AWEN PRIVACY NOTICE

Effective date: 25 August 2026

Awen AI Corporation ("Awen," "we," "us" or "our") respects the privacy of the individuals whose Personal Data we process.

This Privacy Notice explains how we collect, use, store, disclose and protect Personal Data when you access or use Awen's websites, applications, artificial-intelligence platform, products and related services (collectively, the "Services").

It also explains how Awen handles Personal Data contained in prompts, uploaded materials, generated content, account records, provenance information and rights or safety complaints.

1. We do not train on your data

Your work is not our training data.

Awen does not use your prompts, uploaded files, projects, Brain Content, generated outputs or other content processed through the Services to train, fine-tune, retrain or otherwise update the parameters of artificial-intelligence or machine-learning models.

This protection applies to every Awen User, including Users of free, individual, team and enterprise Plans. You do not need to opt out or enter into a separate Data Processing Agreement for this protection to apply.

When Awen uses third-party model providers or subprocessors to process your content, we take commercially reasonable measures to require them not to use that content to train, fine-tune, retrain or otherwise improve their models.

Where technical controls or provider configurations are available, Awen uses configurations designed to prevent Customer Content from being used for model training or improvement.

Awen does not knowingly route Customer Content through a provider, product or configuration that permits Customer Content to be used to train, fine-tune, retrain or otherwise update or improve an artificial-intelligence or machine-learning model.

If we become aware that a provider has used Customer Content in violation of these restrictions, we will take reasonable and prompt steps to stop the unauthorized use, prevent further unauthorized processing, investigate the circumstances and take appropriate remedial action.

Awen may create embeddings, indexes, temporary caches, retrieval systems or similar technical resources where necessary to provide features requested by a Customer or User. These processes are used to provide the Services and are not used to train or update model parameters.

Awen may use technical identifiers, service-performance information, error information, security signals and aggregated or anonymized operational information to operate, secure and improve the Services where that information:

(a) does not contain the substance of Customer Content;

(b) cannot reasonably be used to identify a Customer or User; and

Enterprise Customers may enter into a Data Processing Agreement or another written agreement with Awen that provides additional protections. The no-training commitment described above applies independently to all Customers and Users.

2. Scope of this Privacy Notice

This Privacy Notice applies to Personal Data Awen processes in connection with:

(a) the Awen website and applications;

(b) creation and administration of Awen Accounts;

(d) use of Awen's artificial-intelligence and creative tools;

(e) prompts, Inputs and Output Content;

(f) projects, workspaces, Brains and related functionality;

(g) support and communications;

(h) security, fraud prevention and abuse prevention;

(i) provenance, lineage, audit and safety functionality;

(j) reports, complaints, claims and legal requests; and

(k) sales, demonstrations and other interactions with Awen.

"Personal Data" means information relating to an identified or identifiable individual and includes equivalent concepts such as "personal information" where applicable privacy law uses different terminology.

Capitalized terms not defined in this Privacy Notice have the meanings given to them in Awen's Terms of Use.

3. Our roles when processing Personal Data

Awen can process Personal Data in different legal capacities depending on the circumstances.

3.1 Awen as controller

Awen generally acts as an independent controller, business or equivalent responsible party for Personal Data used for purposes including:

(a) Account creation and administration;

(b) billing and subscription management;

(d) security and fraud prevention;

(e) abuse detection and enforcement;

(f) communications;

(g) support;

(h) operation of Awen's website;

(i) rights, safety and abuse complaints;

(j) establishment, exercise or defence of legal claims;

(k) legal and regulatory compliance; and

(l) Awen's legitimate business administration.

3.2 Awen as processor

Where a Customer submits or processes Personal Data contained in Customer Content through the Services for its own purposes, the Customer will generally determine the purposes and means of that processing.

In those circumstances:

(a) the Customer generally acts as controller, business or equivalent responsible party; and

(b) Awen generally acts as processor, service provider or equivalent processor on the Customer's behalf.

Where applicable, Awen's Data Processing Agreement governs that processing.

If your Personal Data was submitted to Awen by an organization using the Services, you may need to contact that organization directly regarding requests concerning Personal Data for which that organization acts as controller.

4. Personal Data we collect

Depending on how you interact with Awen, we may process the following categories of Personal Data.

4.1 Account and identity information

This may include:

(a) name;

(b) username;

(d) telephone number;

(e) company or organization;

(f) job title;

(g) country or region;

(h) Account identifiers;

(i) authentication information; and

(j) age, identity or authority verification information where verification is required.

4.2 Subscription, transaction and billing information

This may include:

(a) subscription and Plan information;

(b) billing address;

(d) payment status;

(e) invoices;

(f) refunds;

(g) purchase history; and

(h) limited payment-method information received from payment providers.

Payment-card information may be processed directly by our payment providers rather than stored by Awen.

4.3 Customer Content

Depending on how you use the Services, Customer Content may contain Personal Data.

This may include Personal Data appearing in:

(a) prompts;

(b) instructions;

(d) photographs and images;

(e) video;

(f) audio and voice recordings;

(g) designs;

(h) references;

(i) project materials;

(j) Brain Content;

(k) generated or edited Output Content; and

(l) other information submitted to or processed through the Services.

Customers and Users determine the content they submit to the Services and must ensure that they have an appropriate legal basis and any rights or permissions required to submit Personal Data relating to other individuals.

4.4 Human likeness, voice and identity information

Customer Content may contain information relating to an identifiable person's:

(a) face;

(b) image;

(d) likeness;

(e) voice;

(f) performance;

(g) signature;

(h) persona;

(i) identity characteristics; or

(j) other indicia of identity.

Depending on the circumstances and applicable law, some information may constitute sensitive Personal Data or biometric information.

Awen does not characterize all images, voices or likenesses as biometric identifiers merely because they depict or relate to a person. Classification depends on the nature and purpose of the processing and applicable law.

4.5 Usage and technical information

When you use the Services, we may automatically collect information such as:

(a) IP address;

(b) device and browser information;

(d) Account and session identifiers;

(e) timestamps;

(f) authentication events;

(g) feature usage;

(h) request and response metadata;

(i) model and workflow selections;

(j) capacity and usage information;

(k) error and performance information;

(l) security events;

(m) network information; and

(n) similar technical logs and telemetry.

4.6 Generation, provenance and lineage information

Where supported by the Services, we may process records associated with generation, editing and transformation operations, such as:

(a) prompts and Inputs;

(b) Output Content;

(d) model information;

(e) workflow steps;

(f) editing or transformation history;

(g) asset identifiers;

(h) provenance metadata;

(i) machine-readable authenticity or AI-generation indicators;

(j) content credentials; and

(k) other lineage or audit information.

This information may be associated with an Account or User and may therefore constitute Personal Data.

4.7 Communications and support information

When you contact Awen, we may process:

(a) your contact information;

(b) support requests;

(d) feedback;

(e) call or meeting information where applicable; and

(f) information you provide in connection with troubleshooting or support.

4.8 Rights, safety and abuse complaint information

If you submit, are the subject of, or are otherwise involved in a rights, safety or abuse complaint, we may process information such as:

(a) your name and contact details;

(b) evidence of identity;

(d) identification of disputed content;

(e) URLs, asset identifiers or Account information;

(f) allegations and descriptions of the relevant conduct;

(g) evidence of ownership, consent, authorization or other legal rights;

(h) copies or descriptions of disputed content;

(i) correspondence concerning the complaint;

(j) legal notices or demands;

(k) information provided by the Customer or User responding to the complaint; and

(l) other information reasonably necessary to investigate or address the matter.

4.9 Prospect and business-contact information

If you request a demonstration, contact our sales team or otherwise engage with Awen in a business context, we may process:

(a) name;

(b) professional email address;

(d) job title;

(e) telephone number;

(f) correspondence; and

(g) information concerning your interest in the Services.

4.10 Website and cookie information

Depending on your choices and applicable law, Awen may use cookies and similar technologies for:

(a) functionality;

(b) authentication;

(d) analytics;

(e) security; and

(f) marketing.

Where consent is required by law, non-essential cookies or similar technologies will be used only in accordance with the consent choices made available to you.

5. Where we obtain Personal Data

We may obtain Personal Data:

(a) directly from you;

(b) from the Customer or organization through which you access the Services;

(d) automatically from your device or use of the Services;

(e) from payment, authentication, infrastructure, security and other service providers;

(f) from model providers where information concerning a generation or processing operation is returned to Awen;

(g) from complainants, rights holders or their authorized representatives;

(h) from courts, regulators, law-enforcement agencies or other authorities;

(i) from business partners where legally permitted; and

(j) from publicly available sources where reasonably necessary to verify information, investigate misuse, protect rights or comply with law.

6. Why we process Personal Data

Awen processes Personal Data only where there is an appropriate legal basis under applicable law.

Depending on the circumstances, the purposes and legal bases may include the following.

6.1 Providing the Services

We process Personal Data to:

(a) create and maintain Accounts;

(b) authenticate Users;

(d) process Inputs;

(e) generate Output Content;

(f) operate projects, workspaces and Brains;

(g) save and retrieve content;

(h) provide collaboration functionality;

(i) administer subscriptions;

(j) manage capacity and usage; and

(k) provide technical support.

Where applicable, this processing is necessary to perform our contract with you or to take steps at your request before entering into a contract.

Where Awen processes Personal Data on a Customer's behalf, processing is performed in accordance with the Customer's instructions and applicable Data Processing Agreement.

6.2 Security and fraud prevention

We may process Personal Data to:

(a) authenticate Accounts;

(b) detect unauthorized access;

(d) prevent fraud;

(e) detect identity abuse;

(f) prevent misuse of payment systems;

(g) enforce rate limits and safety measures;

(h) detect malicious automation; and

(i) protect the integrity of the Services.

Depending on the circumstances, this processing may be necessary for our legitimate interests, the legitimate interests of Customers and Users, performance of our contractual obligations or compliance with legal obligations.

6.3 Safety, abuse prevention and enforcement

We may process Personal Data to:

(a) detect suspected violations of the Terms of Use;

(b) prevent prohibited or unlawful activity;

(d) protect individuals from identity abuse or impersonation;

(e) investigate potential misuse of Synthetic Media or deepfakes;

(f) restrict or suspend harmful activity;

(g) preserve relevant evidence; and

(h) enforce our Terms, policies and provider restrictions.

We generally rely on our legitimate interests and the legitimate interests of Customers, Users and affected third parties in operating a safe and lawful service, preventing abuse and protecting legal rights.

Where applicable, we may also process information to comply with legal obligations.

6.4 Rights complaints and protection of third parties

Where Awen receives a complaint concerning alleged infringement, privacy, publicity, personality, Identity Rights, unauthorized Synthetic Media, impersonation, fraud, nonconsensual intimate imagery, harassment or another legal or safety issue, we may process Personal Data to:

(a) receive and authenticate the complaint;

(b) identify the relevant content or Account;

(d) determine whether interim protective action is appropriate;

(e) request evidence of rights, consent or authorization;

(f) communicate with the complainant and relevant Customer or User;

(g) prevent continuing harm;

(h) preserve information relevant to a dispute;

(i) establish, exercise or defend legal claims;

(j) respond to valid legal process; and

(k) comply with legal or regulatory obligations.

Depending on the circumstances, this processing may be based on:

(a) Awen's legitimate interests;

(b) the legitimate interests of an affected person or other third party;

(d) establishment, exercise or defence of legal claims;

(e) protection of vital interests where applicable; or

(f) another legal basis permitted by applicable law.

Awen assesses the necessity and proportionality of processing where required by applicable data-protection law.

6.5 Establishment, exercise and defence of legal claims

We may process and preserve Personal Data where reasonably necessary to:

(a) investigate an anticipated or existing dispute;

(b) establish facts;

(d) enforce contractual rights;

(e) defend Awen, a Customer, User or other person against a claim;

(f) pursue a legal remedy; or

(g) respond to litigation, arbitration or another proceeding.

Where Personal Data would otherwise be deleted, we may preserve it where applicable law permits or requires retention in connection with an existing or reasonably anticipated legal claim.

6.6 Legal and regulatory compliance

We may process Personal Data to:

(a) comply with laws and regulations;

(b) respond to court orders, subpoenas and other valid legal process;

(d) comply with tax, accounting and corporate obligations;

(e) prevent or report unlawful activity where required;

(f) comply with sanctions or other legally required screening; and

(g) satisfy mandatory preservation, reporting, removal or disclosure obligations.

The legal basis is generally compliance with a legal obligation or another basis permitted by applicable law.

6.7 Billing and commercial administration

We process Personal Data to:

(a) administer subscriptions and Orders;

(b) issue invoices;

(d) manage unpaid amounts;

(e) maintain financial records; and

(f) manage our commercial relationship with Customers.

This processing may be necessary for performance of our contract, compliance with legal obligations or our legitimate interests in operating our business.

6.8 Service operation and improvement

Awen may process technical and operational information to:

(a) diagnose errors;

(b) measure performance;

(d) maintain infrastructure;

(e) improve reliability;

(f) allocate capacity;

(g) improve security; and

(h) develop and improve the functionality of the Services.

Awen does not use Customer Content to train artificial-intelligence or machine-learning models.

Where possible, information used for operational analytics is aggregated or anonymized.

6.9 Communications and marketing

We may process contact information to:

(a) provide service and Account communications;

(b) notify you about changes affecting the Services;

(d) invite business contacts to events or demonstrations; and

(e) send marketing communications where permitted by applicable law.

Depending on the circumstances, the legal basis may be contract, consent or Awen's legitimate interest in communicating with existing or prospective business customers.

You may unsubscribe from marketing communications using the method provided in the relevant communication.

7. Rights complaints and disclosure of User information

Awen takes claims involving unauthorized use of a person's image, likeness, voice, identity or other rights seriously.

This section explains how Personal Data may be handled when a third party alleges that an Awen User has violated their rights.

7.1 Investigation and preservation

When we receive or reasonably anticipate a credible complaint, dispute, legal demand, safety matter or legal claim, Awen may preserve and review information reasonably relevant to that matter.

This may include:

(a) Inputs and prompts;

(b) Output Content;

(d) provenance and lineage information;

(e) Account information;

(f) email or other contact information;

(g) identity or authority verification information;

(h) IP addresses and relevant technical identifiers;

(i) timestamps and logs;

(j) security and fraud-prevention information;

(k) model or workflow information;

(l) subscription and billing records where relevant; and

(m) relevant communications with Awen.

Preservation may continue notwithstanding deletion of the affected asset, closure of an Account, termination of a subscription or an otherwise applicable deletion schedule where preservation is legally permitted or required.

7.2 Information we may provide to the affected User

Awen may provide a Customer or User with information about a complaint where reasonably necessary to allow that person to understand and respond to the allegation.

This may include information concerning:

(a) the nature of the complaint;

(b) the disputed content;

(d) relevant evidence supplied to Awen.

We may withhold information where disclosure is prohibited by law, would create a material safety or fraud risk, would reveal confidential security information or would otherwise be inappropriate.

7.3 Information we may provide to a complainant or rights holder

A complaint does not automatically entitle a complainant to another User's Personal Data.

However, where permitted by applicable law, Awen may disclose limited information identifying or enabling contact with a Customer or User to:

(a) an individual credibly alleging that their rights have been violated;

(b) an individual depicted, represented or impersonated in disputed content;

(d) an authorized representative of such a person.

Before making a voluntary disclosure, Awen may consider matters including:

(a) whether the requester has demonstrated a plausible legal claim, right or legitimate interest;

(b) the seriousness and credibility of the alleged conduct;

(c) whether the requested information is reasonably necessary for the establishment, exercise or defence of a legal claim or protection of legal rights;

(d) whether a less intrusive means is reasonably available;

(e) the privacy, safety and other rights of the affected User;

(f) the amount and sensitivity of the information proposed for disclosure; and

(g) whether disclosure is lawful, necessary and proportionate.

Where appropriate, Awen will seek to limit disclosure to information reasonably necessary for the relevant lawful purpose.

Awen may instead require the requester to obtain a subpoena, court order, administrative order or other valid legal process before identifying a User.

Nothing in this Privacy Notice promises that Awen will voluntarily disclose another person's identity or contact information to a private claimant.

7.4 Disclosure to authorities

Awen may disclose relevant Personal Data to courts, regulators, law-enforcement authorities or other competent governmental bodies where:

(a) disclosure is required by applicable law or valid legal process;

(b) Awen reasonably believes disclosure is legally permitted and necessary to protect a person or legal right;

(d) another lawful basis permits the disclosure.

Where legally permitted and reasonably appropriate, Awen may notify the affected User of a legal request.

Awen may delay or withhold such notice where notice is prohibited or where it could compromise an investigation, create a safety risk, facilitate evidence destruction, facilitate fraud or materially prejudice another person's rights.

7.5 No public identification

The powers described above do not authorize Awen to publicly identify a User merely because a complaint has been submitted.

Any disclosure is subject to applicable law and Awen's assessment of the relevant circumstances.

8. When we disclose Personal Data

Awen may disclose Personal Data to the following categories of recipients.

8.1 Model providers

Where a User requests functionality supplied by a third-party AI model, Awen may transmit the information reasonably necessary to perform the requested operation to that model provider.

This may include relevant Inputs and technical information.

Awen takes commercially reasonable measures to require model providers not to use Customer Content to train or improve their models.

8.2 Cloud, infrastructure and other subprocessors

We use service providers to support functions such as:

(a) hosting;

(b) cloud infrastructure;

(d) content delivery;

(e) authentication;

(f) security;

(g) payments;

(h) communications;

(i) analytics;

(j) support; and

(k) other operational functions.

These providers may process Personal Data only as necessary to provide their services to Awen and subject to applicable contractual and data-protection requirements.

A current list of relevant subprocessors is available at https://compliance.awen.ai/subprocessors.

8.3 Customer administrators

If you use Awen through an organization, administrators of that organization may have access to information associated with your organizational Account, depending on the configuration of the applicable Services.

This may include information concerning Account status, usage, projects, permissions and other information controlled by the organizational Customer.

8.4 Professional advisers and insurers

We may disclose Personal Data where reasonably necessary to:

(a) lawyers;

(b) accountants;

(d) insurers;

(e) security advisers; and

(f) other professional advisers,

subject to appropriate professional or contractual obligations.

8.5 Rights holders and affected persons

We may make limited disclosures in connection with rights, safety or abuse complaints as described in Section 7.

8.6 Authorities and legal process

We may disclose Personal Data to courts, regulators, law-enforcement authorities and other competent authorities as described in this Privacy Notice.

8.7 Corporate transactions

If Awen is involved in a merger, acquisition, financing, corporate reorganization, sale of assets or similar transaction, Personal Data may be disclosed to prospective or actual transaction participants and their advisers where reasonably necessary and subject to appropriate confidentiality safeguards.

If responsibility for Personal Data transfers as part of such a transaction, affected individuals will receive any notice required by applicable law.

9. International transfers

Awen operates a service that may use cloud, model, infrastructure and other providers located in different countries.

As a result, Personal Data may be processed in countries outside the country in which you reside, including countries outside the European Economic Area ("EEA"), United Kingdom or Switzerland.

Where applicable data-protection law requires safeguards for an international transfer, Awen will use an appropriate transfer mechanism.

Depending on the circumstances, this may include:

(a) an adequacy decision;

(b) Standard Contractual Clauses approved by the European Commission;

(d) the EU-U.S. Data Privacy Framework, UK Extension or Swiss-U.S. Data Privacy Framework where applicable and valid for the recipient; or

(e) another transfer mechanism permitted by applicable law.

Where required, Awen may also assess whether supplementary technical, contractual or organizational safeguards are appropriate for a particular transfer.

10. Data retention

Awen retains Personal Data only for as long as reasonably necessary for the purposes for which it was collected, subject to legal, contractual, security and operational requirements.

Different categories of information may therefore have different retention periods.

10.1 Account and contractual records

We may retain Account information, contracts, Orders, invoices and related commercial records for the duration of the Customer relationship and afterwards for the period reasonably required to:

(a) satisfy accounting and tax requirements;

(b) establish or defend legal claims;

(d) comply with applicable recordkeeping obligations.

Certain contractual and transaction records may be retained for approximately six years after termination where appropriate for those purposes, subject to applicable law.

10.2 Customer Content

Retention of Customer Content depends on the applicable Plan, feature, Account status and configuration.

Customer Content may be deleted or made inaccessible after:

(a) the Customer deletes it;

(b) an applicable retention period expires;

(d) a subscription terminates or expires; or

(e) the relevant functionality is discontinued.

This is subject to backups, legal holds, security requirements and other lawful preservation described in this Privacy Notice.

10.3 Security and technical logs

Security, authentication, fraud-prevention and operational logs are retained for periods reasonably necessary to:

(a) maintain the security and integrity of the Services;

(b) detect and investigate incidents;

(d) resolve technical issues; and

(e) establish or defend legal claims.

10.4 Rights complaints and legal matters

Information relating to a complaint, investigation, preservation request, legal demand or dispute may be retained for as long as reasonably necessary to:

(a) investigate the matter;

(b) prevent continuing harm;

(d) comply with legal obligations;

(e) establish, exercise or defend legal claims; and

(f) complete any applicable appeal, limitation or enforcement period.

10.5 Prospects

Information relating to prospective business customers may generally be retained for up to three years following the most recent meaningful interaction, unless:

(a) a different period is required by law;

(b) you ask us to delete the information and no lawful retention basis applies; or

10.6 Cookies

Cookie retention periods depend on the relevant cookie and purpose.

Awen will provide additional information through its cookie-consent mechanism or Cookie Notice where required by applicable law.

When Awen no longer has a lawful or legitimate reason to retain Personal Data, we will delete, anonymize or otherwise dispose of it in accordance with our retention processes.

11. Deletion requests and legal preservation

A right to deletion or erasure is not absolute.

Where you request deletion of Personal Data, Awen may retain information where applicable law permits or requires retention, including where necessary to:

(a) perform an existing contract;

(b) comply with law;

(d) prevent fraud or abuse;

(e) protect the rights and safety of Awen or another person;

(f) establish, exercise or defend legal claims;

(g) comply with a legal hold or binding request;

(h) investigate a rights, safety or abuse complaint; or

(i) maintain records necessary to demonstrate compliance.

Where appropriate, information retained for one of these purposes may be isolated or restricted from ordinary use.

12. Security

Awen uses technical and organizational measures designed to protect Personal Data against unauthorized or unlawful access, use, alteration, disclosure, destruction or loss.

Depending on the relevant systems and data, these measures may include:

(a) encryption in transit;

(b) encryption at rest;

(d) role-based access controls;

(e) access logging;

(f) security monitoring;

(g) segregation of duties;

(h) network and infrastructure protections;

(i) backup and recovery procedures;

(j) vulnerability and software-management processes; and

(k) incident-response procedures.

Access to Personal Data is restricted to personnel and service providers with an appropriate need for access.

No technical or organizational security measure can guarantee absolute security.

Users are also responsible for protecting their Account credentials and notifying Awen promptly of suspected unauthorized access.

13. Your privacy rights

Depending on where you live and the applicable law, you may have some or all of the following rights.

13.1 Access

You may have the right to request confirmation as to whether Awen processes your Personal Data and obtain access to that information.

13.2 Rectification

You may have the right to ask Awen to correct inaccurate or incomplete Personal Data.

13.3 Erasure

You may have the right to request deletion of Personal Data in circumstances provided by applicable law.

This right is subject to lawful exceptions, including those described in Section 11.

13.4 Restriction

You may have the right to ask Awen to restrict certain processing of your Personal Data.

13.5 Data portability

Where applicable, you may have the right to receive certain Personal Data in a structured, commonly used and machine-readable format and to transmit that information to another controller.

13.6 Objection

Where Awen relies on legitimate interests, you may have the right to object to processing based on grounds relating to your particular situation.

Awen will assess the request in accordance with applicable law and may continue processing where compelling legitimate grounds or the establishment, exercise or defence of legal claims permits it.

13.7 Withdrawal of consent

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawal does not affect the lawfulness of processing that occurred before consent was withdrawn.

13.8 Marketing

You may opt out of marketing emails using the unsubscribe mechanism included in the communication or by contacting us.

Service, security, Account and legal communications are not marketing communications and may continue where necessary.

13.9 Complaint to a supervisory authority

Where applicable, you may lodge a complaint with the data-protection supervisory authority responsible for your location or for the relevant processing.

13.10 Post-mortem privacy rights

Where applicable law provides such a right, including under certain French privacy rules, you may have the ability to provide instructions concerning the handling of Personal Data after your death.

14. How to exercise your rights

To exercise an applicable privacy right, contact:

privacy@awen.ai

Please describe the right you wish to exercise and provide sufficient information for us to identify the relevant Personal Data.

We may need to verify your identity before fulfilling a request.

Where a request is made through an authorized representative, we may also require appropriate evidence of the representative's authority.

Awen will respond within the period required by applicable law.

Where Awen processes Personal Data solely on behalf of a Customer, we may refer your request to that Customer or assist the Customer with the request as required by applicable law or our Data Processing Agreement.

15. European Economic Area, United Kingdom and Switzerland

If European data-protection law applies to our processing, the legal bases described in this Privacy Notice are intended to correspond, as applicable, to bases including:

(a) performance of a contract;

(b) compliance with legal obligations;

(d) protection of vital interests where applicable; and

(e) legitimate interests pursued by Awen or a third party, except where overridden by the interests or fundamental rights and freedoms of the affected individual.

Our legitimate interests may include:

(a) providing and administering the Services;

(b) securing our systems;

(d) protecting Users and third parties;

(e) investigating rights complaints;

(f) protecting intellectual-property, privacy, publicity and Identity Rights;

(g) establishing, exercising and defending legal claims;

(h) maintaining business records;

(i) improving the reliability and functionality of our Services; and

(j) communicating with business customers and prospects.

Where processing involves special categories of Personal Data, Awen will rely on an additional condition required by applicable law where necessary, such as explicit consent, establishment, exercise or defence of legal claims, or another applicable condition.

If you are located in the EEA, you may lodge a complaint with the supervisory authority in your Member State.

If the processing relates to France, the competent supervisory authority is:

Commission Nationale de l'Informatique et des Libertés (CNIL)

16. California and other U.S. state privacy rights

Residents of certain U.S. states may have additional privacy rights under applicable state law.

Where such law applies to Awen, those rights may include:

(a) the right to know or access categories or specific pieces of Personal Data;

(b) the right to know the categories of sources from which Personal Data was collected;

(d) the right to know categories of third parties to whom Personal Data is disclosed;

(e) the right to request deletion, subject to exceptions;

(f) the right to correct inaccurate Personal Data;

(g) the right to opt out of certain sales, sharing, targeted advertising or profiling where applicable;

(h) the right to limit certain uses or disclosures of sensitive Personal Data where applicable; and

(i) the right not to receive unlawful discriminatory treatment for exercising privacy rights.

Whether a particular U.S. state privacy law applies to Awen depends on the requirements and thresholds of that law.

Where Awen engages in processing for which a specific opt-out mechanism is legally required, Awen will make the required mechanism available.

Requests may be submitted to:

privacy@awen.ai

Where required, Awen will provide an appeal process for a denied privacy request.

17. Children

The Services are not intended for children under thirteen years of age.

Awen does not knowingly permit children under thirteen to create Accounts or use the Services.

Where applicable law requires a higher age for independent use or consent, the User must satisfy that requirement or use the Services with the authorization of a parent or legal guardian as permitted by law and Awen's Terms.

If Awen learns that Personal Data relating to a child was collected in circumstances where collection was not lawful, Awen will take reasonable steps to delete or otherwise appropriately handle that information.

Certain models or functionality may be subject to higher age restrictions.

18. Cookies and similar technologies

Awen may use cookies and similar technologies to:

(a) operate the Services;

(b) authenticate Users;

(d) protect security;

(e) measure performance;

(f) understand usage; and

(g) support marketing where permitted.

Strictly necessary technologies may be used where required to provide or secure the Services.

Where applicable law requires consent for analytics, advertising or other non-essential technologies, Awen will request that consent.

You may be able to manage your choices through Awen's cookie-preference interface and applicable browser or device controls.

19. Third-party websites and services

The Services may contain links to, integrate with or permit interaction with third-party websites, products or services.

Those third parties may process Personal Data independently under their own privacy notices.

Awen is not responsible for independent privacy practices of third parties except to the extent applicable law provides otherwise.

20. Automated systems

Awen uses automated systems as part of providing the Services, including generative AI, security tools, fraud-prevention tools, content-safety systems and operational systems.

Awen may use automated tools to flag potentially prohibited or risky activity for restriction or further review.

Where applicable law provides rights relating to decisions based solely on automated processing that produce legal or similarly significant effects, Awen will respect those rights.

A generation, moderation result, safety flag or risk indicator does not by itself constitute a legal determination concerning an individual.

21. Changes to this Privacy Notice

Awen may update this Privacy Notice from time to time to reflect:

(a) changes to the Services;

(b) new models or functionality;

(d) security or safety developments;

(e) legal or regulatory requirements; or

(f) other operational changes.

Where required by applicable law, we will provide notice of material changes before they take effect.

We encourage you to review this Privacy Notice periodically.

The "Effective date" shown at the beginning of this Privacy Notice identifies when the current version became effective.

22. Contact

Questions, concerns or requests regarding this Privacy Notice or Awen's handling of Personal Data may be sent to:

Awen AI Corporation
Email: privacy@awen.ai