PRIVACY POLICY

Innate Q - AI System for Analyzing Innate Talents

Last Updated: May 16, 2026

1. INTRODUCTION

These terms apply globally to users outside the EU/EEA. Where the mandatory local law of your country provides different protections, those provisions prevail.

Welcome to Innate Q ("we," "us," "our," or the "Company"). Innate Q is operated by Affect Group Inc. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website located at innateq.ai and app.innateq.ai (the "Website"), our mobile applications (the "App"), and our services (collectively, the "Services").

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THE SERVICES.

2. ABOUT OUR SERVICES

Innate Q provides AI-powered personality and talent analysis services based on birth data (date, time, and place of birth). Our Services include:

Talent Analysis: Calculation of 180 innate potentials based on over 150,000 parameters

AI Psychological Profiles: Generation of detailed personality profiles using artificial intelligence

AI Mentor: Personalized recommendations and insights based on your profile

Daily AI Insights: Personalized daily recommendations and guidance (subscription feature)

Compatibility Analysis: Comparison with friends via personal codes (with mutual consent)

Public Demonstration Profiles: Example profiles of public figures for demonstration purposes

2.1 Important Disclaimers

NATURE OF THE SERVICE: Our Services provide self-knowledge insights based on date, time, and place of birth. The AI-generated profiles, talent scores, and insights are intended to complement, not replace, the user's own judgment and consultation with qualified professionals. They are NOT a substitute for medical, psychological, legal, financial, or career counseling. Always consult qualified professionals for important life decisions.

2.2 Public Figure Demonstration Profiles

Innate Q may display demonstration profiles of public figures (celebrities, business leaders, historical figures, etc.) for illustrative purposes. These profiles are calculated algorithmically using publicly available birth date data from open sources (Wikipedia, public records, biographical databases).

The calculations are provided solely to demonstrate how the Service works. We make no claims regarding the accuracy of these profiles or their correspondence to any real person’s actual abilities or characteristics. The display of public figure profiles does not constitute advertising.

If you are a public figure or authorized representative and wish to have a demonstration profile removed, please contact us at support@innateq.ai.

3. INFORMATION WE COLLECT

3.1 Information You Provide

We collect information you voluntarily provide when using our Services:

Account Information: Email address, password, profile name

Birth Data: Date of birth, time of birth, place of birth — essential for talent calculations

AI Mentor Conversations: Messages and queries you send to the AI Mentor

Questionnaire and Essay Responses: Free-text answers you provide in personality questionnaires and self-reflection essays within the Service. These responses may contain personal information of any nature, including potentially sensitive data (health, beliefs, personal life), which you share voluntarily.

Rectification Questionnaire Responses: If you purchase Birth-Time Rectification, you provide structured responses to a questionnaire of significant life events (e.g., relationships, career changes, relocations, health events, family events). These responses may contain Sensitive Personal Information under the CCPA/CPRA (Cal. Civ. Code § 1798.140(ae)), such as health information or information about religious or philosophical beliefs. We process these responses only on the basis of your explicit, informed consent given at the time of purchase, and only for the purpose of performing the rectification service. We will not use these responses to train AI models, for marketing, or for any other purpose without your separate consent.

Payment Information: Processed securely by third-party payment processors; we do not store full payment card details

Support Communications: Messages you send to our support team

Note on Names: We do not intentionally collect your full legal name. Your profile name may be a nickname or alias. Your real name may only appear if you voluntarily provide it in your profile, AI Mentor conversations, questionnaire responses, or support messages.

3.2 Information Generated by the Service

Talent Calculations: 180 calculated talent scores based on your birth data

AI Psychological Profiles: AI-generated personality descriptions and insights

Daily Insights: Personalized recommendations generated for subscribers

Comparison Results: Compatibility analyses when you compare profiles with friends

3.3 Automatically Collected Information

Device Information: Device type, operating system, unique device identifiers

Usage Data: Features used, pages visited, time spent, actions taken

Log Data: IP address, browser type, access times, referring URLs

Cookies and Tracking: Cookies and similar technologies for analytics and functionality

4. SENSITIVE PERSONAL DATA

The AI-generated psychological profiles may be considered sensitive personal data under certain privacy laws (such as GDPR). By using our Services, you explicitly consent to the processing of this data for the purposes described in this Policy.

Important: AI-generated profiles are algorithmic interpretations intended to support self-knowledge and personal reflection, and do not constitute actual psychological assessments or diagnoses.

4.1 Special Categories of Personal Data

Some Users may voluntarily provide special category personal data (as defined in GDPR Art. 9: data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership; genetic data, biometric data, data concerning health, data concerning a natural person's sex life or sexual orientation) in free-text fields such as questionnaire essays or AI Mentor conversations. We process such data ONLY with the User's explicit consent under Art. 9(2)(a) GDPR (or equivalent provision in CCPA/PDP), for the sole purpose of providing the personalized analysis the User has requested. Users may withdraw consent and request erasure at any time via support@innateq.ai.

4.2 Aggregated and Anonymized Data

We may process aggregated, anonymized data derived from User content (e.g., to improve our talent classification algorithm or to publish aggregate insights). Such aggregated data is not personal data under applicable privacy laws and is not subject to data subject rights. We ensure aggregated data cannot be re-identified.

5. HOW WE USE YOUR INFORMATION (LAWFUL BASIS TABLE)

We use collected information for the following purposes, each on the lawful basis indicated. GDPR Article references are included for users who also have rights under the EU/UK GDPR; equivalent bases under U.S. state privacy laws apply for U.S. residents.

Additional supporting purposes:

Payment Processing: To process purchases, subscriptions, and message packages

Friend Comparison: To enable profile comparisons via personal codes

Communications: To send service-related notifications and respond to inquiries

Legal Compliance: To comply with legal obligations and protect our rights

AI Training: Anonymized and aggregated data may be used to improve AI accuracy

Performing Birth-Time Rectification: Authorized personnel — including operators acting under our supervision and supervised AI processing tools — review your questionnaire responses to estimate your birth time and may contact you by email with clarifying questions. The result is reviewed by a human operator before delivery (not solely automated decision-making). Your rectification responses are not used for any other purpose, and not used for AI training, without your separate consent.

6. FRIEND COMPARISON FEATURE

Our personal code feature allows you to share your profile with friends for compatibility analysis.

6.1 What Friends Can See

When you share your personal code, the recipient may view:

All 180 calculated talent scores

Portions of your AI-generated psychological profile

Compatibility analysis between your profiles

6.2 Your Responsibilities

Only share your code with people you trust

You control who receives your code

You may generate a new code to revoke previous access

7. THIRD-PARTY SERVICE PROVIDERS

We work with third-party service providers to operate our Services. These providers have access to your information only to perform specific tasks on our behalf and are obligated to protect your data.

Categories of service providers include:

Cloud Infrastructure Providers: For hosting, data storage, and server infrastructure

AI Technology Providers: For powering AI Mentor responses and profile generation

Payment Processors: For secure handling of payment transactions

Analytics Providers: For understanding usage patterns and improving Services

Email Service Providers: For sending transactional and service emails

Authorized personnel performing manual review of Birth-Time Rectification questionnaires (e.g., operators acting under written confidentiality obligations) may be located outside your country and may process your data using the service providers listed above. All such processing occurs under appropriate contractual and technical safeguards. A list of specific subprocessors is available on request to support@innateq.ai.

8. ADVERTISING AND RETARGETING

We may share your email address with advertising platforms (such as Meta, Google) to deliver personalized advertisements. This allows us to show you relevant ads on third-party platforms based on your interest in our Services.

You can opt out of personalized advertising by:

Contacting us at support@innateq.ai with the subject "Opt-out of advertising"

Adjusting your ad preferences on the respective advertising platforms

Using browser-based opt-out tools provided by advertising networks

9. MARKETING COMMUNICATIONS

With your consent, we may send you newsletters, updates, and promotional materials about our Services via email.

You can opt out of marketing communications at any time by:

Clicking "Unsubscribe" in any marketing email

Contacting us at support@innateq.ai

Please note that even if you opt out of marketing communications, we may still send you transactional emails related to your account and purchases.

9.1 In-App Product Analytics Opt-Out

We use in-app product analytics to understand how users interact with our Services and to improve them. To opt out of in-app product analytics, please email support@innateq.ai with the subject line "Opt out of analytics". We will action your request within 30 days of receipt.

10. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to collect and store information about your interactions with our Services.

10.1 Types of Cookies We Use

Essential Cookies: Required for basic functionality, authentication, and security

Analytics Cookies: Help us understand how users interact with our Services to improve user experience

10.2 Managing Cookies

You can control cookies through your browser settings. Disabling certain cookies may affect functionality of the Services.

11. DATA RETENTION

We retain your personal data for as long as your account is active or as needed to provide Services. Specific retention periods:

Account Data: Retained while your account is active and for up to 3 years after account deletion request to handle legal claims and disputes

Talent Calculations & AI Profiles: Retained while your account is active; deleted within 90 days of account deletion request

AI Mentor Conversations: Retained for 12 months after generation for service improvement, then anonymized or deleted

Payment Records: Retained for 7 years as required by U.S. tax and accounting regulations

Analytics Data: Retained for up to 14 months in identifiable form, then anonymized; aggregated and anonymized data may be retained indefinitely

Rectification Questionnaire Responses: Retained for up to 12 months from delivery of the result, then deleted, unless you request earlier deletion. This window allows us to reopen the case if you provide additional information.

Upon account deletion request, we will delete or anonymize your data within a reasonable timeframe, except where retention is required by law.

12. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal data, including:

Encryption of data in transit (TLS/SSL) and at rest

Secure authentication mechanisms

Access controls limiting data access to authorized personnel

Regular security assessments

Secure third-party service providers with appropriate safeguards

Note: No method of transmission or storage is 100% secure. We cannot guarantee absolute security.

13. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. By using our Services, you consent to the transfer of your information to countries outside your country of residence, including the United States.

For users in the European Economic Area (EEA) or United Kingdom (UK), we ensure appropriate safeguards are in place for international transfers, such as Standard Contractual Clauses approved by the European Commission.

14. YOUR RIGHTS AT A GLANCE

Plain-language summary of the rights detailed in the next section. The detailed legal-basis enumeration follows.

Access: You can ask us for a copy of the personal data we hold about you.

Correction: You can ask us to fix any data that is wrong or out of date.

Erasure: You can ask us to delete your data when we no longer need it.

Objection: You can object to certain uses of your data, such as profiling or marketing.

Restriction: You can ask us to pause processing while a dispute or correction request is open.

Portability: You can ask for your data in a portable, machine-readable format.

Consent withdrawal: Where we rely on your consent, you can withdraw it at any time without affecting prior processing.

14A. YOUR RIGHTS — DETAILED

14.1 Rights for All Users

Regardless of your location, you have the right to:

Access: Request a copy of your personal data

Correction: Request correction of inaccurate data

Deletion: Request deletion of your personal data

Withdraw Consent: Withdraw consent where processing is based on consent

To exercise these rights, contact us at support@innateq.ai. We will respond to your request within 30 days.

14.2 Additional Rights for EEA/UK Users (GDPR)

If you are located in the EEA or UK, you also have the right to:

Data Portability: Receive your data in a structured, machine-readable format

Restriction: Request restriction of processing

Object: Object to processing based on legitimate interests

Lodge Complaint: Lodge a complaint with your local Data Protection Authority

14.3 Additional Rights for California Residents (CCPA/CPRA)

California residents have the right to:

Know: What personal information we collect, use, and disclose

Delete: Request deletion of personal information

Correct: Request correction of inaccurate information

Opt-Out of Sale: We do not sell personal information

Non-Discrimination: We will not discriminate against you for exercising your rights

14B. PROSPECTIVE CUSTOMER NOTICE

This Notice applies if you provide your email address through our website forms (e.g., to access the full talent classification preview, sign up for updates, or request more information) before creating a User account.

Personal data collected: email address, IP address (for fraud prevention), referral source.

Purpose of processing:

To deliver the requested resource (e.g., classification preview link).

With your additional consent, to send you product updates, educational content, and marketing communications about Innate Q.

Legal basis (CCPA/CPRA — for California residents; equivalent business-purpose disclosures apply to other U.S. state-law residents):

For delivering the requested resource: performance of a requested service (pre-contract / business purpose).

For marketing communications: your opt-in consent (email-based).

Retention: We retain prospective-customer email addresses for up to two (2) years from the last interaction. After this period, we delete or anonymize the data unless you have created a User account.

Your rights: You have the same rights as Users under this Privacy Policy, including the right to request access, correction, deletion, or opt-out of marketing emails. To unsubscribe from marketing emails, click the unsubscribe link in any email or contact support@innateq.ai.

If you create a full User account, your prospective-customer record is merged into your User account and the User Privacy Notice supersedes this Notice.

15. CHILDREN’S PRIVACY AND PARENTAL CONSENT

Innate Q does not allow direct registration by users under 16 years of age. Parents or legal guardians may register on behalf of a minor, in which case:

• The parent or guardian acknowledges that they hold parental authority and consent to the processing of the minor's personal data
• The registration email and email-verification link confirm parental consent
• All rights and obligations under this Privacy Policy and our Terms of Service apply to the parent or guardian acting on behalf of the minor

Parents and legal guardians may also use our Services to analyze birth data of their children of any age. By entering a child's birth data, the parent or guardian confirms they have the legal authority to provide this information and consent to its processing on behalf of the child.

If you believe a child under 16 has created an account without parental consent, please contact us at support@innateq.ai, and we will delete such account.

16. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Material changes will be notified via email or through the Services. Your continued use of the Services after changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this Policy periodically.

16A. TESTIMONIALS / USER STATEMENTS

The Innate Q website displays testimonials from real Users — including their names, photos, and statements. Each individual depicted has provided written consent (typically via email or messaging-platform exchange) authorizing use of their likeness and statement for marketing purposes. Consents are retained on file and may be revoked at any time by emailing support@innateq.ai; on revocation, the testimonial is removed within fourteen (14) days. This use is consistent with the right-of-publicity laws of the user's state of residence.

16B. PUBLIC-FIGURE COMPATIBILITY COMPARISON

The Innate Q App allows registered Users to compare their personal innate-talents profile against algorithmically-derived profiles of public figures (historical and contemporary celebrities, business leaders, scientists, artists, etc.). Public-figure profiles are computed from publicly-available biographical data (date and place of birth, available in open-source biographical databases — Wikipedia, public records, biographical encyclopedias, etc.). No biometric, sensitive, or non-public data of public figures is collected or processed. The User's own data is processed locally for the comparison and is not shared with any third party. This use is consistent with U.S. fair-use principles for public-domain biographical information.

17. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Affect Group Inc

1401 21st Street, Sacramento, CA 95811, USA

Email: support@innateq.ai

Website: https://innateq.ai

For EEA/UK Users

If you are located in the EEA or UK and have unresolved concerns about our data processing practices, you have the right to lodge a complaint with your local Data Protection Authority.

18. NOTICE TO CALIFORNIA RESIDENTS (CCPA/CPRA)

This section applies to California residents and supplements the rest of this Privacy Policy. It is provided pursuant to the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act ("CPRA").

18.1 Right to Know (CCPA §1798.110)

You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the business or commercial purpose for collecting the information, and the categories of third parties with whom we share that information.

18.2 Right to Delete (CCPA §1798.105)

You have the right to request deletion of personal information we have collected from you, subject to certain exceptions permitted by law (e.g., where retention is required to complete a transaction, comply with a legal obligation, or detect security incidents).

18.3 Right to Opt Out of Sale or Sharing (CCPA §1798.120)

We do not sell or share personal information for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA. Because we do not engage in such sales or sharing, no "Do Not Sell or Share My Personal Information" link is required. You may still email us at support@innateq.ai to confirm or to object to any future change in this practice.

Note: We do not run advertising-based marketing. We do not enable conversion tracking pixels (Meta, Google Ads, etc.). Stripe Conversion Tracking is not enabled.

18.4 Right to Correct (CPRA §1798.106)

You have the right to request correction of inaccurate personal information that we maintain about you.

18.5 Right to Limit Use of Sensitive Personal Information (CPRA §1798.121)

California residents have the right to limit our use and disclosure of "sensitive personal information" to those uses necessary to provide the Services or as otherwise permitted by law. Birth data and AI-generated psychological profiles may qualify as sensitive personal information. We use such information solely for the purposes described in Section 5 of this Policy.

18.6 Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny goods or services, charge different prices, or provide a different level of service because you have exercised these rights.

18.7 Authorized Agents

You may designate an authorized agent to make a request on your behalf by providing the agent with written, signed permission to do so. We will require the agent to provide proof of your written authorization and may require you to verify your identity directly with us.

18.8 Categories of Personal Information Collected

Within the 12 months preceding the effective date of this Policy, we have collected the following categories of personal information defined under the CCPA:

Identifiers: Identifiers (email address, profile name, account ID, IP address, device identifiers)

Commercial information: Commercial information (subscription and purchase history)

Internet activity: Internet or other electronic network activity (interactions with the Services, log data)

Inferences: Inferences drawn to create a profile reflecting the user's preferences, characteristics, and aptitudes (AI-generated talent and personality profiles)

Sensitive personal information: Sensitive personal information (date, time, and place of birth; free-text questionnaire and AI Mentor responses that may contain health or belief information voluntarily shared by you)

18.9 Shine the Light

California's "Shine the Light" law (Cal. Civ. Code §1798.83) permits California residents to request information regarding our disclosure of personal information to third parties for those parties' direct-marketing purposes. We do not disclose personal information to third parties for their direct-marketing purposes.

18.10 How to Exercise Your California Rights

To exercise any of the rights described above, contact us at support@innateq.ai with the subject line "California Privacy Rights Request". We will verify your identity by matching information you provide against our records and will respond within the timeframes required by the CCPA (generally 45 days, extendable by an additional 45 days where reasonably necessary).

19. NOTICE TO OTHER U.S. STATE RESIDENTS

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Tennessee, Indiana, New Hampshire, New Jersey, Delaware, Minnesota, and Rhode Island have rights under their state's data protection law similar to those listed in §18 (Notice to California Residents). To exercise rights, follow the same procedure as California residents.

Residents of other U.S. states with applicable comprehensive data protection laws may also exercise equivalent rights through the same channel by emailing support@innateq.ai.

20. GOVERNING LAW

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of California, United States, without regard to conflict of law principles. For users in the European Union, nothing in this Policy affects your rights under mandatory consumer protection laws of your country of residence.

* * *

By using Innate Q, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your information as described herein.

© 2026 Affect Group Inc. All rights reserved.