By accessing our Website or using our Services you are agreeing to the following Privacy Policy.

Effective as of: December 12th, 2026

1. Introduction

(1) Billow Myndbend, Inc. (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy. We are also committed to protecting your privacy in accordance with the principles laid out in the applicable legislation. This policy describes the types of information we may collect from you or that you may provide when you visit our website located at https://www.myndbend.com (“Website”) and use our applications, platform and services, including the Myndbend Approval Intelligence Platform (the “Platform”) (collectively our “Service”) as well as our practices for collecting, using, maintaining, protecting, and disclosing that information. Section 4 describes additional practices that apply only to the Platform. This policy applies to information we collect: (a) while using the Service; and (b) in email, text, and other electronic messages between you and the Company. This policy does not apply to any information collected by: (a) us offline or through any other means, including on any other website or application operated by Company or any third party (including our affiliates or subsidiaries); and (b) any third party, including through any application or content that may link to or be accessible from or in the Services.

(2) Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Service. By accessing or using this Service, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of this Service after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

2. Information We Collect About You and How We Collect It

(1) We may collect several types of information from and about users of our Service, including information: (a) by which you may be personally identified, such as your name, e-mail address, telephone number, credit card, other payment information and billing address (“Personal Information”); (b) that is about you but individually does not identify you; and/or (c) about your internet connection, the equipment you use to access our Service and usage details.

(2) We collect this information: (a) directly from you when you provide it to us; and (b) automatically as you navigate through the Website. Information collected automatically may include usage details, location, IP address, browser type and other information collected through cookies, web beacons, and other tracking technologies.

(3) We may also collect information provided by third parties, including, without limitation, websites or other services that post our advertising materials.

3. Information You Provide to Us

(1) The information we collect on or through our Service may include: (a) information that you provide by filling in forms on our Website, including information provided at the time of registering to use our Website or Service, requesting services or report a problem with our Service; (b) records and copies of your correspondence (including email addresses and voice call details), if you contact us; (c) details of transactions you carry out through our Service, as you may be required to provide financial information; and (d) your response to surveys we may ask you to complete.

(2) We may also receive Personal Information that you provide when you place an order within our Services and the order is processed by another party, such as the payment processor. Such Personal Information may include billing and payment information.

4. Additional Information for the Myndbend Approval Intelligence Platform

(1) This Section 4 describes additional practices that apply to the Platform. It applies only to data processed in the Platform and does not change how we handle information in connection with our Website or our other applications and services.

(2) Customer Data. The Platform is used by businesses (our “Customers”). When a Customer uses the Platform, it may submit or connect data that includes Personal Information about its employees, contractors, end users or other individuals (“Customer Data”). We process Customer Data on behalf of our Customers, in accordance with their instructions and our agreements with them, and the Customer’s own privacy policy governs its practices. If you are an individual whose Personal Information is included in Customer Data, please contact the relevant Customer with any questions or requests regarding that information. We will assist our Customers in responding to such requests as required by our agreements with them and applicable law.

(3) Information Processed in the Platform. Customer Data processed in the Platform may include: approval requests and related information, such as the identity and role of the person making a request; a Customer’s policies, rules and process configurations; decision records, such as who made a decision, the policy that applied, the information shown to the decision-maker and the reasons recorded; information retrieved from or written to the Customer’s connected systems, which may include names, email addresses and roles of the Customer’s personnel and other individuals; and information submitted to and generated by the Platform’s artificial intelligence (“AI”) features. We also collect usage and activity information about the Platform, such as event counts and activity and audit logs.

(4) AI Providers. The Platform uses AI models provided by third-party providers (“AI Providers”). When a Customer uses an AI feature, the relevant Customer Data is sent to an AI Provider as needed to generate the result. Our agreements with AI Providers prohibit them from using Customer Data to train their models. A list of our current AI Providers and other subprocessors is available to Customers upon request.

(5) No Model Training on Customer Data. We do not use Customer Data, including information submitted to or generated by the Platform’s AI features, to train or fine-tune AI models, and we do not use one Customer’s Customer Data to provide services to any other Customer. We may use information about the operation and performance of the Platform, such as feature usage, error rates and usage volumes, to provide, maintain, secure and improve the Platform.

(6) Integrations. Customers may connect the Platform to their other systems. A Customer authorizes each connection directly with the third-party provider using the provider’s authorization process, such as OAuth 2.0. We do not receive or store the passwords for those accounts. We store the access and refresh tokens the provider issues, encrypted at rest with keys managed in a key management service and accessible only to Myndbend’s authorized systems. We request the narrowest permissions the provider offers for the features the Customer uses, and we use tokens only to run the workflows the Customer has configured. A Customer can revoke access at any time through the provider’s settings. Each provider processes data in its own systems under its own terms and privacy policy.

(7) Human Oversight and Decisions About Individuals. Each Customer chooses how much human review applies to its processes on the Platform, from human approval of every AI-assisted step to fully automated operation. Decisions made using the Platform are made by, and are the responsibility of, the Customer. If you have questions about a decision made about you, including any rights you may have regarding automated decision-making under applicable law, please contact the Customer that made the decision.

(8) Subprocessors. We use subprocessors, including AI Providers, to help provide the Platform. Customers may request a copy of our current subprocessor list, and we notify our Customers of changes as provided in our agreements with them. Third-party integration providers that a Customer engages directly are not our subprocessors.

(9) Retention. We retain Customer Data processed in the Platform for as long as needed to provide the Platform to the Customer and as otherwise provided in our agreement with the Customer. After a Customer’s subscription or pilot ends, we make its Customer Data available for export for a limited period and may then delete it, as provided in that agreement.

5. Information We Collect Through Automatic Data Collection Technologies

(1) As you navigate through and interact with our Website or with any of our advertising materials on third party services, we may use automatic data collection technologies to collect certain information about your equipment, interactions with the Website, and patterns, including, without limitation: (a) details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website; and (b) information about your computer and internet connection, including your IP address, operating system, and device type.

(2) The information we collect through automatic data collection technologies may include Personal Information, or we may maintain it or associate it with Personal Information we collect or receive from third parties. It helps us to improve our Service, including by enabling us to estimate our audience size and usage patterns and store information about users’ preferences. Section 5(3) and Section 6 describe the cookies and similar technologies we use, and Section 9 describes your choices about them.

(3) The technologies we use for this automatic data collection may include, without limitation:

(a) Cookies (or browser cookies). A cookie is a small file placed on your device when you visit a website. We use: (i) strictly necessary cookies, which are needed for the Website to function and to remember your cookie preferences; (ii) analytics cookies, which help us understand how visitors use the Website; and (iii) advertising cookies, which help us measure and deliver our advertising, including on other websites. A current list of the cookies we use is available through the cookie settings link on our Website.

(b) Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related websites.

(c) Tracking Pixels. We and our advertising partners may use tracking pixels, tags and similar technologies on our Website to measure the effectiveness of our advertising, to show our advertisements to people who have visited our Website when they later visit other websites and online services (known as remarketing or retargeting), and to exclude certain users from promotional content.

(d) Google Analytics and Other Similar Services. We may use Google Analytics and other similar services that use cookies to help us analyze how users interact with our Website and improve your experience in it, as further described in Section 6.

(4) Your Consent. Where required by applicable law, including for visitors from the European Economic Area, the United Kingdom and Switzerland, we will ask for your consent before placing analytics or advertising cookies or activating tracking pixels on your device. Strictly necessary cookies do not require consent. You can give, refuse or withdraw your consent at any time as described in Section 9(1)(a). Withdrawing consent does not affect information collected before you withdrew it.

6. Third-Party Use of Cookies and Other Tracking Technologies

(1) Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services.

(2) Among content and applications served by third-parties, we may use, without limitation, the following services:

(a) Analytics – Google Analytics. Google Analytics is a web analytics service offered by Google LLC that tracks and reports website traffic. We use Google Analytics to understand how visitors use our Website. Google Analytics uses cookies and similar technologies to collect information such as the pages you visit, the time you spend on them, the website that referred you, your device and browser type and your approximate location. Google Analytics does not log or store your full IP address. Google may use the information it collects in accordance with its own privacy policy, including, depending on our settings, to provide and improve its own services, and where we link Google Analytics with Google Ads, for the advertising purposes described in Section 6(2)(b). You can opt out of Google Analytics by declining analytics cookies through our cookie settings, or by installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout. For more information on how Google uses information from websites that use its services, please visit https://policies.google.com/technologies/partner-sites, and for Google’s privacy practices, please visit https://policies.google.com/privacy.

(b) Advertising and Remarketing – Google Ads and Other Advertising Partners. We may use Google Ads, an advertising service provided by Google LLC, and similar services offered by other advertising partners, to show our advertisements to people who have visited our Website when they visit other websites and online services, and to measure the results of our advertising campaigns. These services use cookies, pixels and similar technologies to recognize your browser or device. You can manage the advertisements Google shows you at https://myadcenter.google.com. You can also learn more about interest-based advertising, and opt out of it with participating companies, at https://optout.aboutads.info and https://optout.networkadvertising.org. Where required by applicable law, we will use these services only with your consent, and we will honor the choices described in Section 9.

(c) Payment Processing – We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processor we work with is Stripe – Their Privacy Policy can be viewed at https://stripe.com/us/privacy.

(3) We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

7. How We Use Your Information

(1) We use information that we collect about you or that you provide to us, including any Personal Information: (a) to present our Website and its contents to you; (b) to provide you with access to or use of the Service or functionality; (c) to provide you with information, products, or services that you request from us; (d) to fulfill any other purpose for which you provide it; (e) to perform and develop services, deliveries, payments and products in connection with our Service; (f) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, collection, bookkeeping, support and marketing; (g) to notify you about changes to our Service or any products or services we offer or provide through it; (h) to develop our Services and provide better services, including by identifying and correcting technical issues; (i) to deliver and target our marketing; (j) to prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; (k) in any other way we may describe when you provide the information; and (l) for any other purpose with your consent.

(2) We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at the e-mail at the bottom of this Privacy Policy.

(3) We will keep your Personal Information in our possession for the period necessary for the fulfillment of our collection purposes, as provided in Section 7(1) above.

8. Disclosure of Your Information

(1) We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

(2) We may disclose Personal Information that we collect or you provide as described in this privacy policy: (a) to our subsidiaries, affiliates and related companies; (b) to contractors, service providers, subprocessors, and other third parties we use to support our business, including, but not limited to firms for payment processing, developing, operations, sales, support, data analysis and marketing; (c) with respect to the Platform, as described in Section 4; (d) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Company about our customers and/or users is among the assets transferred; (e) to fulfill the purpose for which you provide it; (f) with your consent; or (g) for any other purpose disclosed by us when you provide the information.

(3) We may also disclose your Personal Information: (a) to comply with any court order, law, or legal process, including to respond to any legal duty, government or regulatory request; (b) to enforce or apply any other agreements, including but not limited to for billing and collection purposes; (c) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others, including but not limited to exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

9. Choices About How We Use and Disclose Your Information

(1) We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

(a) Cookies, Tracking Technologies and Advertising. When you first visit our Website, we will display a cookie banner that lets you accept or reject analytics and advertising cookies and tracking pixels. Where consent is required by applicable law, those technologies will not be activated unless you accept them. You can change your choices at any time by clicking the “Cookie Settings” link in the footer of our Website. Strictly necessary cookies cannot be switched off through the cookie settings because the Website cannot function without them. You can also use your browser settings to delete cookies already stored on your device or to block cookies, although some parts of the Website may then not function properly, and if you delete your cookies you may need to set your preferences again.

(b) Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by following the instructions contained in each promotional email we send you or by sending us an email stating your request to the e-mail provided at the bottom of this policy. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.

(c) Global Privacy Control and Do Not Track. If your browser or browser extension sends a Global Privacy Control (“GPC”) signal, we will treat it as a request to opt out of advertising cookies and tracking pixels for that browser, and we will not activate them while the signal is present. Because there is not yet a common industry standard for responding to “Do Not Track” browser signals, our Website does not currently respond to them.

(2) We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

10. Your Privacy Rights

(1) Certain jurisdictions may permit certain users of our Service to withdraw its consent to this Privacy Policy. To make such a request, please send an email to the e-mail address at the bottom of this Privacy Policy. Please note that by withdrawing of your consent to this Privacy Policy you will not be able to use the Website or use our Services. We will process such request in accordance with the applicable law.

(2) You may send us an email at the e-mail address at the bottom of this Privacy Policy to request access to, object, correct or delete any Personal Information that you have provided to us, as well as obtain restriction of processing in the cases provided by the applicable law. However, we reserve the right to not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

11. Data Security

(1) The safety and security of your information also depends on you. Where we have given you a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We require you not to share your password and login details with anyone.

(2) The Company takes the security of your data seriously. Payment Information is generally protected through the use of PCI-DSS-compliant third-party payment processors. For the handling of personal data, we protect your Personal Information using encryption in transit with Transport Layer Security (TLS) and encryption at rest [using AES-256 or an equivalent industry-standard algorithm]. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Services. Unless otherwise provided in the applicable legislation, any transmission of Personal Information is at your own risk.

12. Transfer to other Countries

Personal Information we collect may be transferred to third countries, as some third parties, affiliates and subsidiaries supporting our business may be located in these countries. Your Personal Information may therefore be subject to privacy laws that are different from those in your country of residence. Please note that some countries may not offer the same type of protection and privacy for Personal Information provided. If you are located outside of the United States, please note that we transfer and process information, including Personal Information, in the United States.

13. Individuals Outside the United States

(1) Our Platform and other paid Services are offered to businesses located in the United States and are not directed to individuals or businesses in the European Economic Area, the United Kingdom or Switzerland. If you are located in one of those jurisdictions, please do not register for, subscribe to or submit Personal Information through our Services unless we have agreed otherwise with you in writing.

(2) Our Website is accessible from outside the United States. If you visit our Website from the European Economic Area, the United Kingdom or Switzerland, we will use only strictly necessary cookies unless you consent to other cookies and similar technologies as described in Sections 5(4) and 9(1)(a).

(3) This Section 13 does not apply to Customer Data, which we process on behalf of our Customers as described in Section 4. Information we collect is transferred to and processed in the United States as described in Section 12.

(4) If you have questions, please contact us at privacy@myndbend.com.

14. Privacy Policies of Linked Sites and Apps

Our Services may contain links to third-party websites or applications. We are not responsible for the privacy practices or the content of such third parties. Please note that, once you leave our Service or Website, third parties’ privacy policies will apply to any information collected. If you have any questions about how these other websites or applications use your information, you should review their policies and contact them directly.

15. Children’s Privacy

Our Service is not intended for children under 16 years of age. No one under age 16 may provide any information to the Service. We do not knowingly collect Personal Information from persons under 16. If you are under 16 and unless your consent is given or authorized by the holder of your parental responsibility in accordance with applicable law, do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Service or provide any information about yourself to us. If you believe we might have any information from or about anyone under 16, please contact us at the e-mail at the bottom of this Privacy Policy.

16. Changes to Our Privacy Policy

It is our practice to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by updating our Privacy Policy on the Website. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

17. Governing Law and Dispute Resolution

This Privacy Policy and any dispute arising hereunder will be governed by the laws of the State of New York without regard to its choice of law or conflicts of law principles. Both you and the Company agree that all claims and disputes arising out of or relating to this Privacy Policy will be litigated exclusively in the courts located in New York City, New York.

18. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Billow Myndbend, Inc.
By mail: PO Box 150306, Brooklyn, NY 11215
By email: privacy@myndbend.com