PRIVACY POLICY

Last Updated: October 2, 2026

FifthRow Inc ("we," "us" or "FifthRow") cares about protecting the personal information of our customers and visitors (collectively, our “Users”) who use our website at https://www.fifthrow.com/ and any subdomains (collectively the “Site”), or any products and services provided to you by us including our FifthRow Platform (collectively along with the Site, the “Services”). The FifthRow Platform is an AI-powered tool which based on inputs provided by the Company, will conduct automated market research based within the inferred problem space, generate potential new venture ideas, rank them based on market viability and alignment with the Company's assets and strategy, create personas and conduct simulations to extract product insights and auto-generate landing pages for market testing in order to provide a comprehensive recommendation for highest potential ventures within the space and aligned with the Company's goals. The platform also features Flows which is a platform for automating business processes with AI Agents. It features an ever-growing MarketPlace catalog of preprogrammed agents that perform tasks on top of unstructured data from the internet, startup databases or private data uploaded to FifthRow.

This Privacy Policy explains how we collect, use, and disclose Personal Information about users and other individuals, including people mentioned in public-source research. Use of the Services is governed by the Terms of Use. Using the Services or providing information does not, by itself, constitute consent to every processing activity. Where consent is required, we obtain it for the relevant purpose and explain how it may be withdrawn.

DEFINITIONS:

For the purposes of this Privacy Policy, the following capitalized terms shall have the meanings set forth below. These definitions are intended to align with those used in our Terms of Use:

“Account” means the registration credentials and associated profile created by or for a User to access and use the Services.

“Authorized User” means an individual subscribing on their own behalf or anyone the Company authorizes to access and use its account, including employees, contractors, and officers.

“Company” means the individual or organization subscribing to or contracting for the Services, whether on its own behalf or through an authorized representative. A company workspace is an account structure and does not by itself determine the subscriber's legal status.

“Company Content” refers to information input, uploaded, submitted, or otherwise made available by the Company or its Authorized Users through the Services, including briefs, uploaded files, datasets, prompts, App and Flow definitions and instructions, configurations, and settings. Company Content may include Personal Information; Personal Information remains subject to the provisions of this Policy and applicable law that govern it.

“Flow” means a configurable automation or sequence of actions performed by AI Agents on the Platform, often based on plain language descriptions, that may interact with third-party data or services.

“Large Consulting Model” or “LCM” is FifthRow's marketing name for its research and automation infrastructure, which uses third-party AI models together with tools, data, and workflows. LCM is not a standalone AI model.

“Marketplace” refers to the component of the Platform where prebuilt Flows, Apps, and AI agents are made available for discovery, customization, or use by Authorized Users.

“Output” means the deliverables or results generated by the Services in response to Company Content or input, including but not limited to reports, personas, landing pages, analytics, recommendations, and other materials generated using the Platform.

“Personal Information” (also referred to as “Personal Data”) means any information that identifies, relates to, describes, or can reasonably be associated with an individual, whether alone or when combined with other data. This includes, but is not limited to, names, email addresses, device identifiers, billing information, and usage data.

“Platform” refers to the proprietary FifthRow software-as-a-service (SaaS) environment operated by FifthRow Inc., including all components, modules, features, interfaces, underlying code, and technology infrastructure provided to Users.

“Services” refers to the Platform and all related products, features, tools, applications, APIs, documentation, and support services provided by FifthRow Inc. through the Site or otherwise.

“User” refers to any individual or entity who accesses or uses the Services, including both Companies and their Authorized Users.

“We,” “Us,” “FifthRow,” or “Our” means FifthRow Inc., the legal entity that owns and operates the FifthRow Platform and associated Services.

“You” or “Your” refers to the User accessing or using the Services, or the individual or entity whose data is collected under this Privacy Policy.

HOW WE COLLECT AND USE YOUR INFORMATION

We collect information in order to provide the Site and its Services to our Users, improve the User experience, and to communicate with Users about the Site and its Services. When you visit the Services, we collect certain information about your device, your interaction with the Services, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. Personal Information has the meaning given in the definitions above, including information that identifies an individual when combined with other data. The information we collect from Users will depend on a User's particular interaction with the Site and Services. Different portions of this Privacy Policy may apply to Users at different times. See the list below for more information about what Personal Information we collect and why. We also collect and process information related to your subscription plan, Agent Hours balance, and usage of Flows and Apps on the Platform, including usage frequency, execution history, and Agent Hours consumption. This information is used to administer your subscription, calculate applicable charges, and provide usage transparency.

INFORMATION WE COLLECT.

Information You Give Us.

When you access the Services to make an order or to create an account; contact us or when we communicate with you; visit our social media pages; use our products and services as an authorized user on behalf of one of our customers; or receive any deliverables from us or one of our customers, we may collect certain information about you, including but not limited to: name, billing address, payment information (including credit card numbers, and other alternative payment details), email address, and phone number.

We process information you provide for the purposes and on the legal bases described below. International transfers, where they occur, are subject to applicable data-protection law and required safeguards; providing information does not itself constitute consent to an international transfer.

Information Collected from Your Use of the Services.

When you use our Services, we automatically receive and record information on our server logs from your browser or device, which may include the following: IP address, device identifiers and information, web browser information, page view statistics, what sites or products you view, search terms, browsing history, usage information, time zone, transaction information (e.g. transaction amount, date and time such transaction occurred), identifying information from cookies and certain other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.) — for more information, see “How We Collect Data” section below, location information (e.g. IP address, zip code), including geolocation/GPS data – for more information, see below, and Log data (e.g. access times, hardware and software information) and how you interact with the Services.

Information We Receive from Others.

We may receive information about you from others, including but not limited to: (i) Other Partners - We may receive information about you from third party services, such as analytics providers and advertising partners; and (ii) Publicly Available Information - Including information from social media platforms and apps.

MINORS

Our Services are strictly intended for users aged 18 and older. If you are under 18, please do not use our Services or submit any personal information. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

HOW WE USE YOUR INFORMATION

We use the information we collect, both on its own and combined with any other information we collect about you, for a variety of business purposes, including:

• to provide products or services to you, to process your payment information, to fulfil your requests for our products and services on the Site, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services; and to provide other customer support services.
• to load the Services accurately for you, and to perform analytics on Services’ usage to optimize our Services.
• To notify you about changes to the Services and to communicate with you about your Account, our Services and policy changes
• To provide analytics services and to analyze and improve our Services pursuant to our legitimate interest, such as: detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity; undertaking research for technological development and demonstration measuring interest and engagement in our Services and short-term, transient use; developing new products and Services; and enforcing our terms and policies;
• To create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create; and
• We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you.
• We process Company Content to provide the Services and, as described below and in the Terms of Service, to analyze App and Flow configurations and derive generalized learnings for service improvement and catalog development. FifthRow does not use Company Content or Output, including shared Answers, to train or fine-tune AI or machine-learning models. This describes FifthRow's own processing; it does not describe the separate practices of a connected client provider. FifthRow remains responsible for its processing, including its use of service providers, under applicable law and any data processing agreement that applies between the Company and FifthRow. Personal Information remains subject to applicable law and any such agreement.

COMPANY CONTENT AND OWNERSHIP

Company Content refers to information provided through the Services, including briefs, uploaded files, prompts, App and Flow definitions and instructions, configuration data, and other inputs. It may include Personal Information, which remains subject to the provisions of this Policy and applicable law that govern it. Company Content remains the Company's property. We process it to provide the Services and as described in this Policy and the Terms of Service. In particular, we may analyze Company Content and Output, including App and Flow definitions, instructions, prompts, workflow structures, and integration patterns to understand recurring task types and use cases and derive generalized workflow and integration learnings. We may use those learnings to improve the Services and develop, offer, and commercialize catalog Apps, Flows, templates, and related products. We apply reasonable safeguards when accessing and analyzing Company Content. Generalized learnings used for these purposes will not identify the Company or individuals, disclose the Company's Confidential Information, or reproduce raw Company Content, confidential customer-specific prompts or instructions, or proprietary code or materials. We do not use Company Content or Output, including shared Answers, to train or fine-tune AI or machine-learning models, including by instructing a service provider to do so. Improvement of Apps, Flows, and Agents may include evaluating their performance, refining instructions and prompts, changing tool selection and execution steps, and improving verification, error correction, and retrieval of shared facts and Answers. These activities improve the workflows that use AI models; they do not train or fine-tune the underlying models or modify their weights. Reusing and extending the shared research library can improve coverage over successive runs, including recurring research in a Company's field. These activities remain subject to the permissions and restrictions in this Policy and the Terms of Use. FifthRow remains responsible for its processing, including its use of service providers, under applicable law and any data processing agreement that applies between the Company and FifthRow. You may delete Flows, App results, and templates from your workspace using available controls. Workspace deletion removes these items from your workspace but does not delete shared Answers or public-source facts; requests concerning information held by FifthRow, including shared Answers, remain subject to applicable privacy rights and the removal process described in this Policy. Similar outputs may be generated for different users based on similar inputs; we do not guarantee that outputs will be unique.

CONNECTED AI CLIENTS AND FIFTHROW LCM MCP

FifthRow LCM MCP lets you connect a supported AI client, such as ChatGPT, Codex, Claude, Cursor, or Microsoft Copilot, to your FifthRow account. LCM is FifthRow's marketing name for its research and automation infrastructure, not a standalone AI model. The connection uses account authorization. Tool requests run with the permissions of the signed-in FifthRow user. We receive the tool requests and information the client sends to the integration, which may include text from your conversation if the client includes it in a request. We do not receive your entire client conversation merely because you connected the integration.

Depending on the tools you use, we process the following categories of information to authenticate requests, carry out your requested work, return results, track long-running work, provide support, protect the Services, and administer usage and billing:

• Account and connection information, such as your identity, email address, company, role, saved profile, authorization grants, and connection identifiers. A client receives account or profile details only when it calls the relevant tool.
• Tool inputs, such as research questions, App instructions and inputs, selected documents or datasets, automation settings, and identifiers of records you ask the client to access.
• Tool results, such as App and Flow reports, Answers, source references, run status, progress, usage records, and diagnostic or security metadata. Results returned to the client may appear in its conversation or embedded interface.
• If you enable event delivery, the callback URL, resource identifiers, subscription status, and encrypted signing credentials needed to send status events to the endpoint you configure.

The connected client provider receives the tool responses needed for the request, which may include Company Content, Personal Information, generated output, and source references. The provider's handling of information in your client conversation is governed by its own terms and privacy policy. We also use hosting, security, AI, search, and other service providers to deliver FifthRow functionality, as described elsewhere in this Policy. If you configure an event callback, status events are sent to that destination. Choose a client and callback you trust before sharing sensitive information through them.

FifthRow does not use information received through LCM MCP or the resulting Output to train or fine-tune AI or machine-learning models, including by instructing a service provider to do so. This describes FifthRow's own processing; it does not describe the separate practices of a connected client provider. FifthRow remains responsible for its processing, including its use of service providers, under applicable law and any data processing agreement that applies.

Answers is a shared public-source research library. Public-source questions and research requests submitted to or generated for Answers, including agent-generated questions, and their results and source references enter the shared library automatically and may be retrieved and reused by other authenticated FifthRow users in later research. Sharing is an integral part of Answers and is not subject to a customer publishing choice, per-question approval, or sharing opt-out. This applies through the Platform, APIs, and Apps, Flows, and Agents, including connected clients and recurring automations. Where private data is added to research, that private data and questions, context, and results incorporating it are excluded from the shared library; independently obtained public-source research remains eligible for shared reuse. Private data must be supplied through the Services' private-data inputs, not placed in a public-source Answers question. Customers are not required to review each question generated by an Agent before it enters the library. Searching for or retrieving existing Answers does not itself submit new research. Public-source research may include public professional information where its processing is lawful; public availability does not remove privacy obligations or third-party rights. The Company must have the rights required for material it supplies and must not deliberately submit confidential or private information through public-source research inputs. Shared reuse is part of the feature, not a consent-based publication option. It does not remove any statutory privacy rights. Individuals may contact support@fifthrow.com about information concerning them, including to request access, correction, objection, or deletion where applicable. You do not need to hold a FifthRow account or to have submitted the information yourself.

You may disconnect the client or revoke its authorization to stop future access through that connection. This does not remove information already returned to the client or automatically delete saved Apps, reports, or shared Answers. To remove information retained by the client provider, use that provider's controls or contact it directly. You can request access, export, correction, or deletion of information held by FifthRow using the contact instructions below, subject to applicable rights, technical limits, and legal obligations.

PUBLIC-SOURCE RESEARCH AND OUR PRIVACY ROLES

Our Agents collect, structure, compare, and evaluate information from public websites, publications, public professional profiles, and other research sources to answer questions and maintain the shared facts and Answers library. This can include individuals' names, professional roles, employers, publicly reported professional activities and statements, source references, and research inferences. People mentioned in this research may not be FifthRow users. We use this information to provide research, check and update findings, avoid duplicating research, and improve coverage across successive runs and customers. Shared questions, findings, and source references are available to authenticated FifthRow users for reuse through the Services and to the providers needed to operate them. Source availability does not establish accuracy or remove applicable privacy or third-party rights.

FifthRow acts as a controller for processing whose purposes and means it determines, including account administration, billing, security, its own service improvement, and maintenance and reuse of its public-source research library. Where we process private Company information solely on its instructions, we act as its processor under the applicable processing agreement. A single service may involve both roles for different activities. Separate enterprise agreements may specify additional obligations; they do not remove individuals' statutory rights.

LEGAL BASES

Where the GDPR or equivalent law requires a legal basis, the following applies to processing for which FifthRow is controller:

• Account creation, service delivery, requested support, and billing: performance of our contract where the individual is the contracting customer; for organization representatives and Authorized Users, our legitimate interests in administering and delivering the organization's Services.
• Security, fraud prevention, service diagnostics, and enforcing or defending legal rights: our legitimate interests in protecting the Services, customers, and our business, and compliance with legal obligations where applicable.
• Public-source research, shared-library maintenance and reuse, workflow evaluation and improvement, and deriving generalized learnings for catalog development: our legitimate interests in providing useful research, improving reliability and efficiency, and developing our products, only to the extent necessary and where not overridden by individuals' interests or fundamental rights. Contractual permission does not replace that assessment or other requirements of applicable law.
• Product communications and marketing: our legitimate interests in informing customers and business contacts about relevant Services where permitted, or consent where required. Non-essential cookies and similar tracking use consent where required by applicable law. Marketing objections and applicable tracking choices remain available independently of continued service use.
• Accounting, tax records, legally required disclosures, and compliance with privacy requests: compliance with applicable legal obligations.

Where we rely on consent, you may withdraw it using the relevant controls or by contacting support@fifthrow.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. For processing we perform on a Company's instructions, the Company is responsible for identifying its applicable legal basis and providing required notices; FifthRow remains responsible for its own obligations. Public-source collection is subject to applicable notice requirements, including requirements for information obtained indirectly, unless a lawful exception applies.

SHARING OF PERSONAL INFORMATION

We disclose Personal Information to the recipients and for the purposes described below and in the public-source research section, on the applicable legal bases and subject to applicable safeguards. Acceptance of the Terms of Use does not replace consent where the law requires it.

Service Providers and Business Partners.

We may share your information with our third-party service providers and business partners that help us to accomplish certain business purposes (e.g., marketing and analytics providers, security and technology providers, advertising partners, and payment processors). When we share personal information with certain third-party partners, including marketing and advertising partners, that information includes your name, email address and other information enabling partners to fulfil business purposes, which may include:

• validate your identity and fitness to use the Services,
• prevent fraudulent use of the Services,
• process payments pursuant to your usage of the Services,
• assist you in using our products and services,
• contact you with offers, services or products that may be of interest to you, and
• provide you with their products or services.

The categories of service providers (processors) to whom we entrust personal information include: IT and related services; information and services; payment processors; customer service providers; and vendors to support the provision of the Services. We may also share non-personal information with certain third parties, including the media, industry observers, marketing and advertising partners, vendors, customers, potential customers or partners.

Affiliates

We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Policy. Within our corporate family of companies, we may require to share your information to allow us to provide the services to you, if our companies support us in the context of being service providers, which may include, data hosting, server maintenance, customer support, data analytics, marketing, legal and financial services, payment processing and safety and security services.

Optional Services:

Some optional Apps and Flows may access or retrieve data from third-party websites without using an official API. Use of those features is subject to the Terms of Use. Any Company indemnity relating to such use is limited to the scope and conditions in Sections 9.1 and 11.2 of the Terms of Use.

Aggregate Data

We may create and use anonymous aggregate information for lawful business purposes, including analytics, research, service improvement, product development, and sharing or licensing it to business partners. Information is anonymous only where an individual is not identifiable by means reasonably likely to be used. Pseudonymized or de-identified information that can reasonably be linked to an individual remains Personal Information. Generalized workflow learnings and shared Answers are governed by their specific provisions in this Policy and the Terms of Use, not by this aggregate-information permission. Aggregation, de-identification, or anonymization does not create an exception to our no-training commitment, override confidentiality obligations, or expand our permissions to disclose or reproduce Company Content or Output.

We do not sell Personal Data.

Legal Disclosures

Subject to applicable law and our contractual confidentiality obligations, we may disclose information where reasonably necessary: (a) in response to a legal request, such as a subpoena, court order, or government demand; (b) to investigate or report illegal activity; (c) to enforce our rights or defend claims; (d) to comply with applicable laws and regulations. If we have a good faith belief that such disclosure is reasonably necessary, we may disclose your personal information to other relevant third parties, such as internet service providers, to conduct an investigation, bring legal action, protect the rights of our user base, prevent harm to others or pursue other relief when you or a third party are or may be doing certain actions, such as: violating our terms and conditions of use; causing injury or other harm to, or otherwise violating the property or other legal rights, of us, other users, or third parties; or violating federal, state, local, or other applicable law.

Business Transfers

We may also transfer your information to (a) any affiliate of our corporate group or (b) another company in connection with a merger, financing due diligence, corporate restructuring, sale of any or all of our assets, or in the event of bankruptcy.

We do not sell personal information to third parties. We may permit third parties to collect the personal information described above through our service and share personal information with third parties for business purposes as described in this Privacy Policy, including but not limited to providing advertising outside of our service based on Users’ online activities over time and across different sites, services, and devices. The information practices of these third parties are not covered by this Privacy Policy.

HOW WE COLLECT DATA

We may use different technologies to collect, process and store your information. These technologies include:

• Log Files. A log file is a file that records events that occur in connection with your use of the Services, such as your service use data.
• Cookies and other similar Data Collection Technologies. A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Services. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor. We use cookies necessary for the functioning of the store and for reporting and analytics to optimize your experience on our Site and to provide our Services. The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device. You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible. Where required by applicable law, non-essential cookies and similar technologies require consent before use; browser defaults do not supply that consent. You may use any available cookie controls and your browser settings to manage preferences. Blocking cookies does not necessarily exercise a separate legal right to opt out of sale or sharing. We may use also use tracking technologies to monitor your interactions with specific features of the Platform, including Marketplace browsing, Flow executions, and App usage, in order to optimize recommendations, enforce usage limits, and enhance your experience.
• Third Party. We may embed third party scripts or put embeds in the page that send requests to external sites which may allow third parties to drop and read cookies on your browser. Your browser may allow you to disable cookies from third party sites.
• Other Data Collection Technologies. We may use pixel tags, web beacons, local storage, and similar technologies on our Services.

DO NOT TRACK AND PRIVACY PREFERENCE SIGNALS

Some web browsers have a “Do Not Track” (“DNT”) feature that tells a website that a User does not want to have their online activity tracked. Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not change our practices in response to a DNT signal alone. DNT is distinct from legally recognized opt-out preference signals such as Global Privacy Control. Where applicable law requires us to honor such signals for sale, sharing, or targeted advertising, those requirements apply. You may also contact support@fifthrow.com to exercise applicable opt-out rights.

UPDATING OR REMOVING INFORMATION

Where you have consented to our use of your personal information, you may withdraw your consent at any time by contacting us. Some privacy laws may give you the right to review the personal information we keep about you. You can also request a copy of your personal information by contacting us. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us at support@fifthrow.com. We may request information reasonably necessary to verify identity where permitted by applicable law. This does not apply to opt-out requests for which identity verification is prohibited. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful. If you would like to have us delete your account information, we may do so by deactivating your account first and then permanently deleting your account. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for our Services, or to respond to any inquiry or request made by you, as applicable. You may opt out of marketing without closing your account or stopping use of the Services. Necessary transactional, security, billing, and service communications may continue.

THIRD-PARTY NOTICE

The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our Users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting, accessing or utilizing these other websites or applications is at your own risk.

To manage the information we receive about you from other third parties (if applicable), you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available. The information we collect is covered by this privacy policy and the information the third-party collects is subject to such third party’s privacy practices. Choices made on an independent third-party site do not automatically change FifthRow account preferences. This does not limit any legally effective consent withdrawal, objection, or opt-out signal applicable to our processing.

SECURITY

The security of your information is a serious issue for us and we are committed to protecting the information we receive from you. We use reasonable security measures to protect against the loss, misuse and alteration of your personal information under our control; and to ensure that your information is treated in accordance with this Privacy Policy. Notwithstanding such measures, please be aware that no security measures are perfect or impenetrable, and we cannot guarantee the security of any information transmitted to or from the Services. Independent websites and providers you select and engage separately are governed by their own terms and practices. This does not exclude or limit FifthRow's responsibilities for its own processing or for service providers acting on its behalf under applicable law or an applicable data processing agreement.

We may communicate electronically about security, privacy, and administration of the Services. Where a personal data breach requires notification to a customer, affected individual, or authority, we will provide the notification in the manner and within the time required by applicable law and any applicable processing agreement. General service notices do not replace legally required individual notifications.

Password-protected areas of the Services, if any, can be accessed only with a valid password. Each password owner is responsible for keeping the password confidential and safe. If you believe there has been any unauthorized access or use of your information, please contact us immediately. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security.

RETENTION

We retain Personal Information for as long as reasonably necessary for the purposes described in this Policy and applicable legal obligations. We determine retention by the type and sensitivity of the information, continued need to deliver the Services or maintain relevant and accurate research, account status, applicable deletion or objection requests, security needs, and legal recordkeeping or claims periods. Account and billing records, workspace content, research records, and operational logs may therefore have different retention periods. Absence of a fixed automatic expiry does not mean that Personal Information is retained without limits or that applicable deletion rights are unavailable.

For LCM MCP, broker refresh credentials are configured with a rolling 30-day expiry: a successful refresh resets the expiry, and a credential that is not successfully refreshed expires after 30 days. This applies to the broker refresh credential only; access tokens and upstream provider credentials may have separate lifetimes. Credential expiry does not itself delete associated information. App-execution polling tokens are configured to expire after 48 hours; token expiry does not itself delete associated execution records or results. Saved Apps, Flows, reports, account data, and shared Answers do not have a fixed automatic expiry. Flows, App results, and templates may be deleted from a user's workspace using available controls, but workspace deletion does not delete shared Answers or public-source facts and is not a complete data-deletion request. Customers cannot self-delete shared Answers or facts through workspace controls. Shared Answers may remain available after you disconnect a client or close an account unless separately removed. You may request review or removal of shared Answers and associated public-source facts under applicable privacy rights and the process described in this Policy. Legal, billing, security, backup, and service-provider records may be retained for different periods where required for their purposes or by law. Contact support@fifthrow.com for a request concerning a specific record or for information about the applicable retention period.

AUTOMATIC DECISION-MAKING

The Services generate research, recommendations, and rankings. A Company may configure workflows and use their results in its own decisions; it is responsible for the legal requirements applicable to that use, including any required notices and safeguards. This is distinct from FifthRow making decisions about individuals for its own purposes. Where applicable data-protection law restricts decisions based solely on automated processing that produce legal or similarly significant effects, the relevant controller must satisfy those requirements, including applicable rights to human intervention, to express a view, and to contest a decision. Contact support@fifthrow.com about FifthRow's processing; for decisions made by a Company using the Services, contact that Company. FifthRow remains responsible for its own legal obligations.

YOUR RIGHTS

GDPR

Where the GDPR or other applicable data-protection law applies, you may have the rights below, subject to the conditions and exceptions established by law. These rights are not conditional on a data processing agreement or on holding a FifthRow account. Contact support@fifthrow.com to exercise them. We may request information reasonably necessary to verify identity or authority where permitted by law. Where we act on a Company's instructions, we may direct a request to that controller and assist as required. We will respond within the applicable legal period and explain any refusal, restriction, or permitted extension. You may complain to a competent supervisory authority, including in the EU/EEA the authority where you habitually reside, work, or believe an infringement occurred, and seek available judicial remedies.

ACCESS - You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with. In order to obtain information and access to data held by you, please contact us at support@fifthrow.com.

PORTABILITY - You have the right to receive a subset of the personal information you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such personal information to another party. If you wish for us to transfer the personal information to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. An independent recipient is responsible for its subsequent processing; FifthRow remains responsible for its own transfer and any obligations imposed by applicable law.

CORRECTION - You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

ERASURE - You may request that we erase the personal information we hold about you in the following circumstances:

• where you believe it is no longer necessary for us to hold the personal information;
• we are processing it on the basis of your consent and you wish to withdraw your consent;
• we are processing your data on the basis of our legitimate interest and you object to such processing;
• you no longer wish us to use your data to send you marketing; or
• you believe we are unlawfully processing your data.

RESTRICTION OF PROCESSING TO STORAGE ONLY - You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:

• You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate;
• We wish to erase the personal information but you want us to simply restrict the use of that data;
• We no longer need the personal information for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
• You have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information.

OBJECTION - You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.

WITHDRAWAL OF CONSENT - Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by emailing us at support@fifthrow.com.

FOR CALIFORNIA CONSUMERS

Depending on your residency, you may have certain data subject rights. These rights vary by state and country, but they may include the right to: (i) request additional disclosures about the Personal Information we collect, use, and disclose; (ii) obtain a copy of Personal Information; (iii) request correction or deletion of Personal Information; (iv) opt out of sale or sharing of Personal Information where applicable; and (v) limit certain uses or disclosures of sensitive Personal Information where applicable. We will not discriminate against you for exercising any of your rights under the California Consumer Privacy Act (“CCPA”). However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels when that difference is reasonably related to the value provided to us by the data. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

The CCPA requires specific disclosures for California residents.

Categories of Personal Information We Collect

• Identifiers, such as your name, alias, address, phone numbers, or IP address;
• Demographic information, such as language;
• commercial information, such as subscription and monetization activities;
• Internet or other electronic network activity information;
• Geolocation data, such as the location of your device or computer, for example if you enable location services to enable us comply with applicable laws; and
• inference data, such as information about your preferences.

Categories of Personal Information Transferred to Third Parties

• Identifiers, such as your name, address, or phone numbers;
• Demographic information such as your language;
• commercial information, such as the details of subscription and monetization activities;
• Internet or other electronic network activity information; and
• geolocation data.

Business Purpose for Which Information May Be Used or Disclosed

• Protecting against security threats, abuse, and illegal activity. We use and may disclose information to detect, prevent and respond to security incidents, and for protecting against other malicious, deceptive, fraudulent, or illegal activity.
• Maintaining our services. We use information to ensure our services are working as intended, such as tracking outages or troubleshooting bugs and other issues that you report to us.
• Auditing and measurement. We use information for analytics and measurement to understand how our Services are used, as well as to fulfill obligations to our partners like publishers, advertisers, developers, or rights holders. We may disclose non-personally identifiable information publicly and with these partners, including for auditing purposes.
• Research and development. We use information to improve our services and to develop new products, features and technologies that benefit our Users and the public.
• Use of service providers. We share information with service providers to perform services on our behalf, in compliance with our Privacy Policy and other appropriate confidentiality and security measures.
• Legal reasons. We also use information to satisfy applicable laws or regulations, and discloses information in response to legal process or enforceable government requests, including to law enforcement.

How to Submit a Request

To submit a privacy request, contact support@fifthrow.com, identify the right you wish to exercise, and provide information reasonably sufficient to locate the relevant records. You do not need a prescribed subject line, a FifthRow account, or to have personally posted the information. Where applicable law permits, an authorized agent may submit a request for you. We request verification of identity or agent authority only where permitted and reasonably necessary; sale or sharing opt-outs are not subject to identity verification required for access or deletion requests. We respond within the period required by law, including permitted extensions, and charge a fee or deny or limit a request only where the law permits. Applicable opt-out preference signals are addressed in the section "Do Not Track and Privacy Preference Signals."

CHOICE/OPT-OUT (MARKETING COMMUNICATIONS FROM US, EMAIL, PHONE, COOKIES)

You always have the opportunity to opt out of our marketing communications with you or change your preferences by emailing us at support@fifthrow.com or by using the unsubscribe link (if any) found at the bottom of a marketing email to opt out of receiving future emails. You may manage billing preferences, including disabling automatic top-up where it applies, within your account settings. While automatic top-up is disabled, scheduled Autopilot dispatch is paused, and new executions requiring more Agent Hours than are available cannot proceed. Disabling automatic top-up does not cancel executions already in progress. Some communications from us are considered transactional or service communications, and our Services are provided to you upon the condition that you receive these communications from us. You must cancel your account and/or order for our Services, as applicable, if you do not wish to receive any transactional or service communications.

CHANGES

We may update this Privacy Policy to reflect changes to our practices or for operational, legal, or regulatory reasons. We will provide notice of material changes and obtain consent where required by applicable law. An update does not retroactively authorize a use of information that requires a separate legal basis or consent.

CONTACT

If you have any questions about this Privacy Policy or about accessing, changing, or deleting your personal information, or closing your Account with any one of our Services, please visit our Site or contact us at support@fifthrow.com indicating the details of the personal information you want to access, change or delete or which Service(s) you wish to close with sufficient information to locate the relevant records. You do not need to be a registered user to exercise applicable privacy rights. Any contractual dispute arising out of or relating to this Policy is subject to the governing-law and dispute-resolution provisions in Sections 10.2 and 10.3 of our Terms of Service. Those provisions do not exclude or limit any mandatory consumer right, remedy, or forum protection, or any rights under applicable data-protection law.

If you have an inquiry regarding our privacy practices or desire to access your personal data in our possession, we encourage you to contact us at support@fifthrow.com

For questions or opinions regarding this Privacy Policy, please contact us via e-mail at support@fifthrow.com.

Terms of Service