Privacy Policy

02. Scope of this Privacy Policy

This Privacy Policy applies to information collected through:

• The Rationale IQ public website.
• The Rationale IQ platform.
• Pilot Program applications and participation.
• Contact forms.
• Communications with our team.
• Product inquiries.
• Customer onboarding activities.
• Authorized use of the Rationale IQ platform.

This Privacy Policy applies only to information collected by Rationale IQ.

It does not apply to:

• Third-party websites that may be accessible through links contained within our Services.
• Third-party products or services integrated with our platform.
• Websites, services, or applications operated by organizations other than Rationale IQ.

We encourage users to review the privacy policies of any third-party websites or services they access through links provided by our Services.

03. Our Privacy Principles

At Rationale IQ, our approach to privacy is guided by the following principles.

• Customer Ownership — Customers retain ownership of the documents, information, and other content they upload to or generate through the platform.
• Data Minimization — We strive to collect only the information reasonably necessary to provide our Services, improve platform functionality, communicate with users, and satisfy applicable legal and contractual obligations.
• Security by Design — Security considerations are incorporated throughout the design, development, and operation of our platform. We continually evaluate and enhance administrative, technical, and organizational safeguards intended to protect customer information.
• Transparency — We believe users should understand what information we collect, why we collect it, how it is used, and the choices available regarding their information.

04. Definitions

For purposes of this Privacy Policy:

• "Account" — Means an authorized user account created to access the Rationale IQ platform.
• "Customer" — Means the organization that purchases, subscribes to, licenses, or otherwise receives access to the Services.
• "User" — Means any individual authorized by a Customer to access or use the Services.
• "Customer Content" — Means documents, financial statements, disclosures, accounting memoranda, contracts, spreadsheets, reports, communications, and other information uploaded, submitted, or otherwise provided by a Customer or User for processing through the Services.
• "Personal Information" — Means information that identifies, relates to, describes, or can reasonably be associated with an identified or identifiable individual, as defined under applicable U.S. privacy laws.
• "Services" — Means the Rationale IQ website, AI-powered accounting and financial reporting platform, software applications, Pilot Program, and any related services provided by Rationale IQ.
• "Platform" — Means the Rationale IQ software application used to provide AI-powered accounting and financial reporting services.

05. Applicability

This Privacy Policy applies to all users of the Services, including:

• Website visitors.
• Individuals submitting inquiries through our website.
• Pilot Program applicants.
• Pilot Program participants.
• Authorized users of Customer accounts.
• Existing and prospective customers.
• Individuals communicating with Rationale IQ regarding our Services.

Different features of the Services may collect different categories of information depending on how the Services are used.

The remainder of this Privacy Policy explains those categories of information and how they are handled.

06. Information We Collect

To provide, maintain, improve, and secure our Services, Rationale IQ may collect several categories of information depending on how you interact with our website, participate in our Pilot Program, communicate with us, or use the platform.

The categories of information we collect are described below.

6.1 Information You Provide to Us

We collect information that you voluntarily provide when you interact with Rationale IQ.

Depending on your interaction with our Services, this information may include:

Contact Information

• Full name
• Business email address
• Business telephone number
• Company name
• Job title
• Business mailing address (if provided)

Account Information

When an account is created for the platform, we may collect:

• User name
• Business email address
• Password credentials (stored using secure authentication technologies)
• User role and permissions
• Account preferences

Pilot Program Information

When applying to participate in our Pilot Program, we may collect:

• Company information
• Industry
• Contact information
• Job title
• Number of accounting and financial reporting team members
• Information voluntarily included within application comments

Communications

When you communicate with us, we may collect information contained in:

• Contact forms
• Email correspondence
• Customer support requests
• Product inquiries
• Feedback
• Survey responses
• Other communications voluntarily provided to us

6.2 Customer Content

The Services are designed to assist accounting and financial reporting professionals by analyzing information provided by authorized users.

Accordingly, users may upload or otherwise submit Customer Content for processing through the platform.

Customer Content may include:

• Financial statement disclosures
• Quarterly reports
• Annual reports
• Registration statement disclosures
• Financial statement footnotes
• Technical accounting memoranda
• Contracts
• Agreements
• Accounting transaction documentation
• Supporting schedules
• Spreadsheets
• Accounting analyses
• Business narratives
• Transaction fact patterns
• Documents uploaded for AI-assisted analysis
• Information entered through conversational interfaces

Customers should upload only information reasonably necessary to perform the requested analysis.

6.3 Information Collected Automatically

When users access the website or platform, certain technical information may be collected automatically to support platform functionality, security, and performance.

This information may include:

• IP address
• Browser type and version
• Device type
• Operating system
• Date and time of access
• Session information
• Referring pages
• Website navigation activity
• Platform usage activity
• Error logs
• Performance metrics
• Authentication events

This information is generally used to maintain system reliability, improve user experience, enhance platform performance, and support security monitoring.

6.4 Cookies and Similar Technologies

The Rationale IQ website and platform may use cookies and similar technologies to:

• Maintain user sessions
• Remember user preferences
• Improve website functionality
• Measure website performance
• Support analytics
• Enhance security

Users may manage cookie preferences through their browser settings; however, disabling certain cookies may affect the functionality of portions of the Services.

6.5 Information from Third-Party Services

Depending on how the Services are configured, Rationale IQ may receive limited information from third-party service providers that support operation of the platform.

Examples may include:

• Identity and authentication providers
• Cloud infrastructure providers
• Analytics providers
• Security monitoring services
• Email delivery providers

We collect only the information reasonably necessary for these services to support operation of the platform.

6.6 Information We Do Not Intentionally Collect

Rationale IQ is designed for business use by accounting and financial reporting professionals.

We do not intentionally collect Personal Information directly from children under the age of 13.

Users should avoid uploading unnecessary Personal Information or confidential information unrelated to the requested analysis.

6.7 Accuracy of Information

Users are responsible for ensuring that the information they provide to Rationale IQ is accurate, complete, and current.

Customers are also responsible for ensuring they have the necessary rights and permissions to upload Customer Content to the platform.

07. How We Use Information

Rationale IQ uses the information collected through the Services to operate, maintain, secure, and continually improve our website, platform, and related services.

We use information only for legitimate business purposes consistent with providing our Services.

7.1 Provide the Services

We use information to:

• Create and manage user accounts.
• Authenticate authorized users.
• Provide access to platform features.
• Process customer requests.
• Perform AI-assisted accounting and financial reporting analyses.
• Generate requested reports and outputs.
• Deliver requested platform functionality.

7.2 Process Customer Content

Customer Content is processed solely to provide the Services requested by the Customer.

Depending on the selected workflow, Customer Content may be processed to:

• Analyze financial statement disclosures.
• Perform peer benchmarking analyses.
• Evaluate historical SEC comment letter trends.
• Support technical accounting analyses.
• Draft accounting position memoranda.
• Generate reports requested by authorized users.

7.3 Support Artificial Intelligence Processing

Artificial intelligence is used to assist accounting and financial reporting professionals by:

• Understanding uploaded documents.
• Identifying accounting topics.
• Organizing transaction facts.
• Analyzing financial reporting information.
• Generating structured analyses.
• Drafting requested reports and memoranda.
• Improving workflow efficiency.

AI-generated outputs are intended to support—not replace—professional judgment.

7.4 Use of Information

Rationale IQ also uses information to:

• Communicate with users.
• Maintain platform security.
• Improve platform functionality.
• Administer the Pilot Program.
• Comply with legal obligations.
• Support normal business operations.

We do not sell Customer Content, use Customer Content for advertising purposes, or claim ownership of Customer Content.

08. AI Processing of Customer Content

Artificial intelligence is a core component of the Rationale IQ platform and is used solely to assist accounting and financial reporting professionals in performing analyses requested by authorized users.

AI processing may be used to:

• Analyze financial statement disclosures.
• Identify accounting topics.
• Understand transaction facts.
• Organize accounting research.
• Compare disclosures against peer company filings.
• Analyze historical SEC comment letter trends.
• Support technical accounting analyses.
• Draft accounting position memoranda.
• Generate reports requested by authorized users.

Customer Content is processed only to complete the requested workflow.

Customers remain responsible for reviewing all AI-generated outputs and exercising independent professional judgment.

Where applicable, the platform provides references and citations supporting its analyses and may include links directing users to external sources where the applicable accounting guidance can be accessed.

Customer Content submitted for AI processing is handled in accordance with Rationale IQ's security and privacy practices.

Rationale IQ does not use Customer Content to develop or train its own proprietary artificial intelligence models.

Customer Content processed by third-party artificial intelligence providers is handled in accordance with those providers' applicable terms of service and data usage and retention policies, which are incorporated by reference. Those providers' data use, model training, retention, and deletion practices depend on the specific services and terms applicable to Rationale IQ's use. Rationale IQ does not control, and cannot guarantee, the practices of third-party providers, and those providers' terms and policies govern their handling of Customer Content.

Rationale IQ implements administrative, technical, and organizational safeguards designed to protect Customer Content throughout its processing within the platform.

AI-generated analyses may not identify every relevant accounting issue or disclosure consideration and should always be reviewed by qualified accounting professionals.

09. Customer Ownership of Data

Customers retain all right, title, and interest in and to the Customer Content they upload, submit, or otherwise provide through the Services.

Nothing in this Privacy Policy transfers ownership of Customer Content to Rationale IQ.

Subject to applicable law and the Terms of Use, Customers retain ownership of reports, analyses, accounting memoranda, disclosure assessments, benchmarking reports, SEC comment letter analyses, and other outputs generated using their Customer Content.

Customers grant Rationale IQ a limited, non-exclusive right to process Customer Content solely as necessary to:

• Provide the Services.
• Perform AI-assisted analyses.
• Generate requested reports.
• Maintain platform functionality.
• Support customer requests.
• Protect the security and integrity of the Services.

Rationale IQ does not sell Customer Content or use Customer Content for advertising or unrelated commercial purposes.

Customers remain responsible for ensuring they have the necessary rights to upload Customer Content and control which documents, analyses, users, and reports are authorized within their organizations.

Customer Content is handled in accordance with the security and privacy practices described throughout this Privacy Policy.

Upon termination of the Services, Customer Content will be retained or deleted in accordance with applicable customer agreements, legal obligations, and Rationale IQ's data retention practices.

In the event of any conflict between this Privacy Policy and the Terms of Use or an applicable customer agreement regarding the handling of Customer Content, the Terms of Use or such agreement control, and the protections afforded to Customer Content may not be diminished by any subsequent change to this Privacy Policy.

10. Disclosure of Information

Rationale IQ is committed to protecting the confidentiality of Customer Content and Personal Information.

We do not sell Customer Content or Personal Information. We do not disclose Customer Content except in the limited circumstances described in this Privacy Policy, as authorized by the Customer, or as otherwise required by applicable law.

10.1 Disclosure with Customer Authorization

Customer Content may be disclosed when expressly authorized or directed by the Customer or an authorized user.

Examples include:

• Sharing reports within the Customer's organization.
• Exporting reports or analyses requested by authorized users.
• Integrations or data transfers initiated by the Customer.
• Other disclosures expressly requested by the Customer.

10.2 Third-Party Service Providers

Rationale IQ utilizes a limited number of carefully selected third-party service providers that are essential to the operation and delivery of the Services.

These providers process information only as necessary to perform the services they provide on behalf of Rationale IQ.

Supabase

Rationale IQ utilizes Supabase to support core platform infrastructure, including:

• User authentication.
• Secure database services.
• File storage.
• Backend infrastructure.
• Platform functionality.

Supabase processes information solely to provide these infrastructure services and does not own Customer Content processed through the Rationale IQ platform.

OpenAI

Rationale IQ utilizes OpenAI to provide certain artificial intelligence capabilities within the platform.

OpenAI may process Customer Content submitted by authorized users solely for the purpose of performing AI-powered analyses and generating the outputs requested by the Customer.

These services may include:

• Disclosure adequacy analyses.
• Peer benchmarking analyses.
• SEC comment letter risk analyses.
• Accounting position memorandum drafting.
• Other AI-assisted accounting and financial reporting workflows requested by authorized users.

Rationale IQ uses OpenAI's API services to provide certain artificial-intelligence capabilities and may submit Customer Content to OpenAI to perform the requested Services. OpenAI's processing of Customer Content is governed by the OpenAI terms of service and data usage and retention policies applicable to the API services Rationale IQ uses, which are available at https://openai.com/policies/row-privacy-policy/, https://openai.com/policies/usage-policies/, https://openai.com/policies/service-terms/, https://openai.com/business-data/ and incorporated by reference. Because Rationale IQ uses OpenAI's API services, OpenAI does not, by default, use Customer Content (inputs or outputs) submitted through the API to train or improve its models, and organizations are opted out of such data sharing unless they expressly opt in. Rationale IQ does not enable any opt-in that would permit OpenAI to use Customer Content to train or improve its models. OpenAI may retain API inputs and outputs for a limited period to provide the Services and monitor for abuse, after which such data is deleted unless retention is required by law. Customer Content is submitted to OpenAI solely to perform the requested Services. Because OpenAI establishes its own terms and practices and may change them, Customers are encouraged to review OpenAI's current applicable terms, and Customers may submit data access or deletion requests directly to OpenAI through OpenAI's privacy portal.

Customer Content is submitted to OpenAI solely to perform the requested Services, and OpenAI's applicable terms and policies govern its handling of Customer Content.

Selection of Service Providers

Rationale IQ selects third-party service providers based on factors that may include:

• Security capabilities.
• Reliability.
• Operational performance.
• Suitability for enterprise software applications.
• Ability to support the secure delivery of our Services.

We periodically evaluate our service providers as our platform and business evolve.

Should Rationale IQ engage additional third-party service providers in the future that materially affect the processing of Customer Content or Personal Information, this Privacy Policy will be updated accordingly.

10.3 Legal Requirements

Rationale IQ may disclose information where we believe disclosure is reasonably necessary to:

• Comply with applicable laws or regulations.
• Respond to lawful requests from governmental authorities.
• Comply with court orders or other legal process.
• Protect the rights, property, or safety of Rationale IQ, our customers, or others.
• Investigate suspected fraud, misuse, or unauthorized access.

Where legally permitted and reasonably practical, we may notify the affected Customer before responding to such requests.

10.4 Protection of the Services

Information may be disclosed where reasonably necessary to:

• Detect or prevent fraud.
• Investigate security incidents.
• Protect customer accounts.
• Respond to unauthorized access attempts.
• Maintain the security, integrity, and availability of the Services.

10.5 Business Transactions

• If Rationale IQ is involved in a merger, acquisition, financing, corporate reorganization, sale of assets, or similar business transaction, information may be transferred as part of that transaction.
• Any successor entity will be expected to honor the commitments described in this Privacy Policy or provide notice of any material changes before they become effective.

10.6 Aggregated and De-Identified Information

Rationale IQ may use or disclose aggregated or de-identified information that cannot reasonably be used to identify an individual or Customer.

Such information may be used for purposes including:

• Platform improvement.
• Performance measurement.
• Product development.
• Business analytics.
• Research.

Aggregated or de-identified information does not include information that directly identifies a Customer or individual user. Where the applicable customer agreement, Terms of Use, or Pilot Program Agreement restricts the use of Customer Content in aggregated or de-identified form, that agreement controls.

10.7 No Sale of Personal Information

Rationale IQ does not sell Personal Information.

We also do not sell Customer Content or disclose Customer Content for unrelated commercial purposes.

11. Data Security

Rationale IQ recognizes that protecting Customer Content and Personal Information is fundamental to the trust our customers place in us.

We are committed to maintaining administrative, technical, and organizational safeguards designed to protect the confidentiality, integrity, and availability of the information processed through our Services.

Although no method of transmitting or storing information can guarantee absolute security, we continually evaluate and enhance our security practices to help reduce risk and protect customer information.

11.1 Security by Design

Security is considered throughout the design, development, and operation of the Rationale IQ platform.

Our objective is to implement security practices that help protect customer information while supporting reliable, secure, and efficient operation of the Services.

11.2 Access Controls

Access to the platform is limited to authorized users with valid credentials.

Security measures may include:

• User authentication.
• Role-based access controls.
• Password protection.
• Session management.
• Access logging.

Customers are responsible for managing user access within their organizations and for protecting the confidentiality of user credentials.

11.3 Encryption

Rationale IQ protects Customer Content using industry-standard encryption in transit and at rest.

11.4 Secure Cloud Infrastructure

The Rationale IQ platform is hosted using secure cloud infrastructure designed to support availability, reliability, and data protection.

Infrastructure providers are selected based on factors including security capabilities, operational reliability, and suitability for enterprise software applications.

11.5 Monitoring and Protection

We implement security practices intended to help identify, prevent, and respond to potential security events.

These practices may include:

• Authentication monitoring.
• System activity monitoring.
• Error logging.
• Security event monitoring.
• Detection of unauthorized access attempts.
• Platform performance monitoring.

11.6 Customer Responsibilities

Customers and authorized users are responsible for:

• Maintaining the confidentiality of account credentials.
• Assigning appropriate user permissions.
• Using the Services in accordance with applicable security policies.
• Promptly notifying Rationale IQ of suspected unauthorized access or security incidents involving their accounts.

11.7 Security Incident Response

• If Rationale IQ becomes aware of a security incident that materially affects Customer Content or Personal Information, we will investigate the incident, take appropriate measures to contain and remediate it, and notify the affected Customer without undue delay and, in any event, within seventy-two (72) hours of confirming the incident, subject to any additional requirements under applicable law or contractual obligations.

11.8 Security Reviews and Improvements

Security is an ongoing process.

As the platform evolves, Rationale IQ may periodically evaluate and enhance its security practices, technologies, and operational procedures to strengthen the protection of Customer Content and Personal Information.

11.9 Customer Questions

Customers with questions regarding the security of the Services may contact Rationale IQ using the contact information provided at the end of this Privacy Policy.

12. Data Retention

Rationale IQ retains Personal Information and Customer Content only for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Privacy Policy, satisfy contractual obligations, comply with applicable legal requirements, resolve disputes, and protect the security and integrity of the Services.

Retention periods may vary depending on the type of information and applicable legal, contractual, operational, and business requirements.

12.1 Customer Content

Customer Content is generally retained for the duration of the Customer's use of the Services unless otherwise agreed in writing.

12.2 Account Information

Account information is retained while a user account remains active and thereafter only as reasonably necessary to satisfy legal, contractual, operational, or security requirements.

12.3 Customer Communications

Customer communications may be retained as reasonably necessary to respond to requests, improve customer support, maintain business records, and comply with legal obligations.

12.4 System Logs and Security Information

System logs, authentication records, and operational information may be retained for periods reasonably necessary to support security monitoring, incident response, platform reliability, and legal compliance.

12.5 Deletion of Customer Content.

Following expiration or termination of the Customer's access to the Services, the Customer may request deletion of its Customer Content, and Rationale IQ will delete such Customer Content within thirty (30) days of the request, subject only to applicable legal obligations, contractual requirements, ongoing legal proceedings, and legitimate business purposes. Rationale IQ's deletion obligation is limited to Customer Content within its direct control and does not extend to Customer Content transmitted to and retained by third-party providers (including OpenAI) under those providers' own terms, which the Customer is responsible for addressing directly.

Upon receiving a valid request, Rationale IQ will take reasonable steps to delete or securely dispose of Customer Content in accordance with applicable laws, contractual obligations, and our internal data management practices.

12.6 Backup Copies

Customer Content may remain in secure backup systems for a limited period following deletion from active production systems to support disaster recovery and business continuity.

12.7 Legal Retention Requirements

Rationale IQ may retain information for longer periods where required or permitted by law.

12.8 Secure Disposal

When information is no longer required, Rationale IQ will take reasonable measures to securely delete, anonymize, or otherwise dispose of such information in accordance with our internal data management practices and applicable legal requirements.

13. Your Privacy Rights

Rationale IQ respects the privacy rights of individuals and is committed to providing transparency regarding the Personal Information we collect and process.

Depending on your relationship with Rationale IQ and applicable U.S. privacy laws, you may have certain rights regarding your Personal Information.

These rights may include:

• The right to request access to your Personal Information.
• The right to request correction of inaccurate or incomplete Personal Information.
• The right to request deletion of Personal Information, subject to applicable legal, contractual, operational, or security requirements.
• The right to update certain account information.
• The right to opt out of marketing communications.
• The right to submit privacy-related requests.

To protect Personal Information, Rationale IQ may request information necessary to verify the identity and authority of an individual submitting a privacy request before processing that request.

Requests may be submitted using the contact information provided below.

We will respond to requests in accordance with applicable law.

14. Children's Privacy

The Rationale IQ website and Services are designed exclusively for business use by accounting and financial reporting professionals.

Our Services are not directed to, intended for, or designed to attract individuals under the age of 13, and we do not knowingly collect Personal Information directly from children under the age of 13.

If we become aware that Personal Information has been collected directly from a child under the age of 13 without appropriate authorization, we will take reasonable steps to delete such information as soon as practicable.

If you believe that a child under the age of 13 has provided Personal Information directly to Rationale IQ, please contact us using the information provided below.

15. Changes to This Privacy Policy

Rationale IQ may update this Privacy Policy from time to time to reflect changes in our Services, technology, business operations, legal requirements, or privacy practices.

When we make material changes, we will update the Effective Date at the beginning of this Privacy Policy.

Where required by applicable law or where we determine appropriate, we may also provide notice of material changes through the website, platform, email communications, or other reasonable means.

We encourage users to periodically review this Privacy Policy.

Continued use of the Services following the effective date of an updated Privacy Policy constitutes acknowledgment of the revised Privacy Policy, except where applicable law requires a different form of consent.

16. Related Agreements

This Privacy Policy does not limit or diminish any data protection, confidentiality, security, or data return or deletion commitments set forth in a written agreement between Rationale IQ and a Customer, including the Terms of Use, the Pilot Program Agreement, or any data processing addendum. In the event of a conflict between this Privacy Policy and such an agreement regarding the handling of Customer Content, the terms of that agreement control, and no amendment to this Privacy Policy will reduce those commitments.

17. Contact Information and Privacy Requests

If you have questions regarding this Privacy Policy, our privacy practices, or wish to submit a privacy-related request, please contact us.

Rationale IQ

General Inquiries

[email protected]

Privacy Requests

Requests relating to:

• Access to Personal Information.
• Correction of Personal Information.
• Deletion of Personal Information.
• Questions regarding Customer Content.
• Questions regarding this Privacy Policy.

may be submitted using the contact information above.

To help protect your information, we may request additional information to verify your identity before responding to certain requests.

Commitment to Privacy

At Rationale IQ, protecting the confidentiality, integrity, and security of Customer Content and Personal Information is fundamental to the way we design, develop, and operate our Services.

We are committed to responsible innovation and to supporting accounting and financial reporting professionals with secure, transparent, and trustworthy technology.

As our platform evolves, we will continue to evaluate and enhance our privacy and security practices to help meet the expectations of our customers and support the responsible use of artificial intelligence within accounting and financial reporting workflows.