Privacy policy

Sphinx Labs Privacy Policy

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Effective date: October 22, 2025

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At Sphinx Labs, Inc. (“Sphinx”), we take your privacy seriously. We consider it very important to limit who can see your Personal Data and to be transparent about how we use it. We don’t sell your Personal Data and, as further described herein.

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Please read the following to learn how we treat your Personal Data. By using or accessing any website operated by Sphinx or Sphinx’s online Software-as-a-Service offering (the “Services”) in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

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Remember that your use of Sphinx’s Services is at all times subject to our Software-as-a-Service Agreement or other similar agreement governing our provision of Services to you, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

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1. What this Privacy Policy Covers

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This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

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2. Personal Data

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Categories of Personal Data We Collect

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Profile or Contact Data

• Real name
• Email address
• Account login information
• Shared with: Service Providers, Analytics Partners, Enterprise Customer Administrator, Other Parties at Your Direction

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Device/IP Data

• IP address
• Device ID
• Domain server
• MAC address
• Type of device/operating system/browser used to access the Services
• IP-based location
• Shared with: Service Providers, Advertising Partners, Analytics Partners, Other Parties at Your Direction

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Web Analytics

• Web page interactions
• Referring webpage/source through which you accessed the Services
• Statistics associated with interactions between device or browser and the Services
• Shared with: Service Providers, Advertising Partners, Analytics Partners

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Other Identifying Information You Voluntarily Provide

• Identifying information in emails, letters, texts, or other communications you send us
• Shared with: Service Providers, Analytics Partners, Other Parties at Your Direction

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Categories of Sources of Personal Data

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We collect Personal Data about you from the following data sources:

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You

• When you provide such information directly to us.
• When you create an account or use our interactive tools and Services.
• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.
• When you use the Services and such information is collected automatically.
• Through Cookies (defined in our Cookie Policy).
• If you use a location-enabled browser, we may receive information about your location.
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

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Third Parties

• Vendors: We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support. We may use vendors to obtain information to generate leads and create user profiles.
• Advertising Partners: We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

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Our Commercial or Business Purposes for Collecting or Disclosing Personal Data

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We do not sell your Personal Data or share your Personal Data with third parties for them to market or advertise their products to you. We process Personal Data to operate, improve, understand and personalize our Services.

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We use Personal Data for the following purposes:

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Providing, Customizing and Improving the Services

• To meet or fulfill the reason you provided the information to us.
• To provide support and assistance for the Services.
• To create and manage your account or other user profiles.
• To personalize website content and communications based on your preferences.
• To process orders or other transactions.
• To improve and develop the Services, including testing, research, analysis and product development.
• To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.
• For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”).

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Marketing the Services

• To market and sell the Services.
• Showing you advertisements, including interest-based, online behavioral or targeted advertising.

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Corresponding with You

• To communicate with you about the Services, including Service announcements, updates or offers.
• To respond to user inquiries and fulfill user requests.

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Meeting Legal Requirements and Enforcing Legal Terms

• To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Protecting the rights, property or safety of you, Sphinx or another party.
• Responding to claims that any posting or other content violates third-party rights.

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We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

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As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers about the Services, or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at privacy@sphinxhq.com.

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3. How We Disclose Your Personal Data

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We do not sell your Personal Data or share your Personal Data with third parties for them to market or advertise their products to you.

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We disclose your Personal Data to the following categories of service providers and other parties:

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• Service Providers. These parties help us provide the Services or perform business functions on our behalf.They include:
  • Security and fraud prevention consultants.
  • Hosting and other technology and communications providers.
  • Staff augmentation and contract personnel.
  • Marketing-related services providers.
• Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you.They include:
  • Ad networks or related third parties who assist us to market and sell our Services.
  • Companies that we partner with to offer joint promotional offers or opportunities.
• Analytics Partners. These parties provide analytics on web traffic or usage of the Services.They include:
  • Companies that track how users found or were referred to the Services.
  • Companies that track how users interact with the Services.
• Enterprise Customer Administrator. This includes the administrator(s) of the entity or enterprise that you utilize our Services through, if any, such as your employer.
• Other Parties at Your Direction.
  • Third parties who you access through the Services.
  • Other parties authorized by you.

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Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under the “Meeting Legal Requirements and Enforcing Legal Terms” section above.

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Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

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Data That is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, provided that we will not share such data in a manner that could identify you.

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4. Data Security

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We seek to protect Personal Data you directly provide to us from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data.

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5. Data Retention

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We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period, we consider who we collected the data from, our need for it, and the sensitivity of the data. In some cases, we may retain Personal Data longer if needed to comply with legal obligations or resolve disputes. We may also retain anonymized data for analysis.

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Examples:

• Profile information and credentials — retained while you have an account.
• Payment data — retained as long as needed to process transactions.
• Device/IP data — retained as long as needed to ensure system integrity.

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6. Personal Data of Children

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As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 16. If you are under 16, please do not use the Services or send us any Personal Data. If we learn we have collected such data, we will delete it promptly. If you believe a child under 16 has provided us Personal Data, please contact privacy@sphinxhq.com.

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7. Managing Your Preferences and Privacy Rights

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You may manage your preferences and exercise certain rights with respect to your Personal Data as provided by applicable privacy laws and as described below.

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General:

You may have the right to object to or opt out of certain uses of your Personal Data. You can withdraw consent at any time by contacting us. Even if you opt out, we may still collect anonymized or non-identifiable data as described above.

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Responding to Requests:

We may verify your identity when responding to privacy requests. Rights may be restricted by law in some cases.

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Email Communications:

If you receive marketing emails from us, you can unsubscribe via the link at the bottom. Transactional and legal communications will still be sent.

If you are a resident of Virginia, your rights may not apply with respect to Personal Data collected in a commercial or employment relationship.

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Opt-Out from Targeted Advertising or Cross-Contextual Behavioral Advertising

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As described in our Cookie Policy, some third-party cookies on our site are used for advertising purposes. These may constitute “selling” or “sharing” under state laws. We do not otherwise sell or share Personal Data. You can opt-out by emailing privacy@sphinxhq.com.

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f you are a resident of Nevada, you may opt out of data sales as defined by Nevada Revised Statutes Chapter 603A by emailing privacy@sphinxhq.com with the subject “Nevada Do Not Sell Request.”

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Common Rights for EEA, UK, California, and Virginia Residents

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You may have rights to:

• Access your Personal Data.
• Rectify or correct inaccuracies.
• Erase Personal Data (with some exceptions).
• Data portability — request a copy in machine-readable format.

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EEA/UK-Specific Rights:

• Object to processing or request restriction.
• Withdraw consent.
• Complain to your local supervisory authority:
• List of authorities

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California-Specific Rights:

• Non-discrimination: exercising rights won’t affect your access to services.
• Direct marketing disclosures: we do not share data for third-party marketing purposes.

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Exercising Rights:

You or your Authorized Agent may submit a request to privacy@sphinxhq.com or call (857)-313-1599.

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We may verify your identity and respond within legally required timeframes.

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Virginia Appeals:

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If we deny your request, you may appeal by emailing privacy@sphinxhq.com with “VCDPA Appeal” in the subject line.

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8. Processing Personal Data Pursuant to the GDPR

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We act as a data controller for Personal Data covered under the GDPR, unless acting as a processor for our customers.

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We process data based on:

• Contractual necessity (e.g., providing Services)
• Legitimate interests (e.g., improving and marketing Services)
• Consent
• Legal obligations or vital interests

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Personal Data may be transferred to the United States and processed there under standard contractual clauses.

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9. Changes to this Privacy Policy

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We may update this Policy periodically and will notify you of material changes via the Sphinx website (www.sphinxhq.com), email, or other reasonable means. Continued use after updates means you accept the new Policy. Use of information is subject to the version in effect at the time of collection.

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10. Contact Information

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If you have questions or requests, contact us at:

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privacy@sphinxhq.com

(857)-313-1599

2261 Market Street, STE 22678, San Francisco, CA 94114