PRIVACY NOTICE

This privacy notice for Boxy AI, Inc. (doing business as Boxy) ("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://boxy.im/, or any website of ours that links to this privacy notice
• Download and use our application(s), such as our mobile application — Boxy or any other application of ours that links to this privacy notice
• 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 info@boxy-ai.com.

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 may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

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 types of parties do we share personal information? We may share information in specific situations and with specific categories of 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 I exercise my rights? The easiest way to exercise your rights is 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. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. DO WE COLLECT INFORMATION FROM MINORS?
12. WHAT ARE YOUR PRIVACY RIGHTS?
13. CONTROLS FOR DO-NOT-TRACK FEATURES
14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
16. DO WE MAKE UPDATES TO THIS NOTICE?
17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

PRIVACY-FIRST ARCHITECTURE

In Short: Boxy is designed so your sensitive data stays on your device, not our servers. Boxy is built with a local-first architecture. When you use the Boxy desktop application, your messages, chat histories, documents, and underlying source content are stored locally on your machine and are not uploaded to our servers. When Boxy’s AI surfaces a suggested action for you (for example, a proposal card summarizing an incoming message), only lightweight metadata about that action — not the underlying message content — is sent to our backend so you can act on it across sessions. Conversations you have with Boxy’s AI assistant are processed by third-party AI model providers under their respective terms, as described in Section 4 below. This architecture means that, for most user activity, we genuinely do not have the data to look at, share, sell, or lose.

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, create an account, 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:

• Name, email address, and, where applicable, phone number (for user identification and account-related communications)
• Payment and billing information (such as credit card details) for subscription or credit-based services
• User preferences and interaction inputs (e.g., responses to proposals, feedback, and selections within the Services)

At account signup, certain fields are required to create and operate your account (first name, last name, email address, job title, and industry). Other fields are optional and collected only if you choose to provide them, including your company or employer name (used to contextualize usage for product research) and your date of birth (used solely to send you birthday rewards, such as bonus token usage). Optional fields can be left blank or updated at any time from your account settings. We do not use your date of birth for advertising or age-inference purposes, and we do not request or knowingly collect your password through any form of communication.

Sensitive Information. We do not process sensitive personal information on our servers. However, with your explicit authorization and as permitted by applicable law, certain categories of sensitive information may be accessed and processed locally on your device (and not transmitted to or stored on our servers), including:

• Government-issued identification information (e.g., passport, driver’s license)
• Health or biometric-related data
• Professional, employment, and education data
• Credit report or credit score information

Such information, where accessed, is processed locally on your device and remains under your control unless you expressly choose to share it. For clarity, certain AI‑powered features may require transmitting limited user prompts or inputs to third‑party AI model providers for real‑time inference, as further described below, even where other categories of data are processed exclusively on your device. Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link(s) here: Stripe Privacy Policy.

Commercial Data. We may access your transaction or purchase history from third-party platforms (such as Amazon) with your authorization; however, such data is processed locally on your device and is not stored on our servers.

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.

Social Media Integration Data. With your authorization, we may access certain data from social media platforms (including Facebook, Google, Twitter/X, LinkedIn, Instagram, WhatsApp, and similar services), such as profile information, contacts, posts, or messages. Such access and processing occur locally on your device and are not stored on our servers unless explicitly required for a feature you enable.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, calendar, camera, microphone, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
• App Usage Data. We collect information about how you interact with the application (e.g., features used, interaction patterns), primarily to improve functionality and user experience.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, audit purposes, and for internal analytics and reporting.

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.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, for audit purposes, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://boxy.im/cookie-policy.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. In many cases, such data is processed locally on your device and not transmitted to our servers.

This information may include mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings.

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:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below).
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information see our Cookie Notice: https://boxy.im/cookie-policy.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services, including generating preference insights based on your interactions, which are processed locally on your device, to better understand usage patterns and improve the Services.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

Transactional messages (such as password resets, receipts, security notices, and other communications necessary to operate your account) cannot be opted out of while you have an active Boxy account, because they are required to use the Services. You can always opt out of non-essential marketing and promotional messages using the unsubscribe link in each message or by contacting us at the email listed in Section 17.

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:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
• Send users information about special offers and discounts on our products and services
• Develop and display personalized and relevant advertising content for our users
• Analyze how our Services are used so we can improve them to engage and retain users
• Support our marketing activities
• Diagnose problems and/or prevent fraudulent activities
• Understand how our users use our products and services so we can improve user experience
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.

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. Click here to learn more.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

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 categories of third parties.

We do not sell your personal information. In limited circumstances, we may share specific contact identifiers — namely your first name, last name, and email address — with certain third‑party social media platforms for cross‑context behavioral advertising, as defined under applicable state privacy laws, where described below. All other data processed by us — including your chat histories, agent interactions, personal preferences, documents, and contextual inputs — is processed locally on your device or within your controlled environment and is not shared with social media platforms, advertising partners, or other third parties for advertising purposes. We only share your personal information with third parties where necessary to operate our Services, process payments, support infrastructure, or as otherwise described below.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf (except that advertising platforms used for cross‑context behavioral advertising act as independent third parties with respect to that processing) and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

Where possible, we limit the amount of personal information shared with such providers and rely on infrastructure services that host or process data on our behalf without independently using such data.

The categories of third parties we may share personal information with are as follows:

• Ad Networks
• Affiliate Marketing Programs
• Cloud Computing and Infrastructure Providers (e.g., Supabase, Render, and potentially Amazon Web Services (AWS))
• Communication & Collaboration Tools
• Data Analytics Services (limited to marketing websites and not used within our core application)
• Data Storage Service Providers
• Finance & Accounting Tools
• Government Entities
• Order Fulfillment Service Providers
• Payment Processors (e.g., Stripe)
• Performance Monitoring Tools
• Product Engineering & Design Tools
• Retargeting Platforms
• Sales & Marketing Tools
• Social Networks
• Testing Tools
• User Account Registration & Authentication Services
• Website Hosting Service Providers

Named Service Providers

As a supplement to the categories listed above, the specific third-party service providers we currently use (or are actively evaluating) are listed below. We review this list regularly and will update this notice if we add or remove a material provider.

AI Model Providers

Where you choose to use AI‑powered features, limited portions of your input may be transmitted directly from your device to third‑party AI model providers solely for real‑time inference. Before transmission, such data is obfuscated locally to minimize identifiability. We do not receive, store, or retain this inference data on our own servers.

Conversations you have with Boxy’s AI assistant may, depending on the feature and your configuration, be processed either locally on your device, by Boxy’s systems, or by third-party AI model providers acting on Boxy’s behalf — currently OpenAI, Anthropic, and Google (Gemini). Where third‑party model providers are used, data submitted solely for inference is transmitted for the purpose of generating responses and is generally subject to the provider’s standard API retention policies. Under those policies, data submitted for inference is typically retained for a limited period (up to approximately thirty (30) days) for abuse monitoring and is then deleted. API-submitted data is not used to train the providers’ models by default. We do not access, retrieve, or control any data retained by these providers under their independent API policies. We engage these providers as processors to perform inference services and do not permit them to use submitted data for any purpose other than providing the requested functionality. Please refer to the applicable provider privacy policies for further details regarding their practices. We are evaluating enterprise zero-retention arrangements with these providers and will update this Privacy Notice if and when such arrangements are implemented.

Co-Marketing with Partners

Where we mention sharing information with business partners, the scope of any such co-marketing arrangement is intentionally limited. We will only share limited information (specifically, your email address and professional role) with a co-marketing partner when we have entered into a formal co-marketing arrangement backed by a signed Data Processing Agreement with the partner. We do not share your first name, last name, date of birth, company name, or any other personal information with co-marketing partners. Before any such sharing occurs, you will be given advance notice and the opportunity to opt out, and you can withdraw from future co-marketing at any time.

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

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Cloud Infrastructure. We use Supabase (https://supabase.com/privacy) for database hosting and Render (https://render.com/privacy) for server infrastructure. We may migrate to other providers, such as Amazon Web Services (AWS), as we scale. These providers process data solely on our behalf as infrastructure providers.
• When we use Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include: Google Display Network Impression Reporting, Google Analytics Demographics and Interests Reporting, and Remarketing with Google Analytics. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link. We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: device GPS coordinates, approximate geolocation data (via IP address), and location-based search queries, and other similar information. A full list of what we use information for can be found in this section and in the previous section titled “HOW DO WE PROCESS YOUR INFORMATION?” The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein and Norway) or the United Kingdom, please take a look at our Cookie Notice, which can be found at this link: https://boxy.im/cookie-policy.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• Advertising and Marketing Partners. Where we engage in cross‑context behavioral advertising, we may share limited contact identifiers (namely your first name, last name, and email address) with third‑party advertising platforms for the purpose of delivering, measuring, and optimizing advertising across third‑party websites and services.
• Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. 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 support essential functionality, security, aggregated analytics, and limited advertising involving basic contact identifiers. We do not use cookies or tracking technologies to share chat content, agent data, or other locally processed information for cross‑context behavioral advertising. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://boxy.im/cookie-policy.

7. 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. If you log in using Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes; and you may choose to grant or deny us access to each individual permission.

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.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in the United States, and other countries. Where AI model providers process inference requests on our behalf, such processing may occur on infrastructure located outside your country of residence, including in the United States, subject to appropriate contractual safeguards.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

9. 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). In general, we retain personal information for the duration of your account and for up to thirty (30) days following account deletion, unless otherwise specified below.

We categorize and retain personal information based on its nature, purpose, and storage location, as follows:

• Account & Financial Data. Profile information (such as name and email address) and billing-related data are stored for the duration of your active account. We delete or anonymize such data within thirty (30) days following a deletion request or account termination, or after twelve (12) months of account inactivity. However, certain transaction records may be retained for up to seven (7) years as required for tax, accounting, and legal compliance purposes.
• Technical Audit Data. Security and audit logs (such as IP addresses, device identifiers, and access timestamps) are retained for a rolling twelve (12) month period to maintain system integrity, monitor performance, and prevent fraud or abuse.
• User-Controlled Data. Certain categories of data (including sensitive or third-party integrated data, such as health, financial, or social media information) may be processed locally on your device and are not transmitted to or stored on our servers. As a result, we do not retain such data and apply a zero-day retention policy with respect to this information. This zero‑day retention applies to Boxy’s systems and storage only and does not apply to limited‑duration retention by third‑party AI model providers used solely to perform inference, as described in the section titled “AI Model Providers.”

10. 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.

Our technical and organizational safeguards include, where appropriate: encryption of data in transit using TLS/HTTPS; encryption at rest for sensitive fields in our databases; access controls under the principle of least privilege; multi-factor authentication for employee access to production systems; regular security reviews of our subprocessors; and logging and monitoring of administrative activity. If we become aware of a security incident affecting your personal information, we will notify affected users and relevant supervisory authorities as required by applicable law without undue delay, including within required timeframes under the GDPR where applicable.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@boxy-ai.com.

12. 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 or updating your preferences.

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.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists — however, we may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

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

• Log in to your account settings and update your user account.
• Contact us using the contact information provided.

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. You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie Notice: https://boxy.im/cookie-policy.

If you have questions or comments about your privacy rights, you may email us at info@boxy-ai.com.

13. 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.

Global Privacy Control (GPC). Separately from DNT, some browsers support Global Privacy Control (GPC), a browser-level signal that indicates a user’s intent to opt out of the sale or sharing of their personal information. When our systems detect a GPC signal, we treat it as a valid opt-out of the sale or sharing of personal information for the applicable browser, consistent with the California Consumer Privacy Act (as amended by the CPRA) and similar state laws. This applies regardless of whether you have an account with us.

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you are granted specific rights regarding access to your personal information.

What categories of personal information do we collect?

As of the date of this Privacy Policy, the Services have not yet launched, and we have not collected any personal information in the past twelve (12) months. The categories listed below represent the types of personal information we anticipate collecting once the Services become available to users:

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A - Retained for the duration of your account and up to thirty (30) days after account deletion
• Category B - Retained for the duration of your account and up to thirty (30) days after account deletion, unless processed locally only (in which case no server-side retention applies)
• Category C – N/A
• Category D - Payment-related records retained as required by law (up to seven (7) years); other data processed locally and not retained on our servers
• Category E – N/A
• Category F - Retained for up to twelve (12) months for audit, security, and system monitoring purposes
• Category G - Retained only as necessary for service functionality or processed locally depending on feature usage
• Category H - Processed locally on your device and not retained on our servers
• Category I - Processed locally on your device and not retained on our servers
• Category J - Processed locally on your device and not retained on our servers
• Category K - Generated locally on your device and not retained on our servers
• Category L - Processed locally on your device and not retained on our servers (zero-day retention)

Where data is processed locally on your device, we do not collect, transmit, or retain such data on our servers unless you explicitly choose to share it through a feature of the Services. Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information. 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 CAN YOU CONTACT US ABOUT THIS NOTICE?”

We collect and share your personal information through:

• Targeting cookies/Marketing cookies
• Social media cookies
• Beacons/Pixels/Tags
• Click redirects: Tracking links used for measurement and attribution in digital advertising campaigns, which may pass certain personal data (such as IP address and device identifier) to third-party ad networks before directing you to our website or application.
• Social media plugins: Facebook, Instagram, LinkedIn, and X (formerly Twitter). We use social media features, such as a "Like" button, and widgets, such as a "Share" button in our Services. Such features may process your Internet Protocol (IP) address and track which page you are visiting on our website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with a widget or button belonging to that social media platform, this information may be recorded to your profile of such social media platform. To avoid this, you should log out from that social media platform before accessing or using the Services. Social media features and widgets may be hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy notices of the companies that provide them. By clicking on one of these buttons, you agree to the use of this plugin and consequently the transfer of personal information to the corresponding social media service. We have no control over the essence and extent of these transmitted data or their additional processing.

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 who 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 disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers
• Category B. Personal information, as defined in the California Customer Records law
• Category C. Characteristics of protected classifications under state or federal law
• Category D. Commercial information
• Category E. Biometric information
• Category F. Internet or other electronic network activity information
• Category G. Geolocation data
• Category H. Audio, electronic, visual, and similar information
• Category I. Professional or employment-related information
• Category J. Education information
• Category K. Inferences drawn from collected personal information
• Category L. Sensitive personal information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We may share limited contact identifiers (first name, last name, and email address only) for cross‑context behavioral advertising, as defined under applicable state privacy laws, where described below, and no other categories of personal information have been shared for advertising.

California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You have the right to request the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, or our compliance requirements resulting from a legal obligation, or any other applicable regulatory or legal requirement. Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share your personal information to third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, sharing, or selling personal information; and
• the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

If the business collects any of the following:

• social security information, drivers’ licenses, state ID cards, passport numbers
• account login information
• credit card numbers, financial account information, or credentials allowing access to such accounts
• precise geolocation
• racial or ethnic origin, religious or philosophical beliefs, union membership
• the contents of email and text, unless the business is the intended recipient of the communication
• genetic data, biometric data, and health data
• data concerning sexual orientation and sex life

you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services. Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes. Please note that sensitive personal Information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information. To exercise your right to limit use and disclosure of sensitive personal Information, please email info@boxy-ai.com.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
• You can opt out from the selling or sharing of your personal information by disabling cookies in Cookie Preference Settings and clicking on the Do Not Sell or Share My Personal Information link on our homepage

To exercise these rights, you can contact us by email at info@boxy-ai.com. If you have a complaint about how we handle your data, we would like to hear from you.

Financial Incentives

"Financial incentive" means a program, benefit, or other offering, including payments to consumers as compensation, for the disclosure, deletion, sharing, or sale of personal information.

The law permits financial incentives or a price or service difference if it is reasonably related to the value of the consumer’s data. A business must be able to explain how the financial incentive or price or service difference is reasonably related to the value of the consumer’s data. The explanation must include:

• a good-faith estimate of the value of the consumer’s data that forms the basis for offering the financial incentive or price or service difference; and
• a description of the method the business used to calculate the value of the consumer’s data.

We may decide to offer a financial incentive (e.g., price or service difference) in exchange for the retention, or sale or sharing of a consumer’s personal information.

If we decide to offer a financial incentive, we will notify you of such financial incentive and explain the price difference, as well as material terms of the financial incentive or price of service difference, including the categories of personal information that are implicated by the financial incentive or price or service difference.

If you choose to participate in the financial incentive you can withdraw from the financial incentive at any time by emailing us at info@boxy-ai.com.

Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

To submit a request to exercise these rights described above, please email info@boxy-ai.com.

We share limited contact identifiers (first name, last name, and email address only) to third parties or process personal data for targeted advertising. You can opt out from the selling or sharing of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings. If we decline to take action regarding your request and you wish to appeal our decision, please email us at info@boxy-ai.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

We share limited contact identifiers (first name, last name, and email address only) to third parties or process personal data for targeted advertising. You can opt out from the selling or sharing of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings. To submit a request to exercise these rights described above, please email info@boxy-ai.com. If we decline to take action regarding your request and you wish to appeal our decision, please email us at info@boxy-ai.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Utah Residents

This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data

We share limited contact identifiers (first name, last name, and email address only) to third parties or process personal data for targeted advertising. You can opt out from the selling or sharing of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings. To submit a request to exercise these rights described above, please email info@boxy-ai.com.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA): "Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context. "Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information. "Sale of personal data" means the exchange of personal data for monetary consideration. If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

Your rights with respect to your personal data

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

We share limited contact identifiers (first name, last name, and email address only) to third parties or process personal data for targeted advertising. Please see the following section to find out how you can opt out from further selling or sharing of your personal data for targeted advertising or profiling purposes.

Exercise your rights provided under the Virginia VCDPA

You can opt out from the selling or sharing of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings.

You may contact us by email at info@boxy-ai.com.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at info@boxy-ai.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

Other US States

A growing number of US states have enacted comprehensive consumer privacy laws beyond the five addressed above. If you are a resident of Texas, Oregon, Montana, Delaware, Iowa, New Jersey, New Hampshire, Minnesota, Tennessee, Indiana, Kentucky, Maryland, or another state with an active comprehensive consumer privacy law, you generally have rights similar to those described above for California, Colorado, Connecticut, Utah, and Virginia, including the rights to:

• Be informed whether we process your personal data
• Access your personal data
• Correct inaccuracies in your personal data
• Request deletion of your personal data
• Obtain a portable copy of your personal data
• Opt out of targeted advertising, the sale of personal data, and profiling where required

As a matter of company policy, we extend these rights to every Boxy user regardless of their state of residence. To exercise any of these rights, or to appeal a denial of a request, please email info@boxy-ai.com. We will respond within the timeframes required by applicable law (generally 45 days, with a possible extension when reasonably necessary).

15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• manage your account with us
• respond to or help with your requests
• confirm your identity and protect your account

At any time, you have the right to request access to or correction 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 REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and for a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction 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 REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

16. 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.

In practice, we distinguish between minor updates and material changes. Minor updates (for example, correcting a typo, adding a new subprocessor of the same type, or clarifying existing language) will be reflected by updating the “Last updated” date above and, for account holders, an email summarizing the change. Material changes (for example, adding new categories of collected data, changing the legal basis of processing, or expanding sharing with partners) will be rolled out with a longer notice period. We will: (1) update the “Last updated” date above; (2) send a notification email to every active account holder at least thirty (30) days before the changes take effect; (3) display a prominent banner on our website and inside the Boxy application for at least thirty (30) days; and (4) on your next login after the effective date, display an in-app modal summarizing the changes and requiring you to actively accept them before continuing to use the Services. If you do not accept the updated notice, you can close your account at any time. Continued use of the Services after you accept (or after the effective date has passed, whichever is later) constitutes acceptance of the updated notice.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by email at info@boxy-ai.com.

If you have any further questions or comments, you may also contact us by post at the following corporate address:

EU and UK Representative (GDPR Article 27)

Because Boxy offers its Services to residents of the European Union and the United Kingdom without being established in either jurisdiction, we are required by Article 27 of the GDPR and the corresponding provision of the UK GDPR to appoint a Representative within each of those jurisdictions. The Representative serves as a local point of contact for data subjects and supervisory authorities. We are in the process of engaging a qualified representative service and will list the designated Representative’s name, address, and contact details in this section once the appointment is finalized. In the interim, EU and UK residents may direct all privacy inquiries and rights requests to info@boxy-ai.com, and we will respond within the timeframes required by the GDPR and UK GDPR.

18. 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 contact us by email at info@boxy-ai.com.

Verification and Our Approach to Rights Requests

For users with a Boxy account — we generally verify rights requests by sending a confirmation link to the email address on file for your account. This approach is designed to be proportionate and consistent with applicable data‑protection requirements. We do not require copies of your government ID or any other form of heightened identity verification for typical privacy requests, as doing so would involve collecting additional sensitive information that is not necessary to process the request.

For users without a Boxy account — we may not have personal information that we can individually link to you as most substantive user data is processed and stored locally and not retained on our servers. Rights related to limited contact identifiers shared for advertising may be exercised through us or directly with the relevant platform, as applicable. . In those situations, we will explain what we can and cannot do and direct you to the appropriate self-service mechanisms, such as: managing non-essential cookies through our cookie banner; using the industry opt-out portals at the Digital Advertising Alliance (http://www.aboutads.info/choices/), DAA Canada (https://youradchoices.ca/), or the European Interactive Digital Advertising Alliance (http://www.youronlinechoices.com/); and submitting deletion requests directly to the third‑party advertising providers, if any, described in this notice through each provider’s own privacy portal. We respond to all privacy rights requests within the timeframes required by applicable law — generally within 45 days, with a possible extension of up to an additional 45 days when reasonably necessary. We do not charge a fee for reasonable requests, and we will not discriminate against you for exercising your rights.