This Product Privacy Policy describes how Copient AI LLC and its affiliated companies (collectively, “Copient AI”, “we”, “our” or “us”) collects, stores, uses and discloses the following categories of personal data:

Last Edited Date: October 1, 2026

Section A: Definitions and Scope

A.1 Client Data: personal data (as defined in Section 1) that we collect, process, and manage on behalf of our business clients in connection with their use of the Platform under one or more applicable order forms. This includes data from Client Prospects, meaning individuals who participate in pre-sales activities such as enterprise trials, demos, or pilot deployments within the Platform environment. It does not include data collected from website visitors or marketing interactions, which are governed by our Website Privacy Policy.

A.2 Student Data: As a subset of Client Data, if our Client’s use of the Platform involves the collection and processing of student data (e.g., training participants in educational or corporate learning environments), this data is processed on behalf of and under the instruction of the respective Client, in compliance with applicable laws, such as FERPA or similar regulations.

A.3 User Data: personal data concerning individuals acting on behalf of our Clients in respect of their engagement with Copient AI, and users of the Platform on behalf of such Clients, e.g., the account administrators and users, billing contacts and authorized signatories on behalf of the Client (collectively, “Users”); as well as the Client’s business needs and preferences, as identified to us or recognized through our engagement with them.

A.4 Platform Interaction Data: refers to the content Users and Clients submit to or generate through the Platform, as well as data derived from such interactions.

Section B: Applicability and Use Context

If you are a Client or User, please read this Product Privacy Policy carefully and make sure that you fully understand it. This Privacy Policy forms part of the Copient AI Use Terms and the short acknowledgment presented at the point of use.

B.1 Applicability of Terms

By default, the terms and conditions and this Product Privacy Policy apply to all Clients. In cases where specific processing instructions or additional requirements are necessary, such Client Data is processed on behalf of and under the instruction of the respective Client, as outlined in a mutually agreed-upon Data Processing Addendum.

B.2 Business-Only Scope

Our Services are offered in two modes: (a) to business, educational, and program-provider Clients, whose learners and users access the Platform under the applicable Client agreement; and (b) to individuals who create a direct, self-paid account with Copient AI under the Copient AI Use Terms. Where you access the Platform through a Client, we treat your personal data as pertaining to you in your capacity as a learner, trainee, or business representative of that Client. Where you use the Platform on a direct account, this Product Privacy Policy applies to you as an individual, and Copient AI is the data controller as described in Section 13.

B.3 Voluntary Provision of Personal Data

You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us and avoid any interaction with us or with our Sites, or use our Services.

Section 1: Data Collection and Processing

1.1 Definition of Personal Data

When we use the terms “personal data” or “personal information” in this Product Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

1.2 Sources of Data

Sometimes we collect personal data automatically when an individual interacts with our Services or Sites (such as through our website chat feature) and sometimes we collect personal data directly from an individual. At times, we may collect personal data about an individual from other sources and third parties (such as our Clients and Service Providers), even before our first direct interaction. Copient AI does not seek to collect sensitive personal data beyond the voice audio and, where Copient AI has enabled session recording at a Client’s request, audio-video recordings that are inherent to the Platform’s operation as described in Section 1.3, and the Copient AI Use Terms instruct users not to submit sensitive or regulated information about real individuals.

1.3 Categories of Data Collected

We may collect or generate the following types of Client Data, User Data, and Platform Interaction Data through the Services:

1. Automatically collected data: Usage, login credentials, and device information concerning Users and Clients (e.g., connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses, device data like type, OS, device ID, browser version, locale and language settings used, activity logs, log-in credentials to the Services, cookies and pixels installed or utilized on their device, and inferred or presumed data generated from their use of the Services).

2. User-provided data: Contact and business details such as name, email, phone number, position, workplace and related business insights, our communications with such individuals (correspondences, sensory information including call and video recordings, and transcriptions and analyses thereof), feedback, testimonials, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement. Additionally, any other data voluntarily provided by individuals, such as gender, title, resumes, or other information relevant to applications or engagements, may also be collected.

3. Client Data: Personal data contained in Client Data provided by our Clients or processed on their behalf and under their instruction. This may include any of the types of personal data described above (with respect to Users or other individuals whose data is contained in the Client Data).

4. Client Content: Inputs uploaded by clients or users, including scenarios, prompts, scripts, or audio/video recordings.

5. Client Outputs: Data generated by the Platform, including transcripts, scores, coaching feedback, and analytics reports.

6. Aggregated Data: De-identified data used internally to improve the Platform, develop benchmarks, and conduct research. This data does not identify individual users.

7. Audio and session recording data: To operate, the Platform captures a learner’s speech and transmits it to a speech-to-text provider to create a transcript; this audio capture is inherent to the Service and occurs whenever the Service is used. The audio itself is not retained by Copient AI; only the resulting transcript is stored. Full session recordings (audio and, where applicable, video) are off by default and are enabled only by Copient AI, at a Client’s request, for that Client. Where recording is enabled, the acknowledgment presented to the learner before they can access the Service says so, and the learner’s acceptance of that acknowledgment is their consent to the recording; the learner cannot access the Service without accepting it, so no recording begins before consent.

Section 2: Data Uses

We use personal data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services, e.g., in understanding how our Services are used and gaining insights which help us dedicate our resources and efforts more efficiently; in providing client service and technical support; and protecting and securing our Clients, Users, Prospects, ourselves and our Services (“Legitimate Interests”).

If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing) (“Consent”), your acceptance of our Terms and Conditions and this Product Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at privacy@Copient.ai

2.1 Purpose-Based Uses

Specifically, we use personal data for the following business and commercial purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

Client and User personal data

1. To facilitate, operate, enhance, and provide our Services (Performance of Contract; Legitimate Interests);

2. To provide our Clients and Users with assistance and support, to test and monitor the Services, or diagnose or fix technology problems, and to train our Clients and Client-facing staff (Performance of Contract; Legitimate Interests);

3. To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities to make our Services easier to use (Performance of Contract; Legitimate Interests);

4. To gain a better understanding on how individuals use and interact with our Services, which content and data they have processed through our Services, and how we could improve their and others’ user experience and the value they can generate from using the Services, so we could continue improving our products, offerings and the overall performance of our Services, including through the utilization and optimization of Artificial Intelligence and Machine Learning capabilities (Legitimate Interests);

5. To contact our Clients and Users with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (Performance of Contract; Legitimate Interests; Consent);

6. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity (Performance of Contract; Legitimate Interests; Legal Obligation);

7. To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose (Legitimate Interests);

8. To enforce our Terms and Conditions, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties (Legitimate Interests);

9. To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards (Performance of Contract; Legitimate Interests; Legal Obligation); and

10. For any other lawful purpose, or other purpose that you consent to (Legal Obligation; Consent).

Section 3: Data Location

We and our authorized Service Providers (defined below) currently, as of August 2026, maintain, store and process personal data in the United States of America and may expand to other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Copient AI is committed to protect personal data in accordance with this Product Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

Section 4: Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to provide our Services, comply with legal and contractual obligations, resolve disputes, and enforce our agreements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes of processing, and applicable legal requirements. Personal data will be deleted or anonymized when no longer required, unless we are legally obligated to retain it or it is needed to establish, exercise, or defend legal claims.

If you have any questions about our data retention policy, please contact us by e-mail at privacy@Copient.ai

Section 5: Data Disclosure

We disclose personal data in the following ways:

5.1 Service Providers: We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers may include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, our website chat feature, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and client relation management systems, LLMs, voice-to-text, error/logging services, and our legal, financial and compliance advisors (collectively, “Service Providers”). Our Service Providers may have access to personal information, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.

5.2 Partnerships: We may engage resellers or implementation partners to support client onboarding and fulfillment. In such cases, they may access limited account details solely for that purpose and remain subject to our contractual obligations.

5.3 Service Integrations: You may choose to use a third-party service to integrate with our Services, for example in order to upload or retrieve personal data to or from the Services, or to enrich the data you have processed on either service or enhance your usage thereof (provided that such integration is supported by our Services). The provider of this integrated third-party service may receive certain relevant data about or from your account on the Services, or share certain relevant data from your account on the third-party provider’s service with our Services, depending on the nature and purpose of such integration. This could include your Client Data and/or User Data. Note that we do not receive or store your passwords for any of these third-party services (but do typically require your API key in order to integrate with them).

5.4 Business Clients: As a processor, we process personal data on behalf of our Clients in accordance with their instructions. We provide reasonable assistance to our Clients to enable them to fulfill their obligations under applicable data protection laws, including responding to data subject requests and ensuring access to personal data as required.

5.5 Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.

5.6 Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Copient AI, any of our Users or Clients, or any members of the general public.

5.7 Copient AI Subsidiaries and Affiliated Companies: We may share personal data internally within our group, for the purposes described in this Product Privacy Policy. In addition, should Copient AI or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. We may disclose personal data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.

5.8 Anonymized Use: For the avoidance of doubt, Copient AI may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

Section 6: Subprocessors and Third Parties

Copient AI engages third-party subprocessors to support the delivery, functionality, and security of the Platform. These subprocessors include well-established, industry-standard service providers responsible for areas such as cloud infrastructure, user authentication, analytics, and large language model (LLM) integrations. All subprocessors process data solely on Copient AI’s behalf and are subject to contractual obligations governing their access to and use of personal data.

While Copient AI does not assume responsibility for the independent compliance practices of subprocessors, we conduct rigorous due diligence on all vendors and engage only those who meet our internal standards for security, privacy, and compliance.

We do not engage subprocessors that use client data to train their models. Specifically, every AI model provider and AI tool Copient AI uses, including the providers that run sessions and the business editions of AI assistants and coding tools our personnel use to prepare client programs, is used under business or API terms that keep submitted data confidential and prohibit its use for model training. Those personnel tools do not receive learner session data.

Speech-to-text providers engaged to transcribe learner audio are contractually barred from using that audio or the resulting transcripts to train their models and from retaining them beyond what is required to provide the transcription service.

A current list of subprocessors, along with links to their privacy policies, is available to Clients upon request by contacting privacy@copient.ai.

Section 7: Use of Aggregated and De-Identified Data

Copient AI may use aggregated, anonymized, or de-identified data derived from Client Data, User Data, or Platform Interaction Data to improve the functionality, performance, and security of the Platform; to develop new features and services; and to generate insights and benchmarks.

Such data will not identify any individual or Client and does not constitute personal data under applicable privacy laws. Copient AI may use and disclose this data for internal business purposes or share it in non-identifiable form with partners, researchers, or the public for research, analytics, and industry insight purposes.

Section 8: Cookies and Data Collection Technologies

We and our Service Providers use cookies, logs, pixels and other technologies to enable and improve the Services we provide, to track the performance of our Sites, perform analytics and gain insights on the use of our Services and the performance of our activities, and for personalization purposes.

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.

We use “Persistent Cookies” to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.

Some cookies are essential for the proper functioning of our Services and cannot be declined or disabled unless you choose to delete or block them through your web browser settings. Other cookies are optional and are used to enhance functionality, improve performance, and analyze usage.

We use analytics and tracking technologies to understand how Users interact with our Services. These tools may collect information such as page content viewed, clicks, touch interactions, movements, scrolls, and other engagement activities. This information helps us improve the user experience and the effectiveness of our Services.

For additional information on managing cookies and analytics settings, please refer to your browser settings or the opt-out options provided by relevant analytics services. For an updated list of analytics tools used by Copient AI, you may reach out to privacy@copient.ai.

Section 9: Generative AI Use

The Platform uses Generative AI (GenAI) technologies to facilitate conversation practice, scoring, coaching, and feedback. These outputs are probabilistic and may not always be accurate, complete, or contextually appropriate.

Clients are solely responsible for reviewing and validating all generated outputs before relying on them for any educational, operational, or business decisions.

Copient AI does not use Client Data to train or fine-tune any artificial intelligence model, including large language models, unless explicitly authorized in writing by the Client. Where permitted, only de-identified and anonymized data may be used to improve AI performance and overall platform functionality.

Section 10: Communications

We engage in service and promotional communications, through e-mail, phone, SMS and notifications.

10.1 Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. If you are registered as a User to our Services, you can typically control your communications and notifications settings from your profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).

10.2 Optional Updates: Where legally permitted and relevant to your use of the Platform, we may notify administrative users of new features, system enhancements, or training opportunities that support your organization’s use of the service. You may opt out of non-essential communications by contacting us at privacy@copient.ai.

Section 11: Data Security

We are committed to protecting your personal data and take reasonable steps to secure it. Our systems, applications, and procedures are designed to minimize the risks of theft, damage, loss, unauthorized access, or misuse of your personal data. We rely on industry-leading cloud infrastructure providers, including Render and AWS, for the physical and virtual security of our systems. However, we cannot guarantee that our Sites or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Section 12: Data Subject Rights

12.1 Rights of Individuals: Individuals have rights regarding their personal data, depending on the applicable laws (e.g., GDPR, LGPD, CCPA, FADP). These may include:

1. Access: Request access to specific personal data, categories of data, sources, purposes of processing, and third parties with whom data is shared.

2. Correction or Erasure: Request correction of inaccurate data or deletion of data where legally permissible.

3. Restrict or Object: Restrict or object to data processing, including opting out of the sale or sharing of personal data.

4. Data Portability: Request a copy of your data in a machine-readable format.

5. Freedom from Discrimination: Exercise your rights without discrimination.

6. Lodge Complaints: File complaints with supervisory authorities (e.g., EU Data Protection Authorities, UK ICO, Brazilian ANPD).

12.2 How to Exercise Rights: To exercise your rights, contact us at privacy@Copient.ai. You may also designate an authorized agent to submit requests on your behalf. Verification of your identity or authorization may be required to process your request.

12.3 Verification Process: When submitting a request, we may:

1. Ask for credentials to confirm your identity and ensure compliance with privacy laws.

2. Request additional details to understand the scope of your request.

3. Forward requests to the appropriate Client if we act as their “data processor” or “service provider.” We recommend contacting the Client directly for such requests. This referral applies only where you access the Platform through a Client; for direct accounts, Copient AI responds to your request as the data controller.

12.4 Special Considerations

1. FERPA Compliance: If you are a student or parent subject to FERPA, requests related to educational records will be processed in accordance with FERPA regulations.

2. Redaction: We may redact personal or confidential information related to others when fulfilling your requests.

12.5 Dispute Resolution: If you have unresolved concerns about our data practices, you may escalate your complaint:

1. EU, UK, and Swiss Residents: Contact relevant Data Protection Authorities (DPAs).

2. Federal Oversight: Copient AI LLC is subject to the Federal Trade Commission (FTC) for compliance investigations.

Section 13: Data Controller/Processor

Certain data protection laws, such as the GDPR, CCPA, and LGPD, define two main roles in handling personal data:

Data Controller (or “Business” under CCPA): Determines the purposes and means of data processing.

Data Processor (or “Service Provider” under CCPA): Processes data on behalf of the data controller.

13.1 Our Roles

I. Client Data:

1. Your Role: As our Client, you act as the data controller. You define how personal data—such as training scripts, voice recordings, or interaction data—is used in the context of our Services.

2. Our Role: Copient AI acts as the data processor, processing Client Data based on your instructions. We do not make independent decisions about this data. Any third-party tools we use to deliver our services (e.g., speech-to-text, text-to-speech, AI avatars, or LLMs) function as sub-processors on our behalf.

II. Prospect and User Data:

1. For personal data collected directly by Copient AI, such as user account information or platform analytics, we act as the data controller and assume responsibilities for compliance under applicable law.

III. Direct Accounts: If you use the Platform on a direct, self-paid account with no Client agreement in place, Copient AI acts as the data controller for the personal data processed in connection with your account and your use of the Platform, including your session transcripts and, where enabled, session recordings. In that case, submit requests under Section 12 to privacy@copient.ai and we will respond as the data controller rather than referring your request to a Client.

Client Responsibilities

1. Consent and Transparency: As the data controller, you are responsible for providing notice to your end users (e.g., trainees, employees, or participants) and obtaining any required consents for data collection and processing within the platform.

2. Legal Compliance: You must ensure compliance with all applicable laws, including GDPR, CCPA, and FERPA (if relevant), particularly when processing personal data within an employment or training context.

13.2 Institutional Use and FERPA

When the Platform is used by educational institutions, Copient AI acts as a “school official” under the Family Educational Rights and Privacy Act (FERPA), performing services on behalf of the institution with a legitimate educational interest and under its direct control.

Institutions using the Platform are responsible for:

- Obtaining any required parental or student consent under FERPA or applicable state law;

- Limiting the scope of Student Data provided to Copient AI to what is necessary for the intended educational purpose;

- Managing student access or deletion requests, including reviewing and directing such requests to Copient AI where applicable.

Copient AI will support institutional FERPA compliance in accordance with its role as a data processor and school official. Copient AI does not determine the means or purposes of FERPA-covered data processing and does not assume responsibility for obtaining educational records consents or for compliance with institutional data governance requirements beyond its role as a processor.

13.3 Data Subject Requests

If an end user submits a request regarding their personal data (e.g., access, deletion, or correction), we will refer the request to you as the data controller. We will assist you in fulfilling such requests, as outlined in our agreements.

13.4 Third-Party Tools and Sub-Processors

To deliver our services, we rely on third-party tools (e.g., speech-to-text, text-to-speech, and AI-powered technologies). These tools process data on your behalf as sub-processors. A list of our sub-processors and their privacy practices can be provided upon request or as outlined in our agreements.

13.5 Processing Boundaries

Copient AI processes Client Data strictly in accordance with your instructions, as detailed in our Data Processing Addendum and commercial agreements. We do not sell or share Client Data for purposes outside of providing our services.

Section 14: Additional Notices & Contact Details

14.1 Updates and Amendments: We may update and amend this Product Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe that the changes involved materially alter your rights, via any of the communication means available to us or via the Services. Your continued use of the Service constitutes your acknowledgment of the updated policy.

14.2 External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Product Privacy Policy applies only to our Services.

14.3 Children’s Privacy: Direct, self-paid accounts may be created only by individuals who are at least 18 years old. Individuals under 18 may use the Platform only where a Client (such as a school, employer, or program provider) has enrolled them and confirmed that any parental or guardian consent required by applicable law has been obtained. K-12 use is permitted only under the direction of an educational institution acting as the data controller. If you believe that we might have any such data, please contact us by e-mail at privacy@Copient.ai

For use of our marketing website, please refer to our Website Privacy Policy.