PRIVACY POLICY

Effective Date: May 29, 2026
Last Updated: May 29, 2026

1. WHO WE ARE AND SCOPE OF THIS POLICY

This Privacy Policy explains how Actuality Live Inc. (“Actuality”, “we”, “us”, or “our”) collects, uses, shares, and protects personal information when you use our website, platform, and related services (the “Services”).

Actuality is incorporated in Delaware, USA, with operations in Burlington, Ontario, Canada. This policy applies to information processed in connection with the Services. Where we process personal information on behalf of a customer as a service provider/processor (for example, personal information contained in uploaded RFPs or personnel records), our handling is governed by our agreement with that customer; this policy describes our practices as a controller/business for information we collect directly.

Privacy Officer. We have designated a Privacy Officer responsible for our compliance with applicable privacy laws, including PIPEDA and Quebec's Law 25. You may contact them at hello@actuality.live (Attn: Privacy Officer).

2. INFORMATION WE COLLECT

a. Information you provide directly:

• Account information: name, email address, phone number, company name, job title, and billing/payment details.
• Customer Content: documents, data, and materials you upload or generate, such as RFPs, proposals, resumes, project records, and personnel information.
• Communications: records of your interactions with our team and any feedback you provide.

b. Information collected automatically:

• Usage data: how you interact with the Services, including IP address, browser type, pages viewed, and timestamps.
• Device information: hardware model, operating system, and device identifiers.
• Cookies and similar technologies: used to operate the Services and understand usage. Cookies are retained for up to 12 months. See Section 11.

c. Information from third parties:

• Integrations: if you connect third-party tools (for example, Procore, Revit, Gmail, or Outlook), we may receive data from them as directed by you and in accordance with their privacy practices.

3. HOW WE USE YOUR INFORMATION

We use personal information to:

• Provide, operate, secure, and improve the Services;
• Process transactions and manage subscriptions;
• Personalize and support your experience;
• Communicate with you about updates, support, and (with your consent where required) promotional materials, from which you can opt out;
• Maintain the security and integrity of the platform; and
• Comply with legal obligations and resolve disputes.

Legal bases for processing (where applicable): your consent; performance of a contract with you; compliance with legal obligations; and our legitimate business interests, balanced against your rights.

4. AI PROCESSING AND OUR NO-TRAINING COMMITMENT

The Services use artificial intelligence to generate draft content from the information you provide. We want to be explicit about how this works:

• We do not use your Customer Content to train, fine-tune, or develop generalized or foundation AI/ML models.
• We contract with our AI model providers under terms that prohibit them from using your Customer Content to train their models.
• Your Customer Content is processed solely to provide the Services to you.
• Any analytics we use to improve the Services rely only on de-identified or aggregated usage metadata and never expose the substance of your Customer Content.

We may create de-identified and aggregated information from data processed through the Services. Once de-identified, such information is no longer personal information, and we may retain and use it for any lawful business purpose, including operating, securing, analyzing, and improving the Services. We maintain de-identified information without attempting to re-identify it.

Automated decision-making. Our AI Features generate drafts and recommendations as an aid; they do not make legally or similarly significant decisions about you without human involvement. Where applicable law gives you rights regarding automated decision-making or profiling, you may request human review by contacting us.

5. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We share information only as described here:

• Service providers / subprocessors: vendors who help us deliver the Services (such as cloud hosting, AI model providers, payment processing, and analytics), bound by contractual confidentiality and data-protection obligations. See Section 6.
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets.
• Legal obligations: when required by law or valid legal process, or to protect our rights, safety, or property or that of others.
• With your consent: when you direct or authorize us to share.

We may disclose aggregated or de-identified information that cannot reasonably identify you.

6. SUBPROCESSORS

We engage trusted third parties to process information on our behalf. Our current subprocessors include:

We maintain written data-processing agreements with our subprocessors that prohibit them from using your Customer Content to train AI models or for any purpose other than providing services to us. We will update this list when it changes; you may request advance notice of changes by emailing hello@actuality.live.

7. INTERNATIONAL DATA TRANSFERS

Your information may be processed in the United States and other countries that may have different data-protection laws than your own. Where we transfer personal information across borders — including from Canada or the EEA/UK to the United States — we use appropriate safeguards, such as Standard Contractual Clauses and, where required, Transfer Impact Assessments, and we comply with applicable cross-border transfer requirements under PIPEDA and Quebec's Law 25.

8. DATA RETENTION

We retain personal information only as long as necessary to fulfill the purposes described in this policy, to maintain our business relationship with you, and to comply with legal obligations. When information is no longer needed, we securely delete or anonymize it. Customer Content is retained per your subscription and is available for export for a limited period after termination, after which it may be deleted.

9. DATA SECURITY AND BREACH NOTIFICATION

We use technical and organizational measures designed to protect personal information, including encryption in transit (SSL/TLS) and at rest for sensitive data, access controls, and monitoring. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Use strong passwords and protect your credentials.

If a breach affecting your personal information occurs, we will notify affected individuals and applicable regulators (including, where required, the relevant data-protection authority and, for Quebec residents, the Commission d'accès à l'information) as required by applicable law and without undue delay, describing the nature of the incident and our response.

10. YOUR RIGHTS AND CHOICES

Depending on where you live, you may have rights to:

• Access a copy of your personal information;
• Correct inaccurate or incomplete information;
• Delete your personal information in certain circumstances;
• Object to or restrict certain processing, including direct marketing;
• Data portability — receive your data in a structured, machine-readable format;
• Withdraw consent where processing is based on consent; and
• Lodge a complaint with your data-protection authority.

To exercise these rights, contact us at hello@actuality.live. We will respond as required by applicable law and may need to verify your identity.

Do Not Track. Our Services do not currently respond to browser "Do Not Track" signals. You can manage tracking through your browser and our cookie controls.

EEA / UK Residents (GDPR)

You have the rights listed above and may contact your supervisory authority. Our legal bases are described in Section 3.

California Residents (CCPA/CPRA)

You may request disclosure of the categories and specific pieces of personal information we collect, request deletion or correction, and opt out of any "sale" or "sharing" of personal information (we do not sell or share your personal information as those terms are defined). We will not discriminate against you for exercising these rights.

Canada (PIPEDA)

You have the right to access and correct your personal information and to withdraw consent (subject to legal or contractual restrictions). Our Privacy Officer oversees compliance and handles requests and complaints. You may also contact the Office of the Privacy Commissioner of Canada.

Quebec Residents (Law 25)

In addition to the rights above, you have the right to data portability, the right to request that we stop disseminating your information, and rights concerning automated decision-making. Our Privacy Officer is the contact for Law 25 matters. You may file a complaint with the Commission d'accès à l'information du Québec.

11. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to operate the Services, remember preferences, and analyze usage. You can manage cookies through your browser settings. Where required by law (including for Quebec residents under Law 25), non-essential tracking technologies are enabled only with your consent via our cookie controls. Disabling some cookies may affect functionality.

12. CHILDREN'S PRIVACY

The Services are not intended for anyone under 18, and we do not knowingly collect personal information from minors. If you believe we have collected information from a minor, contact us at hello@actuality.live and we will delete it.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. For material changes, we will post the updated policy with a new "Last Updated" date and, where appropriate, notify you directly. Continued use of the Services after changes take effect constitutes acceptance.

14. CONTACT US

Questions, concerns, or requests regarding this Privacy Policy or our data practices:

Actuality Live Inc. — Attn: Privacy Officer
2337 Sutton Drive, Burlington, Ontario, Canada
Email: hello@actuality.live