California Privacy Policy (CCPA)

This California Privacy Policy describes how Lyon Innovations, LLC ("AtListen," "Company," "we," or "us") collect and process personal information about our consumers who reside in California. The California Consumer Privacy Act ("CCPA") requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.

This Privacy Policy does not apply to our collection and use of personal information from residents outside of California. Consumers residing in other locations should see our general privacy policy.

Personal Information Collected

We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). Personal information does not include:

• Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
• Lawfully obtained, truthful information that is a matter of public concern.
• Deidentified or aggregated consumer information.

Personal Information Categories Chart

The chart below identifies the categories of personal information we collected from our consumers within the last 12 months.

Sensitive Personal Information Categories Chart

Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.

The chart below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last 12 months.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you, such as from the forms or other information you provide to the Company.
• Indirectly from you, such as from your interactions with the Company's websites, mobile applications, or social media platforms.
• From our service providers, such as customer service support providers, data analytics providers, and advertising networks.
• Inferences generated by the Company's or our service providers' computer systems.

How We Use Personal Information

Personal Information Collection, Use, and Disclosure Purposes

We may use and disclose the personal information we collect to advance the Company's business and commercial purposes, specifically to:

• Develop, offer, and provide you with our products and services, including AI-powered tools for creating study materials, including summaries, flashcards, and other educational content based on user-submitted materials.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.
• Fulfil the purposes for which you provided your personal information or that were described to you at collection, and as the CCPA otherwise permits.
• Improve our products or services, marketing, or customer relationships and experiences.
• Notify you about changes to our products or services.
• Administer our systems and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Enable your participation in our websites' or mobile apps' interactive, social media, or other similar features.
• Protect our Company, employees, or operations.
• Make suggestions and recommendations to you and other consumers about our goods or services that may interest you or them.
• Manage your consumer relationship with us, including for online account creation, maintenance, and security; and reaching you, when needed, about your account.
• Perform data analytics and benchmarking.
• Administer and maintain the Company's systems and operations, including for safety purposes.
• Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.
• Comply with all applicable laws and regulations.
• Exercise or defend the legal rights of the Company and its employees and customers.
• Respond to law enforcement requests and as required by applicable law or court order.

Sensitive Personal Information Use and Disclosure Purposes

We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):

• Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.
• Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
• Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.
• Ensuring physical safety.
• Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not disclose the sensitive personal information to another third party; or use it to build a profile about you or otherwise alter your experience outside your current interaction with the Company.
• Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
• Activities required to verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.
• Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

We do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes.

Additional Categories or Other Purposes

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

Disclosing, Selling, or Sharing Personal Information

Business Purpose Disclosures

We may disclose the personal information we collect, including sensitive personal information, to service providers and contractors for the business purposes described in the Personal Information Collection, Use, and Disclosure Purposes section and in the list below, such as to support our business functions. For example, we may disclose information from your visits to the Company's website to service providers that host and maintain our platform, process data on our behalf, provide analytics services, support our artificial intelligence functionality, or assist with security and fraud prevention.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA's other contract requirements for engaging service providers or contractors.

The list below identifies the personal information categories we disclosed to service providers or contractors for a business purpose over the preceding 12 months and the specific business or commercial purpose for disclosing that information.

Business Purposes Disclosure Personal Information Category and Purposes List

• Identifiers (such as name, email address, IP address) to service providers for account management, platform functionality, and security.
• Internet or other electronic network activity information (such as usage data) to service providers for analytics, performance monitoring, and improvement of our services.
• Audio, electronic, or similar information (such as recordings or user-submitted content) to service providers to provide and improve our AI-powered services.
• Inferences drawn from personal information to support personalization and functionality of the platform.

Selling or Sharing Personal Information

We do not sell your personal information to third parties and have not sold it in the preceding 12 months. We do not share your personal information with third parties for cross-context behavioral advertising purposes and have not shared your personal information in the preceding 12 months.

Our personal information sales and sharing does not include information about consumers we know are under age 16.

Your Rights and Choices

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the "right to know"), including the specific pieces of personal information we have collected about you (a "data portability request"). Our response will cover the 12-month period preceding the request, although we will honor requests to cover longer periods that do not extend past January 1, 2026, unless doing so would be impossible or involves disproportionate effort. You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:

• The categories of personal information we collected about you; and sources from which we collected your personal information.
• The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
• If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we disclosed for a business purpose to each category of persons; and sold or shared to each category of third parties.
• When your right to know submission includes a data portability request, a copy of your personal information, subject to any permitted redactions.

For more on exercising this right, see Exercising the Rights to Know, Delete, or Correct.

Right to Delete and Right to Correct

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the "right to delete"). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers to take appropriate action.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the "right to correct"). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.

For more on exercising these rights, see Exercising the Rights to Know, Delete, or Correct.

Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA's Permitted SPI Purposes (the "right to limit"). As we do not use or disclose sensitive personal information beyond the CCPA's Permitted SPI Purposes, we do not currently provide this consumer right. For more on exercising this right, see Exercising the Right to Limit, or Opt-Out.

For more on the Permitted SPI Purposes, see Sensitive Personal Information Use and Disclosure Purposes.

Personal Information Sales or Sharing Opt-Out and Opt-In Rights

You have the right to request that businesses stop sharing your personal information at any time (the "right to opt-out"), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer's parent or guardian for consumers under age 13 (the "right to opt-in").

We cannot share your personal information after we receive your request to opt-out unless you later consent to the sharing of your personal information. For more on exercising your opt-out rights, see Exercising the Right to Limit, or Opt-Out.

Right to Non-Discrimination

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

How to Exercise Your Rights

Exercising the Rights to Know, Delete, or Correct

To exercise the right to know (including data portability), delete, or correct described above, please submit a verifiable request to us by either:

• Calling us at [PHONE NUMBER].
• Emailing us at hello@atlisten.com.
• Visiting AtListen.com.

Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know, including for data portability, twice in a 12-month period.

Exercising the Right to Limit, or Opt-Out

You can submit your request to limit or opt-out through:

• An interactive form accessible via the "Do Not Sell or Share my Personal Information" form.
• Emailing hello@atlisten.com.
• Calling [PHONE NUMBER].

You can also submit your request to opt-out of personal information sales and sharing through an opt-out preference signal.

Verification Process and Authorized Agents

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your personal information. If your minor child is our consumer, you may also make a verifiable request on their behalf. To designate an authorized agent, you must provide the agent with written permission to submit a request on your behalf, and we may require you to verify your identity directly with us. We may also require the authorized agent to provide proof of their authorization. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your personal information.

We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. We will only use personal information provided in the request to verify the requestor's identity or authority to make the request.

We consider requests made through your password-protected account with our company sufficiently verified when the request relates to personal information associated with that specific account.

For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer's name, email address, or account username.

Responding to Your Requests to Know, Delete, or Correct

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the ten-day timeframe, please contact hello@atlisten.com.

We endeavor to substantively respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address or password-protected account, if applicable. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period preceding the request's receipt date. We will consider requests to provide longer disclosure periods that do not extend past January 1, 2026, unless providing the longer timeframe would be impossible or involves disproportionate effort.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Response and Timing on Rights to Limit or Opt-Out

In response to your request to limit or opt-out, we will process your request, as soon as feasibly possible, but no later than fifteen (15) business days from the date we receive the request. We will only use personal information provided from your request to comply with the request.

We will also notify our service providers, contractors, and certain other downstream recipients of your request to limit or opt-out and instruct them to both:

• Comply with your request.
• Forward the request to their own downstream recipients, if applicable.

We may deny opt-out requests if we have a good-faith, reasonable, and documented belief that the request is fraudulent and will clearly explain our denial decision to the requestor.

Once you make a request to limit or opt-out, we will wait at least twelve (12) months before asking you to reauthorize personal information sales or sharing. However, you may change your mind and opt back in at any time via the opt-in link.

Privacy Policy Changes

We reserve the right to update this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will update the policy's effective date and post the updated policy on our website. We encourage you to check our website to review the current Privacy Policy in effect.

Contact Information

If you have any questions or comments about this policy, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: [PHONE NUMBER]
Website: AtListen.com
Email: hello@atlisten.com

If you need to access this Privacy Policy in an alternative format due to a disability, please contact hello@atlisten.com.