Privacy Policy of Franklin AI

Welcome to Franklin AI's privacy policy. We're deeply committed to protecting your privacy and maintaining transparency about how we handle your financial information. This policy helps you understand what data we collect, why we need it, and how you can exercise control over your personal information.

Latest update: May 31, 2026

Quick Summary

Franklin AI is an AI-powered financial advisory service designed to help you make smarter financial decisions. To deliver personalized guidance, we:

• Securely access your financial data through trusted services like Plaid
• Leverage artificial intelligence from OpenAI and Anthropic to analyze your finances and generate tailored recommendations
• Safeguard your information using bank-level encryption and rigorous security measures
• Empower you with full control to access, modify, or delete your data whenever you choose

Table of Contents

1. Owner and Data Controller
2. Types of Data Collected
3. How We Process Your Data
4. Why We Process Your Data
5. Financial Data Integration (Plaid)
6. AI Processing Partners (OpenAI & Anthropic)
7. Third-Party Services We Use
8. Advertising and Marketing
9. Additional Data Processing Information
10. Cookie Policy
11. Your Rights (European Union)
12. Your Rights (Quebec, Canada – Law 25)
13. Additional Information About Data Collection
14. Definitions and Legal References
15. How to Contact Us

1. Owner and Data Controller

Franklin AI LLC 8 The Green Suite A Dover, Delaware 19901

Owner contact email: legal@meetfranklin.ai

Privacy Officer

Franklin has designated a Privacy Officer responsible for the protection of personal information and for handling rights requests from data subjects, including residents of Quebec under An Act respecting the protection of personal information in the private sector (commonly known as "Law 25").

Privacy Officer: Andrew Hendel Email: privacy@meetfranklin.ai

You may contact the Privacy Officer directly to exercise any of the rights described in this policy, to request information about our data handling practices, or to file a complaint.

2. Types of Data We Collect

To deliver personalized financial guidance, Franklin AI collects various categories of information. We obtain this data either directly from you or through carefully vetted third-party services. Here's a comprehensive breakdown of what we collect:

Personal Information

• First name and last name
• Email address
• Password (encrypted and secured)
• Social media account credentials (only if you opt to sign in using social authentication)

Financial Information

• Payment information (credit card details, bank account information)
• Transaction histories and account balances (securely accessed via Plaid)
• Financial account data necessary to deliver personalized recommendations

Usage and Technical Data

We automatically collect information about how you interact with our application:

• Device information (operating system, browser type, unique device identifiers)
• Usage patterns (features accessed, pages viewed, time spent, clicks, navigation pathways)
• Session information (session count, session duration, app launches)
• Interaction data (scroll position, mouse movements, touch events, keypress events)
• Technical data (IP address, crash logs, browser fingerprint)
• Location data (city, state, country, ZIP code, approximate latitude/longitude)
• Motion sensor events (on mobile devices)

Device Permissions

Our mobile application may request the following permissions from your device:

• Contacts permission
• Phone permission
• Call permission

Important Notice About Data Collection

Personal data may be voluntarily provided by you or, in the case of usage data, automatically collected when you use Franklin AI. Unless we explicitly state that certain data is optional, all information we request is essential for providing our services effectively. If you're uncertain whether specific information is required, please don't hesitate to contact us at legal@meetfranklin.ai.

We also utilize cookies and similar tracking technologies to collect data. These technologies enable us to deliver the services you've requested and continuously improve your experience. Additional details are available in our Cookie Policy section below.

3. How We Process Your Data

Methods of Processing

We take your data security seriously and implement robust measures to prevent unauthorized access, disclosure, modification, or destruction of your information. Our data processing is conducted using secure computing systems and IT-enabled tools, adhering to strict organizational procedures that align with the purposes outlined in this policy.

Beyond our internal team members (who handle administration, sales, marketing, legal matters, and system administration), your data may be accessible to carefully selected external parties. These include third-party technical service providers, communication carriers, hosting providers, IT companies, and communications agencies. When necessary, these parties are formally designated as Data Processors and are contractually bound to protect your information.

You may request an updated list of all entities with access to your data at any time by contacting us.

Where We Process Data

Franklin AI is headquartered in the United States, and your personal data is processed primarily in the United States. Our infrastructure runs on Google Cloud Platform (United States regions). We rely on the following processors based in the United States: Plaid (financial account connectivity), Stripe (payment processing), OpenAI and Anthropic (AI model inference), Firebase (authentication, hosting, push notifications, crash reporting), Cloudflare (CDN, bot protection), and Amazon Web Services (transactional email delivery via Simple Email Service).

For users located outside the United States — including in the European Economic Area, the United Kingdom, and Canada (including Quebec) — providing services to you necessarily involves the transfer of your personal data across borders to the United States.

Franklin has completed Transfer Impact Assessments for each of these processors and relies on contractual safeguards including signed Data Processing Agreements and, where applicable, Standard Contractual Clauses (or equivalent mechanisms) to ensure your personal data receives a level of protection consistent with the requirements of applicable law in your jurisdiction. You may request a summary of these Transfer Impact Assessments by contacting our Privacy Officer.

Data Retention Period

We retain personal data only as long as needed for the purposes set out in this policy and to meet our legal, accounting, or reporting obligations. The table below summarizes the standard retention periods for the principal categories of personal data we process:

After the applicable retention period expires, your personal data is securely deleted or irreversibly anonymized. Once data has been deleted, you will no longer be able to exercise rights of access, rectification, erasure, or portability with respect to that data.

If you have specific questions about the retention period applicable to a particular category of your data, please contact our Privacy Officer at privacy@meetfranklin.ai.

4. Why We Process Your Data

We collect and process your data to achieve the following objectives:

Personalized Financial Guidance

To analyze your financial situation comprehensively and deliver tailored recommendations, actionable insights, and strategic guidance that empower you to make informed financial decisions.

Service Provision and Enhancement

To operate Franklin AI effectively, fulfill legal obligations, respond to enforcement requests, protect our rights and interests (and those of our users), detect fraudulent or malicious activity, and continuously enhance our platform's functionality, user experience, and overall performance.

Communication

To deliver important updates, service notifications, newsletters, and other relevant information concerning your use of Franklin AI.

Compliance and Security

To monitor transactions for suspicious or fraudulent activity, maintain platform security, and ensure compliance with our legal obligations under applicable laws and regulations.

We accomplish these objectives through various activities including:

• Analytics and performance monitoring
• User registration and authentication
• Platform services and hosting
• Spam and bot protection
• Infrastructure monitoring
• Payment processing
• Contact management and communications
• Beta testing and feature development

5. Financial Data Integration (Plaid)

How We Access Your Financial Accounts

To provide personalized financial advice, Franklin AI requires secure access to your financial account information. We utilize Plaid, a trusted and industry-leading financial data aggregation service, to establish secure connections with your bank accounts, credit cards, and other financial institutions.

What is Plaid?

Plaid is a specialized third-party service that securely links your financial accounts to Franklin AI. Widely trusted by thousands of financial applications and major financial institutions, Plaid provides enterprise-grade security. When you connect your accounts through Plaid:

• Your login credentials are encrypted end-to-end and never stored by Franklin AI
• Plaid employs bank-level security protocols and encryption standards
• You retain full control and can revoke access instantly through your Franklin AI settings

What Financial Data We Access Through Plaid

With your explicit consent, we access the following information through Plaid:

• Account balances (checking, savings, credit cards, loans, investment accounts)
• Transaction histories (purchases, transfers, deposits, withdrawals)
• Account holder information (account names, masked account numbers, account types)
• Identity verification information (to confirm account ownership)

Why We Need This Data

Franklin AI analyzes your financial data to:

• Understand your spending patterns and financial behaviors
• Identify opportunities to optimize savings or reduce unnecessary expenses
• Deliver personalized budgeting strategies and financial planning recommendations
• Alert you to unusual transactions or potential financial concerns
• Monitor your progress toward achieving financial goals

Your Control Over Financial Data

You maintain complete control over your financial data connections:

• You can disconnect any account instantly at any time
• You have full discretion to choose which accounts to connect
• You can request permanent deletion of all financial data
• Disconnecting accounts will limit certain features but won't terminate your Franklin AI account

For comprehensive information about how Plaid handles your data, please review Plaid's privacy policy at https://plaid.com/legal/

6. AI Processing Partners (OpenAI & Anthropic)

How We Utilize Artificial Intelligence

Franklin AI is powered by cutting-edge artificial intelligence to deliver personalized, intelligent financial guidance. We partner with two industry-leading AI companies—OpenAI and Anthropic—to process and analyze your financial information and generate sophisticated recommendations.

What Are OpenAI and Anthropic?

OpenAI is a pioneering AI research organization that develops advanced language models capable of understanding and generating human-like text. They are the creators of GPT (Generative Pre-trained Transformer) technology.

Anthropic is an AI safety company focused on building reliable, interpretable, and steerable AI systems. They created Claude, an AI assistant engineered to be helpful, harmless, and honest.

What Data Do We Share with AI Partners?

When you interact with Franklin AI, we may transmit the following information to OpenAI and/or Anthropic for processing:

• Your questions and prompts directed to Franklin AI
• Aggregated and anonymized financial data (transaction summaries, spending categories, account balances)
• Contextual information necessary to deliver personalized advice (your stated financial goals, preferences you've shared)

Critical Privacy Protections

We implement multiple layers of protection to safeguard your privacy when utilizing AI services:

1. Minimized Identifiers: We minimize or remove personally identifiable information (such as your name, email, specific account numbers) before transmitting data to AI partners wherever technically feasible.

2. Data Processing Agreements: Both OpenAI and Anthropic operate under strict data processing agreements that contractually prohibit them from using your data to train their models or for any purpose beyond providing services to Franklin AI.

3. Encryption in Transit: All data transmitted to AI partners is encrypted during transit using industry-standard TLS/SSL protocols.

4. Limited Retention: AI partners retain conversation data only as long as operationally necessary to provide the service, typically 30 days or less, unless legally required otherwise.

5. No Model Training: Your data is expressly excluded from being used to train or improve OpenAI's or Anthropic's general AI models.

Why We Partner with Multiple AI Providers

We collaborate with both OpenAI and Anthropic to optimize your experience:

• Different AI models possess distinct strengths for various types of financial analysis
• We can select the most appropriate AI model for your specific question or task
• Multiple partners ensure service reliability, redundancy, and continuity

Your Rights Regarding AI Processing

You have the right to:

• Be informed when AI is processing your data
• Understand the methodology behind AI-generated recommendations
• Request that we minimize data shared with AI partners
• Object to AI processing (though this may significantly limit service functionality)

For comprehensive information about how our AI partners handle data:

• OpenAI's privacy policy: https://openai.com/policies/privacy-policy
• Anthropic's privacy policy: https://www.anthropic.com/legal/privacy

7. Third-Party Services We Use

To deliver Franklin AI's services effectively, we collaborate with carefully vetted third-party companies. Below is a comprehensive catalog of all services we utilize, organized by category. These partners are contractually obligated to protect your data and use it exclusively for the specific purposes we've outlined.

Analytics Services

These services enable us to understand how users interact with Franklin AI, allowing us to continuously improve your experience.

Google Analytics 4 Company: Google LLC Location: United States Data processed: Number of users, session statistics, usage patterns

Cloudflare Web Analytics Company: Cloudflare, Inc. Location: United States Data processed: Device information, page views, performance metrics

User ID Extension for Google Analytics Company: Google LLC Location: United States Data processed: Trackers

Analytics Collected Directly Data processed: Trackers, usage data

Beta Testing Services

These services facilitate testing of new features and gathering feedback before full release to all users.

Google Play Beta Testing Company: Google LLC Location: United States Data processed: Data communicated while using the service, device information, usage patterns

TestFlight Company: Apple Inc. Location: United States Data processed: Device information, crash data

User Contact Services

Contact Form Company: Franklin AI (directly operated) Data processed: Email address, first name, last name, message content

Productivity and Collaboration Tools

These services enable our team to collaborate internally and manage operational activities.

Google Workspace (Docs, Sheets, Gmail) Company: Google LLC Location: United States Data processed: Data communicated while using the service, usage data

Google Meet Company: Google LLC Location: United States Data processed: Email address, usage data, meeting information, participant data

Payment Processing Services

We employ secure third-party payment processors to handle all financial transactions. Franklin AI does not directly store your complete payment card information.

Stripe Company: Stripe, Inc. Location: United States Data processed: Email address, payment information, billing address, transaction details

Google Pay Company: Google LLC Location: United States Data processed: Email address, payment information, device information, transaction history

Apple Pay Company: Apple Inc. Location: United States Data processed: Payment information, device information

Android Pay Company: Google LLC Location: United States Data processed: Payment information, device information

App Store and Play Store Payment Processing Companies: Apple Inc. and Google LLC Location: United States Data processed: Device information, payment information, purchase history, app usage

Hosting and Infrastructure Services

These services host Franklin AI's application and securely store your data.

Google Cloud Platform Company: Google LLC Location: United States Data processed: Various types of data as specified in Google Cloud's privacy policy

Google Cloud Storage Company: Google LLC Location: United States Data processed: Various types of data as specified in Google Cloud's privacy policy

Firebase Hosting Company: Google LLC Location: United States Data processed: Various types of data as specified in Firebase's privacy policy

Infrastructure Monitoring

Crashlytics Company: Google LLC Location: United States Data processed: Crash data, device information, app version, stack traces

Messaging and Notifications

Firebase Cloud Messaging Company: Google LLC Location: United States Data processed: Trackers, device tokens, message content

App Distribution Platforms

Google Play Store Company: Google LLC Location: United States Data processed: Usage data

App Store Connect Company: Apple Inc. Location: United States Data processed: Trackers, usage data, device information

Authentication Services

These services enable you to sign in to Franklin AI using existing accounts from trusted providers.

Google OAuth Company: Google LLC Location: United States Data processed: Trackers, email address

Firebase Authentication Company: Google LLC Location: United States Data processed: Email address, password (encrypted)

Sign in with Apple Company: Apple Inc. Location: United States Data processed: Email address

Stripe OAuth Company: Stripe, Inc. Location: United States Data processed: Trackers, account information

Direct Registration Company: Franklin AI (directly operated) Data processed: Email address, first name, last name, password

Social Features

Firebase Dynamic Links Company: Google LLC Location: United States Data processed: Various types of data as specified in Firebase's privacy policy

Security and Bot Protection

These services protect Franklin AI from spam, automated bots, and malicious activities.

Google reCAPTCHA Company: Google LLC Location: United States Data processed: Answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events, trackers

Cloudflare Bot Management Company: Cloudflare, Inc. Location: United States Data processed: App information, browser information, browsing history, city, clicks, country, county, crash data, device information, geography/region, interaction events, IP address, latitude/longitude, launches, metro area, mouse movements, number of sessions, operating systems, page events, page views, province, scroll position, scroll-to-page interactions, search history, session duration, session statistics, state, touch events, trackers, unique device identifiers, usage data, video views, ZIP code

Cloudflare Turnstile Company: Cloudflare, Inc. Location: United States Data processed: Browser fingerprint, browser information, device information, trackers

Content Delivery and Performance Optimization

These services optimize Franklin AI's performance, speed, and global accessibility.

Google Cloud CDN Company: Google LLC Location: United States Data processed: Usage data

Cloudflare CDN Company: Cloudflare, Inc. Location: United States Data processed: Trackers, usage data

Cloudflare DNS Company: Cloudflare, Inc. Location: United States Data processed: Usage data

8. Advertising and Marketing

Opting Out of Interest-Based Advertising

In addition to any opt-out features provided by the services listed in this document, you can learn more about how to generally opt out of interest-based advertising by reviewing the dedicated section of our Cookie Policy below.

9. Additional Data Processing Information

Equal Protection of Your Data

Franklin AI shares user data exclusively with third parties that are rigorously selected to ensure they provide equivalent or superior data protection as stated in this privacy policy and as mandated by applicable data protection laws. You can find more information about our third parties' data processing and privacy practices in their respective privacy policies.

Analysis, Predictions, and Automated Decision-Making (Profiling and AI)

Franklin AI uses your personal data, financial data, and usage data to build and refine an internal profile that informs the recommendations, summaries, and insights we provide to you. Some of this analysis is performed by automated systems, including large language models operated by our AI partners (OpenAI and Anthropic). When you ask Franklin a financial question or when Franklin proactively surfaces an insight, that output is in part generated by automated processing of your data.

Your rights with respect to automated processing:

• You have the right to be informed when automated processing is being used to evaluate or make decisions about you. This section serves as that disclosure.
• You have the right to request information about the logic involved in the automated processing and the significance of the outcome.
• You have the right to request human review of any specific AI-generated recommendation. To exercise this right, contact our Privacy Officer at privacy@meetfranklin.ai with a description of the recommendation you would like reviewed, and a member of our team will respond within 30 days.
• You have the right to object to the use of automated processing of your data, though doing so will significantly limit Franklin's ability to provide its core service.

Franklin does not use your data to train OpenAI's or Anthropic's general AI models — see Section 6 for details on the contractual protections in place.

Data Breach Notification

In the event of a confirmed security incident affecting personal data, Franklin will notify affected users without undue delay and in accordance with applicable law. Where required, we will also notify the relevant supervisory authorities — including the Commission d'accès à l'information du Québec for incidents affecting residents of Quebec, and equivalent authorities in other jurisdictions. Our incident response procedure includes severity classification, internal escalation to the Privacy Officer, coordination with legal counsel, and a written post-incident review.

Personal Data Collected Through Sources Other Than You

Franklin AI may have legitimately collected personal data about you without your direct knowledge by reusing or sourcing data from third parties (such as Plaid for financial data or our authentication partners) based on the legal grounds mentioned in the section specifying the legal basis of processing.

Where we have collected personal data through these means, you may find specific information regarding the source within the relevant sections of this document or by contacting us directly.

Push Notifications

Franklin AI may send push notifications to you to achieve the purposes outlined in this privacy policy, such as delivering financial alerts, reminders, or critical updates.

In most cases, you can opt out of receiving push notifications by accessing your device settings (such as the notification settings for mobile phones) and adjusting those settings for Franklin AI or for all apps on your device.

Please be aware that disabling push notifications may negatively impact the utility of Franklin AI, as you may miss important financial alerts or time-sensitive updates.

Selling Goods and Services Online

The personal data we collect is utilized to provide you with services or to facilitate the sale of goods, including processing payments and handling any necessary delivery.

The personal data collected to complete payments may include credit card information, bank account details, or any other payment method you choose. The specific data collected depends on the payment system you select.

SessionStorage

SessionStorage allows Franklin AI to store and access data directly in your browser. Data in sessionStorage is automatically deleted when the session concludes (when you close the browser tab). This temporary storage mechanism helps provide a seamless user experience during your active session.

Unique Device Identification

Franklin AI may track users by storing a unique identifier for their device. We employ this for analytics purposes or to preserve your preferences, ensuring a consistent experience across sessions.

User Identification via Universally Unique Identifier (UUID)

Franklin AI may track users by storing a universally unique identifier (UUID) for analytics purposes or for preserving your preferences.

This identifier is generated upon initial installation of Franklin AI. It persists across app launches and updates but is permanently deleted when you uninstall the application. If you reinstall Franklin AI, a new UUID will be generated.

10. Cookie Policy

Understanding Cookies and Trackers

Franklin AI employs cookies and other tracking technologies (collectively termed 'Trackers'). Trackers are small data fragments stored on your device that facilitate our ability to provide and enhance our services.

Trackers encompass:

• Cookies: Small text files stored in your browser
• Unique identifiers: Codes that identify your device or session
• Web beacons: Tiny graphics embedded in pages or emails
• Embedded scripts: Code that collects information about your interactions
• E-tags: Cache validation mechanisms
• Fingerprinting: Techniques that identify your device based on its unique characteristics

Purpose of Trackers

We employ trackers to:

• Deliver the services you've requested
• Remember your preferences and customized settings
• Understand how you interact with Franklin AI to drive continuous improvement
• Analyze performance and resolve technical issues proactively
• Protect against fraud and malicious activities
• Provide relevant content and personalized recommendations

Managing Your Cookie Preferences

You can control cookies through your browser settings. Most browsers enable you to:

• View what cookies are currently stored
• Delete existing cookies
• Block cookies from specific websites
• Block all third-party cookies
• Block all cookies entirely

Please note that blocking cookies may adversely affect your ability to use certain features of Franklin AI.

11. Your Rights (European Union)

If you are located in the European Union, this section applies to you and delineates your rights under the General Data Protection Regulation (GDPR).

Legal Basis for Processing

We may process your personal data if one or more of the following legal bases applies:

• You have provided your consent for one or more specific purposes
• Processing is necessary for the performance of a contract with you or for pre-contractual obligations
• Processing is necessary for compliance with a legal obligation to which we are subject
• Processing is related to a task carried out in the public interest or in the exercise of official authority vested in us
• Processing is necessary for the purposes of legitimate interests pursued by us or by a third party

We are pleased to help clarify the specific legal basis that applies to your data processing. Please contact us if you require more information about whether providing certain personal data constitutes a statutory, contractual, or necessary requirement.

Data Retention Period

Unless specified otherwise in this document, we process and store personal data for as long as required by the purpose for which it was collected, and may retain it for extended periods due to applicable legal obligations or based on your explicit consent.

Specifically:

• Personal data collected for purposes related to performing a contract with you will be retained until the contract has been fully performed
• Personal data collected for our legitimate interests will be retained as long as needed to fulfill those purposes
• We may retain personal data for an extended period when you have provided consent, provided that such consent remains unrevoked
• We may be legally obligated to retain personal data for an extended period when required by law or by governmental authority

Once the retention period expires, personal data will be securely deleted. After deletion, you will no longer be able to exercise rights such as access, erasure, rectification, or data portability.

Your Rights Under GDPR

You may exercise certain rights regarding your data processed by Franklin AI. To the extent permitted by law, you have the right to:

1. Withdraw Consent: You can withdraw your consent at any time where you have previously provided consent to process your personal data.

2. Object to Processing: You can object to the processing of your data if the processing is carried out on a legal basis other than consent.

3. Access Your Data: You can learn whether we are processing your data, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the data undergoing processing.

4. Verify and Seek Rectification: You can verify the accuracy of your data and request that it be updated or corrected.

5. Restrict Processing: You can restrict the processing of your data. In this case, we will not process your data for any purpose other than storing it.

6. Have Your Data Deleted: You can request the erasure of your data from Franklin AI.

7. Receive and Transfer Your Data: You can receive your data in a structured, commonly used, and machine-readable format and, if technically feasible, have it transmitted to another controller without hindrance.

8. Lodge a Complaint: You can file a claim before your competent data protection authority.

You are also entitled to learn about the legal basis for data transfers abroad, including to any international organization governed by public international law or established by two or more countries (such as the UN), and about the security measures we implement to safeguard your data.

Details About the Right to Object to Processing

When personal data is processed for a public interest, in the exercise of official authority, or for our legitimate interests, you may object to such processing by providing grounds related to your particular situation to justify the objection.

However, if your personal data is processed for direct marketing purposes, you can object to that processing at any time, free of charge, and without providing any justification. When you object to processing for direct marketing purposes, your personal data will no longer be processed for such purposes.

To determine whether we are processing personal data for direct marketing purposes, please refer to the relevant sections of this document.

How to Exercise Your Rights

Any requests to exercise your rights can be directed to us through the contact details provided in this document. Requests are free of charge and will be addressed as promptly as possible, always within one month. We will provide you with the information required by law.

Any rectification or erasure of personal data or restriction of processing will be communicated by us to each recipient (if any) to whom your personal data has been disclosed, unless this proves impossible or involves disproportionate effort. Upon your request, we will inform you about those recipients.

12. Your Rights (Quebec, Canada – Law 25)

If you are a resident of Quebec, this section describes the rights you hold under An Act respecting the protection of personal information in the private sector (CQLR c P-39.1, commonly referred to as "Law 25"), as well as how to exercise those rights with Franklin.

Our Privacy Officer

Franklin has designated a Privacy Officer responsible for ensuring that personal information is processed in accordance with Law 25. The Privacy Officer is your primary point of contact for any question, request, or complaint concerning your personal information.

Privacy Officer: Andrew Hendel Email: privacy@meetfranklin.ai

Your Rights Under Law 25

As a Quebec resident, you have the right to:

1. Be informed about the collection, use, communication, and retention of your personal information — including the purposes for which it is collected, the categories of persons within Franklin who have access to it, and the third parties to whom it may be communicated.
2. Access the personal information Franklin holds about you and receive a copy of that information.
3. Rectify personal information that is inaccurate, incomplete, or equivocal.
4. Withdraw consent to the collection, use, or communication of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect Franklin's ability to provide its services to you.
5. Request the cessation of dissemination of your personal information, and the de-indexation of any hyperlink attached to your name that provides access to that information by a technological means, where the dissemination contravenes the law or a court order, or where the dissemination causes serious injury that outweighs the public's interest in the information (commonly described as the "right to de-indexation" or "right to be forgotten").
6. Receive your personal information in a structured, commonly used technological format and, where technically feasible, to have it communicated directly to another organization (the "right to data portability").
7. Be informed when an automated decision is made about you based exclusively on automated processing of your personal information, to obtain information about the personal information used to render the decision, the reasons and principal factors that led to the decision, and to request that the decision be reviewed by a human being. See Section 9 (Automated Decision-Making) for how Franklin uses automated processing and how to request human review.
8. Object to the use of your personal information for direct marketing purposes at any time, free of charge.
9. File a complaint with our Privacy Officer, and if unsatisfied with our response, to file a complaint with the Commission d'accès à l'information du Québec (CAI) at https://www.cai.gouv.qc.ca/.

Cross-Border Transfers

Franklin is a U.S. company and processes personal information primarily in the United States. Where Franklin transfers your personal information outside Quebec — including to our processors listed in Section 7 — we have conducted a Privacy Impact Assessment for each transfer in accordance with section 17 of Law 25, considering the sensitivity of the information, the purposes for which it is to be used, the protection measures (contractual, technical, and organizational) that would apply to the information, and the legal framework applicable in the destination jurisdiction.

A summary of these Privacy Impact Assessments is available on request from our Privacy Officer.

How to Exercise Your Rights

To exercise any of the rights above, contact our Privacy Officer at privacy@meetfranklin.ai. Please include:

• Your full name and the email address associated with your Franklin account.
• A description of the right you wish to exercise.
• Any additional details that will help us locate and act on your request (for example, the specific information you would like access to or rectification of).

We will respond to your request within 30 days of receipt, as required by Law 25. If we are unable to act on your request, we will explain why and inform you of your right to file a complaint with the CAI.

There is no charge for exercising your rights, except in cases where requests are manifestly unfounded or excessive, in which case a reasonable fee may apply and will be disclosed in advance.

Data Breach Notification

In the event of a confidentiality incident presenting a risk of serious injury to you, Franklin will notify you and the Commission d'accès à l'information du Québec with diligence, as required by section 3.5 of Law 25. See Section 9 for our broader incident response commitments.

13. Additional Information About Data Collection

Legal Action

Your personal data may be utilized for legal purposes by Franklin AI in court or in the preliminary stages leading to possible legal action arising from improper use of Franklin AI or our services.

You acknowledge that we may be legally required to disclose personal data upon request of public authorities.

Additional Information About Your Personal Data

In addition to the information contained in this privacy policy, Franklin AI may provide you with supplementary and contextual information concerning particular services or the collection and processing of personal data upon request.

System Logs and Maintenance

For operational and maintenance purposes, Franklin AI and any third-party services we utilize may collect files that record interactions with Franklin AI (system logs) or employ other personal data (such as IP addresses) for this purpose.

Information Not Contained in This Policy

Additional details concerning the collection or processing of personal data may be requested from us at any time. Please refer to the contact information at the beginning of this document.

Changes to This Privacy Policy

We reserve the right to modify this privacy policy at any time by notifying you on this page and possibly within Franklin AI. We may also send notice to you via any contact information available to us, where technically and legally feasible.

We strongly recommend that you review this page regularly, referring to the date of the last modification listed at the top of this document.

Should the changes affect processing activities performed based on your consent, we will collect new consent from you where legally required.

14. Definitions and Legal References

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information—including a personal identification number—enables the identification or identifiability of a natural person.

Usage Data

Information collected automatically through Franklin AI (or third-party services employed in Franklin AI), which can include:

• The IP addresses or domain names of the computers utilized by users
• URI addresses (Uniform Resource Identifier)
• The timestamp of the request
• The method employed to submit the request to the server
• The size of the file received in response
• The numerical code indicating the server response status (successful outcome, error, etc.)
• The country of origin
• The features of the browser and operating system utilized
• Various temporal details per visit (e.g., time spent on each page)
• Details about the navigation path followed within the application, particularly the sequence of pages visited
• Other parameters concerning the device operating system and/or the user's IT environment

User

The individual utilizing Franklin AI who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the personal data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of processing personal data, including the security measures concerning the operation and use of Franklin AI. The Data Controller, unless otherwise specified, is the Owner of Franklin AI.

Franklin AI (or This Application)

The means by which the personal data of the user is collected and processed.

Service

The service provided by Franklin AI as described in the relative terms (if available) and on this application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are trackers consisting of small sets of data stored in the user's browser.

Tracker

Tracker indicates any technology—such as cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting—that enables the tracking of users, for example by accessing or storing information on the user's device.

Legal Information

This privacy policy relates solely to Franklin AI, unless stated otherwise within this document.

15. How to Contact Us

What You Can Do

Regarding Your Data:

• Request to know and access the information we hold about you
• Request corrections to information we hold about you
• Request deletion of the information we hold about you (the right to be forgotten)
• Request to port your data to another service provider
• Request human review of an automated decision
• Object to the use of your data for direct marketing
• Withdraw any consent you previously provided

In Case of Issues

While we strive to create an exceptional user experience, we understand that concerns may occasionally arise. If you have questions, complaints, or feedback, please don't hesitate to contact us. We're here to assist you.

Contact Information

For privacy rights requests, complaints, or questions about your personal data: Privacy Officer: Andrew Hendel privacy@meetfranklin.ai

For general legal or business inquiries: Franklin AI LLC 8 The Green Suite A Dover, Delaware 19901 legal@meetfranklin.ai

By using Franklin AI, you acknowledge that you have read and understood this Privacy Policy and agree to the terms outlined herein.