Privacy Policy

Last updated: September 30, 2026

This Privacy Notice for Georgios Sgouridis (“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• Download and use our mobile application (BP Copilot), or any other application of ours that links to this Privacy Notice
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at bpcopilot\@studio9.app.

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using the table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us (Section 1).

Do we process any sensitive personal information? Some of the information may be considered “special” or “sensitive” in certain jurisdictions, for example your health data. We only process this sensitive personal information with your explicit consent, and it is processed entirely on your device. Learn more about sensitive information we process (Section 1).

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information (Section 2).

In what situations and with which parties do we share personal information? We do not operate our own servers. We may share limited technical and purchase-related information with specific third-party service providers. Learn more about when and with whom we share your personal information (Section 4).

How do we keep your information safe? Because we do not operate our own servers, your health data remains on your device, protected by your device’s own security features. For information handled by our service providers, we rely on their technical and organizational security measures. Learn more about how we keep your information safe (Section 7).

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights (Section 9).

How do you exercise your rights? The easiest way to exercise your rights is by contacting us using the details in Section 14. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full below.

Table of Contents

1. What Information Do We Collect?
2. How Do We Process Your Information?
3. What Legal Bases Do We Rely On to Process Your Personal Information?
4. When and With Whom Do We Share Your Personal Information?
5. Is Your Information Transferred Internationally?
6. How Long Do We Keep Your Information?
7. How Do We Keep Your Information Safe?
8. Do We Collect Information From Minors?
9. What Are Your Privacy Rights?
10. Controls for Do-Not-Track Features
11. Do United States Residents Have Specific Privacy Rights?
12. Do Other Regions Have Specific Privacy Rights?
13. Do We Make Updates to This Notice?
14. How Can You Contact Us About This Notice?
15. How Can You Review, Update, or Delete the Data We Collect From You?

1. What Information Do We Collect?

No Company-Operated Servers. We do not operate our own servers or backend infrastructure of any kind. The personal information described in this Privacy Notice is either processed directly on your device or, where noted below, processed by our named third-party service providers (Sentry and RevenueCat) on their own infrastructure.

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You — Stored Locally on Your Device Only. If you choose to provide the following information, it is stored locally on your device only and used for app functionality, such as personalizing PDF reports and enabling a simplified send feature that shares a PDF report with a pre-configured recipient via your device’s native email or share function.

• Name
• Date of birth
• Recipient email address

Providing this information is optional and used only for app functionality. If you do not provide it, some app features may not be available.

Sensitive Information. When necessary, with your explicit consent, we process the following categories of sensitive information:

• Health data

Payment Data. If you choose to make a one-time in-app purchase, payment data necessary to process it — such as your payment instrument number and the security code associated with your payment instrument — is collected, handled, and stored directly by our payment processor, RevenueCat. This data is never transmitted to or stored by us, as we do not operate any servers. See Section 4 for more details.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s health data from HealthKit and Health Connect (blood pressure and resting heart rate), and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

On-Device Health Data Processing. Health data synced from Apple HealthKit or Health Connect (blood pressure and resting heart rate) is processed entirely on your device to generate charts and PDF reports within the app. This health data is not transmitted to or accessible by any third party, including our service providers Sentry and RevenueCat.

Exporting and Sharing Your Data. The app allows you to export your health data in various file formats (such as PDF or CSV) and share these exports using your device’s native sharing features (such as email, messaging apps, AirDrop, cloud storage, or printing). This export and sharing — including the one-tap send feature described above — is performed entirely by you, at your own discretion, through your device’s native functionality; we do not transmit this data ourselves. Once exported or shared, this data is no longer within our control, is not subject to this Privacy Notice, and is instead governed by the privacy practices of whichever service or recipient you choose to share it with.

This information is primarily needed to maintain the security and operation of our application(s) and for troubleshooting.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services.

We do not use any analytics tools, and no analytics or performance-monitoring features of our service providers are enabled — Sentry is configured for crash and error reporting only.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information automatically collected when you access or use our Services and which is recorded in crash and error logs by our service provider, Sentry. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings). Sentry does not collect or transmit personal identifiers beyond default technical crash context, and does not receive health data.
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

2. How Do We Process Your Information?

In Short: We process your information to provide and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. (Retention period: For as long as necessary to provide the service and manage purchases and entitlements, or until the information is no longer required, subject to the retention periods of our service providers.)
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. (Retention period: For as long as necessary for security and diagnostic purposes, in accordance with the retention period configured for our service provider, Sentry.)
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

We do not carry out any automated decision-making, including profiling, that produces legal or similarly significant effects concerning you.

3. What Legal Bases Do We Rely On to Process Your Personal Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time (see “Withdrawing your consent” in Section 9).
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms — for example, to diagnose problems and/or prevent fraudulent activities.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

Processing of Health Data. Because health data is a special category of personal data under Article 9 GDPR, we only process it on the basis of your explicit consent, given when you grant HealthKit or Health Connect permissions within the app. This health data is processed entirely on your device and is not transmitted to us or to any third party. You may withdraw this consent at any time through your device’s health data permission settings, which will stop the app from accessing this data going forward.

Provision of Data. Providing personal information described in this notice is generally voluntary. If you choose not to grant certain permissions (such as HealthKit or Health Connect access) or not to provide optional information (such as your name, date of birth, or a recipient email), some features of the App may not be available to you, as described in Section 1.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or accuracy of the information, and collection is reasonable for investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. When and With Whom Do We Share Your Personal Information?

In Short: We do not operate our own servers. We may share limited information described in this section with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The third parties we may share personal information with are as follows:

• App Crash and Error Reporting — Sentry. Sentry receives technical diagnostic data (such as device information, operating system version, and crash logs) to help us identify and fix bugs. Only Sentry’s crash and error reporting feature is enabled; its analytics and performance-monitoring features are not used. Sentry’s default PII-collection setting is disabled in our integration, and Sentry does not receive health data, which is processed entirely on your device. You may find Sentry’s privacy notice here: https://sentry.io/privacy/
• One-Time In-App Purchase Management — RevenueCat. RevenueCat processes payment and purchase information to manage one-time in-app purchases. You may find RevenueCat’s privacy notice here: https://www.revenuecat.com/privacy-policy

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Is Your Information Transferred Internationally?

In Short: We do not operate our own servers. Limited technical and purchase-related information may be transferred, stored, and processed by our third-party service providers in countries other than your own.

Regardless of your location, please be aware that information described in Section 4 may be transferred to, stored by, and processed by our third-party service providers in their own facilities, including facilities in the United States and other countries. Health data is not included in these transfers, as it is processed exclusively on your device and is never sent to us or to any third party.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we require our service providers to take all necessary measures to protect your personal information in accordance with applicable law.

Sentry is self-certified under the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions), which the European Commission and applicable authorities have recognized as providing an adequate level of data protection for transfers to the United States.

European Commission’s Standard Contractual Clauses. For transfers not otherwise covered by an adequacy mechanism, our third-party service providers implement measures to protect personal information, including the European Commission’s Standard Contractual Clauses for transfers of personal information originating from the EEA or UK. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Further details on these safeguards can be provided upon request.

6. How Long Do We Keep Your Information?

In Short: We do not operate our own servers, so we do not directly store your personal information ourselves. Health data is retained only on your device; other information is retained by our service providers.

We do not operate our own servers, so we do not directly store or retain your personal information ourselves. Health data, along with any name, date of birth, or recipient email you choose to provide, is retained only on your device, for as long as you choose to keep it there, and is deleted when you delete the app or manually remove it from your device.

Technical diagnostic information and purchase-related information are retained by our service providers (Sentry and RevenueCat) in accordance with their own retention practices and the retention periods described in Section 2, unless a longer retention period is required or permitted by law.

7. How Do We Keep Your Information Safe?

In Short: Because we do not operate our own servers, your health data remains on your device rather than being exposed to server-side risk. For information handled by our service providers, we rely on their security measures.

Because we do not operate our own servers, your health data is not transmitted to or stored on any server-side infrastructure of ours — it remains on your device, protected by your device’s own security features, such as passcode, biometric lock, and operating system-level encryption.

For technical and purchase-related information handled by our service providers (Sentry and RevenueCat), we rely on the technical and organizational security measures those providers have implemented.

However, despite these safeguards, no electronic transmission over the Internet or information storage technology, including on-device storage, can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat security measures and improperly collect, access, steal, or modify your information. You should only access the Services within a secure environment and keep your device’s operating system and security features up to date.

8. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age (or the equivalent age as specified by law in your jurisdiction).

We do not knowingly collect, solicit data from, or market to children under 18 years of age (or the equivalent age as specified by law in your jurisdiction), nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 (or the equivalent age as specified by law in your jurisdiction) or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at bpcopilot\@studio9.app.

9. What Are Your Privacy Rights?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions like the EEA, UK, Switzerland, and Canada, you have certain rights under applicable data protection laws. These may include the right to: (i) request access and obtain a copy of your personal information, (ii) request rectification or erasure, (iii) restrict the processing of your personal information, (iv) if applicable, data portability, and (v) not be subject to automated decision-making. As noted in Section 2, we do not carry out automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the details in Section 14.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018.

How to contact us:

• Email: bpcopilot\@studio9.app
• Post: See Section 14

What happens after you complain:

• We will acknowledge your complaint within 30 days of receiving it.
• We will investigate without unjustifiable or excessive delay.
• We will keep you informed of progress and explain the outcome.

If you are not happy with our final response, you can refer your complaint to the Information Commissioner’s Office, the UK supervisory authority:

• Website: ico.org.uk/make-a-complaint
• Helpline: 0303 123 1113
• Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or the UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent. If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the details in Section 14, or, for health data specifically, by revoking HealthKit or Health Connect permissions in your device settings.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at bpcopilot\@studio9.app.

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you in particular. For a comprehensive inventory of all personal information we process, please refer to Section 1.

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	YES
D. Commercial information	Transaction information, purchase history, financial details, and payment information	YES
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	YES
G. Geolocation data	Device location	NO
H. Audio, electronic, sensory, or similar information	Images and audio, video, or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level, job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO
L. Sensitive personal information	Health data — processed entirely on your device and not shared with us or any third party	YES

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels
• Facilitation in the delivery of our Services and to respond to your inquiries

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A — For as long as necessary to provide the service, or until the user deletes the information from their device.
• Category B — For as long as necessary to provide the service, or until the user deletes the information from their device.
• Category C — For as long as necessary to provide the service, or until the user deletes the information from their device.
• Category D — For as long as necessary to manage purchases and entitlements, subject to the retention periods of our service providers.
• Category F — For as long as necessary for diagnostic and security purposes, in accordance with the retention period configured for our service provider, Sentry.

Sources of Personal Information

Learn more about the sources of personal information we collect in Section 1.

How We Use and Share Personal Information

Learn more about how we use your personal information in Section 2.

Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in Section 4.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or “sharing” as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (Connecticut)
• Right to review, understand, question, and correct how personal data has been profiled (Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us using the details in Section 14.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request, and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at bpcopilot\@studio9.app. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact details provided in Section 14.

12. Do Other Regions Have Specific Privacy Rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020.

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular to:

• Offer you the products or services that you want
• Respond to or help with your requests

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the details in Section 15.

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner or a breach of New Zealand’s Privacy Principles to the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the details in Section 15.

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator:

• The Information Regulator (South Africa)
• General enquiries: enquiries@inforegulator.org.za
• Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

13. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at bpcopilot\@studio9.app.

Full legal identity and postal contact details are available in our Imprint/Impressum.

15. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please contact us using the details in Section 14.