This Privacy Policy applies to personal data collected through the Service and does not apply to:

•Employee Data: The processing of personal data related to our employees, contractors, and job applicants, which is governed by separate internal policies and employment agreements.

•Purely Personal or Household Activities: Activities that fall outside the scope of the GDPR and other data protection laws, such as personal or household activities conducted by individuals.

Pattern Automation acts as the data controller for the personal information we collect through the Service. This means we determine the purposes and means of processing your personal data and are responsible for ensuring compliance with applicable data protection laws, including Regulation (EU) 2016/679 (General Data Protection Regulation or GDPR) and Directive 2002/58/EC (ePrivacy Directive).

Pattern Automation (“Pattern Automation”, "we", "us" or "our") provides advanced artificial intelligence (“AI”) platforms, including Neuro AI and Toodly AI. This Privacy Policy describes how we process personal information that we collect through the Neuro AI platform, Toodly AI platform, related mobile apps and browser extensions, and any of our other digital or online properties or services that link to this Privacy Policy (collectively, the “Service”).

For content-safety, see Neuro User Safety & Content Policy. For Prohibited AI Practices, see the Usage Policy.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.

Index

• Personal information we collect

• Tracking and other technologies

• How we use your personal information

• How we share your personal information

• Retention

• Your choices

• Other sites and services

• Security

• International data transfers

• Children

• Changes to this Privacy Policy

• How to contact us

• Notice to European users

  
  

Personal information we collect

Information you provide to us. Depending upon the context in which you interact with us, personal information you may provide to us through the Service includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.

• Profile data, such as the username and password that you may set to establish an online account with the Service, any teams you are a part of, and any other information that you add to your account profile.

• Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.

• Transactional data, such as information relating to or needed to complete your subscriptions on or through the Service, including subscription type and transaction history.

• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

• Inputs, prompts and user-generated content, such as messages, photos, images, audio or voice clips, music, videos, comments, questions, files, works of authorship, third party account credentials and other content or information that you upload/use as an input or prompt to, generate, transmit, or otherwise make available on the Service, as well as associated metadata (e.g., how, when, where content was collected or edited; keywords; location info).

• Derived data. If you use certain features of Neuro AI, such as to convert images to videos, videos to new or different videos, or people to avatars, or to upload audio or voice clips, we may derive certain information from images of individual people or from audio or voice clips in order to provide those features. While we do not use such data for purposes of identifying any unique individual, it is possible that some may consider this data biometric data within the meaning of certain U.S. state laws. We will only use and share this derived data for limited purposes, as described in the “How we use your personal information” and “How we share your personal information” sections, below.

• Audio and Screen Recording

If you use features of the Service that involve audio recording or screen sharing (such as during live sessions, meetings, or real-time assistance), we may process audio clips and screen visuals to provide those features. Before enabling audio or screen recording, you must:

Inform all participants: Notify all participants in the session that audio or screen recording will take place.

Obtain consent: Obtain consent from all participants if required by applicable laws in your jurisdiction.

Disable recording if consent is not given: If any participant does not consent to audio or screen recording, you must disable the recording feature in the Service.

By using audio or screen recording features, you acknowledge your responsibility to comply with applicable laws regarding recording and consent. We are not responsible for your failure to obtain necessary consents or to inform participants of recording activities.

• Payment data needed to complete transactions is collected and processed directly by our payment processors, such as Stripe or RevenueCat, as further described below in the “How we share Your personal information” section.

• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

  
  

We ask that you not provide us with any sensitive personal information (e.g., social security numbers, financial account numbers, government ID numbers, information related to racial or ethnic origin, political opinions, religious or other beliefs, health, biological, biometric or genetic information, criminal background information, or similar data) on or through the Service or otherwise.

Third-party sources. We may combine personal information we receive from you with personal information that we obtain from other sources, such as:

• Public sources, such as public records, social media platforms, and other publicly available sources.

• Third-Party AI Providers. Parts of the Service, including Neuro and Toodly, are integrated with third-party AI platforms (“Third-Party AI Providers or Subprocessors”) that help generate outputs (i.e., responses) to your inputs and prompts. These Third-Party AI Providers may infer information about you and share information with us as part of their processing of your inputs and prompts to the Neuro and Toodly platforms.

·       We work with trusted third-party subprocessors who assist us in providing the Service. These subprocessors may have access to your personal data only to perform specific tasks on our behalf and are contractually obligated to protect your data in accordance with this Privacy Policy and applicable data protection laws.

·       A complete and up-to-date list of our subprocessors, including their names, locations, and the services they provide, is available at [patternautomation.ai/subprocessors]. We will notify you of any changes to our subprocessor list in accordance with applicable legal requirements.

• Service providers that provide services on our behalf or help us operate the Service or our business.

• Third-party login/linked services, such as Google or Apple that you use to log into, or otherwise link to, your Service account, including when you utilize or direct the Service to utilize your third-party accounts. This data may include your username and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. The use of raw or derived user data received from Workspace APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

• At your direction. Where you consent or direct us to interact with a third party, we may receive information about you from that third party.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi‑Fi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Tracking and other technologies

Cookies and similar technologies. Some of the automatic collection described above is facilitated by cookies and other technologies. We also use Chat and other AI technologies, such as those provided by our Third‑Party AI Providers that employ cookies and software code to operate the chat, input and prompt features that you can use to communicate with us and input your prompts and other data through the Service. These Third‑Party AI Providers may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats or within inputs to facilitate the provision of the app or services.

Cloud Browser. With your prior consent, Cloud Browser may encrypt and store cookies/local storage to persist login state across sessions/devices for certain period; you can view or clear this in settings at any time.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section below and our Cookie Policy.

How we use your personal information

We do not process, disclose, or otherwise utilize your personal information for the development, training, or refinement of any artificial‑intelligence or machine‑learning models. We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide the Service;

• transmit your inputs to our Third‑Party AI Providers for processing and to receive outputs, as necessary to fulfill your requests;

• enable security features of the Service;

• establish and maintain your user profile on the Service;

• communicate with you about the Service, including by sending Service‑related announcements, updates, security alerts, and support and administrative messages;

• communicate with you about events or contests in which you participate; and

• provide support for the Service, and respond to your requests, questions and feedback.

We process your personal data only when we have a lawful basis to do so under applicable data protection laws, including the General Data Protection Regulation (GDPR). The legal bases for our processing activities include:

Performance of a contract: Processing is necessary to fulfill our contractual obligations to you, such as providing the Service, processing your subscriptions, and responding to your requests.

Legitimate interests: We may process your data based on our legitimate business interests, such as improving the Service, conducting analytics, preventing fraud, and ensuring security. We balance these interests against your rights and freedoms.

Legal obligations: We process your data to comply with applicable laws, regulations, and legal processes, including tax, accounting, and reporting requirements.

iConsent: Where required by law, we obtain your explicit consent before processing certain categories of personal data, such as for marketing communications, targeted advertising, or processing derived biometric data. You have the right to withdraw your consent at any time.

Service personalization, which may include using your personal information to:

• understand your needs and interests;

• personalize your experience with the Service and our Service‑related communications; and

• remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For more information on analytics, see our Cookie Policy.

Marketing and advertising. We, our service providers and our third‑party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt‑out of our marketing communications as described in the Opt‑out of communications section below.

• Where permitted by law and with your permission where required, we process certain online identifiers to (i) show you more relevant ads, (ii) measure ad performance, and (iii) build or refine audiences. We may share this information—sometimes in hashed or de-identified form—with our advertising partners for conversion measurement, audience creation, and optimization. We only engage in personalized ads and remarketing after we have received your valid consent.

·       By providing your contact information and consenting through our online forms or during account registration, you agree to receive promotional and marketing communications from us via electronic networks, including email, SMS, and phone. You may withdraw your consent to receive marketing communications at any time by:

Clicking the "unsubscribe" link in our marketing emails;

Adjusting your communication preferences in your account settings; or

Contacting us directly at [info@patternautomation.com].

Please note that even if you opt out of marketing communications, we may still send you Service-related and transactional messages that are necessary for the operation of your account.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

• audit our internal processes for compliance with legal and contractual requirements or our internal policies;

• enforce the terms and conditions that govern the Service; and

• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see **How we share your personal information**, below.

To create aggregated, de‑identified and/or anonymized data. We may create aggregated, de‑identified and/or anonymized data from your personal information and that of other individuals whose personal information we collect. We make personal information into de‑identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de‑identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, and for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

• Affiliates. Our corporate parent, subsidiaries, and affiliates.

• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

• Third‑Party AI Providers. We use Third‑Party AI Providers to power certain aspects of the Manus and Monica platforms, such as operating the chat and/or processing user inputs/prompt features, data analytics and recommendations.

• Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe and RevenueCat. Our payment processors may use payment data in accordance with their privacy policy located at, https://stripe.com/privacy and https://www.revenuecat.com/privacy/, respectively.

• Advertising Partners. We work with advertising and analytics providers such as Google (Google Ads/Analytics), LinkedIn (Insight Tag/Conversions API), and X (formerly Twitter). These partners may set or read cookies and receive limited information from us to provide ad measurement, audience services, and optimization, subject to your choices. See our Cookie Policy for the specific cookies used, providers, purposes, and retention periods.

• Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

• Linked third‑party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third‑party service, we may share your personal information with that third‑party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third‑party service.

• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

• Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments and financing of Pattern Automation, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Pattern Automation as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

• Other users and the public. At your election, user‑generated content data may be visible to other users of the Neuro and Toodly platforms and the public. For example, other users of the Neuro and Toodly platforms or the public may have access to your information if you chose to make information available to them, such as when you share content. In addition, we offer users the ability to join a team, and certain of their information may be visible to other team members. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Your choices

Your Legal Rights

Under applicable data protection laws, including the GDPR, you have the following rights regarding your personal data:

Right to Access: You have the right to request access to the personal data we hold about you and to receive information about how we process it.

Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.

Right to Erasure ("Right to be Forgotten"): You have the right to request that we delete your personal data in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected or when you withdraw your consent.

Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to our processing.

Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller without hindrance from us.

Right to Object: You have the right to object to our processing of your personal data based on legitimate interests or for direct marketing purposes. If you object to direct marketing, we will stop processing your data for those purposes.

Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority, particularly in the EU member state where you reside, work, or where an alleged infringement of data protection law occurred.

To exercise any of these rights, please contact us at [info@patternautomation.com]. We will respond to your request in accordance with applicable legal requirements and timeframes.

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.

• Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

• Opt‑out of communications. You may opt‑out of marketing‑related emails by following the opt‑out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt‑out of marketing‑related emails, you may continue to receive service‑related and other non‑marketing emails.

• Cookies. For information about cookies and other technologies employed by the Service and how to control them, see our Cookie Policy.

We use the following types of cookies and similar tracking technologies on the Service:

Essential Cookies: These cookies are necessary for the Service to function properly and enable core features such as login, security, session management, and user preferences. You cannot opt out of essential cookies.

Analytics Cookies: These cookies help us understand how users interact with the Service by collecting information about pages visited, time spent on pages, and navigation paths. This data is used to analyze user activity and improve the Service.

Functionality Cookies: These cookies remember your preferences and settings to personalize your experience with the Service, such as language preferences, display settings, and customized content.

Targeting/Advertising Cookies: These cookies track your browsing behavior and engagement with features to analyze what content and features you interact with. They may be used to deliver more relevant advertisements and measure ad performance.

You can manage your cookie preferences through your browser settings or by visiting our Cookie Policy at Cookie Policy. Please note that disabling certain cookies may affect the functionality of the Service.

• Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

• Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

• Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

• Linked third‑party platforms. If you choose to connect to the Service through your Google or Apple account or other third‑party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third‑party platform, that choice will not apply to information that we have already received from that third party.

• Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

  
  

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. Security procedures are in place to protect the confidentiality of your data. Despite commercially reasonable safeguards, online and email transmissions are not fully secure. Please submit information at your own discretion; we accept no liability for any unauthorized circumvention of the Services’ or third‑party privacy or security measures.

We implement robust technical and organizational security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include:

•Data Encryption: We use industry-standard encryption protocols to protect data in transit.

•Secure Storage: Personal data is stored on secure servers with restricted access and regular security monitoring.

•Access Controls: We limit access to personal data to authorized personnel only, based on the principle of least privilege and need-to-know basis.

•Regular Security Assessments: We conduct regular security audits, vulnerability assessments, and penetration testing to identify and address potential security risks.

•Incident Response Protocols: We have established incident response procedures to detect, respond to, and mitigate security breaches in a timely manner.

While we take reasonable steps to protect your data, no system is completely secure. We cannot guarantee absolute security, and you acknowledge that you provide your personal data at your own risk.

International data transfers

We are headquartered in Estonia and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should read the important information provided below about transfer of personal information outside of Europe.

When we transfer your personal data outside the European Economic Area (EEA) or other jurisdictions with comprehensive data protection laws, we ensure that appropriate safeguards are in place to protect your data. These safeguards include:

Adequacy Decisions: We may transfer your data to countries that have been recognized by the European Commission as providing an adequate level of data protection.

Standard Contractual Clauses (SCCs): We use Standard Contractual Clauses approved by the European Commission to ensure that your data is protected when transferred to countries that do not have adequacy decisions.

Other Appropriate Safeguards: Where applicable, we may rely on other legally recognized transfer mechanisms, such as binding corporate rules or certifications under approved frameworks.

You may request a copy of the safeguards we have in place for international data transfers by contacting us at [info@patternautomation.com].

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Depending on the change that we make to this policy, we might notify you of the change or ask for your consent to it. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).

How to contact us and our Data Protection Officer

We have appointed a Data Protection Officer responsible for overseeing privacy compliance.
Contact: info@patternautomation.com.

Notice to European users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.

Controller. Pattern Automation is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so‑called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the ‘How to contact us’ section above for our contact details.

Our GDPR Representatives. We do not have appointed the following representatives in Europe as required by the GDPR for now – you can also contact them directly in the future:

• Our Representative in the EU. Our EU representative appointed under the EU GDPR is EDPO. You can contact them:

• via: https://edpo.com/gdpr-data-request/

• by post: Avenue Huart Hamoir 71, 1030 Brussels, Belgium

• Our Representative in the UK. Our UK representative appointed under the UK GDPR is EDPO. You can contact them:

• via: https://edpo.com/gdpr-data-request/

• by post: 8 Northumberland Avenue, London, WC2N 5BY, UK

Our Data Protection Officer. We have appointed a Data Protection Officer (DPO). The DPO independently performs their duties—informing and advising us and monitoring our compliance with the EU GDPR and the UK GDPR (as applicable). The DPO’s contact details are provided in the “How to contact us and our Data Protection Officer” section.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

• Contractual Necessity. Where we need to perform a contract, we are about to enter into or have entered into with you.

• Legitimate Interests. Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

• Compliance with Law. Where we need to comply with a legal or regulatory obligation.

• Consent. Where we have your specific consent to carry out the processing for the Purpose in question.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’

Purpose

Categories of personal information involved

Legal basis

Service delivery and operations

· Contact data· Profile data· Communications data· Transactional data· Inputs, prompts and user-generated content· Derived data· Payment data· Data from Third Party Services· Device data

· Contractual Necessity

Security

· Contact data· Device data· Online activity data· Location data

· Compliance with Law· Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service and associated IT services, systems, and networks.

Service improvement and analytics

· Contact data· Profile data· Device data· Online activity data· Location data· Inputs, prompts and user-generated content· Derived data· Data from Third Party Services

· Legitimate Interests. We have a legitimate interest in providing you with a good service, which is personalised to you and that remembers your selections and preferences.· Consent, in respect of any optional cookies used for this purpose.

Direct marketing

· Contact data· Profile data · Communications data · Transactional data· Marketing data

· Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose.· Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.

Compliance and protection

· Any and all data types relevant in the circumstances

· Compliance with Law.· Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.

Research and developmentTo create aggregated, de-identified and/or anonymized data

· Any and all data types relevant in the circumstances

· Legitimate interest. We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Services operate as intended.

Further uses

· Any and all data types relevant in the circumstances

· The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected.· Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Other info

We may use limited profiling to personalise advertisements and measure performance.

Your rights

European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Access – Provide you with information about our processing of your personal information and give you access to your personal information.

• Correct – Update or correct inaccuracies in your personal information.

• Delete – Delete your personal information where there is no good reason for us continuing to process it.

• Transfer – Transfer a machine‑readable copy of your personal information to you or a third party of your choice.

• Restrict – Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.

• Object – Object to our processing of your personal information where we are relying on Legitimate Interests; also object to direct marketing at any time.

• Withdraw Consent – When we use your personal information based on your consent, you may withdraw that consent at any time.

Exercising these rights. You may submit requests by email to info@patternautomation.com or our postal address above. We may request specific information from you to help confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on several factors (e.g., why and how we are processing your personal information). If we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here, but for now not available : https://edpb.europa.eu/about-edpb/board/members_en

For users in the UK – the contact information for the UK data protection regulator is below:

The Information Commissioner’s Office

Water Lane, Wycliffe House

Wilmslow - Cheshire SK9 5AF

Tel. +44 303 123 1113

Website: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

We may share your personal information with third parties who are based outside Europe.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by implementing one of the following mechanisms:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time).

Transfers to territories without an adequacy decision.

We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g. the United States, Estonia).

However, in these cases:

we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at info@patternautomation.com.

Notice to South Korea users

This section applies to individuals in the Republic of Korea and, where applicable, to our provision of services that is subject to Korea’s Personal Information Protection Act (PIPA).

We have appointed a Personal Information Protection Officer under the PIPA—see How to contact us for contact details. Other PIPA disclosures are set out in this Privacy Policy.

We transfer personal information to service providers outside of South Korea for hosting, storage, customer support and security. Because these transfers are necessary to provide the Service, we rely on the bases permitted under the PIPA for cross-border outsourcing/storage and we supervise such providers.

Notice to Japan users

This section applies to individuals in Japan under the Act on the Protection of Personal Information (APPI), including APPI’s extraterritorial provisions where applicable. Pattern Automation is the “personal information handling business operator” for the processing covered by this Privacy Policy.

Notice to Singapore users

This section applies to individuals in Singapore and is subject to the Personal Data Protection Act 2012 (PDPA) and its regulations and guidelines.

Pattern Automation is a company incorporated in Estonia, act as data controller and is responsible for the collection, use, and disclosure of your personal data as described in this Privacy Policy.

If a notifiable data breach occurs, we will notify the Personal Data Protection Commission (PDPC) and affected individuals where required, within the timelines prescribed by law.

When transferring personal data outside Singapore, we ensure that the recipient provides a standard of protection that is comparable to the PDPA.

Notice to Users in Other Jurisdictions

For Users in the Russian Federation:

If you are located in the Russian Federation and use the Toodly platform, but with Neuro AI it does not work, your personal data will be processed in accordance with applicable Russian data protection laws. You have rights under Russian law to access, correct, delete, and object to the processing of your personal data. To exercise these rights, please contact us at [info@patternautomation.com].

For Users Outside the European Economic Area:

If you are located outside the EEA, your personal data may be processed in countries with different data protection standards. By using the Service, you acknowledge and consent to the transfer and processing of your data in accordance with this Privacy Policy and applicable laws. We take appropriate measures to ensure that your data is protected in accordance with GDPR-level protections where applicable.

Policy Approval

This Privacy Policy has been approved by order of the Co-Founder and CEO of Pattern Automation, Daniil Biryukov, Order No. 723-8, dated 18.11.2025. This Policy comes into force from the date of its approval.

Changes and amendments to this Privacy Policy may be made and will be approved by order of the Co-Founder and CEO. The current version of this Privacy Policy is available at [patternautomation.ai] and [patternautomation.com].

All content and information on the Service belong to Pattern Automation.