Seldon - Privacy Policy

We believe privacy should be understandable. This Privacy Policy explains what information we collect, how we use it, who we share it with, and the choices available to you when you use Seldon's Services.

Blok Intelligence Inc., doing business as Seldon (“Seldon”, “we”, “us”, or “our”), is committed to protecting your privacy and handling personal information responsibly.

This Privacy Policy explains how we collect, use, disclose, and protect personal information when you:

• visit our website;
• create or use a Seldon account;
• use our Services;
• communicate with us; or
• otherwise interact with Seldon.

Depending on the context, Seldon acts either as a data controller or a data processor (or service provider). Additional information regarding the processing of Customer Data is available in our Data Processing Addendum, and the contractual terms governing use of the Services are set out in our Terms of Service or applicable Master Services Agreement.

If you have any questions about this Privacy Policy or our privacy practices, you can contact us at hello@seldon.com.

We collect information in three ways: information you provide directly, information generated through your use of the Services, and information collected automatically.

Information You Provide

Depending on how you use the Services, you or your organization may provide information including:

• name, email address, company, job title, and account details;
• authentication credentials;
• billing and payment information;
• support requests and communications with us;
• prompts, instructions, and other inputs submitted to the Services;
• repositories, source code, documentation, configuration files, uploaded files, browser automation configuration and inputs, and other related materials;
• URLs and other information required to perform Customer-authorized workflows; and
• any other Customer Data submitted through the Services.

Information Generated Through Your Use of the Services

As you use the Services, we may generate or store information including:

• reports, simulations, recommendations, test plans, quality assessments, and other outputs generated by the Services;
• software quality assurance results and generated test plans;
• browser automation results and interaction metadata;
• usage logs;
• diagnostic and performance information; and
• aggregated and de-identified Usage Data used to operate, maintain, secure, and improve the Services.

Information Collected Automatically

When you visit our website or use the Services, we may automatically collect information such as:

• IP address;
• browser and device information;
• operating system;
• referring URLs;
• usage analytics;
• cookie identifiers; and
• information about how you interact with our website and Services.

We use cookies and similar technologies to operate, secure, and improve the Services. Additional information is available in our Cookie Policy where applicable.

Certain features of the Services allow Customers to connect third-party systems, including source code repositories, development environments, identity providers, issue tracking systems, and other development tools.

When Customer authorizes such integrations, Seldon may receive and process information made available through those services, including repository metadata, source code, documentation, configuration files, pull requests, issue information, authentication details, and other Customer Data necessary to provide the Services.

Seldon accesses and processes such information solely for the purpose of providing the Services requested by Customer. Customer remains responsible for selecting, configuring, and managing the permissions granted to connected third-party systems.

We use personal information to:

• provide, maintain, secure, and support the Services;
• authenticate users and manage accounts;
• perform Customer-authorized workflows;
• generate reports, simulations, quality assessments, recommendations, and other outputs;
• provide software validation, quality assurance, browser automation, and related features;
• improve the reliability, security, performance, and functionality of the Services;
• communicate with Customers and respond to inquiries or support requests;
• comply with legal obligations and enforce our agreements; and
• detect, investigate, and prevent fraud, abuse, security incidents, or other unlawful activity.

Where we process Customer Data on behalf of our Customers, we do so only in accordance with Customer's documented instructions, the applicable agreement, and our Data Processing Addendum.

We do not use Customer Data to train generalized artificial intelligence models made available to other customers or third parties unless Customer has expressly authorized us to do so.

Legal Bases for Processing (Where GDPR Applies)

Where the General Data Protection Regulation (“GDPR”) or UK GDPR applies, Seldon processes personal information on one or more of the following legal bases:

The Services use artificial intelligence, machine learning, browser automation, and software analysis technologies to generate reports, simulations, quality assessments, recommendations, and other outputs.

To provide these features, Customer Data may be processed by Seldon and, where applicable, by carefully selected third-party AI service providers acting on Seldon's behalf.

Outputs are generated using probabilistic models and may be inaccurate, incomplete, inconsistent, or unsuitable for Customer's intended use. Customers remain responsible for reviewing and validating all outputs before relying upon or implementing them.

Seldon does not attempt to re-identify individuals from de-identified information or use Customer Data to infer sensitive characteristics beyond Customer's documented instructions.

Automated Decision-Making

Seldon does not make decisions on behalf of individuals and does not engage in solely automated decision-making that produces legal or similarly significant effects within the meaning of applicable data protection law.

Customers remain responsible for determining whether and how to rely upon Outputs generated by the Services.

We may share personal information:

• with service providers and subprocessors that assist us in providing, maintaining, securing, and supporting the Services;
• with cloud infrastructure, hosting, authentication, repository integration, analytics, payment, communications, and artificial intelligence providers acting on our behalf;
• with professional advisers, auditors, insurers, and legal counsel where reasonably necessary;
• in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business;
• where required by law, regulation, court order, or legal process; or
• where necessary to establish, exercise, or defend legal claims or protect the rights, property, or safety of Seldon, our Customers, or others.

A current list of our subprocessors is available at trust.seldon.com.

We do not sell personal information or share personal information for cross-context behavioral advertising.

Seldon may process personal information in the United States and other countries where we or our service providers operate.

Where required by applicable data protection law, we implement appropriate safeguards for international transfers of personal information, including the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or other lawful transfer mechanisms.

Additional information regarding international transfers is available upon request.

We retain personal information only for as long as necessary to:

• provide and support the Services;
• comply with legal, regulatory, accounting, or reporting obligations;
• resolve disputes and enforce our agreements; and
• maintain the security and integrity of the Services.

Where we process Customer Data on behalf of Customers, retention is governed by the applicable agreement and, where applicable, the Data Processing Addendum.

Upon termination of the applicable agreement or Customer's use of the Services, Customer Data will be returned or deleted in accordance with the applicable agreement and our documented retention practices, except where retention is required by law.

We may retain aggregated, anonymized, or de-identified information that does not identify Customer or any individual. Where reasonably practicable, personal information is securely deleted or anonymized once it is no longer required for the purposes described in this Privacy Policy.

Depending on your location and applicable law, you may have certain rights regarding your personal information, including the right to:

• access the personal information we hold about you;
• correct inaccurate or incomplete personal information;
• request deletion of your personal information;
• restrict or object to certain processing activities;
• request a copy of your personal information in a portable format; and
• withdraw consent where processing is based on consent.

Where Seldon processes Customer Data on behalf of a Customer, we generally act as a data processor or service provider. If you wish to exercise your rights in relation to such Customer Data, please contact the relevant Customer directly. We will reasonably assist our Customers in responding to such requests where required by applicable law.

To exercise your privacy rights or ask questions about this Privacy Policy, please contact us at privacy@seldon.com.

If you are a California resident, you may also have rights under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). Seldon does not sell personal information or share personal information for cross-context behavioral advertising, and we do not discriminate against individuals for exercising their privacy rights.

Where applicable under the California Privacy Rights Act (“CPRA”), Seldon does not use or disclose sensitive personal information for purposes other than those permitted by applicable law and does not sell or share sensitive personal information for cross-context behavioral advertising.

Seldon maintains administrative, technical, and organizational safeguards designed to protect personal information appropriate to the nature of the Services and the risks presented by our processing activities.

These safeguards include measures designed to protect personal information against unauthorized access, use, disclosure, alteration, or destruction.

Where Customer authorizes the Services to access repositories, browser automation, or other connected third-party systems, Seldon uses such access solely for the purpose of providing the Services.

While no method of transmission or storage is completely secure, we continuously review and improve our security practices to help protect the information entrusted to us.

Additional information regarding our security practices is available in our Trust Center and, where applicable, our Data Processing Addendum.

The Services are intended for business use only and are not directed to children.

We do not knowingly collect personal information from individuals under the age required by applicable law to provide valid consent. If you believe that a child has provided personal information to us, please contact us at privacy@seldon.com, and we will take appropriate steps to delete such information.

We may update this Privacy Policy from time to time to reflect changes to our Services, applicable law, or our privacy practices.

When we make material changes, we will update the “Last Updated” date above and, where required by applicable law, provide additional notice through the Services or by other appropriate means.

Your continued use of the Services following the effective date of an updated Privacy Policy constitutes acceptance of the revised Privacy Policy, except where applicable law requires a different form of consent.

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@seldon.com.