BROKER AGENTX INC.

This Privacy Policy (“Policy”) describes how Broker Agentx Inc., a corporation incorporated under the laws of Ontario, Canada (“Company,” “we,” “us,” or “our”), collects, uses, discloses, and safeguards personal information in connection with the Broker Agentx platform and all associated services (collectively, the “Service”).

This Policy is incorporated by reference into our Terms and Conditions of Service. By accessing or using the Service, you consent to the practices described in this Policy. If you do not agree with this Policy, you must not access or use the Service.

The Company complies with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

1. Information We Collect

1.1 Information You Provide

We collect personal information that you provide directly when you:

• Register an Account — name, email address, company name, and any other details submitted during sign-up.
• Use the Service — data, documents, files, or information you upload or enter into the platform (“User Content”), including client-related data you input for AI-assisted workflows.
• Contact us — messages, support requests, or feedback submitted to support@brokeragentx.com or through in-app forms.
• Make a payment — billing information processed by our third-party payment processor, Stripe, Inc. We do not store payment card data on our own systems.

1.2 Information Collected Automatically

When you access the Service, we may automatically collect:

• Usage data — pages visited, features used, session duration, and interaction logs.
• Device and browser data — IP address, browser type and version, operating system, and device identifiers.
• Session data — authentication tokens and session identifiers stored in secure, server-side sessions backed by our database.
• Log data — server-side logs recording requests, errors, and system events for operational and security purposes.

1.3 Information from Third Parties

We may receive limited information from third-party services integrated with your Account (for example, authentication or workflow automation services) solely as necessary to deliver the Service.

2. How We Use Your Information

We use the personal information we collect to:

• Create, authenticate, and manage your Account.
• Provide, operate, maintain, and improve the Service.
• Process User Content through AI-powered features to generate outputs on your behalf.
• Send transactional communications — account confirmations, billing receipts, service notices, and security alerts.
• Respond to support inquiries and provide customer assistance.
• Detect, investigate, and prevent fraudulent, unauthorized, or unlawful activity.
• Comply with applicable legal obligations and respond to lawful requests from regulatory or law enforcement authorities.
• Analyze aggregated, de-identified usage data to understand how the Service is used and to improve its functionality.

We do not sell your personal information. We do not use your User Content to train AI models.

3. Disclosure of Your Information

3.1 Service Providers

We engage trusted third-party service providers to help operate the Service. These providers may process personal information on our behalf and are contractually obligated to use it only as directed by us and to maintain appropriate security standards. Key categories of service providers include:

• Cloud infrastructure and hosting — for servers, databases, and file storage.
• Third-party AI model providers — User Content submitted to the Service may be processed by large language model providers (such as OpenAI) to deliver AI-powered features. Under our current service agreements, User Content is not used by these providers to train foundation models. Details of sub-processors are available upon written request.
• Payment processing — Stripe, Inc. processes payment transactions. Their privacy practices are governed by Stripe’s own privacy policy.
• Email and communication services — for delivering transactional and support emails.
• Workflow automation — third-party automation tools may handle certain data routing tasks as part of Service delivery.

3.2 Business Transfers

In the event of a merger, amalgamation, acquisition, financing, reorganization, or sale of all or substantially all of the Company’s assets, your personal information may be transferred as part of that transaction. We will provide notice through the Service or by email if your personal information becomes subject to a materially different privacy policy as a result of such a transfer.

3.3 Legal Requirements

We may disclose personal information if required to do so by applicable law, court order, or lawful request from a regulatory or government authority, or where we believe in good faith that disclosure is necessary to protect the safety of any person, investigate fraud, or enforce our Terms of Service.

3.4 With Your Consent

We may share personal information with third parties in any other circumstances where we have obtained your explicit consent.

4. Data Retention

We retain personal information for as long as your Account is active or as necessary to provide the Service, comply with our legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Account data is retained for the duration of your Subscription and for a reasonable period thereafter to comply with legal obligations.
• User Content is retained for thirty (30) days following Account termination or Subscription expiry, after which it may be permanently deleted.
• Log and usage data may be retained for up to twelve (12) months for security and operational purposes.

You may request deletion of your personal information at any time by contacting us at support@brokeragentx.com. We will action deletion requests subject to any overriding legal retention obligations.

5. Data Security

The Company implements reasonable technical and organizational security measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, or loss. These measures include encrypted data transmission (TLS), server-side session management, role-based access controls, and secure credential storage.

No method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your Account credentials and should notify us immediately at support@brokeragentx.com if you suspect any unauthorized access to your Account.

6. Cookies and Tracking

The Service uses session cookies that are strictly necessary for authentication and to maintain your logged-in state across requests. These cookies are server-issued, HTTP-only, and do not persist beyond your active session unless you choose to remain logged in.

We do not currently use advertising, analytics, or tracking cookies from third parties. If this changes, we will update this Policy and, where required by law, seek your consent.

7. Your Privacy Rights

Subject to applicable law, you have the following rights with respect to your personal information:

• Access — you may request a copy of the personal information we hold about you.
• Correction — you may request that we correct inaccurate or incomplete personal information.
• Deletion — you may request deletion of your personal information, subject to legal retention obligations.
• Withdrawal of Consent — where our processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Complaint — you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) or a relevant provincial privacy commissioner if you believe your privacy rights have been violated.

To exercise any of these rights, please contact our Privacy Officer at support@brokeragentx.com. We will respond to verified requests within thirty (30) days, or notify you if additional time is required.

8. Children’s Privacy

The Service is intended for commercial use by adults aged 18 and over who are licensed insurance professionals. We do not knowingly collect personal information from individuals under the age of 18. If you believe we have inadvertently collected such information, please contact us immediately so that we can delete it.

9. International Data Transfers

The Service is operated from Canada. If you access the Service from outside Canada, your personal information may be transferred to and processed in Canada, where data protection laws may differ from those in your jurisdiction. By using the Service, you consent to such transfer. Where required, we take steps to ensure that cross-border transfers comply with applicable privacy law.

User Content processed by third-party AI providers may be transmitted to servers located in the United States. These transfers occur under data processing agreements that impose appropriate safeguards.

10. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated by email to the address on file and/or by a notice within the Service no less than fourteen (14) days before taking effect. Your continued use of the Service after the effective date of any change constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact our Privacy Officer:

Broker Agentx Inc.
Redfern Avenue, Hamilton, Ontario, Canada
Email: support@brokeragentx.com
Website: www.brokeragentx.com

— End of Privacy Policy —

Broker Agentx Inc. • Hamilton, Ontario, Canada • www.brokeragentx.com