Privacy Policy

Last revised on: June 20, 2025

This Privacy Policy describes the privacy practices of Group14 Technologies, Inc. (“Group14,” “we,” “us” or “our”) and how we handle personal information that we collect as a controller through our website at www.group14.technology (the “Site”) and other activities described in this Privacy Policy, and that we collect as a processor on behalf of our business customers through our mobile application and web-based platform (the app and platform collectively, the “Services”).

If you are located in the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), please consult the Notice to European Users section below for additional information.

 

What information do we collect?

Group14 may collect information, which includes, but it not limited to, the following:

• Personal identification information: Such as your first and last name, email address, mailing address, professional title and company name, and phone number.
• Communications: Information that we exchange with you, including when you contact us with questions or feedback, through the Site, social media, or otherwise.
• Marketing data: Such as your preferences for receiving our marketing communications, details about your engagement with them, and information about how you heard about us.
• Device data: Such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier.
• General location information: Such as city, state, or geographic area.
• Online activity data: Such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Site, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.
• Communication interaction data: Such as your interactions with our email, or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

How do we collect your data?

You directly provide Group14 with most of the data we collect. We collect data and process data when you:

• Provide information to us (e.g., through our Site or when you use the Services).
• Communicate with us with questions or feedback.
• Use or view our website via your browser’s cookies and similar technologies (such as web beacons, pixels, tags, and scripts).

We may also automatically log certain types of information about you, your computer or mobile device, and your interactions over time with us, as described in the “What data do we collect?” section

How will we use your data?

Our legal bases for processing. In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use. Our legal bases along with the purposes for processing your personal information described in this Privacy Policy are listed below:

• Contractual Necessity. Where we need to process your personal information to deliver our Services to you (including our Site).
• Legitimate Interests. Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Consent. Where we have your specific consent to carry out the processing for the Purpose in question.
• Compliance with Law. Where we need to comply with a legal or regulatory obligation.

We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information.

Service delivery

• Legal basis: Contractual Necessity
• Reason for collection: To provide, operate, maintain, and improve the Site, the Services, and our business; communicate with you about the Site and Services (including announcements, updates, security alerts, and support/administrative messages); understand your needs and interests, and personalize your experience; and provide support and respond to your requests, questions, and feedback.

Service providers

• Legal basis: Contractual Necessity
• Reason for collection: Third-parties that provide services on our behalf or help us operate the Site and Services or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).

Research and development

• Legal basis: Legitimate Interests
• Reason for collection: To analyze and improve the Site and Services, and our business. As part of these activities, we may create aggregated, de-identified, or anonymous data from personal information we collect. We may use and share this aggregated, de-identified, or anonymous data with third-parties for our lawful business purposes. We will maintain and use any de-identified data only in a de-identified fashion and will not attempt to re-identify such data.

Marketing and business partners

• Legal basis: Legitimate Interests & Consent
• Reason for collection: To send you Group14-related marketing communications about our products, services, or promotions that may be of interest to you. Third-parties with whom we collaborate on joint activities, with whom we have entered into joint marketing relationships or other joint ventures, or who we think may offer you products or services that you may enjoy.

Compliance, protection, and professional advisors

• Legal basis: Compliance with Law
• Reason for collection: To comply with applicable laws, lawful requests, and legal process (e.g., subpoenas, government requests); protect our, your, or others’ rights, privacy, safety, or property (including legal claims); audit our internal processes for compliance; enforce terms and conditions; and prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity (including cyberattacks and identity theft). Professional advisors such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees

• Legal basis: Legitimate Interests
• Reason for collection: Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Group14 or our affiliates.

How do we store your data?

Group14 securely stores your data using technical, organizational, and physical safeguards designed to protect the personal information we collect. We are headquartered in the United States.

Group14 will keep your personal information generally to fulfill the purposes for which we collected it, including for the purposes described in the “How will we use your data?” section. However, in some circumstances, we will retain your personal information for longer periods of time, as long as it is necessary and relevant for our operations and to provide our Site and Services, and to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Site terms and Services terms and take other actions as permitted by law. Once this time period has expired, we may either delete it, anonymize or deidentify it, or isolate it from further processing.

Marketing

Group14 may send you information about products and services of ours that we think you might like. We may also share information with our business and marketing partners who may offer you products or services that you may enjoy.

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop Group14 from contacting you for marketing purposes or giving your data to other members of the Group14 Group.

If you no longer wish to be contacted for marketing purposes, you may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us using the details below.

What are your data protection rights?

Group14 would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access – You have the right to request Group14 for copies of your personal data. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that Group14 correct any information you believe is inaccurate. You also have the right to request Group14 to complete information you believe is incomplete.
• The right to erasure – You have the right to request that Group14 erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that Group14 restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to Group14’s processing of your personal data where we are relying on legitimate interests (or those of a third-party) and there is something about your particular situation that makes you want to object to processing on this ground, or where we are processing your personal information for direct marketing purposes.
• The right to data portability – You have the right to request that Group14 transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• The right to withdraw consent – When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you make a request, we will respond to you within 31 calendar days. If you would like to exercise any of these rights, please contact us at our email, call us, or write to us using the contact details provided below.

Cookies:

What are cookies?

Cookies are small data files containing a unique identifier that are placed on your computer or mobile device when you visit a website. Cookies and similar technologies enable operators or websites to recognize your device and collect information from it when you interact with them and serve different purposes, like helping us understand how our Site is being used, letting you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experience.

For further information, visit allaboutcookies.org.

How do we use cookies?

Group14 uses cookies and similar technologies in a range of ways to improve your experience on our website, including:

• Improving and personalizing your experience.
• Providing our Services.
• Analyzing Site performance.
• For marketing purposes.
• Understanding how you use our website.

What types of cookies do we use?

There are a number of different types of cookies; however, our website uses:

• Strictly Necessary cookies: These cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will not work as they should.
• Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Site. They help us to know which pages are the most and least popular and see how visitors move around the Site and gather information on error messages. If you do not allow these cookies, we will not know when you have visited our Site, and will not be able to monitor its performance.
• Functional cookies: These cookies enable the Site to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
• Targeting cookies: These cookies record your visit to our Site, the pages you have visited, and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third-parties for this purpose. These cookies may be set through our Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other websites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

How to manage cookies

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of our Site. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise, you should use the ‘Help’ option in your internet browser for more details, for example:

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari

For performance, targeting, and functionality cookies, we request your consent before placing them on your device. You can give your consent by clicking on the appropriate button on the cookie banner displayed to you. If you do not wish to give consent or wish to withdraw your consent to any performance or targeting and functionality cookies at any time, you will need to delete, and block or disable cookies via your browser settings. Please note that disabling these cookies will affect the functionality of the Site and may prevent you from being able to access certain features on the Site.

Privacy policies of other websites

The Group14 website contains links to other websites, mobile applications, and other online services operated by third-parties. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third-party. We do not control websites, mobile applications, or online services operated by third-parties, and we are not responsible for their actions nor are they subject to this Privacy Policy.

Changes to our privacy policy

Group14 keeps its privacy policy under regular review and places any updates on this web page. We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Site. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We recommend that you check this Privacy Policy periodically for any updates or changes.

How to contact us

If you have any questions about Group14’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us:

• by using the following email: legal@group14.technology
• by mail at the following address: Group14 Technologies, Inc., Attn: Legal Department, 400 Fairview Avenue N., #900, Seattle, WA 98109

NOTICE TO EUROPEAN USERS

Where this Notice to European Users applies. The information provided in this “Notice to European Users” section applies where we are processing the personal information of individuals located in the European Economic Area (EEA) or the United Kingdom (UK). The EEA and UK jurisdictions are together referred to as “Europe”.

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from which they are either directly identified or can be identified.

Controller. Group14 Technologies, Inc.is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)).

No obligation to provide personal information. You do not have to provide personal information to us. However, if we need to process your personal information either to comply with applicable law or to deliver our Services to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Services to you. We will notify you if this is the case at the time.

No sensitive personal information. In accordance with Article 9(2) of the GDPR, we ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Services.

No automated decision-making and profiling. As part of the Services, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We will let you know if that changes by updating this Privacy Policy.

Security. We have put in place procedures to deal with breaches of personal information. In the event of such breaches, we have procedures in place to work with applicable regulators. In addition, in certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal information.

Data Processing outside Europe. We are a US-based company and many of our service providers, advisers, partners or other recipients of data are also based in the US. This means that, if you use the Services, your personal information will necessarily be accessed and processed in the US. It may also be provided to recipients in other countries outside Europe. It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the US legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws. Where we share your personal information with third-parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it in accordance with applicable privacy laws by making sure one of the following mechanisms is implemented:

• Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
• Transfers to territories without an adequacy decision.
  • We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the US, see above). However, in these cases:
    • We may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
    • In limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such a country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

How to contact the appropriate authority

Group14 has appointed Bird & Bird DPO Services SRL as a Data Protection Officer (DPO), and the DPO may be reached:

• by using the following email: DPO.GROUP14@twobirds.com
• by mail at the following address: Bird & Bird DPO Services SRL, Avenue Louise 235 b 1, 1050 Brussels, Belgium.

Should you wish to report a complaint or if you feel that Group14 has not addressed your concern in a satisfactory manner, you may contact the data protection regulator in your habitual place of residence.

You can identify the relevant data protection authority of your respective country at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en