Privacy Policy

Last updated September 17, 2026

This Privacy Notice for Legion Code Inc. (doing business as OSPRY) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at <https://www.ospry.ai> or any website of ours that links to this Privacy Notice
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. 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 privacy@legioncodeinc.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? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we identify visitors to websites? Yes. Our core product identifies business visitors to our customers' websites, which means we process personal information about people who have never interacted with OSPRY directly. If you are looking for that, read "OUR VISITOR IDENTIFICATION SERVICES" below; it also explains how to opt out.

Do we collect any information from third parties? We may collect 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 adequate 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 visiting <https://www.ospry.ai/privacy>, or by contacting us. To opt out of the sharing of your personal information for targeted advertising, visit <https://www.ospry.ai/do-not-sell> or use the Cookie Preference Center on our Website. 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. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
6. OUR VISITOR IDENTIFICATION SERVICES
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS NOTICE?
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
16. 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:

• names
• phone numbers
• email addresses
• contact preferences
• billing addresses
• job titles and company names

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: <https://stripe.com/privacy>.

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, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as 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.

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, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

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 approximate location derived from your IP address, which tells us a general area such as your city, region and country. We do not collect precise location from your device. Our Website blocks the browser geolocation feature outright, so we cannot read GPS or device-level location even if you were to permit it.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

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. This information includes 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 X), we receive personal information about you from such platforms such as your name, email address, and gender. You may have the right to withdraw your consent to processing your personal information. Learn more about withdrawing your consent. Any personal information that we collect from your social media account depends on your social media account's privacy settings. Please note that their own use of your information is not governed by this Privacy Notice.

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 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.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

3. 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.*

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 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.

These commitments apply to providers acting on our instructions. They do not describe our identity-resolution partners. Those partners operate their own databases, decide independently how to use the data in them, and serve their own customers as well as us. We do not control that processing and cannot make promises about it on their behalf. What we can tell you about it is in "OUR VISITOR IDENTIFICATION SERVICES" below and on our Sub-Processors page.

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

• Ad Networks
• Affiliate Marketing Programs
• AI Platforms
• Data Analytics Services
• Payment Processors
• Performance Monitoring and Error Tracking Tools
• Retargeting Platforms
• Sales & Marketing Tools
• Social Networks
• User Account Registration & Authentication Services

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.
• 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.

4. 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 gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements or to tailor advertisements to your interests. The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice. You can set and change your choices at any time in the Cookie Preference Center, which is available from the cookie banner and from our Website. Cookies that are strictly necessary to provide the Services cannot be rejected.

Analytics, session analytics, and advertising partners

The tracking technologies on our Services are provided by, and share information with, the following categories of partners. The individual cookies each one sets, and their retention periods, are listed in our Cookie Notice.

• Product and website analytics: Google Analytics, PostHog, and Microsoft Clarity.
• Session analytics and error diagnostics: Microsoft Clarity and Sentry Session Replay. These tools record how a page is used (for example cursor movement, clicks, scrolls, and page errors) so we can find and fix problems. They mask text you type into form fields by default.
• Advertising and retargeting: Google Ads, DoubleClick, Meta (Facebook), LinkedIn, and Microsoft Advertising (Bing).
• Affiliate and referral tracking: FirstPromoter.
• First-party measurement: our own OSPRY pixel, which sets first-party cookies and local storage values on our domain to recognize a returning visit and attribute it to a referring source.

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: Remarketing with Google Analytics, Google Display Network Impressions Reporting and Google Analytics Demographics and Interests Reporting. 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.

5. Do We Offer Artificial Intelligence-Based Products?

*In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.*

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"). We reach large language models through an AI gateway rather than contracting with each model provider directly, so the gateway and the model provider it routes to both process your information. We also use separate providers for text embedding and for the vector database that stores those embeddings. Each is named on our Sub-Processors page, which is the authoritative list and is updated when a provider changes.

As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

• AI automation
• AI bots
• AI document generation
• AI insights
• AI predictive analytics
• AI research
• AI search
• Image analysis
• Image generation
• Text analysis
• AI development
• AI applications

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

6. Our Visitor Identification Services

*In Short: Our product identifies business visitors to our customers' websites. If you visited a website that uses OSPRY, we may have processed personal information about you even though you never contacted us. This section explains what we process, where it comes from, and how to opt out.*

Everything above concerns information we process about people who interact with us. This section concerns our Services themselves, and it may apply to you even if you have never heard of OSPRY.

What the Services do

Our customers install a tag on their own websites. When someone visits, the tag may identify that visitor and report the result to the customer, so the customer knows which businesses and, in some cases, which individuals are researching them. Identification happens in two tiers:

• Company tier (available worldwide). Identifies the organization a visit came from. This tier is company-level and is not information about an identified individual. Company data is powered by Demandbase.
• Person tier (United States only). Identifies an individual business contact, including name, business email address, job title, and professional profile. This tier operates only for visitors located in the United States.

Where the information comes from

We do not operate our own identity-resolution engine. Identification is provided by third-party data partners who maintain the underlying databases, and their tags share the visitor's browser cookies with several identity networks in order to match a hashed identifier. We then enrich the result using our own providers and publicly available sources. Every party in that chain is named in our Sub-Processors list.

What we process

• Identity data. Name, business email address, job title, seniority, professional profile URL, employer, and company firmographics. Depending on the data partner, this may also include additional contact details and demographic or household attributes.
• Network data. IP address and information derived from it, such as approximate location, the organization the address belongs to, and whether it is a proxy or hosting provider. IP addresses are collected server-side and are never exposed to the customer's web page.
• Behavioral data. Pages viewed, referring page, campaign parameters, session timing, and on-page interaction signals.

Consent and the legal basis

The tag does not run until the website visitor accepts, where a consent banner is installed. Our customers are contractually required to deploy a consent banner that blocks the tag until acceptance, to publish cookie-notice and privacy-policy language describing this sharing, and to publish an opt-out link. A consent management platform is mandatory for customers using the worldwide company tier.

Beyond that consent, the underlying databases operate on an interest-based, opt-out basis rather than per-visitor opt-in. They are built from people who agreed to provide their information for third-party marketing generally, and a visit to a business's website is treated as an expression of interest in that business. If that basis is not one you accept, use the opt-out below.

The person tier is limited to the United States. An IP address that appears to be outside the United States is used only to decide not to identify that visitor.

How long we keep it

We keep identity, enrichment, and behavioral records associated with a resolved profile for as long as we have a business need for them, and we delete them when you ask us to. Raw IP data held in our short-term processing cache expires on a rolling 30-day window whether or not you ask.

When you exercise a deletion right, we:

• delete the profile we hold for you, including the identity fields, the enrichment we derived, and the behavioral record of your visits, regardless of which data partner resolved you;
• clear the IP addresses and the location, organization, and network information derived from them;
• remove the embeddings generated from your data from our AI systems;
• delete any contact record created from you; and
• suppress you going forward, so a later visit does not simply recreate the record we just removed.

We forward the request into the upstream data network as well, so it is acted on beyond our own systems.

Your choices

You can opt out of our Services at any time, whether or not you are a customer:

• Opt out and delete: <https://www.ospry.ai/opt-out>
• Do Not Sell or Share My Personal Information: <https://www.ospry.ai/do-not-sell>
• Request to know what we hold: <https://www.ospry.ai/request-to-know>
• Withdraw consent: <https://www.ospry.ai/withdraw-consent>
• By phone: (833) 534-4662
• By email: privacy@legioncodeinc.com

We recognize and honor Global Privacy Control (GPC) signals.

Two limits worth stating plainly. An opt-out stops future processing, but it cannot retrieve information a customer already received and holds in their own systems; that data is the customer's responsibility under their agreement with the individual concerned. And because the underlying databases are operated by our data partners and shared across their customers, we forward opt-out requests into that network as well as acting on them ourselves.

Attribution

The SOC 2 attestation covering our identity-resolution partner is that partner's attestation, not ours, and we do not present it as our own. Company-tier data is powered by Demandbase.

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 X 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.

8. 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).

Where you hold an account with us, we generally keep your account information for as long as that account is open. Information processed through our visitor identification Services is different, because the people it concerns usually have no account with us and never created one. That information is kept for as long as we have a business need for it, and is deleted when you ask us to. See "OUR VISITOR IDENTIFICATION SERVICES" above.

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.

9. 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.

10. 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 collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. 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 privacy@legioncodeinc.com.

11. What Are Your Privacy Rights?

*In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.*

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.

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.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.

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: You can accept or reject each category of non-essential cookie in the Cookie Preference Center, which is available from the cookie banner and from our Website. Cookies that are strictly necessary to provide the Services cannot be rejected. In addition, most Web browsers are set to accept cookies by default, and 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 privacy@legioncodeinc.com.

12. 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.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

Global Privacy Control: We recognize and honor Global Privacy Control (GPC) signals. If you use a browser or extension that supports GPC, we will treat this as a valid request to opt out of the sale or sharing of your personal information for targeted advertising purposes under applicable state privacy laws, including the California Consumer Privacy Act (CCPA). When we detect a GPC signal from your browser, we will automatically apply your opt-out preference without requiring you to take any additional action. For more information about GPC and how to enable it, visit globalprivacycontrol.org.

13. Do United States Residents Have Specific Privacy Rights?

*In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.*

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"

Note on Category C. Within this category we process only limited demographic data, such as gender or age range, that a social media platform provides when you interact with us there or that a marketing data provider appends to a business contact record. We do not collect or process racial or ethnic origin, religious beliefs, sexual orientation, health information, union membership, genetic data, or any other characteristic that qualifies as "sensitive personal information" under applicable US state privacy law.

Note on Category G. The geolocation data we collect is imprecise. It is derived from your IP address and tells us your approximate city, region, and country. We do not collect precise geolocation from your device unless you affirmatively enable it.

Note on Category H. We use session-analytics and error-diagnostic tools that record how a page is used, for example cursor movement, clicks, scrolls, and page errors. These tools mask text input by default. We do not record audio, video, or telephone calls.

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.

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

• Category A - As long as you have an account with us, or, where you have no account, for as long as we have a business need (see Section 6)
• Category B - As long as you have an account with us, or, where you have no account, for as long as we have a business need (see Section 6)
• Category C - As long as you have an account with us, or, where you have no account, for as long as we have a business need (see Section 6)
• Category D - As long as you have an account with us, or, where you have no account, for as long as we have a business need (see Section 6)
• Category F - As long as you have an account with us, or, where you have no account, for as long as we have a business need (see Section 6)
• Category G - As long as you have an account with us, or, where you have no account, for as long as we have a business need (see Section 6)
• Category H - As long as you have an account with us, or, where you have no account, for as long as we have a business need (see Section 6)
• Category I - As long as you have an account with us, or, where you have no account, for as long as we have a business need (see Section 6)
• Category K - As long as you have an account with us, or, where you have no account, for as long as we have a business need (see Section 6)

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

We collect and share your personal information through:

• Targeting cookies/Marketing cookies
• Social media cookies
• Beacons/Pixels/Tags

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.

Selling. We have not sold personal information to third parties for monetary consideration in the preceding twelve (12) months.

Sharing for targeted advertising. We use advertising and retargeting cookies, pixels, and similar technologies on our Services, including those provided by Google Ads, DoubleClick, Meta (Facebook), LinkedIn, and Microsoft Advertising. Under California law and comparable laws in other US states, this activity is treated as "sharing" personal information for cross-context behavioral advertising, also called targeted advertising. In the preceding twelve (12) months we have shared the following categories of personal information for that purpose:

• A. Identifiers, including online identifiers, cookie identifiers, and IP address
• F. Internet or other similar network activity
• K. Inferences drawn from collected personal information

You can opt out of this sharing at any time. Visit <https://www.ospry.ai/do-not-sell>, use the Cookie Preference Center on our Website, or contact us using the details in this notice. We also recognize and honor Global Privacy Control (GPC) signals, as described under "CONTROLS FOR DO-NOT-TRACK FEATURES."

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

• A. Identifiers
• B. Personal information as defined in the California Customer Records statute
• C. Protected classification characteristics under state or federal law
• D. Commercial information
• F. Internet or other similar network activity
• G. Geolocation data
• H. Audio, electronic, sensory, or similar information
• I. Professional or employment-related information
• K. Inferences drawn from collected 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?"

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know 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 the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting <https://www.ospry.ai/privacy>, by emailing us at privacy@legioncodeinc.com, or by referring to the contact details at the bottom of this document.

To opt out of the sale or sharing of your personal information for targeted advertising, visit our Do Not Sell or Share My Personal Information page at <https://www.ospry.ai/do-not-sell>, or set your preferences in the Cookie Preference Center on our Website.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an authorized agent to make a request 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 applicable laws.

Request Verification

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. We will only use personal information provided in your request to verify your identity or authority to make the request. 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.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@legioncodeinc.com. 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 submit a complaint to your state attorney general.

California "Shine The Light" Law

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 by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

14. 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 at the top of this Privacy Notice. 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.

15. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at privacy@legioncodeinc.com, or contact us by post at:

Legion Code Inc. Data Protection Officer 254 Chapman Rd, Ste 208 #27885 Newark, DE 19702 United States

16. How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: <https://www.ospry.ai/privacy>.