Global policy, with Canada, EEA and UK, and United States addenda

Version 3.0

Effective upon January 1, 2023

Last updated August 8, 2026

Applies to genieai.io, runbos.ai, the BOS platform and all Genie AI products and services

Privacy Officer privacy@genieai.ca

This policy explains what Genie AI collects, why we collect it, who we share it with, how long we keep it, and the rights you can exercise. Where Genie AI processes personal information on behalf of a business customer, the customer agreement and Data Processing Addendum govern, and this policy is descriptive only.

1. Who we are and what this policy covers

GENIE AI, Inc. ("Genie AI", "we", "us", "our") is a corporation incorporated federally in Canada under the Canada Business Corporations Act, with its principal place of business in Ontario, Canada. We build BOS, the Business Orchestration System, an AI native platform that orchestrates people and AI agents to run business operations, together with the vertical solutions and applications built on it.

This Privacy Policy applies to personal information we handle through our websites, applications, platform, agents, APIs, events, support channels, sales and marketing activities, and any other product, service, program or feature we provide, online or offline (together, the "Services").

This policy does not apply to third party products or websites that link to or integrate with our Services, or to the internal privacy practices of our customers. Those are governed by their own policies.

1.1 Our two roles

Genie AI handles personal information in two distinct roles. Understanding which one applies to you determines how this policy operates.

+--------------+-------------------------------+-----------------------+ | Role | When it applies | What governs | +==============+===============================+=======================+ | Controller | We decide why and how | This Privacy Policy. | | | information is processed. | | | ("or | This covers visitors to our | | | ganization" | websites, prospects and | | | under | marketing contacts, users who | | | Canadian | create accounts directly with | | | law) | us, billing contacts, | | | | applicants, and partners. | | +--------------+-------------------------------+-----------------------+ | Processor | A business, enterprise or | The customer | | | government customer uses BOS | agreement and our | | ("service | and submits information about | Data Processing | | provider" | its own employees, | Addendum. The | | or | contractors, customers or | customer is the | | "agent") | citizens. We process that | controller and is | | | Customer Content only on the | responsible for | | | customer's documented | notice and consent to | | | instructions. | its own individuals. | +--------------+-------------------------------+-----------------------+

If you are an individual whose information was placed into BOS by an organization, please direct access, correction and deletion requests to that organization. We will support them in responding, and we will refer your request to them if you contact us directly.

1.2 Acceptance

By using our Services you accept this policy. If you do not agree with it, please do not use the Services. If anything here is unclear, contact our Privacy Officer before you continue.

2. Definitions

• Personal information means information about an identifiable individual. It does not include aggregated, de-identified or anonymous information that cannot reasonably be attributed to an individual, which we refer to as non personal information.

• Customer Content means data, documents, records, prompts, workflows, files and other material that a customer or its authorized users submit to, or generate within, the Services.

• Service Data means account, configuration, billing, telemetry, log, diagnostic and usage information generated by operating the Services.

• Sub processor means a third party we engage to process personal information in the course of providing the Services.

• Sensitive personal information means categories treated as sensitive under applicable law, including government identifiers, financial account credentials, precise geolocation, biometric identifiers, health information, and account login credentials.

3. Personal information we collect

We collect only what we need for the purposes described in this policy. The categories below describe what we collect as a controller.

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Category Examples Source

---------------- --------------------------------------- ---------------- Identity and First and last name, business email, You, directly. contact mailing address, phone number, job title, employer, preferred language.

Account and Username, hashed credentials, single You, or your access sign on identifiers, multi factor administrator. enrolment, role and permission assignments, organization membership.

Billing and Billing contact and address, plan and You, and payment transaction licence tier, invoice and payment processors. history, tax identifiers, purchase orders. Card numbers are handled by our payment processors and are not stored on our systems.

Usage and Features used, agents invoked, workflow Automatically. telemetry and task events, session duration, performance and error data, API call metadata.

Device and IP address, browser and device type, Automatically. network operating system, language, referring page, approximate region derived from IP.

Support and Messages, tickets, call and meeting You, directly. communications notes, feedback, survey responses, recordings where you are notified and consent applies.

Marketing and Subscription preferences, campaign You, and event engagement, event registration and partners. attendance, content downloads.

Recruitment Resume, work history, references, right You, and to work confirmation, assessment recruiters. results, where you apply for a role.

Customer Content Whatever a customer chooses to place Our customers. into BOS. This may include personal information about that customer's own people. We do not control what is submitted. -------------------------------------------------------------------------

3.1 Sensitive information

We do not seek sensitive personal information for our own purposes, and we ask that you do not send it to us in support tickets, emails or free text fields. Where a customer configures BOS to process sensitive categories, that processing happens under the customer agreement, on the customer's instructions, and with the additional controls described in section 9.

3.2 Information about children

Our Services are built for business, enterprise and government use. They are not directed to children, and we do not knowingly collect personal information from anyone under the age of majority in their province, state or country. If we learn we have collected such information without valid consent, we will delete it promptly. Contact our Privacy Officer if you believe a child has provided us with personal information.

4. Why we use personal information

We use personal information only for the purposes identified when it was collected, for purposes a reasonable person would consider appropriate in the circumstances, or as otherwise permitted or required by law.

----------------------------------------------------------------------- Purpose Legal basis in the Canadian consent EEA and UK model --------------------------- --------------------- --------------------- Provide, operate, secure Performance of a Express or implied and support the Services, contract. consent at the point including provisioning of collection. accounts and running agents and workflows.

Bill, collect payment, Contract and legal Express consent and manage licences, and meet obligation. legal requirement. tax and accounting obligations.

Maintain, troubleshoot, Legitimate interests. Implied consent, monitor, and improve consistent with reliability, quality and reasonable performance of the expectations. Services.

Protect against fraud, Legitimate interests Permitted use and abuse, unauthorized access and legal obligation. implied consent. and security incidents, and enforce our terms.

Develop new features, Legitimate interests. Implied consent for models, integrations and non personal and de products, using Service identified data. Data and de identified or aggregated data.

Send service and Contract and Implied consent, and administrative notices, legitimate interests. required notice. including security, availability and policy change notices.

Send marketing Consent, or Express or implied communications, legitimate interests consent under CASL, invitations, newsletters for existing business with unsubscribe in and offers. relationships. every message.

Respond to lawful demands Legal obligation. Permitted disclosure from law enforcement, without consent where regulators, courts and required by law. government authorities.

Evaluate candidates and Steps prior to Express consent. manage recruitment. entering a contract and legitimate interests.

Support corporate Legitimate interests. Permitted use, with transactions, financing, the safeguards in due diligence, and business section 8. continuity. -----------------------------------------------------------------------

We may use and disclose non personal information, including aggregated and de identified data, for any lawful business purpose. Where we de identify data we maintain the technical and organizational measures to keep it de identified, and we do not attempt to re identify it.

4.1 If we want to use information for something new

If we intend to use personal information for a purpose that was not identified when we collected it and that you would not reasonably expect, we will identify the new purpose and obtain your consent first, unless the law permits or requires us to proceed without it.

5. Consent, and how to withdraw it

We obtain express consent where the information is sensitive, where the purpose is not obvious, or where the law requires it. We rely on implied consent only where the information is less sensitive, the purpose is clear from the context, and your reasonable expectations support it.

You can refuse to provide personal information, and you can withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice. Withdrawing consent may mean we can no longer provide part or all of the Services to you. Withdrawal does not affect processing that already occurred, and it does not apply to information we are required to retain by law.

To withdraw consent, contact privacy@genieai.ca, or use the unsubscribe link in any marketing message. Service and security notices are not marketing and will continue while your account is active.

6. Cookies, analytics and tracking

We use cookies, local storage, pixels, web beacons and similar technologies on our websites and, in limited form, in the product.

------------------------------------------------------------------------ Type What it does Can you turn it off ---------------- ------------------------------------ ------------------ Strictly Authentication, session integrity, No. The Services necessary load balancing, security and fraud will not function prevention. without these.

Functional Remembers language, region, Yes, with reduced interface and workspace preferences. convenience.

Analytics and Measures traffic, feature adoption, Yes. performance errors and page performance so we can improve the Services.

Marketing and Measures campaign performance and Yes. attribution attributes sign ups to sources. ------------------------------------------------------------------------

Where required by law we present a consent banner and set non essential cookies only after you opt in. You can also control cookies through your browser or device settings, and you can withdraw consent at any time through the cookie preferences link on our website. Blocking cookies may break parts of the Services.

We use third party analytics providers, including Google Analytics. These providers may collect IP address, timestamps, referring pages and return visitor status, and process that information under their own privacy terms. We configure IP anonymization and data retention limits where the provider supports them.

We honour Global Privacy Control and similar recognized opt out preference signals where applicable law requires it. Beyond that, our Services do not currently alter behaviour in response to browser do not track signals, because no common standard for them has been adopted.

7. Artificial intelligence, agents and automated processing

BOS orchestrates AI agents that read, generate, route and act on information. Because that is the core of what we build, we set out our commitments explicitly.

7.1 Model training

• We do not use Customer Content to train, fine tune or improve foundation models for the benefit of other customers or for general model development.

• We contractually require our AI model sub processors not to train their models on Customer Content submitted through our Services, and we use zero retention or limited retention configurations where the provider offers them.

• We may use Service Data, and Customer Content that has been aggregated or irreversibly de identified, to measure quality, tune orchestration logic, evaluate performance and improve reliability.

• Where a customer expressly opts in under a separate written agreement, we may use its Customer Content for that customer's own dedicated models. That opt in is specific, revocable and never assumed.

7.2 Inputs, outputs and retention

Prompts and outputs may be retained for a limited period to deliver the feature, support debugging, maintain audit trails, and detect abuse. Retention periods are set out in section 11 and can be shortened by contract for enterprise and government deployments.

7.3 Accuracy and human oversight

AI generated output can be incomplete, out of date or wrong. Outputs are decision support, not professional advice, and should be reviewed by a person before they are relied on for legal, financial, medical, employment or safety related decisions. Customers configure the approval gates, escalation paths and human in the loop checkpoints appropriate to their use case, and are responsible for doing so.

7.4 Automated decision making

Genie AI does not use automated decision making, including profiling, to make decisions about individuals that produce legal or similarly significant effects on them, without human involvement. Where a customer configures BOS to support such decisions in its own operations, the customer is responsible for the lawful basis, the disclosure, and the individual's right to an explanation and to human review. On request we will provide customers with information about the principal factors and parameters a configured workflow uses, so they can meet those obligations, including under Quebec's Law 25 and Articles 13, 14 and 22 of the GDPR.

7.5 Prohibited uses

Our terms prohibit using the Services to conduct unlawful surveillance, to infer sensitive characteristics for discriminatory purposes, to generate biometric identification of individuals without a lawful basis, or to make consequential decisions about people without meaningful human review.

8. Disclosure and sub processors

We do not sell your personal information, and we do not rent it, trade it, or share it for cross context behavioural advertising.

We disclose personal information only in the circumstances below.

• Sub processors and service providers who help us deliver the Services, under written contracts that limit them to our instructions, impose confidentiality and security obligations at least as protective as ours, and prohibit any independent use.

• Affiliates and our own personnel, advisors and contractors who need the information to do their jobs, on a least privilege basis.

• Your organization, where you use the Services through a workspace administered by an employer or other customer. Administrators can access account, usage and content within their workspace.

• Authorities and third parties where we are legally required to disclose, including in response to a valid court order, subpoena, regulatory demand or lawful investigative request. We assess every demand, require it to be legally valid and appropriately scoped, and notify the affected customer unless we are prohibited from doing so.

• To establish, exercise or defend legal claims, enforce our terms, prevent fraud, or protect the rights, property or safety of Genie AI, our customers or the public.

• In a corporate transaction, including a merger, amalgamation, financing, reorganization, or sale of all or substantially all of our assets. We will require the counterparty to be bound by this policy or by substantially similar protections, and we will act reasonably to ensure continuity of protection, though we cannot guarantee the counterparty's future compliance.

8.1 Categories of sub processors

We engage sub processors in the categories below. The current list of named sub processors, their function and their processing location is published at genieai.io/subprocessors and is updated when it changes.

------------------------------------------------------------------------ Category Function Typical processing region ----------------------- -------------------------------- --------------- Cloud infrastructure Compute, storage, networking, Canada, United and hosting managed databases. States

AI model and inference Language model inference and United States, providers embedding generation. Canada

Identity and access Authentication, single sign on, United States multi factor enrolment.

Payments and billing Payment processing, invoicing, United States, tax calculation. Canada

Communications Transactional email, United States notifications, in product messaging.

Support and ticketing Customer support, knowledge United States, base, session diagnostics. Canada

Analytics and Product analytics, error United States, monitoring tracking, uptime and performance European Union monitoring.

Business operations CRM, contract execution, United States, accounting, collaboration Canada tooling. ------------------------------------------------------------------------

Enterprise and government customers can subscribe to advance notice of new sub processors and, where their agreement provides for it, object on reasonable data protection grounds.

9. Security

We maintain an information security program with administrative, technical and physical safeguards proportionate to the sensitivity of the information we hold. Our program is aligned to recognized frameworks, and our current certification and attestation status is available on request under NDA.

9.1 Controls

• Encryption of personal information in transit using TLS 1.2 or higher, and at rest using AES 256 or equivalent.

• Role based access control, least privilege provisioning, mandatory multi factor authentication for internal systems, and single sign on and SCIM provisioning for customer workspaces.

• Logical tenant isolation so one customer's Customer Content is not accessible to another.

• Centralized audit logging, monitoring and alerting across production systems.

• Secure development lifecycle including code review, dependency scanning, static analysis and change management.

• Independent penetration testing and regular vulnerability scanning, with tracked remediation timelines by severity.

• Background checks where permitted by law, confidentiality agreements, and mandatory privacy and security training for personnel at onboarding and annually.

• Vendor due diligence and security review before a sub processor is engaged, and periodically afterward.

• Documented backup, disaster recovery and business continuity plans, with defined recovery objectives and periodic testing.

9.2 Incident response and breach notification

We maintain a documented incident response plan with defined severity levels, escalation paths and post incident review. If a breach of security safeguards occurs:

• Where we act as a processor, we notify the affected customer without undue delay after becoming aware, and provide the information the customer needs to meet its own notification obligations.

• Where we act as a controller and the breach creates a real risk of significant harm, we notify the Office of the Privacy Commissioner of Canada, the Commission d'acces a l'information du Quebec where applicable, and affected individuals as soon as feasible, and we maintain breach records for the period required by law.

• Where the GDPR or UK GDPR applies, we notify the competent supervisory authority within 72 hours of becoming aware, unless the breach is unlikely to result in a risk to individuals, and we notify affected individuals where the risk is high.

No method of transmission or storage is completely secure. We work hard to protect your information but cannot guarantee absolute security. If you suspect unauthorized access to your account or a security issue in our Services, contact security@genieai.ca immediately. We operate a responsible disclosure process and will not pursue good faith security research conducted within its terms.

10. International transfers and data residency

Genie AI is based in Canada. Personal information we collect may be stored and processed in Canada, the United States, and other jurisdictions where we or our sub processors operate. Those jurisdictions may have data protection laws that differ from those where you live, and information located there may be accessible to local courts, law enforcement and national security authorities under the laws of that jurisdiction.

We take the following steps to protect information that crosses borders.

• We contractually require every recipient to provide a comparable level of protection to the one required in the originating jurisdiction, and we remain accountable for information transferred to a third party for processing.

• For transfers from the EEA we rely on the European Commission's Standard Contractual Clauses, and we complete transfer impact assessments and apply supplementary measures where the assessment indicates they are needed.

• For transfers from the United Kingdom we rely on the UK International Data Transfer Addendum or the IDTA, as applicable.

• For transfers out of Quebec we conduct the privacy impact assessment required by Law 25 before the transfer, and confirm the information will receive adequate protection.

Data residency options are available for enterprise and government deployments, including Canadian region hosting for Canadian public sector workloads. Residency commitments are made in the customer agreement, not by this policy. Contact privacy@genieai.ca to confirm what is available for a specific deployment.

11. Retention

We keep personal information only as long as it is needed for the purposes it was collected for, or as long as required by law, contract, or the resolution of a dispute. When the retention period ends we delete the information, or irreversibly de identify or anonymize it. Our default schedule follows. Customer agreements may specify shorter or longer periods, and where they do, they prevail.

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Information Default retention

--------------------------- ------------------------------------------- Customer Content in BOS For the term of the agreement. On termination, available for export for 30 days, then deleted from production within 90 days.

Account and profile data For the term of the agreement, plus 12 months, unless earlier deletion is requested.

Prompt and output logs 12 months, configurable down to 30 days for enterprise and government deployments.

Billing, invoicing and tax 7 years from the end of the relevant fiscal records year, to meet Canadian tax and corporate record requirements.

Support tickets and 24 months from closure. correspondence

Security, audit and access 12 to 24 months, depending on system and logs regulatory requirement.

Website analytics data 14 months.

Marketing contacts Until consent is withdrawn, or after 24 months of no engagement, whichever comes first. Unsubscribe records are kept indefinitely so we do not contact you again.

Recruitment records 12 months after the competition closes, or longer with the candidate's consent.

Encrypted backups Rolling 35 days, after which deleted records age out. Deletion requests are applied to production immediately and to backups as they cycle. -----------------------------------------------------------------------

12. Your rights

Subject to the exceptions in section 12.3, you can exercise the following rights over personal information we hold about you as a controller.

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Right What it means

---------------- ------------------------------------------------------ Access Obtain confirmation that we hold personal information about you, a copy of it, and an account of the parties to whom, and the circumstances in which, it has been disclosed.

Correction Have inaccurate or incomplete information corrected or completed. If we decline, we annotate the record to show a correction was requested and not made.

Deletion Have information deleted where it is no longer needed, where consent is withdrawn and no other basis applies, or where required by law.

Portability Receive computerized personal information you provided to us in a structured, commonly used technological format, and have it transmitted to another organization where technically feasible.

Withdraw consent Withdraw consent at any time, on reasonable notice, subject to legal and contractual restrictions.

Object and Object to processing based on legitimate interests, or restrict ask us to restrict processing while a dispute about accuracy or legal basis is resolved.

De indexing Ask us to cease disseminating information, or de index a link, where dissemination contravenes the law or a court order, or causes serious injury to reputation or privacy.

Human review Ask for human review of, and an explanation of the factors behind, a decision based exclusively on automated processing.

Non Exercise your rights without being denied service, discrimination charged a different price, or given a lower quality of service.

Complain Lodge a complaint with your privacy regulator. Our response will tell you which one and how to reach it. -----------------------------------------------------------------------

12.1 How to make a request

Send your request to privacy@genieai.ca with the subject line Privacy Request. Include enough detail for us to locate the information and verify your identity. We may ask for proof of identity proportionate to the sensitivity of the information requested, and we use that proof only to verify the request. An authorized agent may act for you with written authorization and proof of their own identity.

12.2 How we respond

• We acknowledge requests promptly and respond no later than 30 days from receipt, or within any different period required by applicable law.

• We may extend the period where the law allows, and where we do we will tell you before the original deadline and explain why.

• Access requests are answered free of charge, except that minimal cost recovery may apply where permitted by applicable privacy legislation, and we will tell you the estimated cost before proceeding.

• Where we correct information, and it is reasonable to do so, we notify third parties to whom we disclosed the incorrect information.

12.3 When we may refuse

We may withhold information, in whole or in part, where the law permits or requires it, including where:

• the information is subject to solicitor client or litigation privilege;

• disclosure would reveal confidential commercial information;

• disclosure could reasonably be expected to threaten the life, safety, or physical or mental health of another individual;

• the information was generated in a formal dispute resolution process;

• the information relates to another identifiable individual and cannot be severed;

• the information was collected without knowledge or consent for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province, or in the course of a lawful investigation.

If we refuse, we will tell you the reasons, the provision of the applicable legislation we rely on, how to reach the Privacy Officer to discuss it, and how to ask for a review by the relevant regulator.

13. Regional addenda

The following terms supplement this policy for individuals in the identified regions. Where an addendum conflicts with the main body, the addendum prevails for those individuals.

13.1 Canada

We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act, Quebec's Law 25 and the Act respecting the protection of personal information in the private sector, and the substantially similar provincial legislation of Alberta and British Columbia.

• Accountability. We have designated a Privacy Officer who is accountable for our compliance and reachable at privacy@genieai.ca.

• Quebec. Privacy settings for any product feature that collects personal information are set to the highest level of confidentiality by default. We conduct privacy impact assessments for projects involving the acquisition, development or overhaul of information systems handling personal information, and before communicating personal information outside Quebec.

• Commercial electronic messages. We comply with Canada's Anti Spam Legislation. Every commercial message identifies us, gives our contact information, and includes a working unsubscribe mechanism that we action within 10 business days.

• Complaints. You may complain to the Office of the Privacy Commissioner of Canada at priv.gc.ca, or to the Commission d'acces a l'information du Quebec, the Office of the Information and Privacy Commissioner of Alberta, or the Office of the Information and Privacy Commissioner for British Columbia, as applicable. We ask that you contact us first so we can try to resolve it directly.

13.2 European Economic Area, United Kingdom and Switzerland

• Controller. GENIE AI, Inc. is the controller for the processing described in this policy, except where we act as a processor for a customer.

• Legal bases. Our legal bases are set out in the table in section 4. Where we rely on legitimate interests, we have carried out a balancing assessment and will provide a summary on request.

• Transfers. We rely on Standard Contractual Clauses, the UK Addendum or the IDTA, and supplementary measures identified by transfer impact assessment. A copy of the relevant safeguards is available on request.

• Rights. In addition to the rights in section 12, you have the right to lodge a complaint with your local supervisory authority, including the Information Commissioner's Office in the United Kingdom and the Federal Data Protection and Information Commissioner in Switzerland.

• Representative. Our representative under Article 27 of the GDPR and the UK GDPR, where required, is identified at genieai.io/legal.

13.3 United States

This section applies to residents of California, Colorado, Connecticut, Virginia, Utah, Texas and other states with comprehensive privacy legislation, to the extent that legislation applies to us.

• Sale and sharing. We have not sold personal information, and we have not shared it for cross context behavioural advertising or targeted advertising, in the preceding 12 months. We do not sell or share the personal information of minors.

• Categories. The categories of personal information we collect, the sources, the purposes, and the categories of recipients are described in sections 3, 4 and 8. We disclose personal information to sub processors for business purposes only.

• Sensitive personal information. We do not use or disclose sensitive personal information for purposes other than those permitted without a right to limit, including providing the Services, security, and legal compliance.

• Rights. California, Colorado, Connecticut and Virginia residents may request to know, access, correct, delete, obtain a portable copy, opt out of targeted advertising, profiling and sale, and appeal a refusal. To appeal, reply to our decision with the subject line Privacy Appeal, and we will respond within the period your state's law requires and tell you how to contact your Attorney General.

• Shine the Light. California residents may request information about disclosures of personal information to third parties for their own direct marketing purposes. We make no such disclosures.

14. Third party links and integrations

Our Services link to and integrate with third party sites, platforms and applications, including social media, identity providers and business tools that customers connect to BOS. When you follow a link or authorize an integration, that third party collects and handles information under its own privacy policy and security practices. We do not control those practices. Review them before connecting anything, and be aware that social media plug ins can connect your browser directly to the provider's servers when the page loads.

15. Changes to this policy

We may update this policy as our Services, our legal obligations, or our practices change. The date at the top shows when it was last revised. If a change materially affects your rights, we will provide notice by posting it prominently on our website, by email, or both, before it takes effect. Continued use of the Services after a change takes effect means you accept it. We maintain prior versions and will provide one on request.

16. Contact us

Direct any question, concern, access request or complaint to our Privacy Officer. We take every complaint seriously, investigate it, and respond in writing with the outcome and the steps you can take if you remain unsatisfied.

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Reason Contact

--------------------------- ------------------------------------------- Privacy questions, requests privacy@genieai.ca, attention Privacy and complaints Officer

Security issues and security@genieai.ca vulnerability reports

General customer service hello@genieai.io

Mail GENIE AI, Inc., attention Privacy Officer, Suite 400, 77 King Street West, Toronto, Ontario M5K 2A1, Canada -----------------------------------------------------------------------

GENIE AI, Inc. Federally incorporated in Canada under the Canada Business Corporations Act. This policy is published in English. Une version francaise est disponible sur demande.

Master terms governing the BOS platform, websites and services

Version 1.0

Effective August 8, 2026

Applies to genieai.io, runbos.ai, BOS, BOS Studio, and all Genie AI products, agents and APIs

Contact legal@genieai.ca

Read these Terms carefully. They include a limitation of liability, a disclaimer of warranties, and provisions governing how disputes are resolved. By creating an account, accessing the Services, or signing an Order Form that references these Terms, you agree to be bound by them.

1. Agreement and acceptance

These Terms of Use (the "Terms") form a binding agreement between GENIE AI, Inc., a corporation incorporated federally in Canada under the Canada Business Corporations Act ("Genie AI", "we", "us", "our"), and the individual or entity accessing the Services ("you", "Customer").

You accept these Terms by creating an account, accessing or using the Services, signing an Order Form that references them, or clicking to accept. If you accept on behalf of an entity, you represent that you have authority to bind that entity, and "you" means that entity. You must be of the age of majority in your jurisdiction and legally capable of entering into a contract.

1.1 Order of precedence

Where documents conflict, the following order applies, from highest to lowest:

• A signed Master Services Agreement or enterprise agreement between the parties.

• The applicable Order Form, statement of work or Quote.

• The Data Processing Addendum and any Security Addendum.

• These Terms.

• The Privacy Policy, Data Policy, Acceptable Use Policy and other policies referenced here, which are incorporated by reference.

These Terms do not modify a signed enterprise agreement. Where no signed agreement exists, these Terms govern in full.

2. Definitions

• Services means BOS and the Business Orchestration System, BOS Studio, BOS Chat, iWork, Project Fx, Agent Mesh, the Orchestration Engine, the Knowledge Graph, vertical solutions including AvatarOS, CommerceOS, AutoOS and Acredex, together with our websites, APIs, agents, documentation, support and related offerings.

• Customer Content means data, documents, records, prompts, files, workflows, configurations and other material that you or your Users submit to, connect to, or generate within the Services.

• Output means content generated by the Services in response to Customer Content, including agent responses, drafts, summaries, classifications, code, plans and actions.

• User means an individual authorized by you to access the Services under your account, including your employees, contractors and agents.

• Order Form means the ordering document, quote, online checkout or subscription record that identifies the plan, licence scope, term and fees.

• Service Data means account, configuration, telemetry, log, diagnostic, security and usage information generated by operating the Services.

• Documentation means the technical and user documentation we make generally available for the Services.

3. The Services

BOS is an AI native platform that orchestrates people and AI agents to run business operations. We provide the Services on a subscription basis in accordance with the Order Form, these Terms and the Documentation.

We may add, modify, deprecate or remove features. Where a change materially reduces the core functionality you subscribed to, we will provide at least 30 days notice, and if the change materially and adversely affects you, you may terminate the affected subscription and receive a pro rata refund of prepaid fees for the unused remainder of the term. Beta, preview and pilot features are excluded from this commitment.

3.1 Licence model

Unless the Order Form states otherwise, BOS is licensed per business rather than per seat. A licence entitles a single legal entity to use the Services for its own internal business operations, for the number of workspaces, environments, agents, workflows, actions or volume limits stated in the Order Form. A licence may not be shared across affiliates, resold, sublicensed, or used to provide services to third parties, except as expressly permitted in the Order Form.

4. Accounts, workspaces and administrators

• You are responsible for the accuracy of your account information and for keeping it current.

• You are responsible for all activity under your account and for your Users' compliance with these Terms. Acts and omissions of your Users are treated as your own.

• You must safeguard credentials, enable multi factor authentication where offered, and notify security@genieai.ca promptly on suspected unauthorized access.

• Administrators you designate can provision and deprovision Users, configure agents and workflows, set retention and approval controls, access Customer Content within their workspace, and export or delete data. You are responsible for who you appoint and what they configure.

• Where your workspace is created under an employer or other organization's domain or subscription, that organization controls the workspace and may assume administrative control of your account.

• Credentials may not be shared, sold, or transferred, and automated account creation is prohibited.

5. Licence and permitted use

Subject to your compliance with these Terms and payment of applicable fees, we grant you a non exclusive, non transferable, non sublicensable, revocable right during the term to access and use the Services for your internal business purposes, within the scope on your Order Form.

You may not, and may not permit anyone else to:

• copy, modify, translate, or create derivative works of the Services;

• reverse engineer, decompile, disassemble, or attempt to derive source code, model weights, prompts, orchestration logic or architecture, except to the extent that restriction is prohibited by law;

• resell, rent, lease, timeshare, or operate the Services as a service bureau for third parties;

• use the Services, Outputs, or benchmark results to build, train or improve a competing product or model, or to publish a benchmark or comparative analysis without our prior written consent;

• scrape, crawl, or use automated means to extract data or Outputs at volume, or circumvent rate limits, quotas or access controls;

• remove, obscure or alter proprietary notices;

• probe, scan or test the vulnerability of the Services except under our published responsible disclosure programme;

• introduce malware, or interfere with the integrity, performance or availability of the Services or the data of any other customer.

6. Acceptable use

You must not use the Services, and must not permit your Users to use them, to:

• break any law, regulation, court order or third party right, including privacy, publicity, intellectual property and contract rights;

• upload content you do not have the right to upload, or personal information you have no lawful basis to process;

• generate or distribute unlawful, defamatory, harassing, hateful, or deceptive content, or content that sexualizes minors;

• impersonate a person or organization, or misrepresent Output as human authored where disclosure is legally required;

• conduct unlawful surveillance, infer sensitive characteristics for discriminatory purposes, or perform biometric identification of individuals without a lawful basis;

• make consequential decisions about individuals, including credit, employment, housing, insurance, education, immigration status, or access to essential services, based solely on automated processing without meaningful human review;

• send unsolicited commercial messages in breach of Canada's Anti Spam Legislation or equivalent law;

• operate safety critical systems, including medical devices, life support, emergency response, aviation, or nuclear facilities, where failure of the Services could cause death, personal injury, or severe environmental damage;

• submit protected health information, payment card data, government classified information, or biometric identifiers, unless we have agreed in writing to support that category and the appropriate addendum is in place.

> If you become aware of a violation on your account, stop it and tell > us at abuse@genieai.ca. We may investigate suspected violations and > may suspend access under section 16.2.

7. Customer Content

7.1 Ownership

As between the parties, you own and retain all right, title and interest in Customer Content. We claim no ownership of it.

7.2 Licence to us

You grant us a worldwide, non exclusive, royalty free licence to host, copy, transmit, display, index, embed, process and otherwise use Customer Content solely to provide, secure, maintain and support the Services for you, to comply with law, and as otherwise permitted in the Data Policy. This licence ends when the Customer Content is deleted, except for copies retained in backups until they cycle out and copies we are required by law to retain.

7.3 Your responsibility

You are solely responsible for Customer Content, for its accuracy, quality and legality, and for having all rights, consents, notices and lawful bases needed for us to process it as contemplated by these Terms. You are responsible for determining whether the Services are appropriate for your data and your regulatory environment, and for configuring retention, approvals and access controls accordingly.

7.4 Backup

We maintain backups as described in the Data Policy, but you remain responsible for maintaining your own copies of Customer Content that is important to you. We are not a system of record for your statutory retention obligations unless the Order Form says otherwise.

8. AI features, agents and outputs

8.1 Ownership of Outputs

As between the parties, and subject to your payment of fees and compliance with these Terms, you own the Outputs generated for you. We assign to you whatever rights we may have in those Outputs. Because generative systems produce similar responses to similar inputs, Outputs are not unique, similar or identical Output may be generated for other customers, and we retain the right to produce and use such Output. Outputs may not be protectable by copyright in some jurisdictions.

8.2 Accuracy

Outputs are probabilistic. They can be incomplete, out of date, biased or factually wrong, and they may describe actions that were not taken or facts that do not exist. Outputs are decision support and not professional advice, and they are not a substitute for legal, financial, tax, medical, engineering, or other qualified judgement. You must evaluate Outputs for accuracy and suitability before relying on them or acting on them.

8.3 Autonomous action

BOS can be configured to take actions in connected systems, including sending messages, creating records, moving work, and calling third party APIs. You control that configuration. You are responsible for the scope of permissions you grant to agents, for the approval gates and human in the loop checkpoints you set, and for the consequences of actions taken within the permissions you configured. We recommend least privilege scoping, staged rollout, and human approval for any action that is irreversible, financially material, externally visible, or legally significant.

8.4 Model providers and training

• We do not use Customer Content to train, fine tune or improve foundation models for other customers or for general model development.

• We contractually require our AI model sub processors not to train on Customer Content submitted through the Services, and we use zero retention or limited retention configurations where the provider offers them.

• We may use Service Data, and aggregated or irreversibly de identified data, to measure quality, tune orchestration logic and improve the Services.

Full detail on how data moves through the platform, including logging, indexing, embeddings and agent memory, is set out in the Data Policy.

9. Third party services and integrations

The Services connect to third party products, including cloud platforms, model providers, communication tools, commerce platforms and business systems. When you enable an integration, you authorize us to access and exchange Customer Content with that third party as needed to operate the integration, and you authorize that exchange under your agreement with the third party.

Third party services are governed by their own terms and privacy policies. We do not control them, we do not warrant them, and we are not responsible for their acts, omissions, availability, pricing changes, or handling of your data. If a third party changes or discontinues its service, we may need to modify or discontinue the related feature, and that will not by itself be a breach of these Terms.

10. Fees, billing and taxes

• Fees, currency, billing frequency and licence scope are set out in the Order Form or on the published pricing page for self serve plans.

• Fees are payable in advance and, except as expressly stated in these Terms, are non refundable and non cancellable. Payment of fees is not contingent on delivery of future features.

• Invoiced amounts are due within 30 days of the invoice date unless the Order Form states otherwise. Self serve subscriptions are charged to your payment method on each renewal date.

• Overdue amounts accrue interest at 1.5 percent per month, or the maximum permitted by law if lower, and you are responsible for reasonable costs of collection.

• If any amount is more than 15 days overdue, we may suspend the Services after giving you at least 10 days written notice.

• Fees exclude taxes. You are responsible for all sales, use, value added, GST, HST, QST, withholding and similar taxes, other than taxes on our net income. Where you are exempt, provide a valid exemption certificate.

• Subscriptions renew automatically for successive terms equal to the prior term unless either party gives written notice of non renewal at least 30 days before the end of the current term.

• We may change pricing effective on renewal, on at least 45 days notice before the renewal date.

• Usage above the limits on your Order Form may be billed at the overage rate stated there, or may require an upgrade. We will notify you before applying material overage charges where reasonably practicable.

11. Trials, betas and pilots

We may offer free trials, pilots, proofs of concept, and beta, preview or early access features. These are provided as is and as available, without any warranty, service level, support commitment, or indemnity, and may be modified, suspended or discontinued at any time. Our aggregate liability arising from free or beta access is limited to one hundred Canadian dollars.

Do not use beta features for production workloads or with sensitive data. Beta features may be subject to additional terms, and information about them is our Confidential Information.

Unless the Order Form states otherwise, trial data may be deleted at the end of the trial period, and we will give you a reasonable opportunity to export it first.

12. Intellectual property and feedback

We and our licensors own all right, title and interest in the Services, including the underlying software, models we develop, orchestration logic, architecture, user interfaces, Documentation, and all improvements to them, together with all associated intellectual property rights. No rights are granted other than the limited licence in section 5. All rights not expressly granted are reserved.

If you give us feedback, ideas, or suggestions, you grant us a perpetual, irrevocable, worldwide, royalty free licence to use them without restriction or obligation to you. We will not identify you as the source without your consent.

We may use Service Data, and aggregated or de identified data derived from your use, to operate, secure, analyze and improve the Services, and to produce statistics and benchmarks, provided that we do not identify you or your Users, and do not disclose Customer Content.

12.1 Publicity

We may identify you as a customer and use your name and logo on our website, in investor materials and in sales materials, in accordance with any brand guidelines you provide. You may withdraw that permission at any time by writing to legal@genieai.ca, and we will stop using your marks in new materials within 30 days. Case studies, quotes and detailed descriptions of your deployment require your prior written approval.

13. Confidentiality

"Confidential Information" means non public information disclosed by one party to the other that is designated confidential or that a reasonable person would understand to be confidential. Customer Content is your Confidential Information. The Services, pricing, roadmap, architecture, security documentation and beta features are ours.

The receiving party will use the same degree of care it uses for its own confidential information, and no less than reasonable care, will use Confidential Information only to perform under these Terms, and will limit access to personnel and advisors who need it and are bound by confidentiality obligations at least as protective.

Confidential Information does not include information that is or becomes public through no fault of the recipient, was rightfully known without restriction before disclosure, is rightfully received from a third party without restriction, or is independently developed without use of the disclosing party's Confidential Information.

A party may disclose Confidential Information where legally compelled, provided it gives prompt notice where lawful and reasonably cooperates in seeking protective treatment. These obligations survive for three years after termination, and indefinitely for trade secrets and Customer Content.

14. Privacy and data protection

Our handling of personal information is described in the Genie AI Privacy Policy, and the operational detail of how data moves through the platform is set out in the Genie AI Data Policy. Both are incorporated into these Terms by reference.

Where we process personal information on your behalf, you are the controller and we are the processor, and our Data Processing Addendum applies. The DPA governs in the event of a conflict with these Terms in respect of personal information. Enterprise, regulated and public sector customers should execute the DPA before submitting personal information to the Services.

15. Support, availability and changes to the Services

Support scope, response targets and any service level commitment are set out in your Order Form or the applicable support and service level documentation. Self serve plans receive commercially reasonable support through published channels, without a service level commitment.

We aim for high availability but do not warrant uninterrupted or error free operation. Scheduled maintenance, emergency maintenance, third party outages, force majeure events and suspensions permitted under these Terms are excluded from any availability measurement.

16. Term, suspension and termination

16.1 Term

These Terms begin when you first accept them and continue until all subscriptions have expired or been terminated.

16.2 Suspension

We may suspend your access, in whole or in part, immediately and without liability where we reasonably determine that: your use poses a security risk to the Services or to another party; your use may harm our systems or subject us to liability; your use violates section 6; your account is more than 15 days overdue after the notice in section 10; or suspension is required by law. We will give notice where practicable, limit the suspension to what is necessary, and restore access promptly once the cause is resolved.

16.3 Termination

• Either party may terminate for material breach on 30 days written notice if the breach is not cured within that period.

• Either party may terminate immediately if the other becomes insolvent, makes an assignment for the benefit of creditors, or has a receiver or trustee appointed.

• You may stop using the Services at any time, but termination for convenience does not entitle you to a refund of prepaid fees except where these Terms expressly provide one.

• We may terminate a free or self serve account on 30 days notice.

16.4 Effect of termination

On termination, your right to access the Services ends and all outstanding fees become immediately due. You may export Customer Content for 30 days after termination using the available export tools. After that period we will delete Customer Content from production systems within 90 days, and from backups as they cycle, in accordance with the Data Policy, unless retention is required by law. Sections 2, 7.1, 8.1, 8.2, 10, 12, 13, 17, 18, 19, 21 and 22 survive termination.

17. Warranties and disclaimers

We warrant that the Services will perform materially in accordance with the Documentation during the term, and that we will provide them with reasonable skill and care. Your exclusive remedy for breach of this warranty is that we will use commercially reasonable efforts to correct the non conformity, and if we cannot do so within a reasonable time, you may terminate the affected subscription and receive a pro rata refund of prepaid fees for the unused remainder of the term.

Each party warrants that it has the authority to enter into these Terms and will comply with laws applicable to its performance.

> Except as expressly stated in this section, the Services, Outputs > and all related materials are provided on an as is and as available > basis, without warranty of any kind.

To the maximum extent permitted by law, we disclaim all other warranties, express, implied, statutory or otherwise, including implied warranties of merchantability, fitness for a particular purpose, title, non infringement, quiet enjoyment, accuracy, and any warranty arising from course of dealing or usage of trade. We do not warrant that the Services will be uninterrupted, secure, or error free, that defects will be corrected, that Outputs will be accurate, complete, current, lawful or fit for your purpose, or that the Services will meet your requirements or produce any particular business result. Some jurisdictions do not allow the exclusion of certain warranties, so parts of this section may not apply to you.

18. Indemnification

18.1 By Genie AI

We will defend you against any third party claim alleging that the Services, when used in accordance with these Terms and the Documentation, infringe that third party's Canadian, United States or European Union patent, copyright or trade mark rights, and we will pay damages finally awarded or amounts we agree in settlement. This obligation does not apply to claims arising from Customer Content, Outputs, your use in breach of these Terms, combination of the Services with anything not provided by us where the claim would not have arisen otherwise, modifications not made by us, use of a superseded version after we provided a replacement, beta or free features, or third party services.

If the Services become, or we believe may become, the subject of an infringement claim, we may at our option procure the right to continue use, replace or modify the Services to make them non infringing, or terminate the affected subscription and refund prepaid fees for the unused remainder of the term. This section states our entire liability and your exclusive remedy for intellectual property infringement.

18.2 By you

You will defend us against any third party claim arising from Customer Content, your Outputs and how you use them, your breach of section 6, your violation of law or third party rights, or your failure to obtain required consents, and you will pay damages finally awarded or amounts you agree in settlement.

18.3 Process

The indemnified party must promptly notify the indemnifying party of the claim, give it sole control of the defence and settlement, and provide reasonable cooperation at the indemnifying party's expense. No settlement that admits liability or imposes obligations on the indemnified party may be made without its consent, not to be unreasonably withheld. Late notice reduces the indemnity only to the extent of resulting prejudice.

19. Limitation of liability

To the maximum extent permitted by law, and except for the Excluded Claims below:

• neither party is liable for indirect, incidental, special, consequential, exemplary or punitive damages, or for loss of profits, revenue, goodwill, anticipated savings, business opportunity, or for loss or corruption of data, even if advised of the possibility;

• each party's total aggregate liability arising out of or related to these Terms will not exceed the fees you paid or owed to us for the Services in the 12 months immediately preceding the event giving rise to the claim, or one hundred Canadian dollars where no fees were paid.

"Excluded Claims" means your payment obligations, either party's indemnification obligations under section 18, breach of section 13, your breach of sections 5 or 6, and liability that cannot be limited or excluded by law, including fraud, fraudulent misrepresentation, death or personal injury caused by negligence, and any liability under applicable consumer protection legislation that cannot be waived.

You acknowledge that Outputs are probabilistic and that you are responsible for reviewing them and configuring appropriate human oversight. We are not liable for decisions made, or actions taken by configured agents within permissions you granted, in reliance on Outputs. These limitations apply regardless of the theory of liability and survive any failure of essential purpose of a limited remedy. The allocation of risk in this section is a fundamental basis of the bargain and is reflected in our pricing.

20. Compliance, export controls and public sector customers

• Each party will comply with applicable anti bribery, anti corruption, anti money laundering and sanctions laws, including the Corruption of Foreign Public Officials Act and, where applicable, the United States Foreign Corrupt Practices Act.

• You will comply with all applicable export control and sanctions laws of Canada, the United States, the European Union and other relevant jurisdictions. You represent that you are not located in, ordinarily resident in, or controlled by a party in a comprehensively sanctioned jurisdiction, and that you are not on any restricted party list. You will not export, re export or make the Services available in breach of those laws, and will not use them for any prohibited end use, including in connection with weapons of mass destruction.

• Public sector customers. Where you are a Canadian federal, provincial or municipal public body, additional terms may be required, including data residency, records management, access to information and privacy obligations, security screening, audit rights and procurement terms. Those terms will be set out in the applicable contract, which prevails over these Terms to the extent of any conflict.

• Regulated customers. If you are subject to sector specific regulation, including financial services, health or critical infrastructure requirements, you are responsible for determining whether the Services meet those requirements, and for putting any required addendum in place before use.

21. Governing law and dispute resolution

These Terms are governed by the laws of the Province of Ontario and the federal laws of Canada applicable in that province, without regard to conflict of laws rules. The United Nations Convention on Contracts for the International Sale of Goods does not apply.

The parties will first attempt to resolve any dispute through good faith discussion between senior representatives for 30 days after written notice of the dispute.

If the dispute is not resolved, the parties irrevocably submit to the exclusive jurisdiction of the courts of the Province of Ontario, sitting in Toronto, and waive any objection based on venue or forum non conveniens. Nothing in this section prevents either party from seeking injunctive or equitable relief in any court of competent jurisdiction to protect its intellectual property or Confidential Information.

Disputes are resolved on an individual basis. To the maximum extent permitted by law, each party waives any right to bring or participate in a class, collective or representative proceeding. Nothing in these Terms limits any non waivable right you may have under the consumer protection laws of your province or country.

22. General provisions

• Changes to these Terms. We may update these Terms. For material changes we will give at least 30 days notice by email or in product notice, and the change takes effect on your next renewal, or on the stated effective date for self serve plans. Continued use after the effective date means you accept the change. If you do not accept a material change, your remedy is to stop using the Services and terminate before it takes effect.

• Assignment. Neither party may assign these Terms without the other's written consent, except that either party may assign to an affiliate or in connection with a merger, reorganization, or sale of all or substantially all of its assets, on written notice. Any other attempted assignment is void.

• Force majeure. Neither party is liable for delay or failure caused by events beyond its reasonable control, including natural disasters, war, terrorism, civil unrest, labour disruption, epidemic, government action, internet or utility failure, and failures of third party providers, excluding payment obligations.

• Notices. Notices to us go to legal@genieai.ca and to GENIE AI, Inc., attention Legal, Suite 400, 77 King Street West, Toronto, Ontario M5K 2A1, Canada. Notices to you go to the administrative contact and billing email on your account, or through in product notice. Notice is effective on receipt, or on the next business day for email.

• Severability. If a provision is held unenforceable, it is modified to the minimum extent needed to make it enforceable, or severed, and the rest remains in effect.

• No waiver. Failure to enforce a provision is not a waiver of it.

• Independent contractors. The parties are independent contractors. Nothing creates a partnership, joint venture, agency or employment relationship.

• No third party beneficiaries. These Terms create no rights for anyone other than the parties and their permitted assigns.

• Entire agreement. These Terms, the Order Form, and the policies incorporated by reference are the entire agreement on their subject matter, and supersede prior proposals and understandings. Terms in a purchase order or vendor portal have no effect.

• Language. The parties have requested that these Terms and all related documents be drawn up in English. Les parties ont demande que ces conditions et tous les documents connexes soient rediges en anglais.

23. Contact

-----------------------------------------------------------------------

Reason Contact

--------------------------- ------------------------------------------- Contracts, legal notices legal@genieai.ca and these Terms

Privacy requests and privacy@genieai.ca, attention Privacy complaints Officer

Security issues and security@genieai.ca vulnerability reports

Abuse and acceptable use abuse@genieai.ca reports

General customer service hello@genieai.io

Mail GENIE AI, Inc., attention Legal, Suite 400, 77 King Street West, Toronto, Ontario M5K 2A1, Canada -----------------------------------------------------------------------

GENIE AI, Inc. Federally incorporated in Canada under the Canada Business Corporations Act. Version 1.0, effective August 8, 2026.

How data moves through BOS: classification, AI handling, residency, retention and control

Version 1.0

Effective August 8, 2026

Applies to BOS, BOS Studio, agents, APIs and all Genie AI products

Audience Customers, security reviewers, privacy officers and procurement teams

Contact privacy@genieai.ca

This Data Policy is the operational companion to the Genie AI Privacy Policy and Terms of Use. The Privacy Policy explains our obligations to individuals. This document explains, at a system level, what data BOS holds, where it goes, who can reach it, how long it stays, and what you control. It is incorporated into the Terms of Use by reference.

1. Purpose and scope

Genie AI builds BOS, an AI native platform that orchestrates people and AI agents to run business operations. Because agents read, generate and act on customer data, we publish this policy so customers can evaluate the platform without a discovery call.

This policy applies to all Genie AI products, environments and APIs. It describes our default posture. Enterprise, regulated and public sector agreements may set stricter terms, and where they do, the agreement prevails.

1.1 How this fits with our other documents

-----------------------------------------------------------------------

Document What it answers

------------------------ ---------------------------------------------- Privacy Policy What personal information we handle, why, and what rights individuals have.

Terms of Use The commercial and legal relationship, licence scope, liability and acceptable use.

Data Policy (this How data physically and logically moves document) through the platform, and what you control.

Data Processing Addendum The binding controller to processor terms, including transfer mechanisms and audit rights.

Security Addendum and Control detail, certifications, penetration Trust Centre test summaries and architecture diagrams, available under NDA. -----------------------------------------------------------------------

2. Data classification

We classify everything the platform touches into five categories. The category determines how the data is handled, who can access it, and how long it is kept.

------------------------------------------------------------------------

Class What it is Examples

-------------- --------------------------- ----------------------------- Customer Data you submit, connect or Documents, records, prompts, Content generate inside your files, workflow definitions, workspace. connected system data, agent outputs.

Account Data Information identifying you Names, business emails, and your users, and roles, workspace administering your configuration, billing subscription. contacts, licence entitlements.

Service Data Machine generated data Event logs, agent invocation produced by operating the records, latency and error platform. telemetry, API metadata, audit trails, security logs.

Derived Data Data computed from Customer Embeddings, vector indexes, Content to make the Knowledge Graph nodes and platform work. edges, classifications, summaries, agent memory.

Genie AI Data Our own material. Platform code, orchestration logic, prompt libraries, models we develop, documentation, aggregate statistics. ------------------------------------------------------------------------

> Derived Data is the class most often missed in vendor reviews. It is > generated from your content, it is treated as your Confidential > Information, it lives inside your tenant, and it is deleted when the > source content is deleted.

3. Ownership and rights

------------------------------------------------------------------------

Class Who owns it What Genie AI may do with it

-------------- ----------------------- --------------------------------- Customer You. Host, process and index it solely Content to provide, secure and support the Services for you, on your instructions.

Derived Data You, as an extension of Use it inside your tenant to Customer Content. power retrieval, orchestration and agent behaviour. Not used for other customers.

Account Data You provide it. We act Provision access, bill, support, as controller for communicate, and meet legal administering the obligations. relationship.

Service Data Genie AI. Operate, secure, troubleshoot, measure and improve the Services. May be aggregated. Not disclosed in a form that identifies you or exposes Customer Content.

Genie AI Data Genie AI. All rights reserved. Licensed to you only as set out in the Terms of Use. ------------------------------------------------------------------------

4. Data lifecycle

Every piece of Customer Content follows the same path. You control the entry point, the configuration, and the exit.

------------------------------------------------------------------------

Stage What happens What you control

------------ --------------------------------- ------------------------- Ingestion Content enters through upload, Which sources are direct entry, API, or an connected, which scopes integration you authorize. It is are granted, and what is encrypted in transit and written uploaded. to your tenant.

Indexing Content may be chunked, embedded Which repositories and and written to a vector index and workspaces are indexed, to the Knowledge Graph so agents and whether indexing is can retrieve it. enabled per source.

Processing Agents read relevant content, Agent scope, tool call a model, and produce an permissions, model Output. Relevant context is selection where offered, assembled per request, not sent and redaction rules. in bulk.

Action Where configured, an agent writes Approval gates, human in back to a connected system or the loop checkpoints, and notifies a person. least privilege scoping of every connector.

Logging The request, decision path and Log retention window, and outcome are recorded for audit, whether prompt and output debugging and abuse detection. bodies are retained or only metadata.

Retention Content and Derived Data persist Workspace and source until deleted by you, or until level retention settings, the retention period ends. and manual deletion at any time.

Deletion Deletion removes the record, its When to delete, and embeddings, its index entries and whether to export first. its graph nodes from production, then ages out of backups. ------------------------------------------------------------------------

5. How data moves through the BOS architecture

BOS is built from six nodes. Each handles data differently, so we describe them separately.

-----------------------------------------------------------------------

Node Data handling

---------------- ------------------------------------------------------ iWork Holds work items, tasks, assignments and status. Stores Customer Content and Account Data. Visible to workspace members according to their role.

BOS Chat Conversational interface. Prompts and responses are Customer Content. Conversation history is scoped to the user and workspace, and is subject to the retention window you set.

Project Fx Project and execution structures, plans, dependencies and artefacts. Stores Customer Content.

Agent Mesh Runs agents. Assembles only the context needed for each request, calls the selected model, and records the invocation. Agents operate within the tool permissions you grant, and cannot reach outside your tenant.

Orchestration Routes work between people and agents. Holds routing Engine rules, approval gates, and execution state. Generates Service Data.

Knowledge Graph Stores entities, relationships and embeddings derived from your content. Derived Data, scoped to your tenant, deleted when the source is deleted. -----------------------------------------------------------------------

Vertical solutions built on BOS, including AvatarOS, CommerceOS, AutoOS and Acredex, inherit this model. Where a vertical introduces an additional data flow, for example commerce order data or generated media assets, it is documented in that product's supplementary data sheet.

6. AI and model data handling

This is the section most security reviews focus on, so we state the position plainly.

6.1 What we commit to

• We do not use Customer Content or Derived Data to train, fine tune or improve foundation models for the benefit of other customers or for general model development.

• We contractually require every AI model sub processor not to train on data submitted through the Services, and we use zero retention or limited retention configurations where the provider offers them.

• Customer Content is never used to build features for, or shown to, another customer.

• Derived Data, including embeddings and Knowledge Graph structures, stays inside your tenant and is never pooled across customers.

• Where a customer wants a dedicated model trained on its own data, that is a separate, written, opt in arrangement, and it is revocable.

6.2 What is sent to a model provider

For each agent invocation we send only the assembled context needed for that request, which typically includes the user's instruction, retrieved excerpts from your content, relevant workspace configuration, and tool definitions. We do not send your full corpus, your user directory, or your billing information. Where redaction or field masking is configured, it is applied before the request leaves our systems.

6.3 What we log

------------------------------------------------------------------------

Record Default **Configurable

retention** --------------------------- ------------------ ------------------------- Prompt and output bodies 12 months Yes, down to 30 days, or metadata only, for enterprise and government deployments.

Invocation metadata (agent, 12 to 24 months Partially, subject to model, timestamp, latency, audit and security token counts, outcome) requirements.

Tool and action audit trail 24 months Extendable where records management rules require it.

Abuse and safety signals 12 months No, retained for platform integrity. ------------------------------------------------------------------------

6.4 Agent memory

Agents can retain memory across sessions where you enable it. Memory is Derived Data, scoped to the workspace or user you assign it to, visible to workspace administrators, editable and deletable at any time, and removed when the workspace is deleted. Memory is off by default for new workspaces in regulated configurations.

6.5 Human review

We do not routinely read Customer Content. Limited human review of specific records occurs only in the circumstances described in section 8, and every instance is logged.

7. Access control and tenant isolation

• Each customer's Customer Content and Derived Data are logically isolated. Every query, retrieval and agent invocation is scoped to a tenant identifier enforced at the data access layer, not only in the application layer.

• Access inside a workspace follows role based access control. Administrators define roles, and permissions are enforced consistently across the interface, the API and agent retrieval, so an agent cannot surface content a requesting user is not entitled to see.

• Single sign on through SAML or OIDC, and SCIM provisioning and deprovisioning, are available so that access follows your identity provider and revocation is immediate.

• Multi factor authentication is available for all accounts and is mandatory for administrative roles in enterprise configurations.

• Connector permissions are scoped per integration. We request the narrowest scope that supports the configured workflow, and we recommend dedicated service accounts rather than personal credentials.

• Dedicated or single tenant deployment is available for customers whose requirements do not permit shared infrastructure. Terms are set in the Order Form.

8. Genie AI personnel access

Our personnel do not have routine access to Customer Content. Access is possible only in the four circumstances below, is granted on a least privilege and time limited basis, and is logged with the actor, the reason, the scope and the duration.

• You request support and authorize access to investigate a specific issue.

• An urgent production incident cannot be diagnosed any other way. This is a break glass path requiring approval by two authorized individuals, and it triggers a notification to your administrators.

• We are legally compelled to access specific data. We assess every demand for validity and scope, and notify the affected customer unless prohibited by law.

• We are investigating a credible report of abuse, fraud or a security threat affecting the platform or another customer.

All personnel are subject to confidentiality agreements, background screening where permitted by law, mandatory privacy and security training at onboarding and annually, and immediate access revocation on role change or departure. Enterprise customers can request access logs relating to their tenant.

9. Data location and residency

Genie AI is a Canadian company. By default, Customer Content is stored in Canadian or United States cloud regions, and processing may occur in either. Some sub processors, including certain model providers and analytics tools, process data in the United States or the European Union.

• Canadian residency is available for enterprise and public sector deployments, so that Customer Content is stored and, where the model provider supports it, processed in Canadian regions.

• Residency commitments are contractual. They are made in the Order Form or Data Processing Addendum, not by this document, and they are confirmed in writing before onboarding.

• Cross border transfers are protected by contractual safeguards, including Standard Contractual Clauses for the EEA, the UK Addendum or IDTA, and, for transfers out of Quebec, the privacy impact assessment Law 25 requires.

• Data stored in a jurisdiction may be subject to lawful access by that jurisdiction's authorities. Our response to any such demand follows section 8 and the Privacy Policy.

10. Sub processors

We publish the current list of sub processors, including function and processing region, at genieai.io/subprocessors. Every sub processor is subject to security and privacy due diligence before engagement and periodically afterwards, and is bound by written terms that restrict processing to our instructions, impose confidentiality and security obligations at least as protective as ours, and prohibit independent use of Customer Content.

Enterprise and public sector customers can subscribe to advance notice of new sub processors and, where their agreement provides, object on reasonable data protection grounds. We remain accountable for our sub processors' performance.

11. Security controls

The full control set is described in the Privacy Policy and the Security Addendum. In summary:

• Encryption in transit using TLS 1.2 or higher, and at rest using AES 256 or equivalent.

• Least privilege access, mandatory multi factor authentication for internal systems, and centralized identity management.

• Secure development lifecycle with code review, dependency and secret scanning, static analysis and change management.

• Independent penetration testing, continuous vulnerability scanning, and tracked remediation by severity.

• Centralized logging, monitoring and alerting across production, with tamper resistant audit trails.

• Documented incident response, business continuity and disaster recovery plans, tested periodically.

Certification and attestation status, architecture diagrams and test summaries are available under NDA. Contact security@genieai.ca.

12. Retention and deletion

Default retention periods are set out in the Privacy Policy and summarized below. Customer agreements may set shorter or longer periods and prevail where they do.

-----------------------------------------------------------------------

Data Default retention

--------------------------- ------------------------------------------- Customer Content For the term. On termination, exportable for 30 days, then deleted from production within 90 days.

Derived Data (embeddings, Deleted together with the source content, graph nodes, agent memory) or when the workspace is deleted.

Prompt and output logs 12 months, configurable down to 30 days.

Account Data Term plus 12 months, unless earlier deletion is requested.

Security, audit and access 12 to 24 months. logs

Billing and tax records 7 years, to meet Canadian tax and corporate record requirements.

Backups Rolling 35 days. -----------------------------------------------------------------------

12.1 How deletion works

• Deleting a record in the interface or by API removes it from production, and removes its embeddings, index entries and Knowledge Graph nodes.

• Deletion is applied to production immediately and propagates to replicas within 24 hours.

• Backups are encrypted and immutable within their retention window, so deleted records age out of backups over the rolling 35 day cycle rather than being surgically removed. We do not restore deleted records from backup except as part of a documented disaster recovery event.

• We retain data past a deletion request only where the law requires it, or where it is needed to resolve a dispute, prevent fraud, or enforce our agreements. Where we do, we tell you why and for how long.

• Certified deletion confirmation is available on request for enterprise and public sector customers.

13. Backups and disaster recovery

• Encrypted backups are taken on a regular schedule and retained on a rolling 35 day cycle.

• Backups are stored in the same residency boundary as the primary data.

• Recovery point and recovery time objectives are defined in our continuity plan and, where committed, in the Order Form.

• Restoration procedures are tested periodically, and results are available to enterprise customers under NDA.

• Backups are for our disaster recovery, not a customer facing archive service. Maintain your own copies of anything you are required to retain.

14. Portability and export

You can export your data at any time during the term, and for 30 days after termination, using the export tools available in the product and through the API. Exports are provided in structured, commonly used, machine readable formats. Where an export requires engineering assistance, we will provide reasonable help and will tell you in advance if a fee applies. We do not hold your data hostage as a commercial lever, and export availability is not contingent on the reason for termination, subject only to payment of undisputed amounts already due.

15. De identification and aggregation

We use aggregated and irreversibly de identified data to measure quality, tune orchestration, benchmark performance and improve the Services. When we de identify data we maintain technical and organizational measures to keep it de identified, we do not attempt to re identify it, and we contractually prohibit recipients from doing so. Aggregate statistics we publish never identify a customer, a user, or the content of any workspace.

16. Incident handling

• We maintain a documented incident response plan with severity levels, escalation paths, defined roles and post incident review.

• Where we act as processor, we notify affected customers without undue delay after becoming aware of a security incident affecting their data, and provide the information needed for their own notification obligations.

• Where we act as controller and an incident creates a real risk of significant harm, we notify the Office of the Privacy Commissioner of Canada, the Commission d'acces a l'information du Quebec where applicable, and affected individuals as soon as feasible.

• Where the GDPR or UK GDPR applies, we notify the competent supervisory authority within 72 hours of becoming aware unless the incident is unlikely to result in risk.

• We provide a written post incident report covering what happened, what data was involved, containment steps and remediation.

• We operate a responsible disclosure programme and do not pursue good faith security research conducted within its terms. Report to security@genieai.ca.

17. Data you must not submit

Unless we have agreed in writing to support the category and the appropriate addendum is in place, do not submit to the Services:

• protected health information subject to HIPAA or equivalent health privacy legislation;

• payment card data subject to PCI DSS, including primary account numbers and card verification values;

• government classified or security marked information above the level we have agreed to support;

• biometric identifiers, or genetic data;

• information about children, or any personal information you have no lawful basis to process;

• credentials, private keys or secrets, other than through the supported secrets management path.

If sensitive data is submitted by mistake, delete it from the workspace and contact privacy@genieai.ca so we can help confirm removal from indexes and logs.

18. Customer responsibilities

Platform controls only work when they are configured. You are responsible for:

• determining that the Services are appropriate for your data, your sector and your regulatory environment;

• having the lawful basis, notices and consents needed for the personal information you place into BOS, and responding to requests from your own individuals;

• configuring roles, retention windows, redaction, approval gates and human review appropriate to the sensitivity and consequence of each workflow;

• scoping connector and agent permissions to the minimum needed, and using dedicated service accounts;

• reviewing Outputs before relying on them, particularly for decisions that are irreversible, financially material, externally visible, or legally significant;

• managing your own users, including timely deprovisioning;

• maintaining independent copies of anything you are required to retain.

19. Audit, assurance and transparency

• Documentation. Security documentation, architecture diagrams, penetration test summaries and current certification status are available under NDA.

• Questionnaires. We complete customer security and privacy questionnaires as part of procurement.

• Audit rights. Enterprise and public sector customers may exercise audit rights as set out in the Data Processing Addendum, ordinarily satisfied by our documentation and third party reports, with on site or bespoke audit available where the agreement provides for it.

• Sub processor notice. Advance notice of new sub processors is available on subscription.

• Government demands. We assess every demand for validity and scope, disclose only what is legally required, and notify the affected customer unless prohibited.

20. Changes and contact

We update this policy as the platform and our obligations evolve. Material changes that reduce protections will be notified to customers at least 30 days before they take effect, and prior versions are available on request.

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Reason Contact

--------------------------- ------------------------------------------- Data handling questions and privacy@genieai.ca, attention Privacy privacy requests Officer

Security documentation, security@genieai.ca questionnaires and vulnerability reports

Contracts, DPA and audit legal@genieai.ca requests

General customer service hello@genieai.io

Mail GENIE AI, Inc., attention Privacy Officer, Suite 400, 77 King Street West, Toronto, Ontario M5K 2A1, Canada -----------------------------------------------------------------------

GENIE AI, Inc. Federally incorporated in Canada under the Canada Business Corporations Act. Version 1.0, effective August 8, 2026. Read with the Genie AI Privacy Policy and Terms of Use.