We at SprintReview, Inc., DBA Actual AI(“Company”, “we”, “us”, “our”) know that our users (“you,” “your”) care about how your personal information is used and shared. We take your privacy seriously and are committed to protecting it through our compliance with this Privacy Policy. Please read the following to learn more about our Privacy Policy explaining our online information practices and the choices you can make about the way your information is collected and used and how you can access and update your information. By visiting or using the actual.ai website (the “Website”) or any other services, products, features, content, or applications offered from time to time by Company in connection therewith (collectively with the Website, the “Service(s)”) in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in accordance with this Privacy Policy. If you do not agree with our policies and practices, your choice is not to use our Services.The Actual AI Services are subject to the Actual AI End User License Agreement (EULA).If you have questions or concerns about our privacy practices, please contact legal@actual.ai. If you would like to report a suspected bug or security vulnerability with our site or products, please contact legal@actual.aiTHIS PRIVACY POLICY MAY CHANGE FROM TIME TO TIME. YOUR CONTINUED USE OF THE SERVICES AFTER WE MAKE CHANGES IS DEEMED TO BE ACCEPTANCE OF THOSE CHANGES, SO PLEASE CHECK THE POLICY PERIODICALLY FOR UPDATES.PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOUR CHOICE IS NOT TO USE OUR SERVICES. BY USING OR ACCESSING THE SERVICES, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

1. What Does This Privacy Policy Cover?This Privacy Policy applies to information we collect: (1) on or through the Services; and (2) in email, text, and other electronic messages between you and our Services.It does not apply to information collected by: (1) us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or (2) any third party, including through any application or content that may link to or be accessible from or on our Services. This Privacy Policy does not apply to Open Source Software (as defined in the EULA).We gather various types of Personal Information from our users, as explained more fully below. We may use this Personal Information to personalize and improve our services, to contact users, to fulfill your requests for certain products and services, to analyze how users utilize the Services, and as otherwise set forth in this Privacy Policy. We may share certain types of Personal Information with third parties, as described below.THE SERVICES ARE NOT INTENDED FOR CHILDREN UNDER 18 YEARS OF AGE. We do not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register for our Services. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any Personal Information to us or on the Services. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at legal@actual.ai

2. What Information Does the Company Collect and How?We may collect several types of information from and about users of our Services, including information: (a) by which you may be personally identified, such as name, postal address, email address, telephone number or any other identifier which is deemed personal information under various laws, rules, and regulations applicable to this Privacy Policy (“Personal Information”); (b) that is about you but individually does not identify you; and (c) about your internet connection, the equipment you use to access the Services, and usage details. We collect this information (i) directly from you when you provide it to us; and (ii) automatically as you navigate through the Service. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies. Below are examples the ways we may collect inormation from you, without limitation the following.Account information: Any information about you when you register for an account or otherwise engage with the Services such as your name and email address you provide during account creation, and your payment info, company name, phone number, title and physical address when you convert to a paid account.Information you provide us: Any information you provide by contracting us through the Service, or any additional information you provide that we may ask for if you contact us or report a problem with the Service, your search queries on the Service, and details of transactions you carry out through the Service. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them. You agree and acknowledge that by submitting such information that you have the authority and necessary consents to provide such information.Application data: Any data that you add to any interactive features of the Services(such as cards, comments, commit messages, pull request messages, release notes, etc.) is stored in our systems. Additionally, when you use any of our applications, we store some usage analytics, the directory, folder and file names on your device where you store your code, and any crash reports sent from your client.Service telemetry and usage data:  To improve our users’ experience with our Services, as you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including, without limitation: (a) telemetry data and details of your use of the Services, logs, location data and other communication data and the resources that you access and use on the Services; (b) information about your computer and internet connection, including your IP address (including geolocation), operating system, product version, and browser type; and (c) your preferences, such as language selection. If you access the Service through a mobile device, we may also be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device’s location services settings.  For instructions on changing the relevant settings, please contact your service provider or device manufacturer. Cookies: We use “cookies” when you use or access any of our browser-based Services. A cookie is a piece of data stored on your hard drive or smartphone, to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to login a password more than once, thereby saving you time. Cookies can also enable us to track and target the interests of our users to enhance the experience. Usage of a cookie is in no way linked to any of your personally identifiable information e. For further information, visit https://www.aboutcookies.org/. You can set your browser not to accept cookies, however, in some cases, some of our Service features may not function as a result.Log Files: As is true of most websites and services, we may collect certain information automatically and store it in log files. This information includes  internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data. For our cloud based Services, the information we collect may include the URLs you accessed (in our log files), usernames as well as elements of your content (such as Jira project names, project keys, status names, and JQL filters, and confluence page titles and space names) as necessary for the cloud Services to perform the requested operations. Occasionally, we connect Personal Information to information gathered in our log files as necessary to improve the Services for individual customers. We do not link this automatically collected data to other information we collect about you.Third Party Authentication Information & Permissions: When you authenticate your user credentials with Jira, Github, or any other similar platforms source control or issue tracking software that Actual AI connects with, you will be asked what information and permissions you’d like those platforms to share with Actual AI. We will collect information that you approve to share from those services. Web Beacons: Pages of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).Submissions: You may provide information to be published or displayed on or through the Service or transmitted to other users of the Service or third parties utilizing interactive features of the Service (each a “Submission”). Your Submissions are posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of the Service with whom you may choose to share your Submission. Therefore, we cannot and do not guarantee that your Submissions will not be viewed by unauthorized persons. To the extent you communicate with the Company via a third-party social media platform, please know that this Privacy Policy does not apply to such third party platforms and any information, including Personal Information, that you post or otherwise submit utilizing such third party service is visible to the public and is transmitted at your own risk.Third Party Analytics: Third party analytics service providers may receive data regarding your usage of our Services in order to provide analytics services to us. If you elect to opt-out of such data collection (to the extent available) and subsequently use our Services through a different device or otherwise change your cookie or privacy settings on your device, you will need to opt-out again.Third Parties: We may also obtain information from third-parties and combine that with information we collect through the Services. For example, we may have access to certain information from a third-party service provider’s service or authentication service if you log into our Services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party service or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third-party service, you authorize us to access and store  your information that the third-party service makes available to us, and to use and share it in accordance with this Privacy Policy. You should check your privacy settings on these third-party services to understand and change the information sent to us through these services.
3. How does the Company Use and Share the Information it Receives?We use information that we collect about you or that you provide to us, including any Personal Information: To present our Services and its contents to youTo provide you with information, products, or services that may be of interest to youTo fulfill any other purpose for which you provide itTo carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection To notify you about changes to our Services or any products or services we offer or provide through itIn any other way we may describe when you provide the information For any other purpose with your consentWe may use cookies or similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we may use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose Personal Information that we collect or you provide as described in this Privacy Policy as follows:The Actual AI Team: Information may be shared internally, including our affiliates and subsidiaries, to help provide, improve, protect, and promote our service.Service Providers: We may disclose information to our contractors, service providers, and other third parties we use to support our business. For example, third party payment processors.3rd Party Applications: If you choose to integrate our Services with 3rd party applications, such as Jira, Github, Asana, Linear, GitLab, HubSpot, Tableau, Chargebee, Stripe, Netsuite and ChartMogul. Such third parties have their own privacy policies and terms that govern their use of your information.Legal: We may disclose your information to third parties if necessary to comply with any court order, law, or legal process, including to respond to any government or regulatory request, or to otherwise enforce our End User License Agreement, Terms of Use, or any other agreement between you and the Company, including without limitation, for billing and collection purposes.Acquisition: We may disclose your information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets and any preliminary negotiations and diligence thereto, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about our Service users is among the assets transferred.To Fulfill Your Request: We may disclose your information to fulfill the purpose for which you provided it, or for any purpose disclosed by us when you provide the information.Protection: We may disclose your information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.Finally, we never use, share, sell or rent the Personal Information provided to us online in ways unrelated to the ones described in this Privacy Policy without also providing you an opportunity to opt-out or otherwise prohibit such unrelated uses.

4. Is Personal Information About Me Secure?The security of your Personal Information is important to us. While we endeavor to protect the privacy of your Personal Information we hold in our records, unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Services. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on or through the Services.The safety and security of your information also depends on you. Where we have given you (or where you have chosen) certain access credentials for use of the Service, you are responsible for keeping this information confidential. We ask you not to share your access credentials with anyone. We urge you to be careful about giving out information in public areas of the Website or other users. Third Party Links: The Services may contain links to other third party sites that are not controlled or owned by the Company. Please be aware that the Company is not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Website and to read the privacy policies of each and every website that collects information. 5. What Personal Information Can I Access or Correct?You may access and edit billing information by emailing us at support@actual.ai. If you have any questions about viewing or updating information we have on file about you, please contact us at support@actual.ai. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
6. What Choices do I have with Regard to my Personal Information?You can always opt not to disclose information to use, but keep in mind some information may be needed to register with us or to take advantage of some of our special features.You may request deletion of your information by emailing us at legal@actual.ai Please note that some information may remain in our records, for example in our archives, after your request of deletion of such information. We may not accommodate a deletion of information if we believe the change would violate any law or legal requirement. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We use this procedure to better safeguard your information. Do-Not-Track Policy: Some web browsers may transmit “do-not-track” (“DNT”) signals with which you may communicate. We currently do not change our tracking practices in response to DNT Settings in your web browsers. To determine whether any of the third-party services the Company uses honor the “Do Not Track” requests, please read their privacy policies.You can unsubscribe from our marketing and promotional ommunicatons at any time by clicking on the unsubscribe link in the emails send, replying “STOP” or “UNSUBSCRIBE” via SMS or emails or by contacting us at support@actual.ai. You will then be removed from the marketing lists. However, we may still communicate with you–for example to send you service-related messages that are necessary to respond to your requests or for other non-marketing purposes as required by law.


7. Changes to This Privacy PolicyWe may revise this Privacy Policy at any time and will post the most current version on our website. If we feel any change is significant, we will notify users of our services.


8. General Data Protection Regulation (GDPR)EU ResidentsIf you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Switzerland or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Company will be the “controller” of your Personal Data processed in connection with the Services. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of services to customers, in which case we are the “processor” of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at legal@actual.aiWhat Personal Data Do We Collect from You?We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:First and last nameCompany nameEmail addressMailing addressTelephone numberCredit card and credit card CVVBilling addressTransaction and Billing DataUsage data and identifiers of your devices

If you choose to integrate the Services with 3rd party applications, remember that their use of your information will be governed by their privacy policies and terms.How Do We Use Your Personal Data?We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:Create and manage user accountsCommunicate with you about the ServicesProcess ordersContact you about Service announcements, updates or offersProvide the Services and support and assistance for the ServicesPersonalize website content and communications based on your preferencesMonitor and analyze trends, usage, and activities in connection with the Services and for marketing or advertising purposesRespond to user inquiriesFulfill user requestsEnable you to communicate, collaborate, and share content with your designated usersResolve disputesProtect against or deter fraudulent, illegal or harmful actionsEnforce our Terms of Service or End User License Agreement

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We will only process your Personal Data if we have a lawful basis for doing so. Lawful basis for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service or End User License Agreement with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.First and last nameEmail addressMailing addressCredit card and credit card CVVTransaction and Billing DataCompany nameAny Personal Data included in source code you provideLegitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.First and last nameEmail addressMailing addressCompany nameUsage data and identifiers of your devicesExamples of these legitimate interests include:Operation and improvement of our business, products and servicesMarketing of our products and servicesProvision of customer supportProtection from fraud or security threatsCompliance with legal obligationsCompletion of corporate transactionsConsent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data?We share Personal Data with our affiliates, vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy, our Terms of Service, or our End User License Agreement. These parties include:Payment processorsFraud prevention service providersHosting service providersCo-location service providersTelecommunications service providers

We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected). You may choose to make use of third-party add-ons in conjunction with certain Services. Third-party add-ons are software written by third-parties to which you grant access privileges to your content (which may include your Personal Data). When access is granted, your content is shared with the third-party. Third-party add-on policies and procedures are not controlled by the Company even though the third-party add-on may be available through the Services. This Privacy Policy does not cover the collection or use of your data by third-party add-ons, and we urge you to examine the privacy policies governing third-party add-ons.We also share Personal Data when we believe it is necessary to:Comply with applicable law or respond to valid legal process, including from law enforcement or other government agenciesProtect us, our business or our users, for example to enforce our Terms of Service or End User License Agreement, prevent spam or other unwanted communications and investigate or protect against fraudMaintain the security of our products and services

Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.We do not sell your Personal Data, nor do we share your Personal Data with third-parties for their marketing purposes (including direct marketing purposes) without your permission.How Long Do We Retain Your Personal Data?We retain Personal Data about you for as long as you are a customer. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.

Afterwards, we retain some information for marketing and promotional activities, unless you have opted out of such promotions.What Security Measures Do We Use?We take reasonable precautions to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction. We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.

What Rights Do You Have Regarding Your Personal Data?You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email legal@actual.ai Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.Erasure: You can request that we erase some or all of your Personal Data from our systems.Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.Restriction of Processing: You can ask us to restrict further processing of your Personal Data.Right to File Complaint: You have the right to lodge a complaint about the Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data:The Services are hosted and operated in the United States (“U.S.”) through the Company and its service providers, and laws in the U.S. may differ from the laws where you reside.By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, may be provided to the Company in the U.S. and may be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the U.S. and possibly other countries. The Company minimizes any potential risk to your rights and freedoms under GDPR by not collecting or storing sensitive information about you.What If You Have Questions Regarding Your Personal Data?If you have any questions about this section or our data practices generally, please contact us using the following information:

Name: SprintReview, Inc., DBA Actual AI
Physical address: 251 LITTLE FALLS DRIVE, WILMINGTON, DE, 19808
Email: legal@actual.ai


9. Special Notice for California Residents. The California Consumer Protection Act (“CCPA”) requires specific disclosures to California residents. These required disclosures are organized separately for convenience and to reflect terminology used in the CCPA. If you wish to request more information from the Company or inquire on exercising your rights under CCPA, you can reach out to the Company by emailing us at eleanor@actual.ai
10. Special Notice for Nevada Residents.The Privacy and Security of Personal Information Chapter of Nevada law provides that where certain types of Personal Information (“Covered Information”) are collected via a website or online service maintained by the operator of such site that the operator notify the consumer of the categories of information collected; how it is collected, shared, used and, where applicable, access by third parties. You will find this information above in Sections 1, 2, and 3. If you wish, you may submit a request with respect to your data, to Company support. 11. Changes to Our Privacy PolicyWe may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

12. Contact Us To ask questions or comment about this privacy policy and our privacy practices, contact us at: legal@actual.ai‍