Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how Sei Software Technologies Inc., a Delaware corporation ("Sei," "we," "us," or "our"), collects, uses, discloses, and protects personal information in connection with our AI-powered, SaaS-based services ("Services"). This Policy applies to all users of our Services, including authorized users, customers, and visitors to our website.

Sei is committed to protecting your privacy and handling your personal information responsibly and in compliance with applicable U.S. federal and state privacy laws and other applicable privacy laws and regulations.

By using our Services, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use our Services.

2. Contact Information

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

Sei Software Technologies Inc.
Attention: Privacy
Email: privacy@seiright.com

3. Information We Collect

We collect various categories of personal information to provide, maintain, and improve our Services. The information we collect may include the following:

3.1 Account and Identity Information

• Full name, email address, and business contact information
• Company name, job title, and professional role
• Username and encrypted password or authentication credentials
• Profile information and account preferences
• Two-factor authentication details (phone number, authenticator app data)
• Billing and payment information (credit card details, billing address)

3.2 Customer Data

Customer Data means any data, information, call logs, models, guidelines, or other material provided to us by customers or generated from customers' use of the Services. Customers retain ownership of their Customer Data, and our use of Customer Data is governed by our SaaS Customer Agreement and this Policy.

3.3 Usage and Performance Data

• Activity logs, feature usage, and interaction patterns with the Services
• Access times, frequency of use, and session duration
• Search queries and commands entered into the Services
• Performance metrics and error reports
• Support requests, correspondence, and feedback

3.4 Technical and Device Information

• IP addresses and approximate geolocation data
• Browser type, version, and language settings
• Operating system and device information
• Cookies, local storage, and similar tracking technologies
• Referral sources and UTM parameters
• Device identifiers and mobile advertising IDs

3.5 Communications and Correspondence

• Email communications and responses
• Customer support inquiries and chat logs
• Survey responses and feedback
• Marketing communications preferences

3.6 Third-Party Integration Data

When customers integrate third-party services with our Services, we may collect information made available through those integrations, including data from CRMs, payment processors, communication tools, and other business applications.

4. How We Collect Information

We collect personal information through the following methods:

4.1 Information You Provide Directly

We collect information you provide directly when you:

• Create an account or register for our Services.
• Complete order forms or subscription agreements.
• Configure settings and preferences.
• Submit support requests or communicate with us.
• Participate in surveys, promotions, or events.
• Subscribe to marketing communications.

4.2 Information Collected Automatically

We automatically collect certain information when you access or use our Services through:

• Cookies, web beacons, and similar tracking technologies.
• Log files and server records.
• Analytics tools and performance monitoring systems.
• Session recording and user behavior tracking (aggregated and anonymized).

4.3 Information from Third Parties

We may receive information from third parties, including:

• Business partners and service providers.
• Payment processors and financial institutions.
• Data enrichment services for business contact information.
• Third-party authentication providers.
• Publicly available sources and business directories.

5. How We Use Your Information

We use the personal information we collect for the following purposes:

5.1 Service Provision and Performance

• To provide, operate, maintain, and support the Services
• To process transactions and manage billing
• To authenticate users and maintain account security
• To fulfill our contractual obligations under the SaaS Customer Agreement
• To respond to support requests and resolve technical issues

5.2 Service Improvement and Development

• To analyze usage patterns and improve Services functionality
• To develop new features, products, and services
• To conduct analytics and performance optimization
• To train and improve our AI models and machine learning algorithms
• To create aggregated and anonymized usage data for research and development

5.3 Communication and Marketing

• To send transactional communications about your account or Services
• To provide customer support and respond to inquiries
• To send marketing communications, newsletters, and promotional materials (with your consent where required)
• To conduct surveys and request feedback
• To notify you of updates, new features, or changes to our Services

5.4 Legal Compliance and Protection

• To comply with legal obligations and regulatory requirements
• To enforce our terms and conditions and protect our rights
• To prevent fraud, security threats, and illegal activities
• To protect the safety and security of our users and Services
• To respond to lawful requests from government authorities

5.5 Business Operations

• To manage our business relationships and customer accounts
• To conduct internal audits and quality assurance
• To maintain business records and documentation
• To facilitate mergers, acquisitions, or business transfers

6. Legal Basis for Processing (Where Applicable)

For users in jurisdictions requiring disclosure of legal basis for processing, we process personal information based on:

• Contract Performance: Processing necessary to perform our SaaS Customer Agreement and provide Services
• Legitimate Interests: Processing necessary for our legitimate business interests, including improving Services, analytics, security, and fraud prevention
• Consent: Processing based on your explicit consent, which you may withdraw at any time
• Legal Obligation: Processing necessary to comply with applicable laws and regulations

7. How We Share Your Information

We may share personal information with the following categories of third parties:

7.1 Service Providers and Subprocessors

We share information with trusted third-party service providers who perform services on our behalf, including:

• Cloud hosting and infrastructure providers (e.g., AWS, Microsoft Azure, Google Cloud)
• Payment processors and billing services
• Customer support and communication platforms
• Analytics and performance monitoring tools
• Security and fraud prevention services
• Email delivery and marketing automation platforms

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

7.2 Business Partners and Integrations

When you choose to integrate third-party services with our Services, we may share relevant information with those third parties to enable the integration. You control these integrations through your account settings.

7.3 Corporate Transactions

We may share information in connection with mergers, acquisitions, consolidations, reorganizations, asset sales, or other business transactions. Any successor entity will be bound by this Policy.

7.4 Legal Requirements and Protection

We may disclose information when required by law or when we believe disclosure is necessary to:

• Comply with legal obligations, court orders, or government requests
• Enforce our terms and conditions or protect our rights and property
• Investigate fraud, security issues, or violations of our policies
• Protect the safety and security of our users or the public

7.5 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably identify you with third parties for analytics, research, marketing, or other business purposes.

7.6 With Your Consent

We may share your information with third parties when you provide explicit consent for such sharing.

8. Cookies and Tracking Technologies

8.1 Types of Cookies We Use

We may use cookies and similar tracking technologies to collect information and improve our Services including the following:

• Essential Cookies: Required for Services functionality, authentication, and security
• Performance Cookies: Collect information about how you use our Services to improve performance
• Functional Cookies: Remember your preferences and settings
• Analytics Cookies: Help us understand user behavior and usage patterns
• Marketing Cookies: Used to deliver relevant advertisements and track campaign effectiveness

8.2 Third-Party Analytics

We use third-party analytics services, including Google Analytics and other such services, to collect and analyze usage information. These services may use cookies and similar technologies.

9. Data Security

The following measures, limitations and risks arise in the use of your data:

9.1 Security Measures

We implement administrative, physical, and technical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. Our security measures include:

• Access controls and authentication mechanisms
• Regular security assessments and penetration testing
• Employee training on data security and privacy practices
• Security monitoring systems

9.2 Security Limitations

While we use commercially reasonable security measures that align with generally accepted industry standards, no system is completely secure. We cannot guarantee absolute security of your information. You are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account.

9.3 Data Transmission Risks

You acknowledge that use of the Services involves transmission of data over networks not owned, operated, or controlled by us. We are not responsible for unauthorized access, interception, or loss of data during transmission over such networks.

10. Data Retention

10.1 Retention Periods

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. Retention periods vary based on:

• The nature and sensitivity of the information
• The purposes for which we process the information
• Legal, regulatory, tax, and accounting requirements
• Potential legal claims and dispute resolution needs
• Our legitimate business interests

10.2 Customer Data Retention

Customer Data is retained in accordance with the terms of our SaaS Customer Agreement. Upon termination or expiration of a customer agreement, we will delete Customer Data within 30 days unless legally prohibited or unless the customer requests data export.

10.3 Deletion and Anonymization

When personal information is no longer needed, we securely delete or anonymize it in accordance with our data retention and deletion procedures.

11. Your Privacy Rights

11.1 Rights Under State Privacy Laws

Depending on your state of residence, you may have the following rights regarding your personal information:

• Right to Know/Access: Request disclosure of the categories and specific pieces of personal information we have collected about you
• Right to Delete: Request deletion of your personal information, subject to certain exceptions
• Right to Correct: Request correction of inaccurate personal information
• Right to Data Portability: Request a copy of your personal information in a portable format
• Right to Opt-Out: Opt out of the sale or sharing of personal information, targeted advertising, and certain automated decision-making or profiling
• Right to Limit Use of Sensitive Personal Information: Limit our use and disclosure of sensitive personal information
• Right to Non-Discrimination: You will not be discriminated against for exercising your privacy rights

11.2 How to Exercise Your Rights

To exercise any of these rights, please contact us using the contact information in Clause 2. We will respond to verified requests within the timeframes required by applicable law (typically 45 days, with possible extension).

To verify your identity, we may request additional information such as your email address, account details, or other identifying information. For deletion requests, we may ask you to confirm your request to prevent accidental deletion.

11.3 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require verification of the agent's authority and your identity before processing the request.

11.4 Appeals

If we deny your privacy rights request, you have the right to appeal our decision. Appeal procedures and deadlines vary by state. We will provide specific appeal information if we deny your request.

12. California-Specific Disclosures

12.1 Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA/CPRA:

12.2 Sources of Personal Information

We collect personal information from the following sources:

• Directly from you
• Automatically through your use of our Services
• From third parties (business partners, service providers, public sources)

12.3 Business and Commercial Purposes

We use personal information for the business and commercial purposes described in Clause 5, including service provision, improvement, communication, legal compliance, and business operations.

12.4 Categories of Third Parties

We share personal information with the following categories of third parties:

• Service providers and subprocessors
• Cloud infrastructure providers
• Payment processors
• Analytics providers
• Business partners (with your consent)
• Legal and regulatory authorities (when required)

12.5 Sale and Sharing of Personal Information

We do not sell personal information in the traditional sense. However, under the broad CCPA/CPRA definitions, certain data sharing practices may be considered "sales" or "sharing" for cross-context behavioral advertising.

In the preceding 12 months, we may have "shared" the following categories for targeted advertising purposes:

• Identifiers (cookies, device IDs)
• Internet activity information

Right to Opt-Out: You have the right to opt out of the sale or sharing of your personal information. To exercise this right, please contact us at privacy@seiright.com.

12.6 Sensitive Personal Information

We do not collect or use sensitive personal information (as defined by CCPA/CPRA) except as necessary to provide the Services. If we collect sensitive personal information, we will use it only for permitted purposes under California law.

12.7 Retention Periods

We retain personal information as described in Clause 10. For California residents, we retain each category of personal information for the periods specified in our data retention schedule.

12.8 Automated Decision-Making Technology (ADMT)

Our Services utilize AI-powered features and machine learning algorithms to provide enhanced functionality. If we use automated decision-making technology for significant decisions affecting California residents we will comply with ADMT compliance provisions as per California law and if required by law, will provide:

• Pre-Use Notice explaining the ADMT and its purposes
• Right to opt out of ADMT for certain significant decisions
• Right to access information about the logic involved in ADMT

12.9 Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA/CPRA rights, including by:

• Denying goods or services
• Charging different prices or rates
• Providing different quality of goods or services
• Suggesting you will receive different prices or quality

However, we may offer financial incentives or different prices if the difference is reasonably related to the value of your personal information.

13. Children's Privacy

Our Services are not directed to children under 16 years of age. We do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16, we will take steps to delete that information promptly.

Parents or guardians who believe we have collected information from a child under 16 should contact us immediately at privacy@seiright.com.

14. International Data Transfers

Our Services are operated in the United States. If you access our Services from outside the United States, your information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those in your jurisdiction.

By using our Services, you consent to the transfer of your information to the United States and processing in accordance with this Policy and applicable U.S. laws.

15. Third-Party Services and Links

This Policy does not apply to third-party services that we may provide links to. We are not responsible for the privacy practices of third parties.

When you integrate third-party services with our Services or click on third-party links, you interact with those third parties subject to their own terms and privacy policies. We encourage you to review the privacy policies of any third-party services you use.

16. Marketing Communications

16.1 Opting Out

If you receive marketing communications from us, you may opt out by:

• Clicking the "unsubscribe" link in any marketing email
• Adjusting your communication preferences in your account settings
• Contacting us at privacy@seiright.com

Please note that even if you opt out of marketing communications, we may still send you transactional or administrative messages related to your account or use of the Services.

16.2 Universal Opt-Out Mechanisms

For residents of states requiring universal opt-out mechanism recognition (California, Colorado, Connecticut, and others), we honor Global Privacy Control (GPC) signals and similar browser-based opt-out preferences.

17. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, Services, legal requirements, or for other operational reasons. We will notify you of material changes by:

• Posting the updated Policy on our website with a new "Last Updated" date
• Sending email notification to your registered email address
• Providing notice through the Services

Your continued use of the Services after the effective date of the updated Policy constitutes acceptance of the changes. We encourage you to review this Policy periodically.

18. State-Specific Rights and Disclosures

In addition to the rights described throughout this Policy, residents of certain states have additional rights:

18.1 Virginia, Colorado, Connecticut, Indiana, Kentucky, and Rhode Island Residents

Residents of these states have rights similar to those described in Clause 11.1, including rights to access, delete, correct, and obtain a copy of their personal information, as well as to opt out of targeted advertising, sale of personal information, and profiling in furtherance of decisions that produce legal or similarly significant effects.

18.2 Processing of Minors' Personal Information

For residents of states with heightened protections for minors:

• We do not sell personal information of individuals we know are under 18
• We do not engage in targeted advertising to individuals we know are under 18 without appropriate consent
• We obtain parental consent when required for processing sensitive data of minors

18.3 Data Protection Assessments

We conduct data protection impact assessments for processing activities that present heightened privacy risks, as required by applicable state laws.

19. Business Contact Information

To the extent we process business contact information in a business-to-business context, such processing is exempt from certain state privacy law requirements. However, we remain committed to protecting all personal information in accordance with this Policy.

20. Questions and Complaints

If you have questions, concerns, or complaints about this Policy or our privacy practices, please contact us using the information in Clause 2.

Acknowledgment and Consent

By using our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, disclosure, and processing of your personal information as described herein.

Sei Software Technologies Inc.
Effective Date: March 9, 2026