Twin Pillar Associates LLC Mobile Application Named ConstellationX Privacy Policy

This Privacy Policy describes how Twin Pillar Associates LLC, a Florida limited liability company ("Twin Pillar Associates LLC," "we," "us," or "our"), located at 3650 Coral Ridge Dr STE 111, Fort Lauderdale, FL 33065, U.S.A., collects, uses, discloses, and retains information in connection with the mobile application named ConstellationX (the "App"), a push-to-talk-over-cellular communications application, and any related services (collectively, the "Services"). Twin Pillar Associates LLC is the legal entity that develops, operates, and is responsible for the App, and is registered as the App's developer with the Apple App Store and Google Play. ConstellationX is the name under which the App is published, marketed, and made available to users; it is not a separate legal entity from Twin Pillar Associates LLC. This Policy is incorporated by reference into, and should be read together with, the ConstellationX End User License Agreement, available at comstat.ai/eula.

ConstellationX accounts are typically provisioned by an administrator on behalf of an organization that has subscribed to the Services (your "Organization"). Depending on how your Organization configures the Services, your Organization's administrators may be able to access account information, group membership, shared location data, and, where enabled, communication records, in order to manage members and respond to SOS alerts. If you have questions about your Organization's specific configuration or data practices, contact your Organization's administrator.

The type of information we collect depends on how you use the Services. Some features are optional; if you do not grant a permission or provide certain information, the related feature will not be available (for example, if you do not allow location access, you cannot share your location with your contacts, and SOS alerts cannot include your position).

Account and registration information: your account ID, display name, login credentials, profile photo, phone number, organization or group membership, region, and language preference.

Messages and media: when you send a voice message, picture, video, or text message, we temporarily process and store the content on our servers solely to deliver it to the users or groups you specify. Real-time voice communications are relayed through our servers to the recipients you choose. We do not permanently retain the content of your communications on our servers beyond what is reasonably necessary to deliver them, after which such content generally resides only on the recipient's device, subject to Section 7 below.

Usage and log information: the features you use (calls, messages, groups, group names and pictures, profile photos), your settings, the time, frequency, and duration of your activity, online/offline and last-seen status, and diagnostic, crash, and performance logs and reports.

Device and connection information: hardware model, operating system and version, app version, battery level, signal strength, mobile network or carrier, connection information, language and time zone, IP address, and device identifiers.

Location information: with your permission, precise location information from your device when you use location-related features — for example, sharing your location with contacts, viewing locations shared with you, appearing on your Organization's dispatch map, or using the SOS emergency feature, which attaches your location to the alert sent to your designated contacts and Organization administrators.

Depending on your device, operating system, and the features you choose to use, the App may request the following permissions, which we make available as broadly as your device and operating system support, so that the Services function consistently regardless of platform. Each permission is used only after you or your device grants it, and declining a permission will disable the related feature.

• Microphone: to facilitate real-time push-to-talk voice communication and record voice or video calls and voice messages you choose to send.
• Location, including background location where permitted: to let you share your location with contacts, view locations shared with you, appear on your Organization's dispatch map, and attach your location to SOS emergency alerts.
• Camera: to scan an administrator-provided QR code for account setup, set or change your profile photo, and capture pictures or video to share with other users.
• Photo library: to select a profile photo and share pictures or video files with other users.
• Notifications: to alert you to incoming calls, messages, and SOS emergency alerts.
• Bluetooth: to connect wireless headsets and push-to-talk accessories.
• Storage and file access, where applicable to your device and operating system: to store your profile photo, app updates, temporary account files, and, with your permission, diagnostic logs used for troubleshooting, data analysis, testing, research, security, and fraud detection.
• Device and phone status information, where applicable to your device and operating system: to share status data with other users as you direct, enable sign-in to third-party services, provide personalized support, and facilitate your Organization's account management.
• Messaging and calling functions, where applicable to your device and operating system: solely to support the SOS emergency feature, which may need to send text messages or place calls to notify your designated contacts of an emergency.

You can review and change permission settings at any time in the App or your device settings. Disabling a permission may disable the corresponding feature, including features relevant to emergency communication.

We use the information we have, subject to your choices and applicable law, to:

• operate, provide, maintain, and improve the Services, including customer support, troubleshooting, and repair;
• understand how the Services are used, evaluate and improve them, and research, develop, and test new features;
• verify accounts and activity, combat harmful or fraudulent practices, and promote the safety, security, and integrity of the Services, including investigating suspicious activity or violations of our terms;
• enable communication and coordination among members of your Organization, including real-time voice calls, video calls, and instant messaging, and to support the SOS/emergency and dispatch-map features described above;
• respond to you when you contact us; and
• comply with, and cooperate with authorities in connection with, applicable law, regulation, court order, subpoena, or other legal process.

We do not sell your personal information, and we do not use the content of your voice messages, calls, or text messages for advertising purposes.

We may create aggregated, anonymized, or de-identified data from information we collect, including usage, performance, and diagnostic data. Such data is not personal data, and Twin Pillar Associates LLC may use, disclose, license, and otherwise exploit it for any lawful business purpose, in its sole discretion, without further notice to or consent from you, to the extent permitted by applicable law.

With people you communicate with: your messages, media, and shared location are delivered to the users and groups you choose. Your display name, profile photo, and online status may be visible to other users of your Organization. Users you communicate with may store or forward information you send them, and we are not responsible for their handling of that information.

With your Organization: if your account is provisioned by an Organization, that Organization's administrators and dispatchers can access account information, group membership, location data shared through the Services, and, depending on configuration, communication records, in order to manage members and operations and respond to SOS alerts.

With service providers: we use third-party providers to support the Services, such as hosting, cloud infrastructure, mapping, and crash-reporting and diagnostics providers (see Section 6). These providers process information only as needed to provide their services to us.

For legal and safety reasons: we may disclose information where we believe in good faith that disclosure is necessary to comply with applicable law, regulation, court order, subpoena, or other legal process; to enforce our agreements; to protect the rights, property, or safety of Twin Pillar Associates LLC, our personnel, our Organizations, our users, or the public; to investigate or prevent fraud, security, or technical issues; or with your consent — and we may do so without notice to you, to the extent permitted by law.

Business transfers: in connection with any actual or prospective merger, acquisition, financing, reorganization, bankruptcy, or sale of some or all of our assets, personal data may be disclosed to the prospective or actual acquirer, investor, lender, or successor and their advisors, as one of the transferred business assets.

To provide certain features, the App integrates third-party software development kits (SDKs), including a mapping SDK (Google Maps) used to display your location and locations shared with you, and a crash-reporting and diagnostics SDK used to collect information such as the time of a crash, device model, operating system version, and network status, for troubleshooting and improving stability. These third parties process information in accordance with their own privacy policies, which are not governed by this Policy. If you believe any integrated third-party service presents a privacy or security risk, please contact us using the information in Section 15.

We retain account information for as long as your account remains active, and message and call content only as long as reasonably necessary to deliver it, as described in Section 2. We retain other personal data for as long as we determine, in our discretion, is necessary or useful for our legitimate business purposes, for compliance with applicable law, or for the establishment, exercise, or defense of legal claims, and in any event for the longer of any such period or any minimum period required by applicable law.

• Update your profile: you can change your profile photo, display name, password, and related settings at any time in the App.
• Control permissions: you can enable or disable microphone, location, camera, photo, notification, and Bluetooth access at any time in your device settings.
• Delete your account: you can request deletion of your account in the App, by contacting your Organization's administrator, or by emailing us at legal@constellationx.ai. After deletion, your information will be deleted or anonymized in accordance with Section 7 and cannot be recovered.

Depending on your location, you may have the right to access, correct, update, restrict, or delete personal information we hold about you, to object to or restrict certain processing, and to data portability, subject to applicable exceptions and our ability to reasonably verify your identity. California residents may have additional rights described in Section 10. To exercise any right, contact us using the information in Section 15.

This Section applies to California residents with respect to personal information Twin Pillar Associates LLC processes as a business in connection with the Services, to the extent no CCPA exception or exemption applies. In the preceding 12 months, we have collected the following categories of personal information from users of the Services: identifiers (account ID, name, phone number); device and internet activity information; precise geolocation; audio and visual information (voice messages and calls); professional/organizational information (Organization and group membership); and inferences or aggregate analytics derived from the foregoing. We have disclosed these categories to service providers as described in Sections 5 and 6, to your Organization's administrators as described in Section 5, and to government or law enforcement authorities where required by law. We do not sell personal information for money. We do not have actual knowledge that we sell or share, for cross-context behavioral advertising, the personal information of California residents under 16 years of age.

California residents may exercise the right to know, delete, or correct personal information, and the right to limit use of sensitive personal information, by emailing legal@constellationx.ai. We will take reasonable steps to verify your identity before acting on a request, and may decline requests we cannot verify or that are exempt under the CCPA.

We use encryption of user passwords and other administrative, technical, and physical safeguards designed to protect your information against loss, misuse, and unauthorized access or alteration. Please keep your account credentials secure. No method of transmission over the internet or method of electronic storage is completely secure, and, to the fullest extent permitted by law, Twin Pillar Associates LLC disclaims liability for unauthorized access to or disclosure of your information that occurs despite our reasonable safeguards.

The Services are not directed to, and may not knowingly be used by, individuals under the age of 13. We do not knowingly collect personal information from children under 13. If we learn we have collected personal information from a child under 13, we will delete it. If you believe a child under 13 has provided us personal information, contact us using the information in Section 15.

Your information is primarily processed in the United States and may be disclosed to our affiliates and service providers as described in this Policy, some of whom may be located outside the country you are based in. We do not currently have offices, personnel, or Organizations located in the United Kingdom or the European Economic Area and do not knowingly process the personal data of individuals located there; if that changes, we will implement any cross-border transfer mechanism required by applicable law.

Any dispute arising out of or relating to this Policy or our data practices is subject to the binding arbitration provision, class-action waiver, limitation of liability, and governing law provisions set forth in the ConstellationX End User License Agreement, which are incorporated into this Policy by reference. To the fullest extent permitted by applicable law, Twin Pillar Associates LLC's aggregate liability for any claim arising out of or relating to this Policy or our data practices shall not exceed the amount set out in the ConstellationX End User License Agreement.

If you have questions about this Privacy Policy or our privacy practices, contact us at:

Twin Pillar Associates LLC (developer and operator of the ConstellationX application)
3650 Coral Ridge Dr STE 111
Fort Lauderdale, FL 33065
Email: legal@constellationx.ai
Website: comstat.ai

We may revise this Policy at any time, in our sole discretion, by posting the updated Policy or notifying you through the App. Changes are effective upon posting unless otherwise stated, and you are responsible for reviewing this Policy periodically. Your continued use of the Services after a change becomes effective constitutes your acceptance of the revised Policy.