Sabi Privacy Notice

Sabi is a product of Wabi, Inc., headquartered in San Francisco, California. This Privacy Notice ("Privacy Notice") describes the types of information Wabi, Inc. ("Sabi", "we", "us", "our") collects, uses, maintains, protects, discloses, or otherwise processes about you when:

• you visit our website at https://getsabi.ai/ ("Website");
• you install and use our mobile applications that you download from an authorized distribution site, such as the Apple App Store® or the Google Play Store® (each, an "Application");
• you use our products and services and any applications created by our users (each, a "Mini-App," and together with our products and services, our "Services");
• you communicate with us via email, text, or other medium; and
• we interact with certain third parties.

Unless otherwise noted in this Privacy Notice, the term "Personal Data" means information that identifies you. It does not include any deidentified or aggregated information.

If you are a California resident, please see our California Privacy Notice. If you are a Nevada resident, please see our Nevada Privacy Notice. If you are a resident of another U.S. state with a comprehensive privacy law, please see Other U.S. State Privacy Rights. If you are a non-US resident, please see our Non-US Privacy Notice.

We collect your Personal Data from various sources, including:

• directly from you when you provide it to us;
• automatically as you navigate through or otherwise use the Website, Applications, and/or Services;
• information that we create about you as you use our Website, Applications, or Services;
• from third parties, for example, service integrations you decide to add; and
• from advertising, analytics, and measurement partners, for example, the advertising platforms on which we run marketing campaigns (see Advertising, Analytics, and Marketing Partners below).

Information You Provide to Us. We collect the following types of Personal Data directly from you when you access or use our Website, Applications, or Services:

• Real name;
• Alias;
• Unique personal identifier;
• Email address;
• Account name;
• Employment information (if using the LinkedIn integration);
• The tasks you ask Sabi to handle and the details needed to complete them, for example dates, addresses, confirmation numbers, documents, and the names and contact details of people or businesses you ask Sabi to contact on your behalf;
• Payment method and financial account information, if you choose to connect a payment method or bank account (for example, through Stripe Link or Plaid) so that Sabi can make purchases, pay bills, or file reimbursements on your behalf. Card numbers and bank credentials are collected by the payment provider, not by Sabi; we receive tokens and transaction details;
• Travel, booking, reservation, and order details when you ask Sabi to arrange or purchase something for you (for example, flights, restaurant reservations, appointments, or other goods and services), where those features are available; and
• Any other personal information contained in accounts you connect to Sabi, such as Gmail, Google Calendar, Notion, LinkedIn, Reddit, or Twitter. Content in connected accounts may include information about other people (for example, the senders of your emails or attendees of your calendar events); we process that information only to perform the task you asked for.

In addition, we also collect other types of information that you may provide when you fill out a form or through your correspondence with us.

We may collect your Personal Data when:

• you provide the information by filling in forms on our Website, Applications, or Services. This includes information provided at the time of registering to use our Website, Applications, and Services, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Website, Applications, or Services;
• you contact us, including records and copies of your correspondence (including email addresses);
• you provide responses to surveys that we might ask you to complete for research purposes;
• you complete transactions through our Website, Applications, and Services and of the fulfillment of your orders. Purchases made through our iOS App are processed by Apple (including via Apple Pay), and any payment details you provide are collected directly by Apple, not by Sabi;
• you submit search queries on the Website, Applications, and Services; and
• you provide information while creating or using a Mini-App.

You also may provide information to be shared with other users of the Services or with third parties, for example when you share a Mini-App or ask Sabi to send a message on your behalf (collectively, "User Contributions"). Your User Contributions are transmitted to others at your own risk. We cannot control the actions of other users or third parties with whom you choose to share your User Contributions, and we cannot guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, Applications, or Services, we may use automatic data collection technologies to collect certain Personal Data about your interaction with our Website, Applications, or Services, including information about your equipment, browsing actions, and patterns. This includes:

• details of your visits to, and use of, our Website, Applications, and Services. This includes: browsing history, search history, traffic data, location data, logs, error information, clickstream data, and other communication data and the resources that you access, use, or otherwise interact with on or through the Website, Applications, or Services;
• your physical location and movements;
• Information about your computing device and internet connection, i.e., your IP address, operating system, device make and model, and browser type; and
• Advertising and device identifiers (such as Apple's Identifier for Advertisers (IDFA), Google Advertising ID (GAID), or a similar platform identifier), cookie identifiers, and campaign click identifiers, together with in-app and on-site events (such as installing or opening the Application, creating an account, starting a trial, or completing a purchase) that we and our advertising partners use to measure and attribute our marketing campaigns.

The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website, Applications, and Services and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences;
• provide you with targeted advertising, which is based on your activities on the Website and Applications and other online activities;
• record your activities on our Website, Applications, and Services for analytics and debugging purposes;
• customize our Website, Applications, and Services according to your individual interests;
• speed up your searches; and
• recognize you when you return to our Website, Applications, and Services.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or otherwise use our Applications. Our Website and Applications may use both session cookies and persistent cookies: Session Cookies. Each time you access the Website, a session cookie containing an encrypted, unique identifier is placed on your device. These session cookies allow us to uniquely identify you when you use the Website and allow us to maintain your login session. Session cookies are required to use the Website and are removed when you logout or close your browser window to the Website. Persistent Cookies. Persistent cookies that may contain a unique identifier are placed on your device when you access the Website. These cookies are used to track aggregate and statistical information about user activity, maintain your preferences, and provide you with targeted or behavioral advertising based on your activities on the Website. The amount of time these cookies remain on your device may vary, depending on the cookie. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Website or Applications. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu. If you have questions about the specific cookies we use and how long they remain on your device, please contact us at privacy@getsabi.ai.
• Web Beacons. Pages of our Website, screens of our Application, and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Sabi, for example, to count users who have visited those pages or screens or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Website Interaction and Performance Monitoring Tools. Our Website and Applications may also use interaction and/or performance monitoring tools (sometimes call tracking scripts, analytics tools, session replay tools, or heatmap tools). These tools execute code in your web browser to help us collect data about your use of and interactions with the pages and content on our Website and Applications. This may include recording your mouse movements, keystrokes, navigation pathways, other actions that you take our Website and Applications, and information automatically transmitted from your web browser or device to our Website and Applications such as information about your operating system, computer hardware, and browser preferences.

Information We Create About You. We may also create certain information about you. When we associate this information with other Personal Data about you, we consider this information to be Personal Data. This information includes: unique identifiers, profile reflecting your preferences, characteristics, behavior, and schedules.

Information We Collect from Third Parties. We may collect Personal Data from third parties. When we associate this information with other Personal Data about you, we consider this information to be Personal Data. This information includes: real name, alias, unique personal identifier, email address, telephone number, account name, employer name and employment history (if using the LinkedIn integration), and payment and transaction information from Apple, our payment processor for App Store purchases. We do not receive or store your payment card number, Apple Pay credentials, or bank account details. We receive limited transaction information from Apple, such as the product purchased, purchase and renewal dates, subscription status, and transaction identifiers, which we associate with your account in order to provide the Services, manage billing, and prevent fraud. If you connect a payment method or financial account so that Sabi can transact on your behalf, we receive account, balance, and transaction information from the provider you connect through (such as Stripe or Plaid) to the extent needed to complete the tasks you request. We may also receive confirmations and receipts from the merchants, airlines, restaurants, and other businesses with which Sabi interacts on your behalf. We may also receive information from advertising and measurement partners about how you found us, such as the advertising platform, campaign, ad, or link that led you to our Website or to an app store listing for our Application, and whether you subsequently installed the Application or took an action in it.

We use information that we collect about you or that you provide to us, including any Personal Data:

• to provide and personalize our Application and Services to you;
• to provide you with information, products, or services that you request from us;
• to support, develop, troubleshoot, and debug our Website, products, and services;
• to create, maintain, customize, and secure your account with us;
• to process your requests, purchases, transactions, and payments and prevent transactional fraud;
• to provide you with notices about your account, including expiration and renewal notices;
• to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
• to personalize your experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and advertisements through our Services, third-party sites, and via email or text message (with your consent, where required by law);
• to help maintain the safety, security, and integrity of our Website, Applications, and Services, and business;
• for internal testing, research, analysis, and product development, including to develop and improve our Website, Applications, and Services, and to develop, improve, or demonstrate our products and services;
• auditing relating to a current interaction with you and concurrent transactions, including, but not limited to, counting advertising impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with any applicable specification and other standards;
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• debugging to identify and repair errors that impair existing intended functionality;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to our Website or Applications or any products or services we offer or provide though them;
• to allow you to participate in interactive features on our Application;
• in any other way we may describe when you provide the information;
• to fulfill any other purpose for which we have collected it; and
• for any other purpose with your consent.

We may further anonymize or aggregate your Personal Data in accordance with applicable law such that it can no longer reasonably be used to identify you and use it without restriction.

Connected accounts and Google user data. We use the content of accounts you connect to Sabi (such as Gmail, Google Calendar, Notion, LinkedIn, Reddit, or Twitter) only to provide and improve the features you ask Sabi to perform. We do not use it for advertising, we do not sell it, and we do not use it to build advertising profiles. Sabi's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. In particular, we do not transfer Google user data to third parties except as necessary to provide or improve user-facing features, for security, to comply with law, or as part of a merger or acquisition with notice to you; we do not use it to serve advertisements; and humans do not read it except with your consent, for security purposes, to comply with law, or when it has been aggregated and anonymized for internal operations.

We may also use your Personal Data to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your Personal Data in this way, you may opt out at any time by using the unsubscribe link in any marketing email, adjusting your notification preferences in the Application, or sending us an email stating your request at privacy@getsabi.ai.

We work with third-party analytics, advertising, and measurement providers to understand how our Website, Applications, and Services are used and to promote them on other platforms. When we run advertising campaigns, we may collect additional Personal Data about you and share limited Personal Data with the advertising platforms described below so that they can show our ads to you and to people like you, measure whether our ads led you to install or use our Application or Services, and help us decide where to advertise. You can find your choices for limiting this activity under Your Advertising Choices below.

Analytics providers. We use Amplitude, an analytics service, to understand how users interact with our Website, Applications, and Services. Amplitude collects technical information such as your time zone, device type, operating system, and unique identifiers, and records interactions that occur in our Application so we can decide which features to focus on. You can read more in Amplitude's Privacy Notice. We also use Google Firebase to deliver notifications, configure the Application, and analyze how users react to changes in the Application. You can read more in Google's Privacy and Security in Firebase documentation.

Ad performance and attribution measurement. To understand which advertising campaigns bring users to us (for example, which advertiser delivered the ad that led you to an app store listing for our Application), we may use the measurement tools offered by the advertising platforms below (such as pixels, software development kits ("SDKs"), and server-to-server "conversions" or "events" APIs) and may use a mobile measurement partner that links ad clicks and views to installs and in-app events. The information used for this purpose typically includes advertising and device identifiers, IP address, device and browser information, campaign and click identifiers, and events such as installs, account creation, trials, and purchases.

Meta (Facebook and Instagram). We use Meta's advertising services, including Meta Ads Manager, the Meta Pixel, the Meta SDK, the Meta Conversions API, and Meta Custom Audiences, to run and measure ads on Facebook, Instagram, and other Meta products. Through these tools we may share with Meta events you complete on our Website or in our Application (for example, installing the Application, creating an account, or purchasing a subscription), together with identifiers such as a hashed email address, advertising identifier, or IP address, so that Meta can measure our ads, show our ads to people who have taken certain actions with our Services, and find new audiences that resemble our users. As a result, you may see more of our ads while using Facebook or Instagram. You can learn how Meta uses this information in the Meta Privacy Policy and control the ads you see through your Facebook ad preferences.

TikTok. We use TikTok for Business, including the TikTok Pixel and the TikTok Events API, to run and measure our ads on TikTok and to show our ads to users who have taken certain actions with our Services or who resemble our users. Through these tools we may share with TikTok events you complete on our Website or in our Application and identifiers such as a hashed email address, advertising identifier, or IP address. You can read more in the TikTok Privacy Policy and adjust your ad settings within the TikTok app.

Snap (Snapchat). We use the Snapchat Advertising Platform, including the Snap Pixel, the Snap Conversions API, and Snap Audience Match, to run and measure our ads on Snapchat and to link the activity of some users of our Services with the Snapchat advertising network. Through these tools we may share with Snap events you complete on our Website or in our Application and identifiers such as a hashed email address, advertising identifier, or IP address. As a result, you may see more of our ads on Snapchat if you use our Services. You can read more in the Snap Privacy Policy and opt out of audience-based ads in your Snapchat settings.

Other ad networks. We may also work with other ad networks, ad agencies, and publishers that display our ads on other websites and apps and that may collect information such as your device identifier or IP address to deliver and measure those ads. We will update this Privacy Notice if we begin working with additional advertising platforms in a way that materially changes the Personal Data we collect or share.

Your Advertising Choices. You can limit the collection and use of your information for advertising in the following ways:

• On iOS, you can decline or withdraw permission for our Application to track you across other companies' apps and websites through the App Tracking Transparency prompt or in Settings > Privacy & Security > Tracking. On Android, you can delete or reset your Advertising ID and opt out of ads personalization in your device's Google settings.
• You can adjust your advertising preferences directly with each platform using the Facebook, Instagram, TikTok, and Snapchat ad settings linked above.
• You can learn more about interest-based advertising and opt out of participating companies at the Network Advertising Initiative (www.networkadvertising.org) and the Digital Advertising Alliance (www.aboutads.info, and www.youradchoices.com/appchoices for mobile apps).
• You can opt out of the disclosure of your Personal Data to advertising platforms for targeted advertising at any time on our Your Privacy Choices page. The opt-out applies to the browser or device on which you set it.
• We honor the Global Privacy Control (GPC) browser signal as an opt-out request for the browser from which it is sent, as described under Do Not Track and Global Privacy Control Signals below.
• You may also email privacy@getsabi.ai with the subject "Advertising Opt-Out" to ask us not to share your Personal Data with advertising platforms for targeted advertising.

Under certain U.S. state privacy laws, our disclosure of Personal Data to advertising platforms for these purposes may be considered a "sale" of Personal Data or "sharing" for cross-context behavioral or targeted advertising. Please see Jurisdiction-Specific Privacy Rights below for the rights that may be available to you.

Our Website, Applications, and Services are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website, Applications, and Services. We do not knowingly collect Personal Data from children under 13. If you are under 13, do not use or provide any information on our Website, Applications, and Services or on or through any of their respective features, register on or through the Website, Applications, or Services, make any purchases through the Website, Applications, or Services, use any of the interactive or public comment features of our Website, Applications, and Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 13, please contact us at privacy@getsabi.ai.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose anonymized or aggregated information about our users, and information that does not reasonably identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Privacy Notice:

• to our subsidiaries and affiliates;
• to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. These entities include: cloud hosting and infrastructure providers (such as Cloudflare); artificial intelligence model providers that process the content of your requests and connected data in order to generate Sabi's responses and carry out your tasks (currently Google, Anthropic, and OpenAI), under agreements that prohibit them from using your data to train their models and limit how long they may retain it; analytics and customer communications providers (such as Amplitude, Google Firebase, and Loops); and payment and financial account providers (such as Apple, Stripe, and Plaid);
• to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Sabi's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Sabi about our users is among the assets transferred;

• to third-party cookie and other tracking technology providers for the purpose of providing analytics and cross-context behavioral advertising services to us;
• to advertising, analytics, and measurement partners, including Meta (Facebook and Instagram), TikTok, and Snap, for the purpose of delivering, targeting, and measuring our advertising campaigns, as described under Advertising, Analytics, and Marketing Partners above;
• to fulfill the purpose for which you provide it. For example, if you ask Sabi to book a reservation, buy a ticket, or send a message on your behalf, we will disclose the information needed to complete that task to the relevant business or recipient;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our terms of service and other agreements, including for billing and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Sabi, our customers, or others.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data we have collected about you. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies. We may use certain tracking technologies that may record your activities on our Website and your other online activities, and such recordings may be disclosed and processed by third-parties who provide such technologies. This helps us understand our users and the use of our Website. You may disable these technologies by setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent; however, if you disable or refuse cookies in this manner, please note that some parts of our Website may then be inaccessible or not function properly. If you do not disable these technologies, you hereby consent to our use of your Personal Data and our recording and disclosure to third-party cookie providers of your activities on our Website in this way.
• Targeted and Behavioral Advertising. Our Website may use certain technologies, including cookies, to display advertising to you based on your activities of our Website and other online activities. You may disable these technologies by setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent, or by emailing privacy@getsabi.ai with the subject "Advertising Opt-Out" as described under Your Advertising Choices above. If you disable or refuse cookies in this manner, please note that some parts of our Website may then be inaccessible or not function properly. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative ("NAI") on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).

You can review and change your Personal Data by logging into the Application and visiting your account profile page. You can additionally disable profiling and certain kinds of Processing by disconnecting integrations or switching off the "Memory" setting.

You may also send us an email at privacy@getsabi.ai to request access to, correct or delete any Personal Data that we have collected about you. We cannot delete your Personal Data except by also deleting your user account. We may not accommodate a request to change or delete your Personal Data if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.

The jurisdiction in which you are a resident or are located may provide you with additional rights and choices regarding your Personal Data. Please see Jurisdiction-Specific Privacy Rights for more Information.

The law in some jurisdictions may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the privacy addendum for your jurisdiction that is attached to this Privacy Notice.

California Privacy Notice

Right to Opt Out of Sale or Sharing. We do not sell your Personal Data for money. However, our disclosure of identifiers and activity information to advertising platforms such as Meta, TikTok, and Snap for targeted advertising, as described under Advertising, Analytics, and Marketing Partners above, may constitute "sharing" of Personal Data for cross-context behavioral advertising, or a "sale" of Personal Data, as those terms are defined under California law. If you are a California resident, you have the right to opt out of this sharing. You can exercise this right on our Your Privacy Choices page (also linked as "Your Privacy Choices" in the footer of our Website), by enabling the Global Privacy Control signal in your browser, or by emailing privacy@getsabi.ai with "California Opt-Out of Sale/Sharing" in the subject line. We do not knowingly sell or share the Personal Data of consumers under 16 years of age.

Your Other California Rights. Subject to certain exceptions, you have the right to request that we disclose the categories and specific pieces of Personal Data we have collected about you, the categories of sources, our business purposes for collecting or sharing it, and the categories of third parties to whom we disclose it; to request that we correct inaccurate Personal Data; and to request that we delete Personal Data we collected from you. You will not be discriminated against for exercising these rights. You may submit requests by emailing privacy@getsabi.ai. We will verify your request by matching the information you provide with the information in your account and may ask you to confirm the request from the email address associated with your account. You may designate an authorized agent to make a request on your behalf; we may require proof of the agent's authority and verification of your identity. We will respond to verifiable requests within 45 days, which we may extend once by an additional 45 days with notice to you. We do not use or disclose sensitive personal information for purposes other than those permitted by California law.

California law permits minors under the age of 18 to request the removal of your User Contributions, subject to certain exceptions. If you are under the age of 18 in California, you may contact us using the Contact Information below (if you contact us via email, please use the subject "California Eraser Law Request"). We may not remove your User Contributions that we are required to retain under any federal or state law, or that have been provided to a third party. While we will do our best to remove a minor's information upon a valid request, we cannot ensure the complete or comprehensive removal of your User Contributions from our Applications or any information that has been republished, copied, downloaded, or reposted by any third party, and we cannot guarantee that any such information may not be accessible to users of the Internet in the future. We do not advertise or market any of the products or services identified in California Business and Professionals Code Section 22580(i) to users who we have actual knowledge are under 18 years of age.

Nevada Privacy Notice

Sale of Personal Information. If you are a Nevada resident, you have the right to submit a request directing us not to make any sale of your personal information. We do not sell your personal information for monetary consideration as defined under Nevada law. To request email confirmation that we do not sell your personal information, or to opt out of any future sale, please send an email to privacy@getsabi.ai with "Nevada Opt-Out of Sale" in the subject line and in the body of your message.

Other U.S. State Privacy Rights

If you are a resident of a U.S. state that has enacted a comprehensive consumer privacy law (including, among others, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia), you may have some or all of the following rights, subject to the exceptions and thresholds in your state's law:

• Access. To confirm whether we process your Personal Data and to access it.
• Correction. To correct inaccuracies in your Personal Data.
• Deletion. To delete Personal Data provided by or obtained about you.
• Portability. To obtain a copy of your Personal Data in a portable and readily usable format.
• Opt out. To opt out of the processing of your Personal Data for targeted advertising, the sale of Personal Data, or profiling in furtherance of decisions that produce legal or similarly significant effects. You can opt out of targeted advertising and any sale on our Your Privacy Choices page or by enabling the Global Privacy Control signal in your browser.
• Appeal. To appeal our decision if we decline to act on your request. You may appeal by replying to our response or emailing privacy@getsabi.ai with "Privacy Appeal" in the subject line. If your appeal is denied, we will tell you how to contact your state Attorney General.

To exercise these rights, email privacy@getsabi.ai. We will verify your request using the information associated with your account and respond within 45 days, which we may extend by an additional 45 days where reasonably necessary with notice to you. Where your state's law permits it, you may use an authorized agent to submit an opt-out request on your behalf. We do not process sensitive data, as defined by these laws, without your consent or as otherwise permitted by law.

Your Non-US Privacy Notice

Role and Data Controller Contact Details. Certain foreign data privacy laws, including the European Union's General Data Protection Regulation, distinguish between organizations that process personal information for their own purposes (known as "controllers") and organizations that process personal information on behalf of other organizations (known as "processors"). We act as a controller with respect to personal information collected from you as you engage with our Website, Applications, and Services. If you have questions with respect to our processing of your information as a controller, you can contact us at privacy@getsabi.ai.

Lawful Basis for Processing. Certain non-US privacy laws require a "lawful basis" for processing personal information. Our lawful bases include the following:

• To fulfill contractual obligations with you. When you use our Websites, Applications, and Services, or otherwise engage with us, we process your Personal Data to engage in contractual obligations with you. If you refuse to provide such Personal Data, or withdraw your consent, we may not be able to provide you with our Website, Applications, and Services.
• To pursue our legitimate interests. Our legitimate interests include, among others, understanding how our Website, Applications, and Services are functioning, improving our Website, Applications, and Services, developing new websites and services, preventing fraud, and otherwise performing business functions. Where we rely on a legitimate interest to process Personal Data, we carry out a balancing test to weigh the legitimate interest against your right to protection of your Personal Data; however, our processing of your Personal Data will never override your fundamental rights and freedoms, and you can always exercise your right to object to such processing.
• Consent. In certain situations where you provide us with consent, we may process your Personal Data.
• To comply with law. In limited circumstances, we may process Personal Data in order to comply with legal obligations. To the extent we have received such information from third parties with whom we have agreed to certain contractual requirements or obligations (e.g., standard contractual clauses), we will use our reasonable efforts to dispute the disclosure of Personal Data, unless legally required to do so.

Special Categories of Information. Sabi does not intentionally collect special categories of Personal Data. Content in accounts you connect or tasks you ask Sabi to handle may incidentally include such information (for example, a medical appointment in your calendar). Sabi processes this information only to perform the task you requested, with your consent, or as otherwise permitted by applicable law.

Automated Decision Making. Sabi does not use your Personal Data with any automated decision making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.

Onward Transfer. If you choose to provide us with your information, you consent to the transfer and storage of that information on our servers located in the United States. The information we collect is subject to state and federal law in the United States. If you are accessing our websites from outside the United States, please be advised that you are transferring your personal information to us in the United States where data protection and privacy laws may be different or less stringent than the laws of your country.

Your Data Subject Rights. You have the right to:

• Access and Update. You can review and change your Personal Data by logging into the Application and visiting your "Settings" page. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
• Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
• Portability. To the extent the Personal Data you provide Sabi is processed based on your consent and that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
• Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
• Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies. If you delete your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Application users. Proper access and use of information provided on the Website Application, including User Contributions, is governed by our terms of use.
• Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
• How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law. To exercise your rights, please send an e-mail to privacy@getsabi.ai.

We may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they "do not track" your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

Some web browsers and browser extensions permit you to broadcast the Global Privacy Control signal ("GPC Signal") as specified at https://www.globalprivacycontrol.org. We honor GPC Signals. When our Website detects a GPC Signal from your browser, we treat it as a request to opt out of the sale of your Personal Data and of its sharing for targeted or cross-context behavioral advertising, and we stop sending your activity on the Website to our advertising partners from that browser. The GPC Signal applies to the browser from which it is sent; if you want the opt-out to apply to your account across devices, please also email privacy@getsabi.ai.

We retain Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Notice, including to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. In determining retention periods we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and applicable legal requirements. In general:

• Account and profile information is retained for as long as your account is active. When you delete your account, we delete or anonymize it within 30 days, except as described below.
• Task content, conversations, and memory are retained while your account is active so that Sabi can continue to help you; you can delete individual items or switch off Memory in the Application at any time.
• Connected-account content (such as Gmail or Google Calendar data) is processed to perform the task you requested and is not retained longer than needed for that task and for the features you have enabled. Disconnecting an integration stops further access, and we delete the connected data we hold within 30 days.
• Financial and transaction records are retained for as long as required by tax, accounting, and payment-network rules, typically seven years.
• Content sent to AI model providers is retained by those providers only for the limited period permitted under our agreements with them (typically up to 30 days, for abuse monitoring) and is not used to train their models.
• Analytics and advertising data is retained in identifiable form for no more than 24 months, after which it is deleted or aggregated. Advertising partners retain data they receive in accordance with their own privacy policies.
• Backups and logs are retained for up to 90 days and are then overwritten.

We may retain Personal Data longer where required by law, to establish or defend legal claims, to prevent fraud or abuse, or in anonymized or aggregated form.

We have implemented commercially reasonable safeguards to protect your Personal Data. The safety and security of your Personal Data also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Applications, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we have implemented measures to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through our Applications. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed through our Applications.

In order to provide our Website, Applications, and Services to you, we may send and store your Personal Data outside of the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your Personal Data may be processed and stored in the United States and federal, state, and local governments, courts, or law enforcement or regulatory agencies in the United States may be able to obtain disclosure of your information through the laws of the United States. By using our Website, Applications, or Services, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data outside of the country where you reside or are located, including in the United States.

Your Personal Data is transferred by Sabi to another country only if it is required or permitted under applicable data protection law and provided, however, that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with this Privacy Notice when we transfer it to a third party, Sabi uses Data Protection Agreements between Sabi and all other recipients of your Personal Data.

We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users' Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Website's home page. The date this Privacy Notice was last revised is identified at the top of the page, and prior versions are available on request by emailing privacy@getsabi.ai. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.

Your continued use of our Website, Applications, or Services following the posting of changes constitutes your acceptance to such changes.

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Data described in this Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below or through the contact options on our Website or in our Applications.