 3 months.

2. Deletion of Personal Data: We delete personal data whose purposes you have consented to have been fulfilled, or when the retention period stipulated by applicable laws or in the Privacy Policy has expired.

3. Your Rights

You have the right to request access to, transfer of, correction, deletion, suspension of processing, and withdrawal of your personal data.

To exercise these rights, please contact us at: hi@verdent.ai. We may require you to verify your identity before responding to your request.

4. Data Security

We implement necessary and appropriate security measures to protect personal data from unauthorized access, alteration, disclosure, or destruction.

5. Cross-Border Transfer of Personal Data

To provide you with the Services, in accordance with Article 28-8, Paragraph 1, Item 1 of the Personal Information Protection Act, your personal data may be transferred to or processed on servers or data centers located in the United States or other jurisdictions, in whole or in part.

You may opt out of such transfers, unless they are necessary to provide the Services, by contacting us at: hi@verdent.ai.

1. Data Retention: We retain your personal data only for as long as necessary to operate the Services effectively and to support legitimate business needs, including legal compliance, security, dispute resolution, and enforcement of our agreements. For data subject to statutory retention periods under applicable laws, we store such data, where applicable, in compliance with the following requirements, including but not limited to:

Under the Act on the Protection of Personal Information (APPI): Personal data is retained only for the period necessary to achieve the purpose of use, unless a longer retention period is required by law.

2. Deletion of Personal Data

We delete personal data when it is no longer necessary for use or when the statutory retention periods have expired.

3. Your Rights

You have the following rights regarding your personal data under the APPI:

• Right to Access: Request disclosure of your personal data in a tangible form, such as electronic records.

• Right to Rectify: Request correction or addition of inaccurate personal data.

• Right to Delete: Request deletion of your personal data, subject to legal exceptions.

• Right to Stop Use: Request that we stop using your personal data in specific circumstances (e.g., if the data is unlawfully processed).

• Right to Stop Providing to Third Parties: Request that we stop providing your personal data to third parties.

To exercise these rights, please contact us at: hi@verdent.ai. We may require you to verify your identity before responding to your request.

4. Data Security

We implement necessary and appropriate security measures to protect personal data from unauthorized access, alteration, disclosure, or destruction.

5. Cross-Border Transfer of Personal Data

Your personal data may be transferred to or processed on servers or data centers located in the United States or other jurisdictions, in whole or in part. For an overview of the applicable data protection legal framework, please click https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku.

You may opt out of such transfers, unless they are necessary to provide the Services, by contacting us at: hi@verdent.ai.