Privacy Policy

Agentic Private Markets Corp. ("AgenticPM," "we," "us," or "our") is a Delaware corporation that provides an artificial intelligence ("AI") software-as-a-service ("SaaS") platform designed for private markets professionals. Our platform is accessible at agenticprivatemarkets.ai and its subdomains (collectively, the "Services").

This Privacy Policy describes how we collect, use, disclose, retain, and protect personal information when you visit our website, use our platform, or otherwise interact with us. It also explains your rights and choices regarding your personal information.

This Privacy Policy should be read in conjunction with our Terms of Service and End User License Agreement and, where applicable, our Master Service Agreement.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Services.

1. Information We Collect

We collect information in the following categories:

1.1 Account and Registration Information

When you create an account or register for our Services, we collect:

• Full name
• Email address
• Company or organization name
• Job title and role (if provided)
• Password (stored in hashed form)
• Authentication credentials managed through WorkOS

1.2 Customer Content

Our platform enables customers to upload, submit, and process documents and data in connection with their private markets activities. This may include confidential investment memoranda (CIMs), financial models, deal documentation, and other materials ("Customer Content"). Customer Content is stored on Microsoft Azure infrastructure and is accessible only to the customer and authorized personnel within AgenticPM for support and service delivery purposes.

1.3 Usage and Technical Data

We automatically collect certain technical information when you use the Services, including:

• Session tokens and authentication data
• IP address and approximate geographic location
• Browser type, operating system, and device information
• Pages visited, features used, and interaction timestamps
• Referring URLs

1.4 API and Diagnostic Logs

We maintain API logs and diagnostic traces solely for the purposes of troubleshooting, error resolution, and platform reliability. These logs may contain request metadata, error codes, and performance metrics. They are not used for marketing, profiling, or any purpose beyond operational diagnostics.

1.5 Communications Data

If you contact us for support, provide feedback, or otherwise communicate with us, we may collect the content of those communications along with your contact information.

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Service Delivery

• Providing, operating, and maintaining the Services
• Processing and analyzing Customer Content through our AI capabilities to deliver insights and outputs
• Authenticating users and managing account access
• Providing customer support and responding to inquiries

2.2 Platform Improvement and Operations

• Diagnosing technical issues and resolving errors
• Monitoring platform performance and reliability
• Ensuring the security and integrity of the Services

2.3 Legal and Compliance

• Complying with applicable laws, regulations, and legal processes
• Enforcing our Terms of Service and other agreements
• Protecting our rights, property, and safety, and that of our users

2.4 Communications

• Sending service-related notifications (e.g., account verification, security alerts, maintenance updates)
• Responding to your requests and inquiries

3. AI and Automated Processing

AgenticPM uses artificial intelligence and machine learning technologies, including large language models provided by third-party providers (see Section 5), to deliver core platform functionality.

3.1 No Training on Customer Data

We do not use Customer Content or any customer-specific data to train, fine-tune, or improve our AI models or those of our third-party AI providers. Customer Content is processed solely to deliver the specific service outputs requested by the customer.

3.2 How AI Processes Your Data

When you use AI-powered features of the Services, your inputs (including Customer Content you choose to analyze) are transmitted to our third-party AI providers for processing. These providers process the data solely to generate outputs for you and are contractually prohibited from using your data for model training or any other purpose.

3.3 Automated Decision-Making

The Services may generate AI-powered analyses, summaries, and recommendations based on the data you provide. These outputs are intended to assist and inform human decision-making and should not be treated as the sole basis for investment or business decisions. You retain full discretion and responsibility over all decisions made using the Services.

Under applicable data protection laws (including GDPR Article 22), you have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. If you believe any automated processing by the Services has produced such effects, please contact us at privacy@agenticprivatemarkets.ai.

4. Sharing and Disclosure of Information

In certain circumstances we may share your personal information with third parties as set forth below:

• Vendors and service providers: We share information with providers who assist us in delivering the Services, including cloud infrastructure, authentication, AI processing, and support tooling. These providers are contractually limited to processing data only as instructed by us.
• Legal requirements: We may disclose information to comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
• Protection of rights: We may disclose information to enforce our Terms of Service, protect our rights, safety, or property, and that of our users or the public.
• Business transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any material change.
• With your consent: We may share information for any purpose with your explicit consent.

We do not sell personal information. We do not share personal information with third parties for their direct marketing purposes.

5. Third-Party Service Providers (Sub-Processors)

We share personal information with the following categories of third-party service providers who process data on our behalf. Each provider is bound by data processing agreements that limit their use of your data to the purposes we specify.

We will notify customers of material changes to our sub-processor list by email or through the platform at least thirty (30) days in advance.

Our AI providers are contractually prohibited from using Customer Content for training purposes. Data transmitted to AI providers is processed transiently and is not retained by these providers beyond the duration of the processing request, in accordance with their enterprise data processing terms.

6. International Data Transfers

AgenticPM is based in the United States, and our Services are hosted on infrastructure located primarily in the United States. If you are accessing the Services from outside the United States, including from the EEA or the UK, your personal information will be transferred to the United States.

For transfers from the EEA or UK, we rely on the European Commission's Standard Contractual Clauses and, where applicable, providers certified under the EU-U.S. Data Privacy Framework. We implement additional safeguards including encryption in transit (TLS 1.2+) and at rest (AES-256), access controls, and contractual protections with sub-processors. Copies of applicable safeguards are available upon request at privacy@agenticprivatemarkets.ai.

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Account data is retained for the duration of the account plus one year. Customer Content is retained for the duration of the applicable service agreement and deleted upon termination per contract terms. API and diagnostic logs are retained on a rolling 90-day basis. Legal and compliance records are retained as required by applicable law.

Upon termination of a service agreement, Customer Content will be deleted in accordance with our Data Retention Policy. Customers may request a one-time data export prior to deletion. Deletion confirmation reports are available upon request.

8. Data Security

We are committed to protecting your information through industry-standard security measures. Our security practices include encryption of data in transit (TLS 1.2+) and at rest (AES-256), role-based access controls with least-privilege principles, multi-factor authentication for administrative access, regular penetration testing, and continuous security monitoring.

While we implement commercially reasonable security measures, no method of electronic transmission or storage is completely secure. In the event of a security incident involving personal data, we will notify affected users and relevant authorities in accordance with applicable law, including within 72 hours where required under GDPR.

9. Your Privacy Rights

Depending on your location, you may have the following rights with respect to your personal information:

• Right to access: Request a copy of the personal data we hold about you.
• Right to rectification: Request correction of inaccurate or incomplete personal data.
• Right to erasure: Request deletion of your personal data, subject to legal retention requirements.
• Right to restriction or objection: Request that we limit or cease processing your personal data in certain circumstances.
• Right to data portability: Receive your personal data in a structured, machine-readable format.
• Right to withdraw consent: Where processing is based on consent, withdraw that consent at any time.
• Right to non-discrimination: We will not discriminate against you for exercising your privacy rights.

California residents may also have rights under CCPA/CPRA, including the right to know, delete, and correct personal information. We do not sell or share personal information for cross-context behavioral advertising.

To exercise any of these rights, contact us at privacy@agenticprivatemarkets.ai. We will respond to verified requests within 30 days. EEA and UK residents who are not satisfied with our response have the right to lodge a complaint with their local data protection supervisory authority.

10. Cookies and Session Technologies

The AgenticPM platform uses session tokens for authentication and maintaining your logged-in session. These are strictly necessary for the operation of the Services and cannot be disabled.

We do not use third-party advertising cookies, tracking pixels, or behavioral analytics tools within the application. If we introduce any non-essential cookies or tracking technologies in the future, we will update this policy and provide appropriate consent mechanisms in accordance with applicable law.

11. Children's Privacy

The Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have inadvertently collected personal information from a child under 16 (or such higher age as required by applicable law), we will promptly delete it.

12. Third-Party Links and Services

The Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party service you access through or in connection with the Services.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the effective date at the top of this policy and notify you by email or through a prominent notice within the Services. Where required by law, we will obtain your consent to the changes.

Your continued use of the Services after the effective date of a revised policy constitutes acceptance of the updated terms.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: