(pursuant to Art. 13 of the GDPR / UK GDPR)[Last updated: 6.25.2025]

According to the applicable data protection legislation, with particular reference to Regulation (EU) No. 2016/679 (General Data Protection Regulation, “GDPR”) and the United Kingdom (“UK”) GDPR (as defined in the UK Data Protection Act 2018) (together the “Privacy Legislation”), Mana.aI Corp., a Delaware-registered corporation, in its capacity as data controller (“Company”, “Data Controller”, “Mana.ai” or “we/our”), intends to inform you about the processing of your personal data in the context of your use of the Mana.ai mobile applications (the “APP”) and the related services (“Services”).This privacy policy is an integral part of our End-User License Agreement (“EULA”). By using the APP, you confirm your full acceptance of the EULA and acknowledge the contents of this policy. The policy applies to all individuals who install, use the APP and access its Services (“user” or “you”).

DATA THAT WILL BE PROCESSED

The use of our APP and website and Services involves the collection and processing of personal data. The categories of personal data collected are outlined below. Some data is required in order for you to create an account on and access the APP/wesbite  (your e-mail and information from linked accounts such as Google, Apple, Facebook), others are requested only if you decide to activate certain advanced features. As for the sources of your personal data, some information is provided directly by you, other personal data is collected automatically when you interact with us through the APP.

The APP only collects personal data strictly necessary for the provision of the Services offered and the purposes described in this policy. In particular:

Account Data:

To access the APP, you need to create a personal account through Google, Facebook, or Apple authentication services. We will only process the email address and essential information associated with the selected account, which are necessary to create your profile. In any case, the information associated with your account can be updated at any time in the “Profile” section of the APP.

Use of the APP:

While using the APP, you can interact with pre-existing chatbots (which may have been created by us or other users of the APP) or create new ones (which you can keep private or make available to other users). During chats, you might voluntarily share personal data, including sensitive information. We encourage you not to provide unnecessary information, especially regarding third parties. Conversation data will be stored in our systems as outlined in this policy. Additionally, your messages and other data may be used to optimize your chatbot interaction experience and improve the chatbot for all users.

Notifications:

The APP sends push notifications only with the user’s consent. Additionally, the app sends in-app messages. These may include service updates, system announcements, or changes to the EULA and this Privacy Policy.

Support and assistance:

Users can contact us via email at [email protected]. We will only process data voluntarily provided by the user to respond to support requests, encouraging users to limit the information to what is strictly necessary.

Subscription plans:

The APP offers paid subscription plans. For use of the paid subscription plans, we process the data necessary to manage the subscription.

Usage Data:

While using the APP, we automatically collect technical information related to your device and connection, such as the IP address, access time, browser type, operating system, internet service provider, and other technical parameters. We also use essential cookies and similar technologies to enable login and ensure the proper functioning of the Services. Additionally, to resolve technical malfunctions, we log activities associated with your user ID (e.g., login times, chatbot openings, message submissions).

PURPOSES AND LAWFUL BASIS OF THE PROCESSING

The data processing activities described above are carried out exclusively for the purpose of:Registration, creation, and management of your personal account:To access the APP, regardless of the subscription plan you choose, it is necessary to create a personal account. For this purpose, we require only your e-mail address and the data from linked accounts (Google, Apple, or Facebook). Without this information, we will not be able to process your registration or allow you to use the APP. The lawful basis for processing your personal data for this purpose is the performance of (pre)contractual measures.Lawful basis: Art. 6(1)(b) of the GDPR / UK GDPR.

Use of the APP:

We process the personal data provided during registration or subsequently (e.g., identifying data, in-app messages, logs) to enable you to interact with chatbots by sending and receiving text messages, create new chatbots, manage your in-app purchases, and ensure the proper functioning of the APP, including all technical and organizational activities necessary for the provision of the Services. Additionally, we use your data to process and manage support requests in relation to any issues encountered while accessing or using the APP. These processing activities are carried out to fulfill our contractual obligations towards you.Lawful basis: Art. 6(1)(b) of the GDPR / UK GDPR.

Model improvement:

We use personal data derived from your in-app conversations with chatbots to enhance and fine tune the artificial intelligence models on which these chatbots operate. Before we use any conversation data in this way, we remove personal identifiers. This means that only the information you provided in the conversation with a chatbot itself is used for this purpose. This processing aims to optimize the APP’s functionality, ensuring increasingly accurate, personalized, and consistent performance aligned with your expectations. By processing your data, we can provide more engaging conversations, improve interaction quality, and better align chatbot outputs with your needs. This processing is based on our legitimate interest in keeping the APP up-to-date, functional, and competitive in a constantly evolving market.Lawful basis: Art. 6(1)(f) of the GDPR / UK GDPR.

Marketing and advertisement:

We use personal data to send you advertisements if you havea free subscription, based on your consent. If you downloaded the APP throughan advertisement, we may also share certain information, such as your usagepatterns, with our advertising partners to evaluate the performance of theircampaigns and ensure accurate attribution. This processing is based on ourlegitimate interest in ensuring the effectiveness and competitiveness of ourbusiness.
Lawful basis: Art. 6(1)(a) and Art. 6(1)(f) of the GDPR / UK GDPR.

In addition, we may also process your data collected through the APP, ifneeded, in order to:

(i) comply with legal requirements, or orders, decisions and measures issued bycompetent authorities, based on Art. 6(1)(c) of the GDPR / UK GDPR, and
(ii) to establish, exercise or defend our rights before competent courts,according to Art. 6(1)(f) of the GDPR / UK GDPR.
WHO CAN ACCESS YOUR DATA
Your personal data will be accessible only by specifically authorized staffacting under the authority of the Data Controller, duly instructed to processthe data, with particular regard to the protection of your rights and oursecurity standards.

Data will also be shared with the Company’s suppliers involved in various waysin the provision and operation of the APP, as data processors, in accordancewith the instructions and security safeguards dictated by Mana.ai.

Finally, your data may also be disclosed to third parties to fulfill legalobligations and/or requests made by competent authorities.

DURATION OF DATA PROCESSING

The data collected through your use of the APP will not be processed for a longer period than is necessary to achieve the purposes described above, not exceeding, in any case, the duration of the account and five (5) years following its deletion.

In some instances, a longer retention timeframe may be necessary to enable Mana.ai to defend and enforce its rights in the context of legal claims, disputes or proceedings brought against the Company, or in order to comply with applicable laws or orders by competent authorities.

INTERNATIONAL DATA TRANSFERS

The data collected by the APP will be processed and stored in the United States, where Mana.ai has its registered office.

In particular for the provision of the Services, personal data can also be transferred to US data processors. These transfers will be based, if applicable and amongst other potentially applicable data transfer mechanisms (e.g. EU/UK United States Data Privacy Framework), on the Standard Contractual Clauses adopted by the European Commission and the UK International Data Transfer Addendum (or International Data Transfer Agreement) issued by the Information Commissioner’s Office under Art. 46 of the GDPR / UK GDPR. These provisions ensure that your data is subject to protection standards and security guarantees equivalent to those provided within the European Economic Area (EEA) and UK.

DATA SUBJECTS’ RIGHTS

If you are a citizen of the EU or the UK, the rightsoutlined below are available to you under applicable privacy legislation:

Access: You have the right to know whether your data is being processed and, ifso, to receive a copy of that personal data and information about the purposesof the processing, the categories of data involved, the recipients to whom thedata may be disclosed, the applicable retention period, and the existence ofany automated decision-making processes.

Rectification: You have the right to request, without undue delay, thecorrection and updating of any inaccurate personal data concerning you.

Erasure: You may request the deletion of your data, subject to specificexceptions, if:

The data is no longer necessary for the purposes for which it was collected orotherwise processed;


You have withdrawn consent for a specific processing activity, and no otherlawful basis exists;
You have objected to a specific processing activity for reasons related to yourparticular situation (see the “Objection” right below), and no overridinglegitimate grounds exist to continue the processing;


The data has been unlawfully processed; or


The data must be deleted to comply with a legal obligation to which we aresubject.
Restriction of processing: You have the right to request the suspension of dataprocessing in the following cases:

You contest the accuracy of your data, for the time necessary for us to verifyits accuracy;
The processing is unlawful, but you object to the deletion of your data andinstead request a restriction of its use;
Your data is no longer necessary for the purposes identified above, but yourequire it to establish, exercise, or defend a legal claim; or
You have objected to one or more processing activities, and we are stillverifying whether legitimate grounds exist for continuing the processing.
Data portability: You may request to receive the personal data you haveprovided to us in a structured, commonly used, and machine-readable formatand/or request its transfer directly to another controller.

Objection: You may object, on grounds relating to your particular situation, tothe processing of your data based on our legitimate interests. Processing willcease unless:

There are compelling legitimate grounds overriding your interests, rights, andfreedoms, or
The data is necessary for the establishment, exercise, or defense of legalclaims.
Withdrawal of consent: You may withdraw your previously given consent at anytime, without affecting the lawfulness of processing carried out prior to suchwithdrawal.

Complaint: You have the right to file a complaint with your local dataprotection authority if you believe that we have not complied with applicablePrivacy Legislation. This does not prejudice your right to seek administrativeor judicial remedies.

To exercise your rights and/or request any information or clarificationregarding the processing of your data by Mana.ai, you may contact the DataController or the appointed Data Protection Officer (DPO) at any time using thefollowing contact details:

[email protected]