Qbit Privacy Policy

Welcome!

Qbit is the best AI-powered search engine and personal assistant in the world. We created Qbit to make your life easier, to help with great search results and various tasks. Qbit is cute, fun and here to help!

This Privacy Policy describes how MyQbit LLC ("Qbit", "we", "us," "our") collects, uses and discloses information about the people who use our Services, as defined in our Terms of Service. For the purposes of this Privacy Policy, we are the data controller, and "you" and "your" means you as the user of the Services.

Please read this Privacy Policy carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access the Services.

1. Changes to This Privacy Policy

We may modify this Privacy Policy from time to time, in which case we will update the "Updated" date at the top of this Privacy Policy.

2. Collection and Use of Your Information

When you use or access the Services, we collect certain categories of information about you from a variety of sources.

Information You Provide to Us:

Some features of the Services may ask you to provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing some features. Information that you directly submit through our Services includes:

• Basic contact details, such as name, address, phone number, and email ("Contact Information"). We use this information where necessary to perform our contract with you to provide the Services, and to communicate with you (including, with your consent where required, to tell you about certain promotions or products or services that may be of interest to you).
• Account information, such as name, username, email and password ("Account Information"). We use this information where necessary to perform our contract with you to provide the Services and to maintain and secure your account with us. If you choose to register an account, you are responsible for keeping your account credentials safe. You should not share your access details with anyone else.
• Payment information, such as credit or debit card information and billing address, which we collect using a third party payment processor ("Payment Information"). We use this information where necessary to perform our contract with you to process your payment to provide the associated Services.
• Your Input and associated Output, such as questions, prompts and other of your Content that you input, upload or submit to the Services, and the Output created thereby, and any collections or pages that you generate using the Services ("Service Interaction Information"). Service Interaction Information may constitute or contain personal information, depending on the substance and how it is associated with your account. We use this information where necessary to perform our contract with you to generate Output.

Information Collected Automatically:

We and certain third parties also automatically collect certain information about your interaction with the Services ("Usage Data") through the use of cookies, pixels, tags and other tracking technologies ("Tracking Technologies"). Usage Data includes:

• Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.
• Location information, such as approximate location.
• Other information regarding your interaction with the Services, such as browser type, log data, date and time stamps, clickstream data, interactions with marketing emails, and ad impressions.

We use Usage Data in our legitimate interests to tailor features and content to you, run analytics and measure and better understand user interaction with the Services, and we may permit third parties to use Usage Data for such purposes. For more information on how we use Tracking Technologies and your choices, see the section below, Cookies and Other Tracking Technologies.

Information Collected From Other Sources:

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. Such information includes:

• Analytics Information — analytics data we receive from analytics providers such as Google Analytics, which we use in our legitimate interests to understand your interaction with, and improve, our Services.
• Advertising Information — information we receive from consumer marketing databases or other data enrichment companies, which we use in our legitimate interests to better customize advertising and marketing to you.
• Partner Information — information we receive from business partners and other companies that we partner with to provide you with free or discounted access to the Services or other offers or promotions, which we use in our legitimate interests to provide you with free or discounted access to the Services.
• Third Party Platform Information — information we receive when you choose to link any third-party platforms to your account, such as if you sign into your account through Google or Apple, or when you voluntarily link one or more of your health and wellness applications (such as HealthKit or myFitnessPal) to Qbit. We use this information only where necessary to perform our contract with you, to maintain your account and login information and to provide you with the Services, including to generate Output.
• Public Information — information from publicly accessible sources, such as information that's publicly available online (like articles, websites, and journals) or from other public sources, which we use at our discretion.

In addition to the specific uses described above, we may use most of the above information to provide you with and improve the Services (including our AI technology) and to maintain our business relationships, including but not limited to enhancing the safety and security of our Services (e.g., troubleshooting, data analysis, testing, system maintenance, and reporting), providing customer support, sending service and other non-marketing communications, monitoring and analyzing trends, and conducting internal research and development. We may also use the information to comply with applicable legal obligations, enforce any applicable terms of service, and protect the Services, our rights, and the rights of our employees, users or other individuals.

You may also have the ability to sync your third party email account or calendar (such as Gmail and Google Calendar) with the Services. If you choose to sync these accounts, we will have access to your contacts and information from the email messages and calendar appointments in your email account, including the content of your emails (together, "Email Service Information"). Notwithstanding anything else in this Privacy Policy, we only use and disclose Email Service Information to provide the Services or as otherwise required by applicable law, and we do not use or disclose Email Service Information to create, train, improve or fine-tune AI models. If you sync your Google account with the Services, we only use and disclose information from your Google account in accordance with the Google API Services User Data Policy, including the Limited Use requirements.

Finally, we may, in our legitimate interests, deidentify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you ("Deidentified Information") (or we may collect information that has already been deidentified/anonymized), and we may use such Deidentified Information for any purpose. To the extent we possess or process any deidentified information, we will maintain and use such information in deidentified/anonymized form and not attempt to reidentify the information, except solely for the purpose of determining whether our deidentification/anonymization process satisfies legal requirements.

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party's policies or practices. For more information, see the section below, Third Party Websites and Links. To the extent the laws in your jurisdiction do not recognize the legal basis of legitimate interest or another legal basis specified above for a particular purpose, you consent to the processing of your personal information for that purpose through using the Services.

Phone Numbers and SMS Communications:

If you choose to enable SMS (text message) alerts or to verify your phone number for sign-in purposes, we collect the mobile phone number you provide and the records associated with messages we send to that number (such as delivery status and the time the message was sent).

We use your phone number for the following purposes only:

• to send you alerts when our content-screening systems flag a message in your child's chat for review;
• to send you one-time verification codes that confirm your phone number or sign you into your account;
• to provide customer support related to the SMS program.

We do not share, sell, or otherwise disclose your mobile phone number or the contents of SMS messages to third parties for their own marketing purposes. Your mobile information is shared only with our SMS delivery provider (currently Twilio) strictly for the purpose of transmitting messages to you, and with our service providers under written contracts that prohibit them from using your information for any other purpose.

We retain your phone number for as long as your account is active, and for a reasonable period thereafter for legal compliance and recordkeeping. You may opt out of SMS messages at any time by replying STOP to any text message from us, or by turning off SMS alerts in your Qbit account settings. Opting out of marketing or alert SMS does not opt you out of receiving verification codes you request yourself.

Message frequency varies. Message and data rates may apply. Carriers are not liable for delayed or undelivered messages.

3. Cookies and Other Tracking Technologies

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser or limit cross-site tracking; however, blocking or deleting cookies may cause some of the Services, including certain features and general functionality, to work incorrectly. If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

Your browser settings may allow you to transmit a 'do not track' signal. Like many websites, our App is not designed to respond to such signals. To learn more about 'do not track' signals, you can visit http://www.allaboutdnt.com/.

4. Disclosure of Your Information

We may disclose your information to third parties subject to this Privacy Policy, including the following categories of third parties:

• Company Entities: Includes affiliates or others within our corporate network, in accordance with our contract with you, and for internal administration or support purposes, in our legitimate interest to run a successful business and in order to provide our Services.
• Service Providers: Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, generative AI and content creation, LLMs, security, customer transaction facilitation and relationship management, marketing communications, web analytics, payment networks, and payment processing.
• Business Partners: Third parties through whom you receive access to our Services, including via use of a promotion code or other method provided by such business partners, in our legitimate interest to provide you with free or discounted access to our Services.
• Other Third Parties, including other users: Third parties to whom you request or direct us to disclose information, such as through your use of social media widgets or login integrations, when you purchase third-party goods through the Services, send an email or interact with your third party email or calendar account through the Services, or otherwise choose to share or make output or other information visible to others, including other users. We do this as necessary for the performance of a contract, or in our legitimate interest to provide you with access to the Services and integrations with third parties, or with your consent.
• Advertising Partners: Third parties who display advertising information on our Services or otherwise assist with the delivery of ads.
• Professional Advisors: As necessary, we will share your personal information with professional advisors such as auditors, law firms, or accounting firms.
• Business Transactions: We will share personal information with a prospective investor, buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to an investment or a change of corporate control such as a restructuring, merger, asset sale or purchase, bankruptcy or other business transaction or re-organization. We do this in our legitimate interest to run a successful and compliant business, and as required by applicable law.

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users. We do this in our legitimate interest to protect our Service and business and to comply with applicable law.

5. Social Features

Certain features of the Services may allow you to initiate interactions between the Services and third-party services or platforms such as Icon.app and other social networks ("Social Features"). Social Features include features that allow you to access our pages on third-party platforms, and from there 'like' or 'share' our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. For more information, see the section below, Third Party Websites and Links.

6. Third Party Websites and Links

We may provide links to third-party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy policy, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

7. Children's Privacy

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children, particularly those under 13 years of age. For users above the age of 13 but below the age where you are able to consent to the processing of your personal information, please obtain your parent or guardian's consent prior to using the Services.

If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a child under the relevant minimum age who has provided us with their personal information, you may contact us at support@qbit.app to request that it be deleted.

8. Data Security and Retention

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee "perfect security." Any information you send to us while using the Services or otherwise interacting with us may not be secure while in transit or in storage. We recommend that you consider this before sending us sensitive or confidential information, and acting accordingly.

We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Policy. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products.

9. U.S. Residents

This section supplements the other sections of this Privacy Policy and applies to you only if you are a resident of California or another U.S. state that has passed a privacy law similar to the California Consumer Privacy Act ("CCPA") that applies to us, and the law requires specific privacy notice disclosures. For purposes of this section, references to "personal information" shall include "sensitive personal information," as these terms are defined under the CCPA.

Processing of Personal Information:

In the preceding 12 months, we collected and disclosed for a business purpose the following categories of personal information:

The specific business or commercial purposes for which we have collected and disclosed your personal information and the categories of sources from which we collect your personal information are described in the section above, Collection and Use Your Information. The third parties that we have disclosed your information to are described in Section 4 (Disclosure of Your Information) above. The criteria we use to determine how long to retain your personal information is described in the section above, Data Security and Retention.

Non-Health Sensitive Information Disclosure:

We may collect the following types of sensitive information when you interact with our Services. Note that we do not use such data for any purposes that are not identified within Cal. Civ. Code § 1798.121.

• When you create or log-in to your account, your account log-in and password (as defined under California law).
• If you choose to submit sensitive information as part of a Service Interaction, we will receive such information. For example, if you were to submit government identifiers, precise geolocation, racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership, contents of mail, email, or text messages, genetic data, neural data, or data concerning sex life or sexual orientation, then we would receive those categories of information.

Health Sensitive Information Disclosure (Consumer Health Data Privacy Notice):

We may collect the following types of health-related sensitive information when you interact with our Services. Note that we do not use such data for any purposes that are not identified within Cal. Civ. Code § 1798.121. We also do not "sell" or "share" sensitive personal information for cross-context behavioral advertising.

• When you upload Content related to your health, genetic, and biometric information.
• If you submit Content that includes health-related sensitive information as part of a Service Interaction, we will receive such information. For example, if you choose to provide to us through the Services health-related data, or data concerning sex life or sexual orientation, then we obviously receive that information.

See Section 11 to exercise your rights concerning health-related data. Your health information may be shared in the following ways, in addition to those described elsewhere in this policy: with service providers that help us provide requested services, Apps/services that you connect to Qbit Health, third party AI models that help us provide requested services.

Selling and/or Sharing of Personal Information:

We do not "sell" (as defined under the CCPA) personal information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we "sell" or "share" personal information of residents under 16 years of age.

10. Data Transfers

The personal information that we collect may be transferred to, stored at/processed in, or accessed from countries outside the jurisdiction in which you are based in, for the purposes described in this Privacy Policy, including countries in which our service providers or other third parties described in Section 4 are located. We also have globally located support, engineering and other teams, including the United States.

We process the personal information that you provide to us when creating an account and using our Services in countries outside the relevant jurisdiction you are resident in in order to perform our contract with you (to provide you with our Services). By using the Services and acknowledging the Privacy Policy, you acknowledge and, if necessary in your jurisdiction, consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, to the jurisdictions specified herein. For such transfers of data outside the relevant jurisdiction will use applicable safeguards, for example, for UK and EEA users, the European Commission's model contracts for the transfer of personal information to third countries (i.e., the standard contractual clauses) (the "Model Clauses"), or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals' rights and freedoms for their personal information. Please contact us at support@qbit.app should you wish to inquire further as to such data transfer mechanisms, including to examine a copy of the Model Clauses.

For EU and UK users:

We comply with the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce (collectively, the "DPF") and have certified to the U.S. Department of Commerce that we adhere to the DPF Principles with regard to the processing of personal information received from the European Union and UK (and Gibraltar) in reliance on the DPF.

If there is any conflict between the terms in this privacy policy and the DPF Principles, the Principles shall govern to the extent applicable to the information at issue. The Federal Trade Commission has jurisdiction over our compliance with the DPF and, in accordance with the DPF, we are responsible for onward transfers to third parties that process personal information subject to the DPF in a way that does not follow the DPF Principles. To learn more about the Data Privacy Framework program, and to view our certification, please visit the Data Privacy Framework website.

We commit to resolve DPF Principles-related complaints about our collection and use of personal information. Individuals in the EU and UK with inquiries or complaints regarding our compliance with the DPF should first contact us, at support@qbit.app. If you have an unresolved complaint concerning our handling of personal information received in reliance on the DPF that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://www.dataprivacyframework.gov/. Under certain conditions you may be entitled to invoke binding arbitration to resolve your complaint. In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, we commit to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner's Office (ICO) with regard to unresolved complaints concerning our handling of personal information received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

11. Your Rights and Choices

Depending on where you live, you may have some or all of the rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to Access / Know. You may have a right to request access to personal information that we hold about you, or to request information about our collection, use and disclosure of your personal information, such as the categories of personal information we have collected or disclosed for a business purpose.
• Right to Request a List of Third-Party Recipients. You may request a list of specific third parties to which we have disclosed personal information. Some areas also allow you to obtain a list of the categories of third parties to which we have disclosed personal information. You can find that information in the table above under Section 9 (U.S. Residents).
• Right to Delete. You may have a right to request that we delete personal information we maintain about you.
• Right to Correct. You may have a right to request that we correct inaccurate personal information we maintain about you.
• Right of Portability. You may have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party.
• Restriction of Processing. You may have the right to ask us to stop, suspend or restrict our processing of personal information.
• Objection. You may have the right to object to our processing of personal information.
• Opt-out of Website Targeted Advertising. We recognize Global Privacy Control (GPC) signals broadcast from web browsers as a valid opt-out request where required by applicable law. Please note that the GPC will apply only to your current browser. We do not recognize the "Do Not Track Signal."
• Withdrawal of Consent. Where we rely on consent to process your personal information, you may have the right to withdraw this consent at any time by contacting us at support@qbit.app. Please note that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal, and that where you withdraw your consent, we may not be able to deliver the expected service to you.

You may choose to stop receiving personalized advertising or marketing promotions from us when using the Services by contacting us at our email address provided below.

You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address and government issued ID, before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. If we deny your request, you may appeal our decision by contacting us using the information provided below. You may also request to delete your account through the settings page or by contacting us at support@qbit.app. If you delete your account, we aim to promptly delete your personal information from our servers. Please contact us at support@qbit.app to request deletion.

12. Complaints

If you have complaints about how we process your personal information, or if you need to access this Privacy Policy in a different form due to a disability, please ask Qbit to provide it to you or contact us at support@qbit.app and we will respond to your request.

If you think we have infringed data protection laws, you can file a claim with the data protection supervisory authority in the country in which you live or work or where you think we have infringed data protection laws, or with the UK Information Commissioner's Office, or other relevant data protection authority as applicable to you.

13. How to Contact Us

Should you have any questions about our privacy practices or this Privacy Policy, please email us at support@qbit.app.

14. Language

It is expressly agreed that it is the will of both Qbit and you that this Privacy Policy has been drawn up in English.