Privacy Policy

Ancientel LLC ("Ancientel," "we," "our," or "us"), a Kentucky limited liability company, operates the geopolitical intelligence platform at ancientel.com and its associated services (collectively, the "Platform"). This Privacy Policy describes the personal information we collect, how we use and share it, your rights, and how to contact us with questions or requests. By accessing or using the Platform, you agree to the practices described in this Policy.

1. Scope of This Policy

This Policy applies to personal information collected through the Platform, including our website, web application, API, and any related services. It does not apply to third-party websites or services linked from the Platform. If you are accessing the Platform on behalf of an organization under a professional, institutional, or enterprise agreement, that agreement may supplement this Policy.

2. Information We Collect

2.1 Information You Provide Directly

When you create an account or use the Platform, we collect:

• ▪  Email address — your login identifier and primary point of contact.
• ▪  Password — stored only as a bcrypt cryptographic hash (cost factor 12). We never store or transmit your plaintext password.
• ▪  Display name — collected automatically when you sign in via Google OAuth from your Google profile.
• ▪  Demographic context — optional, self-reported information you choose to provide to personalize your intelligence experience, such as your industry, professional background, geographic focus, or current decision context. This field is entirely voluntary.
• ▪  Assessment and chat content — the text of your conversations, questions, and assessment requests submitted to the Platform.
• ▪  Referral information — if you participate in the Affiliate Program, we collect your referral link activity and commission-eligible conversion data.

2.2 Information Collected Automatically

When you access the Platform, we automatically collect:

• ▪  IP address — collected at account creation and during sign-in for security purposes and to prevent multi-account abuse.
• ▪  Log data — server logs may include your IP address, browser type, operating system, referring URL, pages visited, and timestamps.
• ▪  Session data — authentication session tokens stored as secure HTTP-only cookies to maintain your logged-in state.
• ▪  Usage and billing data — assessment credit balances, usage periods, monthly spending, auto-recharge configuration, and subscription tier.
• ▪  Account state — subscription tier, account status, onboarding progress, and access timestamps.

2.3 Cookies and Tracking Technologies

The Platform uses the following cookies and similar technologies:

• ▪  Authentication session cookie — a secure, HTTP-only cookie that maintains your authenticated session. This cookie is strictly necessary for the Platform to function and cannot be disabled without logging out.
• ▪  Preference cookies — if applicable, cookies that remember your display preferences. These are functional cookies.

We do not use advertising cookies, cross-site tracking cookies, or third-party behavioral advertising technologies. If we introduce analytics or additional tracking technologies in the future, we will update this Policy and, where required by applicable law, seek your consent.

2.4 Payment Information

Payment processing is handled exclusively by Stripe, Inc. Ancientel does not store full payment card numbers, CVV codes, or bank account details. We retain only limited payment metadata provided by Stripe: your Stripe customer ID, card brand, and last four digits of your card number — solely for billing reference and customer service purposes. Full payment instrument data resides exclusively at Stripe and is governed by Stripe's privacy policy.

2.5 Information We Do Not Collect

Unless voluntarily disclosed by you in a chat message or demographic context field, we do not intentionally collect:

• ▪  Government identification numbers (Social Security numbers, passport numbers, driver's license numbers).
• ▪  Financial account numbers or full payment card data.
• ▪  Health or medical information.
• ▪  Biometric data.

If you enter such information in the chat interface or demographic context fields, it will be transmitted to our AI provider as described in Section 4.

3. How We Use Your Information

We use the information we collect for the following purposes:

• ▪  Service delivery — to provide, operate, and maintain the Platform and generate intelligence assessments and daily briefs.
• ▪  Authentication and security — to verify your identity, maintain your session, and prevent unauthorized access, fraud, and multi-account abuse.
• ▪  Payment processing — to process subscriptions, assessment credit purchases, and affiliate commission payouts.
• ▪  Personalization — to apply your demographic context to intelligence outputs, tailoring assessments to your stated background and situation.
• ▪  Communications — to send transactional emails (account verification, billing receipts, security alerts) and, with your consent, informational updates about the Platform.
• ▪  Affiliate program administration — to track referrals, calculate commissions, and process commission payments.
• ▪  Platform improvement — to analyze usage patterns in aggregate, anonymized form and improve the quality of intelligence outputs.
• ▪  Legal compliance — to comply with applicable laws, respond to lawful requests, and enforce our Terms and Conditions.
• ▪  Safety — to detect and address technical issues, security incidents, and violations of our policies.

4. AI Processing — Data Transmitted to Anthropic and Tavily

4.1 Anthropic

The Platform is powered by Claude, an AI system developed by Anthropic PBC ("Anthropic"). To generate intelligence assessments and daily briefs, we transmit the following to Anthropic via their API:

• ▪  The text of your chat messages and assessment requests.
• ▪  Your demographic context (if provided), included in the AI system prompt to personalize your intelligence experience.
• ▪  Prior conversation turns (up to the last 12 exchanges) to maintain conversational continuity within a session.

Anthropic API data retention: As of the effective date of this Policy, Anthropic retains API inputs and outputs for up to 7 days for trust and safety review purposes, after which they are automatically deleted. Your data is not used by Anthropic to train their AI models under the standard API agreement. This retention period is subject to change; we encourage you to review Anthropic's current privacy and API data retention documentation.

4.2 Tavily (Web Search)

During certain intelligence assessments, the Platform may invoke web search capabilities powered by Tavily. When this occurs, query text derived from your assessment request may be transmitted to Tavily to retrieve current information from the web. This query text may reflect terms you entered. Tavily's own privacy policy governs their handling of this data.

4.3 Important Notice Regarding Sensitive Information

We strongly recommend that you do not enter the following types of information into the assessment interface or demographic context fields:

• ▪  Financial account numbers, Social Security numbers, or other government identification numbers.
• ▪  Medical, health, or biometric information.
• ▪  Attorney-client privileged communications or confidential legal matters.
• ▪  Classified or government-restricted information.

Any information you enter into the Platform may be transmitted to Anthropic and, for search queries, to Tavily, as described in this Section. Ancientel is not responsible for information you voluntarily disclose in the assessment interface.

5. Third-Party Service Providers (Subprocessors)

We share personal data with the following service providers who process data on our behalf. Each provider is subject to appropriate data processing agreements and is obligated to protect your data.

We do not sell your personal information to third parties. We do not share your personal information with third parties for their own marketing purposes.

6. Legal Requests and Law Enforcement

We may disclose your personal information if we believe in good faith that disclosure is required or permitted by law, including:

• ▪  In response to a valid subpoena, court order, search warrant, or other lawful legal process.
• ▪  To comply with applicable federal, state, or local laws and regulations.
• ▪  To protect the rights, property, or safety of Ancientel, our members, or the public.
• ▪  In connection with an investigation of fraud, violation of our Terms and Conditions, or other illegal activity.
• ▪  In connection with a merger, acquisition, reorganization, or sale of all or a portion of our assets, in which case your information may be transferred as a business asset subject to the privacy protections of this Policy.

Where permitted by law, we will attempt to notify you before disclosing your personal information in response to a legal request, unless prohibited by law or court order from doing so.

7. Data Retention

We retain your personal information as follows:

8. Data Security

We implement reasonable technical, administrative, and physical security measures to protect your personal information, including:

• ▪  bcrypt cryptographic password hashing (cost factor 12).
• ▪  TLS encryption for all data in transit.
• ▪  Database access controls and role-based permissions.
• ▪  Secure, HTTP-only authentication cookies.

No security system is impenetrable. We cannot guarantee that your personal information will never be accessed, disclosed, altered, or destroyed by a breach of our security measures. In the event of a security breach affecting your personal information, we will notify you as required by applicable law.

9. Your Rights and Choices

9.1 Access, Correction, and Deletion

You may access, review, and update most of your account information from your account settings page. You may delete your account at any time from account settings. Upon deletion, we will: (a) anonymize your personal identifiers (email, display name, IP address, demographic context, and password hash); (b) delete your conversation history; (c) delete your Stripe customer record. Financial transaction records are retained as described in Section 7.

9.2 Email Opt-Out and Unsubscribe

You may opt out of marketing and non-transactional email communications at any time by: (a) clicking the unsubscribe link in any marketing email; or (b) visiting ancientel.com/unsubscribe. Transactional emails — including account verification, billing receipts, security notifications, and service alerts — may continue regardless of marketing opt-out status, as required by applicable law.

9.3 Demographic Context

Your demographic context is entirely voluntary. You may update, modify, or delete it at any time from your account settings. Deletion removes it from all future AI processing immediately.

9.4 Data Portability

You have the right to receive a copy of your personal account data and conversation history in a portable, machine-readable format. To submit a portability request, contact us at brief@ancientel.com. We will respond within 45 days.

9.5 How to Submit a Rights Request

To exercise any of your privacy rights, contact us at:

• ▪  Email: brief@ancientel.com (subject line: "Privacy Rights Request")
• ▪  Website: ancientel.com

We will acknowledge your request within 10 business days and respond within 45 days. If we need additional time, we will notify you and may extend the response period by an additional 45 days where permitted by applicable law. We may ask you to verify your identity before processing your request.

9.6 Appeals

If we decline to take action on your rights request, you may appeal our decision by contacting us at brief@ancientel.com with the subject line "Privacy Rights Appeal." We will respond to your appeal within 45 days and will provide a written explanation of our reasons. If your appeal is denied, you may contact the Kentucky Attorney General's Office at ag.ky.gov or your applicable state attorney general.

10. California Privacy Rights (CalOPPA / CCPA)

If you are a California resident, you have the following rights under California law:

• ▪  Right to know — to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, our business purposes for collecting it, and the categories of third parties with whom we share it.
• ▪  Right to delete — to request deletion of personal information we have collected, subject to certain exceptions.
• ▪  Right to correct — to request correction of inaccurate personal information.
• ▪  Right to opt out of sale — Ancientel does not sell personal information to third parties.
• ▪  Right to non-discrimination — we will not discriminate against you for exercising any of these rights.

To exercise your California privacy rights, contact us as described in Section 9.5. California residents may also submit requests through a designated agent. We do not respond to Do Not Track browser signals because no uniform standard exists. We do not track users across unaffiliated third-party websites.

11. Kentucky Privacy Rights (KCDPA)

As a Kentucky limited liability company, Ancientel is subject to the Kentucky Consumer Data Protection Act (KCDPA), effective January 1, 2026. Kentucky residents have the following rights:

• ▪  Right to access — to confirm whether we process your personal data and to access that data.
• ▪  Right to correct — to correct inaccurate personal data we hold about you.
• ▪  Right to delete — to request deletion of personal data you have provided or that we have collected about you.
• ▪  Right to data portability — to receive a copy of your personal data in a portable, readable format.
• ▪  Right to opt out of profiling — to opt out of the processing of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise your Kentucky privacy rights, contact us as described in Section 9.5. You have the right to appeal our decision as described in Section 9.6. You may also contact the Kentucky Attorney General at ag.ky.gov.

12. Age Requirement and Children's Privacy

The Platform is intended solely for individuals who are 18 years of age or older. We do not knowingly collect or solicit personal information from individuals under the age of 18. By creating an account, you affirmatively represent that you are at least 18 years old.

If we learn that we have collected personal information from a person under the age of 18, we will take prompt steps to delete that information. If you believe a minor has provided us with personal information, please contact us immediately at brief@ancientel.com.

The Platform is not directed at children and does not have actual knowledge of collecting personal information from children under the age of 13. This Platform is a paid professional intelligence service with adult-oriented content.

13. Cross-Border Data Transfers

Ancientel is based in the United States. If you access the Platform from outside the United States, your personal information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country.

Our primary service providers — including Neon (Washington, DC), Vercel, Stripe, Anthropic, Google, and Tavily — are based in the United States. By using the Platform, you consent to the transfer of your personal information to the United States.

14. Data Breach Notification

In the event of a security breach that affects your personal information, we will notify you as required by applicable law. Kentucky law requires notification of affected individuals within 30 days of discovery of a breach. We will provide notification via email to the address associated with your account and, where required, to relevant regulatory authorities.

15. Marketing Communications

We may send you informational updates, product announcements, and intelligence briefings by email if you have opted in to marketing communications or where permitted by applicable law. You can opt out of marketing communications at any time as described in Section 9.2. We will not send you marketing communications without a lawful basis for doing so.

16. Third-Party Links and Services

The Platform may display links to or references to third-party websites, publications, and services. This Privacy Policy does not apply to those third parties. We are not responsible for the privacy practices of third-party sites and encourage you to review their privacy policies before providing any personal information to them.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or our services. When we make material changes, we will: (a) update the "Last Updated" date at the top of this page; (b) notify active subscribers by email at the address associated with their account; and (c) post a notice on the Platform. Your continued use of the Platform after the effective date of an updated Policy constitutes your acceptance of the changes.

18. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our data practices:

Ancientel LLC 212 N. 2nd St., Ste 100, Richmond, KY 40475 Email: brief@ancientel.com Website: ancientel.com

For privacy rights requests, use the subject line "Privacy Rights Request." For appeals, use "Privacy Rights Appeal." We will acknowledge your message within 10 business days.

Ancientel LLC | ancientel.com | brief@ancientel.com | Effective June 5, 2026