PRIVACY POLICY

Last updated January 31, 2024

This privacy notice for Permafrost AI AS ("we," "us," or "our"), describes how and

why we might collect, store, use, and/or share ("process") your information when you

use our services ("Services"), such as when you:

Visit our website at https://guessr.ai, or any website of ours that links to this

Engage with us in other related ways, including any sales, marketing, or

events

Questions or concerns? Reading this privacy notice will help you understand your

privacy rights and choices. If you do not agree with our policies and practices, please

do not use our Services. If you still have any questions or concerns, please contact

us at post@permafrost.ai.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find

out more details about any of these topics by clicking the link following each

key point or by using our table of contents below to find the section you are

looking for.

What personal information do we process? When you visit, use, or navigate our

Services, we may process personal information depending on how you interact with

us and the Services, the choices you make, and the products and features you use.

Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive

personal information.

Do we receive any information from third parties? We do not receive any

information from third parties.

How do we process your information? We process your information to provide,

improve, and administer our Services, communicate with you, for security and fraud

prevention, and to comply with law. We may also process your information for other

purposes with your consent. We process your information only when we have a valid

legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information?

We may share information in specific situations and with specific third parties. Learn

more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical

processes and procedures in place to protect your personal information. However, no

electronic transmission over the internet or information storage technology can be

guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,

cybercriminals, or other unauthorized third parties will not be able to defeat our

security and improperly collect, access, steal, or modify your information. Learn more

about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the

applicable privacy law may mean you have certain rights regarding your personal

information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by

submitting a data subject access request, or by contacting us. We will consider and

act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the

privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL

INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT

FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register

on the Services, express an interest in obtaining information about us or our products

and Services, when you participate in activities on the Services, or otherwise when

you contact us.

Personal Information Provided by You. The personal information that we collect

depends on the context of your interactions with us and the Services, the choices you

make, and the products and features you use. The personal information we collect

may include the following:

Sensitive Information. We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with us

using your existing social media account details, like your Facebook, Twitter, or other

social media account. If you choose to register in this way, we will collect the

information described in the section called "HOW DO WE HANDLE YOUR SOCIAL

LOGINS?" below.

All personal information that you provide to us must be true, complete, and accurate,

and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our

Services, communicate with you, for security and fraud prevention, and to comply

with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on

how you interact with our Services, including:

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS

YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary

and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like

with your consent, to comply with laws, to provide you with services to enter into or

fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate

business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain

the valid legal bases we rely on in order to process your personal information. As

such, we may rely on the following legal bases to process your personal information:

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e.,

express consent) to use your personal information for a specific purpose, or in

situations where your permission can be inferred (i.e., implied consent). You

can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to

process your information without your consent, including, for example:

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section

and/or with the following third parties.

We may need to share your personal information in the following situations:

5. DO WE USE COOKIES AND OTHER TRACKING

TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store

your information.

We may use cookies and similar tracking technologies (like web beacons and pixels)

to access or store information. Specific information about how we use such

technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media

account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social

media account details (like your Facebook or Twitter logins). Where you choose to do

this, we will receive certain profile information about you from your social media

provider. The profile information we receive may vary depending on the social media

provider concerned, but will often include your name, email address, friends list, and

profile picture, as well as other information you choose to make public on such a

social media platform.

We will use the information we receive only for the purposes that are described in this

privacy notice or that are otherwise made clear to you on the relevant Services.

Please note that we do not control, and are not responsible for, other uses of your

personal information by your third-party social media provider. We recommend that

you review their privacy notice to understand how they collect, use, and share your

personal information, and how you can set your privacy preferences on their sites

and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes

outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the

purposes set out in this privacy notice, unless a longer retention period is required or

permitted by law (such as tax, accounting, or other legal requirements). No purpose

in this notice will require us keeping your personal information for longer than the

period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal

information, we will either delete or anonymize such information, or, if this is not

possible (for example, because your personal information has been stored in backup

archives), then we will securely store your personal information and isolate it from

any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of

organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational

security measures designed to protect the security of any personal information we

process. However, despite our safeguards and efforts to secure your information, no

electronic transmission over the Internet or information storage technology can be

guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,

cybercriminals, or other unauthorized third parties will not be able to defeat our

security and improperly collect, access, steal, or modify your information. Although

we will do our best to protect your personal information, transmission of personal

information to and from our Services is at your own risk. You should only access the

Services within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United

Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater

access to and control over your personal information. You may review, change, or

terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain

rights under applicable data protection laws. These may include the right (i) to

request access and obtain a copy of your personal information, (ii) to request

rectification or erasure; (iii) to restrict the processing of your personal information; (iv)

if applicable, to data portability; and (v) not to be subject to automated decision-

making. In certain circumstances, you may also have the right to object to the

processing of your personal information. You can make such a request by contacting

us by using the contact details provided in the section "HOW CAN YOU CONTACT

US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data

protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing

your personal information, you also have the right to complain to your Member State

data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and

Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your

personal information, which may be express and/or implied consent depending on

the applicable law, you have the right to withdraw your consent at any time. You can

withdraw your consent at any time by contacting us by using the contact details

provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

below.

However, please note that this will not affect the lawfulness of the processing before

its withdrawal nor, when applicable law allows, will it affect the processing of your

personal information conducted in reliance on lawful processing grounds other than

consent.

Account Information

If you would at any time like to review or change the information in your account or

terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your

account and information from our active databases. However, we may retain some

information in our files to prevent fraud, troubleshoot problems, assist with any

investigations, enforce our legal terms and/or comply with applicable legal

requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies

by default. If you prefer, you can usually choose to set your browser to remove

cookies and to reject cookies. If you choose to remove cookies or reject cookies, this

could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at

post@permafrost.ai.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications

include a Do-Not-Track ("DNT") feature or setting you can activate to signal your

privacy preference not to have data about your online browsing activities monitored

and collected. At this stage no uniform technology standard for recognizing and

implementing DNT signals has been finalized. As such, we do not currently respond

to DNT browser signals or any other mechanism that automatically communicates

your choice not to be tracked online. If a standard for online tracking is adopted that

we must follow in the future, we will inform you about that practice in a revised

version of this privacy notice.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC

PRIVACY RIGHTS?

In Short: If you are a resident of , you are granted specific rights regarding access to

your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve

(12) months:

CategoryExamplesCollected
A. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account nameYES
B. Protected classification characteristics under state or federal lawGender and date of birthNO
C. Commercial informationTransaction information, purchase history, financial details, and payment informationNO
D. Biometric informationFingerprints and voiceprintsNO
E. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisementsNO
F. Geolocation dataDevice locationNO
G. Audio, electronic, visual, or similar informationImages and audio, video or call recordings created in connection with our business activitiesNO
H. Professional or employment-related informationBusiness contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with usNO
I. Education InformationStudent records and directory informationNO
J. Inferences drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristicsNO
K. Sensitive personal InformationNONO

We will use and retain the collected personal information as needed to provide the

Services or for:

Category A - As long as the user has an account with us

We may also collect other personal information outside of these categories through

instances where you interact with us in person, online, or by phone or mail in the

context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section, "HOW DO WE

PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a

written contract between us and each service provider. Learn more about how we

disclose personal information to in the section, "WHEN AND WITH WHOM DO WE

SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for

undertaking internal research for technological development and demonstration. This

is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a

business or commercial purpose in the preceding twelve (12) months. We will not sell

or share personal information in the future belonging to website visitors, users, and

other consumers.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant

laws.

We may update this privacy notice from time to time. The updated version will be

indicated by an updated "Revised" date and the updated version will be effective as

soon as it is accessible. If we make material changes to this privacy notice, we may

notify you either by prominently posting a notice of such changes or by directly

sending you a notification. We encourage you to review this privacy notice frequently

to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at

post@permafrost.ai or contact us by post at:

Permafrost AI AS

Hytteveien 6

HARSTAD 9409

Norway

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE

DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request

access to the personal information we collect from you, change that information, or

delete it. To request to review, update, or delete your personal information, please fill

out and submit a data subject access request.

This privacy policy was created using Termly's Privacy Policy Generator.

These terms of use were created usingTermly's Privacy Policy Generator.