PRIVACY POLICY

Innate Q - AI System for Analyzing Innate Talents

Last Updated: October 20, 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-Written Profiles: Talent scores are calculated by a fixed model; AI writes the profile texts, insights and mentor answers

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.

Shadow Mentor Conversations and Shadow Questionnaire: If you activate the Shadow Profile module, we collect your answers to the shadow questionnaire and the messages you exchange with the Shadow Mentor. This content may include special category personal data that you share voluntarily. We process it only on the basis of your explicit consent (GDPR Art. 9(2)(a)) given at module activation, and only to provide the module. We do not use this content to train AI models. See Section 4.3.

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-Written Profile Texts: Profile texts and insights written by AI from your talent scores

Daily Insights: Personalized recommendations generated for subscribers

Comparison Results: Compatibility analyses when you compare profiles with friends

Shadow Calculations: If you activate the Shadow Profile module — 200 computed shadow-inclination indicators based on your birth data, the AI-generated shadow profile, and your work plan

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, advertising measurement, functionality and referral attribution

4. SENSITIVE PERSONAL DATA

The profile texts that AI writes about you 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.

4.3 Shadow Mentor Conversations and Shadow Questionnaire

The Shadow Profile module involves a direct conversation about hindering sides of personality. Your shadow questionnaire answers and Shadow Mentor conversations may therefore reveal special category personal data as defined in GDPR Art. 9 (for example, data concerning health or beliefs). We process this data only with your explicit consent under Art. 9(2)(a) GDPR (or the equivalent provision of the privacy law applicable to you), which you give when activating the module, and for the sole purpose of providing the module: generating the shadow profile and the Shadow Mentor’s responses. We do not use this content to train AI models, for marketing, or for any other purpose without your separate consent. These conversations and answers are stored so that you can return to your work in the module: they are retained until you delete them or your account, whichever occurs first (conversations can be deleted in the app; questionnaire answers are deleted on request via support@innateq.ai; see Section 11), and are encrypted at rest. You may withdraw your consent at any time via support@innateq.ai; after withdrawal the Shadow Mentor and the shadow questionnaire can no longer be provided, while the shadow profile computed from your birth data remains available in your account. Withdrawal does not affect the lawfulness of processing carried out before it.

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.

Advertising Measurement: To measure and improve the advertising of our Services (see Section 8)

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-written profile texts

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. The exception is advertising measurement with Google, which may also use the information it receives for its own purposes, as described in Section 8.

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

To measure and improve the advertising of our Services, we use Google Analytics 4 on our websites and in our app, and we may use its advertising features:

Google signals: In our app, we may use Google signals. Google then associates use of our app with the Google accounts of users who are signed in to Google and have allowed ad personalization. This gives us aggregated reports about our audience and about use across devices, and it allows us to show our ads to people who have used our app (remarketing) and to personalize them.

Google Ads: We may link Google Analytics to our Google Ads account. Google Analytics then reports to it actions on our Services, such as registrations (conversions), so that we can see which ads lead to them.

Contact details you enter: The Google tag may automatically detect contact details that you enter in forms on our websites and in our app, such as your email address, phone number, name or address, and send them to Google in hashed form together with the events it sends. Our app holds back the events it sends to Google Analytics, such as page views and registrations, while a form field you have filled in (for example, with your email address, your name or your child's name) or your email address is shown on the screen.

Google Analytics uses first-party cookies (such as the Google Analytics cookie) and similar identifiers; its advertising features may also use third-party cookies (such as Google advertising cookies). Google receives information such as cookie and device identifiers, IP address, browser and device type, the pages you visit and the actions you take on our Services. As a result, Google may collect information about your online activities over time and across different websites and apps, including our Services, and may also use it for its own purposes under its own privacy policy (see "How Google uses information from sites or apps that use our services" at https://policies.google.com/technologies/partner-sites). We may also use similar advertising tools from Meta (Facebook, Instagram) in the future.

Accounts of minors and school accounts: We do not use these advertising features while an account of a person under 18, or an account activated with a school activation code, is signed in. In accounts in which a parent or guardian manages a child's profile, these features apply to the parent as an adult user. We do not send the child's age, birth data or results to Google or to any other advertising platform, and our app holds back its events to Google Analytics while the child's name is shown in a form field (see above).

EU version: Where we offer an EU version of our Services, these features are used there only after you consent to them in our cookie banner.

Your choices: On our website innateq.ai, Google Analytics runs only if you accept analytics cookies in our cookie banner; to change your choice, delete our cookies in your browser and the banner will appear again. In our app, Google Analytics runs without a cookie banner; you can ask us by email to turn it off for your account (see Section 18.3). You can also turn off ad personalization in your Google ad settings (https://adssettings.google.com), stop Google Analytics from collecting data in your browser with the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout), and block or delete cookies in your browser settings. California residents: see also Section 18.3.

Do Not Track: Our Services do not respond to "Do Not Track" signals sent by web browsers.

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

We use in-app product analytics to understand how users interact with our Services and to improve them. Our product analytics provider receives information about the screens you open, the features you use and the actions you take in our app, technical information about your device and browser, and general account information (such as your language, region, country of birth, age and purchases). We identify your account to it only by its number (user ID), not by your email address or name.

Session replay: While you are signed in to our app, we may record how you use it (session replay) to find and fix problems. The recording shows the layout of the screens and your clicks and scrolls; all text on the screen and everything you type is masked. We do not record sessions of parent accounts or of accounts of persons under 18.

Where analytics run: Where we offer an EU version of our app, product analytics, session replay and Google Analytics run there only after you consent to them in the app's cookie banner. In our app at app.innateq.ai, they run without a cookie banner.

Opting out: 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. We record your request in your account: from your next sign-in, while you are signed in, our app sends no information to our product analytics provider or to Google Analytics, and we ask our product analytics provider to delete the data it holds about your account.

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

Advertising Cookies: Google Analytics cookies and, if we use the advertising features of Google Analytics, Google advertising cookies, to measure and improve the advertising of our Services (see Section 8)

Marketing (Attribution) Cookies: With your consent, a cookie on our website domain, shared with our app, keeps for up to 30 days (renewed on each visit) a record of your visit: a random visitor identifier, the campaign parameters (UTM) and referral code of the link you came from, the landing page, the page that referred you and the time of the visit. With this consent we also send a record of the visit (visitor identifier, campaign parameters, landing and referring page) to our servers, including visits from a campaign without a referring partner, credit the visit to the partner who referred you and show that partner's discount. Without this consent, our website still stores in your browser's local storage a random visitor identifier and a record of your first and latest visit (landing page, referring page, campaign parameters, referral code, time); these entries have no expiry and stay until you clear your browser's site data. It also adds the visitor identifier, the referral code and the campaign parameters to links to our app; when you register, the visitor identifier and the referral code are saved to your account, so that the partner's discount and referral credit can be applied to your purchase. When you open an activation-code link in our app and no other referral is recorded, the app keeps a similar record — a new random visitor identifier, the activation-code source and campaign, the page address with the code's prefix (not the full code) and the time — in a cookie on our domain for 30 days, sends it to our servers and links it to your account when you register; this happens regardless of your cookie choice.

10.2 Managing Cookies

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

10.3 Records of Your Cookie Choices

When you make a choice in the cookie banner on our websites or, where we offer one, in the EU version of our app, we record it so that we can demonstrate your consent, as data protection laws require (for example, Article 7(1) GDPR). The record contains a random visitor identifier, your choice for each category of cookies and whether you accepted all, rejected all or saved your own selection, the date and time, the address of the website or app and its region, the version of the banner, a salted hash of your IP address (not the address itself) and your browser's user-agent string. We keep these records for as long as we may need to demonstrate your choice: while it is in effect and afterwards for as long as claims about it can be brought.

11. DATA RETENTION

We keep personal data only for as long as we need it for the purposes described in this Policy. Instead of fixed periods, we apply the criteria below, which are tied to events such as the deletion of your account; where the law sets a minimum period, we keep the data for at least that period. At least once a year, we review the personal data we hold against these criteria and delete or anonymize data that is no longer needed.

Account Data: Kept for as long as your account exists.

Birth Data, Talent Calculations and Profile Texts: Kept for as long as your account exists.

AI Mentor Conversations: Kept until you delete them in the app or delete your account.

Payment Records: Kept for at least 7 years, and longer where tax or accounting law requires. After your account is deleted, they are kept without a link to your account (amount, date, product and payment reference).

Automatic-Renewal Records: Records of the subscription terms shown to you, your consent to automatic renewal, the confirmations and notices we sent and your cancellation are kept for at least three years, or for at least one year after your subscription ends if that is later, as automatic-renewal laws require. They are kept after your account is deleted, without your name or email address.

Analytics Data: Kept for as long as we need it to understand and improve our Services. When you opt out of analytics or delete your account, we ask our product analytics provider to delete the data linked to your account. Aggregated and anonymized data may be kept indefinitely.

Rectification Questionnaire Responses: Kept after the result is delivered, so that we can reopen your case if you provide additional information, until you ask us to delete them or delete your account.

Shadow Mentor Conversations and Shadow Questionnaire: Kept until you delete them or your account, so that you can return to your work in the module (conversations can be deleted in the app; questionnaire answers are deleted on request via support@innateq.ai).

Records of Cookie Choices: Kept for as long as we may need to demonstrate your choice: while it is in effect and afterwards for as long as claims about it can be brought (see Section 10.3).

Security and Support Records: Server logs and support correspondence are kept for as long as they are needed for security, fraud prevention and support.

11.1 Deleting Your Account

When you ask us to delete your account, we verify your request and then: cancel any active or scheduled subscription immediately, so that you are not charged again; delete your account and the data linked to it, including your profile and birth data, talent calculations and profile texts, questionnaires, AI Mentor and Shadow Mentor conversations, notes and plans, the requests you sent through the forms on our websites, the files we store for your account and the encrypted backups of your calculation results; remove your email address from our mailing lists; and ask our product analytics provider to delete the data linked to your account. We keep a record of the deletion (your account number, the date and the steps carried out) without your other personal data.

What remains after deletion: purchase records and automatic-renewal records, without a link to your account, for the periods stated above, and the corresponding customer and payment records at our payment processor; logs of emails already sent, which our email delivery providers keep under their own retention rules; and working copies of calculation results and calculation job records on our calculation servers, which are removed automatically in the normal course of operation.

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 or Sharing: We do not sell personal information for money; to opt out of sharing for advertising, see Section 18.3

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 keep your email address and the record of your request until you unsubscribe from our emails or object to their use, or until we no longer need them to deliver the requested resource. If you create a User account, the record is merged into your account (see below).

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

You must be at least 18 years old to create your own account. A child or teenager under 18 can use our Services only through the account of a parent or legal guardian (parent mode), in which the parent or guardian creates and manages the child's profile. When a parent or legal guardian registers in parent mode:

• The parent or guardian acknowledges that they hold parental authority and consent to the processing of the minor's personal data
• The parent or guardian confirms this in a separate checkbox, and we record when the confirmation was given; without it, an account cannot be registered in parent mode or switched to it
• 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 the birth date entered for your own account shows that you are under 18, we do not save it, and the account cannot be used for our Services unless a parent or legal guardian switches it to parent mode. If you believe that a person under 18 has created their own account, please contact us at support@innateq.ai, and we will delete that 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 personal information for money. As described in Section 8, we use Google Analytics 4 and may use its advertising features, so Google receives information about your use of our Services, such as cookie and device identifiers, the pages you visit and actions such as registrations, and may receive contact details you enter in forms in hashed form, to measure and improve our advertising. Under the CCPA/CPRA, this disclosure may be considered "sharing" of personal information for cross-context behavioral advertising and, under some interpretations, a "sale".

You can opt out of this sharing at any time by emailing support@innateq.ai with the subject line "Opt out of sharing". We record your request in your account: from your next sign-in, while you are signed in to your account, our app sends no information to Google Analytics, so its advertising features are not used for you either (this also switches off our in-app product analytics, see Section 9.1). On our website innateq.ai, Google Analytics runs only if you accept analytics cookies in our cookie banner (see Section 8). The Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout) stops Google Analytics from receiving information from the browser in which you install it, on our Services and on other websites, whether or not you are signed in. Turning off ad personalization in your Google ad settings (https://adssettings.google.com) stops Google from using the information to show you personalized ads, and blocking or deleting cookies in your browser settings limits the identifiers that link your visits; neither of them stops the information from being sent to Google. We do not use these advertising features while an account of a person under 18, or an account activated with a school activation code, is signed in (see Section 8).

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 the profile texts written by AI 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; shadow questionnaire answers and Shadow Mentor conversations if you activate the Shadow Profile module)

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.

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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.

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