Privacy Policy

Last Updated: May 25, 2026

Introduction

Xplarion Inc. and its affiliates ("Xplarion," "we," "us," or "our") are committed to protecting the privacy of individuals who: (i) visit our website at xplarion.com and its subdomains (the "Website"); (ii) use our web or mobile application (the "Application"); and (iii) use our services including data analysis, AI-driven prospectivity modeling, project management, data hosting, and other services (the "Client Services"). Together, these are referred to as the "Services."

This Privacy Policy explains how we collect, use, and protect your personal information. By visiting or using any of the Services, you agree to be bound by the terms of this Privacy Policy.

Xplarion reserves the right to modify this Privacy Policy at any time. The most current version will always be available at xplarion.com/legal/privacy-policy. We encourage you to review this page periodically. We will notify you of material changes by email or through the Services. Your continued use of the Services following any update constitutes acceptance of those changes.

This Privacy Policy is part of our broader legal framework available at xplarion.com/legal. Our Acceptable Use Policy and Copyright & IP Infringement Policy also apply to your use of the Services.

Personal Information We Collect

Personal information relates to identified or identifiable natural persons. An identifiable natural person is an individual who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, specific location data, online identifier, or similar attributes.

Personal information does not include information that has been anonymized or aggregated such that it can no longer identify a specific natural person, whether on its own or in combination with other information.

We collect two categories of personal information: Account Data and Content.

Account Data

Account Data is personal information you provide or that we collect from you and your devices relating to access and use of the Services, such as registration information or browser information. We collect and use Account Data as a data controller.

Information You Give Us

Account information: When you create an account, you may provide your name, email address, and password.

Billing information: If you purchase a paid version of the Services or make a financial transaction, we collect information about the purchase including billing details and payment card information.

Other information: You may provide information when filling out forms, contacting support, responding to surveys, or using other features of the Services, including optional profile details.

Information We Automatically Collect

Log data and usage information: Our servers automatically record information when you interact with the Services, including your IP address, the web page you visited before using the Services, your browser type and settings, device information, date and time of use, browser configuration and plug-in details, language preferences, unique identifiers, and cookie data.

Location information: When you use our Services, we may collect information about your geographic location.

Cookies and similar technologies: We use cookies and similar tracking technologies to provide and support our Services, as described in our Cookie Notice.

Content

Content that is uploaded to, made available through, downloaded from, or viewed on our Services may contain personal information. When we refer to "Content" in this policy, we mean the personal information included in Content that we process. We process Content only at your direction. In legal terms, we act as a data processor for personal information included in Content.

Our obligations with respect to processing Content on behalf of users are described in the section titled "Content - Xplarion as a Data Processor" below.

Account Data - How We Use It

We use, store, and process Account Data as a data controller to provide, understand, improve, and develop the Services, keep them safe and secure, and comply with legal obligations. Specifically, we use Account Data to:

• Identify you when you create and log into your account
• Enable the operation and delivery of the Services
• Verify transactions and provide purchase confirmation, billing, security, and authentication
• Analyze the Services and information about our users, including research into demographics and behavior, to improve our content and Services
• Contact you about your account and provide customer support, including responding to comments and questions
• Share aggregate (non-identifiable) statistics about users with prospective partners
• Keep you informed about Services, features, surveys, newsletters, and events you may find useful or have requested
• Market Xplarion products and services if you have opted in to commercial communications
• Better understand and address the needs of users, diagnose problems, analyze trends, and improve the usability and features of the Services
• Verify accounts and activity, maintain Services integrity, and keep the Services safe and secure

We use non-identifiable statistical information to track visits to the Services and to introduce improvements. This statistical data may be shared with partners so they understand how frequently the Services are used and how to provide optimal experiences.

Account Data - Legal Basis for Use

The legal basis for our collection and use of Account Data depends on the specific context in which we collect it. We collect personal information where:

• You have consented to the collection
• The personal information is necessary to perform a contract with you, such as delivering the Services you have requested
• Processing serves our legitimate business interests, provided those interests are not overridden by your data protection interests or fundamental rights

Subject to obligations consistent with this Privacy Policy, we may disclose Account Data to our affiliates, agents, contractors, and service providers to facilitate the functioning of the Services or to perform tasks integral to the Services, such as processing transactions or providing support. These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or to comply with legal requirements.

We may also have a legal obligation to collect personal information or need it to protect the vital interests of individuals. Where we rely on your consent to process Account Data, you have the right to withdraw or decline your consent at any time. This does not affect the lawfulness of processing based on consent before its withdrawal.

Account Data - Access, Control and Correction

You may update or correct most Account Data by logging into your account and editing your profile or organization record. To request that Account Data be returned to you, removed, or to make additional corrections, please email our privacy team at info@xplarion.com. Requests will be handled within 30 days and may be subject to a fee as permitted by applicable law.

Depending on your location, you may exercise additional rights under applicable law regarding personal information we hold as a data controller:

Right of erasure: In certain circumstances, you may have a broader right to erasure of personal information we hold about you, for example if it is no longer necessary for the purposes for which it was originally collected. We may retain certain information as long as your account is active, to provide the Services, for record keeping, to comply with legal obligations, resolve disputes, and enforce our Terms.

Right to object to processing: You may request that we stop processing your personal information and/or stop sending you marketing communications.

Right to restrict processing: You may request that we restrict the processing of your personal information in certain circumstances, such as when you believe the information is inaccurate or unlawfully held.

Right to data portability: In certain circumstances, you may have the right to receive your personal information in a structured, machine-readable, and commonly used format and to request that we transfer it to another data controller without hindrance.

To exercise these rights, please contact us. We will consider requests in accordance with applicable law and may verify your identity before complying to protect your privacy and security. You also have the right to complain to a relevant data protection authority about our collection and use of your personal information.

Content - Xplarion as a Data Processor

Users or clients of our Services control how Content is generated, requested, submitted, or published and processed through the Services. The Content that flows through our Services may include personal information of various types, including but not limited to:

• User or client generated content
• Contact details such as name, email address, and telephone number
• Additional individual information such as age, employer, profession, geographic location, and professional background
• Information relating to geographic or project location data

As the user or client, you are the data controller of your Content, and we are the data processor. Where we process Content, we do so at your direction and on your behalf in accordance with the instructions you give us through the Services. We may, in limited circumstances, process Content for the purposes of improving the Services and functionalities you request.

For users invited by Xplarion clients, the applicable client determines the policies regarding Content storage, access, modification, deletion, sharing, and retention. You should check with that client about policies and settings they have implemented.

Access, Correction, and Deletion of Content

In several instances, Content published via the Services will not be in Xplarion's custody, and Content that has been shared or otherwise made available may continue to be available to third parties. Individuals seeking access to, correction of, or deletion of Content stored or processed by Xplarion on behalf of users or clients should direct their queries to those Xplarion clients. Upon receipt of a request from a user or client to remove data, we will respond within 30 days. We may retain certain information as long as accounts are maintained, for record keeping, to comply with legal obligations, resolve disputes, or enforce our Terms.

For Users Subject to the GDPR

Under EU law, Xplarion acts as a Content data processor. We process Content per user and client instructions. Because users and clients control Content collection and use, they are legally the controllers of Content processed through the Services and bear responsibility for GDPR compliance in their use of the platform.

When We May Share Personal Information

Except as described in this Privacy Policy, Xplarion does not share personal information gathered via the Services with third parties. We may share Account Data or Content under the following circumstances:

• With your consent or at your direction
• With service providers, including payment processors, who perform functions or provide services on our behalf, subject to appropriate confidentiality and security obligations
• Where reasonably necessary to comply with laws or regulations, court orders, legal process, or to establish, protect, or exercise legal rights or defend against claims
• When necessary to investigate, prevent, or address illegal activities, fraud, or threats to the rights or property of Xplarion or others
• When necessary to investigate or address security issues, infrastructure abuse, or internet threats such as denial of service attacks
• With parent companies, subsidiaries, joint ventures, or commonly-controlled entities
• Upon acquisition by or merger with another entity, where Xplarion will require that entity to assume the obligations of this Privacy Policy, or in bankruptcy or ownership change proceedings

How Long We Keep Personal Information

We retain Account Data as long as necessary to provide the Services you have requested or for essential purposes such as complying with legal obligations, resolving disputes, and enforcing our Terms.

We retain Content as long as needed to provide the Services, or until you request deletion in accordance with our Terms. Content is retained and used as necessary for legal compliance, dispute resolution, and enforcement of our Terms. After retention is no longer necessary, we dispose of personal information securely in accordance with our data retention and deletion policies.

How We Protect Personal Information

Xplarion follows industry best practices to protect personal information from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect and the current state of technology. For more information, see our Security page.

International Transfers

Xplarion Inc. is a United States company headquartered in Golden, Colorado. We provide our Services primarily from offices in the United States. We use third-party service providers, such as managed hosting providers, payment processors, and technology partners, to help operate the Services. These providers may process or store personal information on servers in various countries.

By using the Services, or submitting or collecting personal information via the Services, you authorize Xplarion and its authorized service partners to use and process Content and Account Data (including any personal information) in these countries.

Whenever we transfer personal information from users located in the European Economic Area to a third-party service provider in a country deemed inadequate under EU law, we do so using approved legal adequacy mechanisms, including the implementation of EU Standard Contractual Clauses.

Cookies and Similar Technologies

When you visit or interact with our Services, we or our authorized third-party service providers may use cookies and similar technologies to provide you with a better, faster, and safer experience, and for analytics and marketing purposes. Details on how we use cookies are in our Cookie Notice. You can manage your cookie preferences at any time on our Cookie Preferences page.

Your Choices

Marketing Emails

You may opt out of Xplarion marketing communications at any time by following the unsubscribe instructions included in each marketing email or by contacting us at info@xplarion.com.

Customized Advertising

We may use Account Data to customize advertising directed to you, utilizing third-party ad networks. The Network Advertising Initiative offers tools to help you understand which third parties have enabled cookies for your browser and to opt out of those cookies.

Children

Our Services are not intended for use by children. The Services should only be accessed by individuals who are at least 18 years old.

Changes to This Privacy Policy

Xplarion reserves the right to make changes to this Privacy Policy at any time. If we make changes, we will post them to this page and encourage you to review it periodically. For material changes, we will notify you by email or through a notice within the Services prior to the change taking effect.

Contacting Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us: