Privacy Policy

PRIVACY POLICY

Last updated April 23, 2026

1. INTRODUCTION

This Privacy Policy describes how ApeirosInsurance Data Exchange, LLC (“Apeiros,” “we,”“us,” or “our”) collects, stores, uses, andshares (“process”) your information when you interact withus, including but not limited to when you:

  • Visit our website at apeiros.ai;
  • Submit information through our “Contact Us” form;
  • Communicate with us regarding sales inquiries or our products; and
  • Perform other activities described in this Privacy Policy.

Throughout this Privacy Policy, “PersonalInformation” means any information relating to an identified oridentifiable individual. We are committed to ensuring the privacy andintegrity of the Personal Information you share with us or weotherwise collect as we provide information about our products andrespond to your inquiries.

Questions or concerns? Reading this Privacy Policy willhelp you understand your privacy rights and choices. If you do notagree with our policies and practices, please do not use our website.If you still have any questions or concerns, please contact us atprivacy@apeiros.ai.

2. ABOUT APEIROS ANDTHIS POLICY

In Short: Apeiros operates a marketingwebsite. It does not itself provide claims processing services oruser account functionality.

Apeiros operates the marketing websitelocated at apeiros.ai. The website is an informational and marketingpresence: it describes our products, shares company information, andallows prospective customers and other interested parties to get intouch with us through a “Contact Us” form.

Apeiros operates as part of a broadercorporate group. While this website functions as a standalonemarketing presence, information submitted through the site may beshared internally with other companies in our corporate group tosupport business operations (e.g., responding to inquiries).

Apeiros acts as a data controllerfor all information collected through this website.

This Privacy Policyapplies to information collected through the apeiros.aiwebsite. The website does not itself provide alogged-in product, user accounts, or claimsprocessing functionality.

3. WHAT INFORMATION DO WECOLLECT?

3.1 Information YouProvide to Us

In Short: We collect PersonalInformation that you voluntarily provide to us when you contactApeiros through our website.

Apeiros collects Personal Information that you voluntarily provideto us when you complete the “Contact Us” form on apeiros.ai,request information about Apeiros, or otherwise communicate with usby email or similar means. The Personal Information we collectthrough these channels may include:

  • First name
  • Last name
  • Email address
  • Company name
  • Phone number (optional)
  • The content of your message or inquiry
  • Any other information you choose to provide to us in the course of your communicationIf you choose not to provide thisinformation, we may not be able to respond to your inquiry or followup with you about Apeiros

.

3.2 Information Automatically Collected

In Short: Some information — such asyour IP address and browser and device characteristics — iscollected automatically when you visit apeiros.ai.

When you visit the apeiros.ai website (“Services”),Apeiros and our analytics providers automatically collect certaintechnical information about your visit through Google Analytics,server logs, and cookies and similar technologies. This informationis used to operate, secure, and improve the Services and tounderstand how visitors engage with our content. The information weautomatically collect includes:

  • Internet Protocol (IP) address
  • Browser type and version, operating system, device type, and other device characteristics
  • Pages viewed, time spent on each page, and navigation paths through the site
  • Referrer URL (the website or source that directed you to apeiros.ai)
  • UTM and other campaign parameters included in inbound links
  • Approximate geographic location derived from your IP address

Apeiros uses Google Analytics tohelp measure and analyze traffic to the Services. For more detail onthe cookies and similar tracking technologies we use and the choicesavailable to you (including how to opt out of Google Analytics),please see Section 8 (Cookies and Tracking Technologies).

3.3 No Sensitive Personal Information Collected

Apeiros does notintentionally collect or request sensitive Personal Informationthrough the Services. We ask that you do not submit sensitivePersonal Information (such as financial account details, healthinformation, or government identification numbers) through thewebsite or Contact Us form.

If you choose toprovide such information, it will be processed in accordance withthis Privacy Policy.

4. HOW DO WE PROCESS YOURINFORMATION?

In Short: We process your PersonalInformation to respond to inquiries you send us, to follow up aboutproducts and services you have asked about, to understand and improvehow our website performs, to keep the Services secure, and to complywith our legal obligations.

We process your Personal Information for the following purposes:

To respond to contact form inquiries and sales requests. We process the information you submit through our Contact Us form so that we can reply to your question, route it to the appropriate team, and follow through on the conversation you initiated.

To send follow-up communications about products and services you have inquired about, where permitted by applicable law and consistent with your marketing preferences. You can opt out of these communications at any time.

To measure site performance and analyze usage trends so that we can understand how visitors interact with apeiros.ai and improve the content, structure, and performance of the Services.

To protect the Services, including security monitoring, fraud detection, and prevention of abuse or misuse of the site.

To comply with applicable laws, lawful requests, and legal process, including responding to subpoenas, investigations, or requests from governmental authorities, and enforcing our terms and policies.

To save or protect an individual’s vital interest, such as where processing is necessary to prevent harm to a person.

5. WHAT LEGAL BASES DO WERELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your PersonalInformation when we have a valid legal basis to do so. For visitorsin the EU, UK, and Switzerland, that basis is typically ourlegitimate interests, your consent, or a legal obligation we mustmeet.

The General Data Protection Regulation (GDPR) and the UK GDPRrequire us to identify the legal basis on which we rely to processyour Personal Information. The table below sets out the legal basisfor each of our processing purposes.

Processing Purpose

Legal Basis

Responding to contact form inquiries and sales requests

Legitimate interests (responding to communications initiated by you)

Sending follow-up communications about products/services you inquired about

Legitimate interests; consent where required by local law

Website analytics via Google Analytics

Consent (for EU/UK/Swiss visitors through cookie banner); legitimate interests in other jurisdictions

Security and fraud prevention

Legitimate interests (keeping our Services safe)

Complying with legal obligations

Legal obligation

5.1 Additional Legal Bases

Consent. Where we rely on your consent to process your Personal Information — for example, to set non-essential analytics cookies for visitors in the EU, UK, or Switzerland, or to send marketing communications where consent is required by local law — you have the right to withdraw that consent at any time. Withdrawing your consent does not affect the lawfulness of processing carried out before the withdrawal.

Vital interests. In rare circumstances, we may process your Personal Information where it is necessary to save or protect an individual’s vital interest, such as to prevent harm to a person.

Providing your data: ProvidingPersonal Information through our Contact Us form is voluntary. If youchoose not to provide the information requested, we may not be ableto respond to your inquiry or follow up with you about our productsor services.

6. WHEN ANDWITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

6.1 Service Providers and Processors

In Short: We share Personal Informationwith vendors who perform services on our behalf, under contracts thatlimit how they can use it.

We rely on a small set of third-party vendors to operateapeiros.ai and support our business. These vendors act as our serviceproviders or processors — they handle Personal Information only toperform services on our behalf, such as hosting the website,supporting communications, analyzing usage, maintaining the securityand performance of the site, and are subject to contractualobligations regarding confidentiality, security, and data protection.

The categories of service providers we use include:

  • Cloud computing and website hosting services
  • Analytics providers (including Google Analytics
  • CRM and email / marketing automation tools
  • Communication and collaboration tools
  • Security and performance monitoring tools
  • Professional advisors (legal, accounting)
  • Government entities (as required by law)

6.2 Specific Sharing Situations

In addition to our service providers,Personal Information may be shared in the following situations:

Business transfers. We may share or transfer Personal Information in connection with, or during negotiations of, any merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider. If such a transaction occurs, the recipient will be required to honor the commitments made in this Privacy Policy or provide you with notice and choice regarding any material changes.

Google Analytics. We use Google Analytics to understand how visitors interact with apeiros.ai. Google processes analytics data in accordance with its own terms and privacy practices, available at https://policies.google.com/privacy. You can opt out of Google Analytics across all sites by installing the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

Affiliates. We may share Personal Information with our affiliates and other companies within our corporate group for internal business purposes, such as coordinating responses to your inquiries or preparing for potential services. All such entities are bound by appropriate data protection obligations.

Legal and regulatory disclosures. We may disclose Personal Information when we believe in good faith that disclosure is necessary to: (a) comply with applicable law, a lawful request, subpoena, court order, or other legal process; (b) enforce our terms, policies, or agreements; (c) protect the rights, property, safety, or security of Apeiros, our affiliates, our users, or the public; or (d) investigate, prevent, or respond to suspected fraud, security incidents, or abuse.

6.3 No Sale or Sharing of Personal Information

Apeiros does not sell PersonalInformation and does not share Personal Information for cross-contextbehavioral advertising, as those terms are defined under theCalifornia Consumer Privacy Act (CCPA) and its implementingregulations. We have not sold or shared Personal Information in thepreceding twelve (12) months, and we do not sell or share thePersonal Information of minors under sixteen (16) years of age.

Because we do not sell or share Personal Information, we do notpost a “Do Not Sell or Share My Personal Information” link onapeiros.ai.

We honor Global Privacy Control (GPC) signals. If yourbrowser or an authorized agent transmits a GPC signal when you visitapeiros.ai, we treat it as a valid request to opt out of any sale orsharing of Personal Information that may occur, consistent with theCCPA and other applicable U.S. state privacy laws.

7. INTERNATIONAL DATA TRANSFERS

In Short: We are based in the UnitedStates and your information may be transferred to and processedthere.

Apeiros operates in the United States. Ifyou access or use the Services from outside the United States, yourPersonal Information may be transferred to, stored in, and processedin the United States or other jurisdictions where our serviceproviders or affiliates operate.

Where required by applicable law, weimplement appropriate safeguards to protect Personal Informationtransferred across borders.

8. COOKIES AND TRACKING TECHNOLOGIES

In Short: We use a limited set ofcookies and similar technologies on apeiros.ai — primarilyessential site cookies and Google Analytics — and we ask for yourconsent before placing non-essential cookies where required by law.

We use cookies and similar tracking technologies (including pixelsand web beacons) on apeiros.ai to operate the site, remember yourpreferences, understand how visitors engage with our content, andmeasure the effectiveness of our marketing. The two primarycategories we use are (i) essential cookies that are necessary forthe site to function, and (ii) analytics cookies set by GoogleAnalytics, which help us understand aggregate traffic patterns andimprove the site.

For visitors located in the European Economic Area, the UnitedKingdom, and Switzerland, Apeiros obtains your consent before placingnon-essential cookies (including analytics cookies) on your device.You can accept, reject, or customize your cookie choices through theconsent banner presented on your first visit, and you may change orwithdraw your consent at any time by clicking the CookiePreferences link in the website footer. Withdrawing consent doesnot affect the lawfulness of processing carried out before thewithdrawal.

You can also control cookies through your browser settings. Mostbrowsers allow you to refuse or accept cookies, delete cookies thathave already been stored, and set preferences for specific sites.Please note that if you disable or block cookies, some features ofapeiros.ai may not function as intended.

For a detailed list of the cookies we use, their purposes,providers, and durations, please refer to our Cookie Notice,available on our website. [TBD— confirm whether apeiros.ai publishes a separate Cookie Notice orinlines the cookie table in this Privacy Policy]

9. DATA RETENTION

In Short: We keep your PersonalInformation only as long as we need it for the purposes described inthis Privacy Policy, unless a longer retention period is required orpermitted by law.

We retain Personal Information only for as long as is necessary tofulfill the purposes set out in this Privacy Policy, unless a longerretention period is required or permitted by applicable law (forexample, tax, accounting, or other legal requirements). The followingtable summarizes our retention periods for the categories of PersonalInformation we collect through apeiros.ai:

Category of Personal Information

Retention Period

Contact form submissions (name, email, company, phone, message)

For the duration of the sales conversation and for a reasonable period thereafter, unless you request earlier deletion

Marketing communication preferences and suppression records

Indefinite, to honor your opt-out

Google Analytics data

14 months from collection (Google Analytics default)

Server logs (IP addresses, request metadata)

90 days

When we no longer have an ongoing legitimate business or legalneed to process your Personal Information, we will either delete itor anonymize it so that it can no longer be associated with you.Where deletion is not immediately feasible (for example, because theinformation is stored in secure backup archives), we will securelyisolate the information from any further processing until deletion ispossible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We use reasonable technicaland organizational measures to protect your Personal Information, butno system is perfectly secure.

We have implemented appropriate and reasonable technical andorganizational security measures designed to protect theconfidentiality, integrity, and availability of any PersonalInformation we process through apeiros.ai. These measures includeaccess controls, encryption in transit, logging and monitoring, andvendor due diligence for the service providers that support the site.

However, despite our safeguards and efforts to secure yourinformation, no electronic transmission over the Internet and noinformation-storage technology can be guaranteed to be 100% secure.We cannot promise or guarantee that unauthorized third parties willnever be able to defeat our security measures or improperly access,collect, use, or disclose your information. Although we will do ourbest to protect your Personal Information, any transmission ofPersonal Information to and from our website is at your own risk, andyou should only access apeiros.ai within a secure environment.

11. YOUR PRIVACY RIGHTS

We want to ensure that you are fully awareof your data protection rights. The rights available to you depend onthe laws that apply to you based on your location. This sectiondescribes the rights available under each applicable privacyframework — the European Union and United Kingdom (GDPR / UK GDPR,as amended by the UK Data (Use and Access) Act 2025), Switzerland(Swiss FADP), and California (CCPA/CPRA).

11.1 EU, UK, and SwissRights (GDPR / UK GDPR / Swiss FADP)

If you are located in the EuropeanEconomic Area (EEA), the United Kingdom, or Switzerland, you have thefollowing rights under the EU GDPR, the UK GDPR, and the SwissFederal Act on Data Protection (nFADP / FADP) respectively:

Right of access. You have the right to request a copy of the Personal Information we hold about you.

Right to rectification. You have the right to request correction of inaccurate Personal Information or completion of incomplete Personal Information.

Right to erasure (“right to be forgotten”). You have the right to request deletion of your Personal Information in certain circumstances, such as when the data is no longer necessary for the purpose for which it was collected.

Right to restriction of processing. You have the right to request that we restrict the processing of your Personal Information in certain circumstances, such as when you contest the accuracy of the data.

Right to data portability. You have the right to receive your Personal Information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.

Right to object. You have the right to object to the processing of your Personal Information where we rely on legitimate interests as our legal basis. You have an absolute right to object to direct marketing at any time.

Right to withdraw consent. Where we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Rights related to automated decision-making. Apeiros does not use automated decision-making, including profiling, that produces legal or similarly significant effects concerning individuals through the apeiros.ai website. For completeness: under the EU GDPR, automated decision-making with legal or similarly significant effects is only permitted where it is necessary for a contract, authorized by law, or based on your explicit consent; under the UK GDPR (as amended by the Data (Use and Access) Act 2025), automated decision-making may be carried out under a broader range of lawful bases provided adequate safeguards are in place. In all cases, where such processing occurs, individuals have the right to obtain human intervention, express their point of view, and contest the decision.

Right to lodge a complaint with asupervisory authority. If you believe that our processing of yourPersonal Information infringes applicable data protection law, youhave the right to lodge a complaint with your local data protectionsupervisory authority.

For individuals in the United Kingdom, this is theInformation Commissioner’s Office (ICO):

Apeiros also maintains acomplaints-handling process in accordance with the UK Data (Use andAccess) Act 2025. You may submit a complaint directly to Apeiros atprivacy@apeiros.ai, and we will acknowledge your complaint within 30days and respond without undue delay.

For individuals in the EU/EEA, you may contact the dataprotection authority in the EU member state where you habituallyreside, where you work, or where the alleged infringement occurred. Alist of EU/EEA Data Protection Authorities is available athttps://edpb.europa.eu/about-edpb/about-edpb/members_en.

For individuals in Switzerland, you have equivalent rightsunder the Swiss FADP — including access, rectification, erasure,objection, and restriction — and you may lodge a complaint with theSwiss Federal Data Protection and Information Commissioner (FDPIC):

Website: https://www.edoeb.admin.ch

11.2 California Rights (CCPA/CPRA)

If you are a California resident, theCalifornia Consumer Privacy Act, as amended by the California PrivacyRights Act (“CCPA”), provides you with the followingrights:

Right to know. You have the right to request that we disclose the categories and specific pieces of Personal Information we have collected about you, the categories of sources, the business or commercial purposes for collection, and the categories of third parties with whom we have shared your Personal Information.

Right to delete. You have the right to request deletion of your Personal Information, subject to certain exceptions provided by law.

Right to correct. You have the right to request that we correct inaccurate Personal Information that we maintain about you.

Right to opt-out of sale or sharing. You have the right to opt out of the sale of your Personal Information or sharing for cross-context behavioral advertising. As noted elsewhere in this Policy, Apeiros does not sell or share your Personal Information.

Right to limit use of sensitive Personal Information. You have the right to direct us to limit the use and disclosure of your sensitive Personal Information. Apeiros does not collect sensitive Personal Information through the apeiros.ai website

Right to non-discrimination. We will not discriminate against you for exercising any of your privacy rights.

Right to designate an authorized agent. You can designate an authorized agent to make a request under the CCPA 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 the CCPA.

In accordance with applicable law, we arenot obligated to provide or delete consumer information that isde-identified in response to a consumer request or to re-identifyindividual data to verify a consumer request.

Categories of Personal Information under CCPA. Thefollowing table summarizes the categories of Personal Information wecollect through the apeiros.ai website, mapped to the CCPA’sstatutory categories:

CCPA Category
Examples
Collected?
Sources
Purpose
Disclosed
Identifiers
Name, email, phone, IP address
Yes
Directly from you (Contact Us form); automaticallyfrom your browser
Responding to inquiries; sales follow-up; sitesecurity; analytics
Yes — cloud hosting, CRM/email, analytics,security monitoring providers; Apeiros affiliates
Customer records (Cal. Civ. Code § 1798.80(e))
Name, company, phone, email
Yes
Directly from you (Contact Us form)
Responding to inquiries; sales follow-up
Yes — CRM/email providers; Apeiros affiliates
Protected classification characteristics
No
Commercial information
Inquiry history, products/services you asked about
Yes
Directly from you (Contact Us form); our internalrecords of our correspondence with you
Responding to inquiries; sales follow-up;measuring marketing effectiveness
Yes — CRM/email providers; Apeiros affiliates
Biometric information
No
Internet or electronic network activity
Browsing interaction with apeiros.ai
Yes
Automatically from your browser and device
Site analytics;
security;
measuring marketing effectiveness
Yes — analytics (Google Analytics), cloudhosting, security monitoring providers
Geolocation data (approximate only)
Approximate location derived from IP
Yes
Automatically from your browser and device
Site analytics; security
Yes — analytics (Google Analytics), cloudhosting, security monitoring providers
Sensory data
No
Professional or employment-related information
Job title, company
Yes
Directly from you (Contact Us form)
Responding to inquiries; sales follow-up
Yes — CRM/email providers; Apeiros affiliates
Non-public education information
No
Professional or employment-related information
Job title, company
Yes
Directly from you (Contact Us form)
Responding to inquiries; sales follow-up
Yes — CRM/email providers; Apeiros affiliates
Non-public education information
No
CCPA Category
No
CCPA Category
No

Apeiros has not sold or shared any of the categories abovein the preceding twelve (12) months (see § 6.3).

11.3 Verification Process

Upon receiving a rights request, we willneed to verify your identity to determine you are the same personabout whom we have the information in our system. These verificationefforts require us to ask you to provide information so that we canmatch it with information you have previously provided us. Forinstance, depending on the type of request you submit, we may ask youto provide certain information so that we can match the informationyou provide with the information we already have on file, or we maycontact you through a communication method (e.g., phone or email)that you have previously provided to us. We may also use otherverification methods as the circumstances dictate.

We will only use Personal Information provided in your request toverify your identity or authority to make the request. To the extentpossible, we will avoid requesting additional information from youfor the purposes of verification. However, if we cannot verify youridentity from the information already maintained by us, we mayrequest that you provide additional information for the purposes ofverifying your identity and for security or fraud-preventionpurposes. We will delete such additionally provided information assoon as we finish verifying you.

11.4 How to ExerciseYour Rights

You can exercise your rights by contactingus using either of the following two designated methods, whichtogether satisfy the California Consumer Privacy Act’s requirementto offer at least two request methods:

Email: privacy@apeiros.ai

Post: Apeiros, 1100 Johnson Road, Unit #17090, Golden, CO 80402, United States of America

We will consider and act upon any requestin accordance with applicable data protection laws and within theresponse timelines those laws require (for example, one month underthe EU/UK GDPR, subject to permitted extensions; and 45 days underthe CCPA, subject to permitted extensions).

12. THIRD-PARTY WEBSITES

In Short: We are not responsible forthe safety of any information that you share with third parties thatwe may link to or who advertise on our Services, but are notaffiliated with, our Services.

The Services may link to third-party websites, online services, ormobile applications and/or contain advertisements from third partiesthat are not affiliated with us and which may link to other websites,services, or applications. Accordingly, we do not make any guaranteeregarding any such third parties, and we will not be liable for anyloss or damage caused by the use of such third-party websites,services, or applications. The inclusion of a link towards athird-party website, service, or application does not imply anendorsement by us. We cannot guarantee the safety and privacy of datayou provide to any third parties. Any data collected by third partiesis not covered by this Privacy Policy. We are not responsible for thecontent or privacy and security practices and policies of any thirdparties, including other websites, services, or applications that maybe linked to or from the Services. You should review the policies ofsuch third parties and contact them directly to respond to yourquestions.

13. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

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

We may update this Privacy Policy from time to time. The updatedversion will be indicated by an updated “Last Updated” date andthe updated version will be effective as soon as it is accessible. Ifwe make material changes to this Privacy Policy, we may notify youeither by prominently posting a notice of such changes or by directlysending you a notification. We encourage you to review this PrivacyPolicy frequently to be informed of how we are protecting yourinformation.

14. HOW CAN YOU CONTACTUS?

If you have questions or comments aboutthis Privacy Policy, you may contact the Apeiros Privacy Team byemail at privacy@apeiros.ai or by post to the addresses below.

United States

Apeiros Attn: Privacy Team 1100 Johnson Road, Unit #17090, Golden, CO 80402, United States of America

United Kingdom (UK GDPR Article 27 Representative)

Apeiros has appointed a representative in the United Kingdompursuant to Article 27 of the UK GDPR. The DPO Centre Ltd, 50 Liverpool Street, London, EC2M 7PY, UK

European Union (EU GDPR Article 27 Representative)

Apeiros has appointed a representative in the European Unionpursuant to Article 27 of the EU GDPR. The DPO Centre Europe Ltd, Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2