Privacy Policy

We may collect personal information from the following sources:

• Provided directly through our Website and Services.
• During Customer or prospective Customer communications.
• From Customers’ event attendee information in association with one of our Customers’ events.
• Automatic collection from visitors to our Website, where we may use online tracking technologies and other automatic data collection technologies, such as pixels, web beacons, software developer kits, and cookies. Learn more about our cookie use below.

Customer Information

In order to serve our Customers, we will collect various information from, or about, our Customers, including:

• Professional contact information including your name, title, company email, phone number, company name, company website URL, or any designated employee contact information in use of the Services.
• Correspondence, which may include any personal information provided during an email correspondence or Customer service engagement.
• Billing and administrative finance information.
• Automated information, including metadata and analytics for your use of our Website and Services, including cookie IDs, IP address, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, and what you do on those pages. Learn more about our cookie use below.

Our Customer’s Event Attendee Information

When our Customers use our Services, they enable us to process various types of personal information on individuals attending our Customers’ live events (“Event Attendees”). Below, we provide a list of the commonly processed personal information of Event Attendees. Please note, the below list is not exhaustive of all personal information, and is intended to serve as a sample set.

• Contact information such as name, company, title, email address, and phone number.
• Preferences and other profile information.
• Personal information provided when communicating with our Services, including our SMS/MMS interactive chat concierge.
• Photographs captured at our Customers’ events. Learn more about Biometric Information processing activities below.
• Additional information with Event Attendee consent.

We may use Customer personal information for the following business purposes:

• To provide and improve our Website and Services.
• To communicate with you.
• To process payments securely.
• For customer support, including email, phone, and chat.
• To send our Customers marketing and promotional communications in accordance with individual marketing preferences.
• To authenticate, verify, or otherwise ensure compliance with Customer written instructions or to mitigate the risk of fraud.

Subject to the terms of our Customer agreements, we may use Event Attendee personal information for the following business purposes:

• To provide our Services to Customers, including:
  • Event Attendee communications. Our Customers may utilize Agent Analog to provide communications support to Event Attendees, including via SMS based on Event Attendee consent, where legally required.
  • Event Attendee photo sharing. Our Customers may utilize Agent Analog to deliver personalized photos and galleries directly to Event Attendees in conjunction with our Customer’s written instructions.
• To improve our Services. For example, we may modify our user interface based on user behavior. Please note that we do not process, store, train AI models, or otherwise use Customer Event Attendee personal information for any independent purposes without either express written consent from our Customer or their Event Attendees.
• For any legal purpose necessary, including intellectual property protection, or if we are required to process information as a result of a court order or other legal or regulatory proceeding.

We may otherwise use personal information with your consent. We may also use aggregated and/or anonymous information for any purpose.

We utilize various service providers to operate our Website and Services, which may include sharing Customer and/or Event Attendee personal information. Some of the types of service providers include:

• Customer relationship management platforms and customer billing software.
• Banking and payment processing providers.
• Customer support providers, including Hubspot, Inc. for providing our contact form and waitlist.
• Communications providers, including Plus Five Five, Inc. (dba Resend) for transactional email communications and Twilio, Inc. for sending and receiving SMS/MMS communications.
• Artificial intelligence providers to support our Services (see “Artificial Intelligence Disclosure” below).
• Amazon Web Services (AWS) to support event photograph storage, delivery, and facial recognition. Amazon Web Services will not use event photos for any purpose other than to support our Services, and are also subject to Amazon Web Service’s applicable terms of service and privacy policy.
• Google LLC to support document and Event Attendee information sharing between us and our Customers.
• Service providers that help manage and optimize our Website and Services (see “Cookies and Other Tracking Technologies” below).

In addition, we may share personal information in order to:

• Protect the legal rights of our Customers, our company, our employees, our agents, and our affiliates.
• Protect the safety and security of those who access and use our Website and Services.
• Detect and protect against fraud.
• Comply with law or legal process.
• Conduct due diligence or complete a legal transaction related to the sale of our business or any assets.

We may disclose de-identified, aggregate, or anonymous information for any purpose. This means that the information does not identify specific individuals.

Because some of our Services collect biometric identifiers, such as photographs associated with specific individuals, we follow heightened standards:

• We collect biometric information only with explicit written instructions from our Customers. Agent Analog does not present, control, or otherwise provide any type of consent request to individuals, but rather relies upon the Customer’s consent mechanism in order to process biometric information on their behalf.
• We use biometric information solely to deliver Event Attendee photographs directly to Customers and/or Event Attendees with specific written instructions to do so on their behalf.
• We do not train AI models, sell, lease, license, trade, or otherwise profit from processed biometric information.
• We retain biometric identifiers only for as long as necessary to provide the Services, and we delete them within a reasonable period after the purpose for collection has been satisfied or upon our Customer’s request, subject to applicable legal retention obligations. For example, our default data retention period is within 30 days following events, but is ultimately subject to Customer terms.

State Biometric Privacy Laws (BIPA / CUBI / MHMD)

Where facial recognition is used to match event photographs to the Event Attendee who appears in them, this constitutes the processing of biometric identifiers under applicable state law, including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and the Washington My Health My Data Act (MHMD). Facial geometry and biometric identifiers are used only during active photo matching for the applicable event and are permanently and irreversibly deleted no later than thirty (30) days following the conclusion of the event. If consent is withdrawn prior to that deadline, the associated biometric data will be deleted within ten (10) business days of a verified request. Attendees subject to these laws may request deletion of their biometric data at any time by contacting privacy@agentanalog.ai. A written biometric data retention and destruction policy is available upon request. Washington residents should also review the important notice under “US State Privacy Rights” below.

Agent Analog uses various third party artificial intelligence tools to enable our Services, including OpenRouter, Inc. to assist with routing requests to underlying AI model providers. Our commercial terms with OpenRouter, Inc. limit the scope of their personal information processing activities to exclusively support our Services, and they are commercially restricted from using personal information or the content of SMS or other interactive chat data for their own product improvement purposes. For more information, visit OpenRouter’s terms of service.

Agent Analog may use SMS or other chat communications to improve our Services’ capabilities, but does not use personal information or individual photograph data to train the artificial intelligence features of our Services.

Agent Analog's SMS concierge service uses artificial intelligence to generate and deliver responses to attendee inquiries. Under the California Consumer Privacy Act (CCPA) regulations effective January 1, 2026, this constitutes the use of Automated Decision-Making Technology (ADMT).

Pre-Use Notice

Before using Agent Analog's AI-powered concierge service, you are hereby notified that:

• Agent Analog uses AI technology to process your SMS requests and generate responses related to event logistics, wayfinding, schedules, and attendee support
• AI-generated responses are assistive and informational only; they do not constitute professional advice and may not always be accurate or complete
• No significant decisions affecting your legal rights, access to services, employment, healthcare, education, or housing are made solely through Agent Analog's AI concierge
• You may request information about the logic and likely outcomes of Agent Analog's ADMT processes by contacting privacy@agentanalog.ai

Opt-Out of ADMT

California residents have the right to opt out of ADMT processing. If you opt out, you will not receive AI-generated concierge responses via Agent Analog SMS during the event. To opt out, contact privacy@agentanalog.ai or reply OPTOUT to any Agent Analog message. Note: opting out of ADMT will limit your ability to use the concierge service but will not affect photo delivery or other event services.

Compliance Timeline

ADMT compliance for existing Agent Analog deployments is required by January 1, 2027 under the CCPA. Agent Analog is actively implementing full ADMT compliance measures ahead of that deadline.

We provide our Customers with the following choices with our use of your personal information:

• Access or correct the personal information we maintain about you.
• Delete the personal information we maintain about you. Please note we may be required by law to retain certain information in compliance with accounting, tax, or other legal obligations.
• Opt out of certain uses of your personal information, notably:
  • Marketing Emails: To opt out of marketing e-mail communications, you may click the “unsubscribe” link in the marketing emails.
  • Marketing Text Messages: To opt out of marketing text messages, you must reply STOP to the text message. You agree that texting “STOP” in response to our text message is the only reasonable method of opting out. You also understand and agree that any other method of opting out, including, but not limited to, texting words other than “STOP” or verbally requesting one of our employees to remove you from our list, is not a reasonable means of opting out.

You can exercise these rights by contacting us at privacy@agentanalog.ai or by visiting agentanalog.ai/opt-out.

If you are an Event Attendee of one of our Customer’s events, and you would like to fulfill your rights to the personal information we maintain about you on behalf of that Customer, we encourage you to exercise these rights by reviewing the Customer’s privacy policy to determine the correct contact method for that Customer. Alternatively, if you email us at privacy@agentanalog.ai and identify the Customer that is utilizing our Services, we can forward your request to the appropriate contact.

Like many companies, we use cookies and similar technologies (such as clear gifs, web beacons, tags, and similar technologies) to collect information about your browsing activities, your interactions with our Website and Services, and for the purposes described in this Privacy Policy. There are a number of ways to opt out of having your online activity and device data collected through these services, which we summarize below:

• Opting Out of Cookie Use in Our Cookie Preference Center. You can opt out of cookies by emailing us at privacy@agentanalog.ai.
• With Each of Our Advertising Vendors Individually. The following third party service partners offer opt-out features that let you opt out of use of your information for interest-based advertising:
  • Google Analytics — Google Analytics Opt Out

Please note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

We maintain reasonable safeguards to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control. Our safeguards include:

• SSL/TLS encryption for data in transit
• Encryption at rest for stored data
• Access controls and role-based permissions
• Limited data retention and scheduled deletion policies
• Consent management for SMS and photo delivery
• Audit logging and monitoring of system access

Despite our efforts, we cannot guarantee that unauthorized access or use will never occur, and no data transmission over the Internet can be guaranteed to be 100% secure. It is important that you take steps to keep your information safe and secure. Choose an account password that is hard for others to guess and don’t reveal it to third parties. If you use a shared public computer, do not opt to have your login ID or password remembered, and be sure to log out of your account when you finish.

We will retain Customer personal information only for as long as it is necessary for the purposes of fulfilling our Website and Services, or otherwise as described in this Privacy Policy or according to the terms of our written agreements with Customers, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We set our default processing of Event Attendee personal information to thirty (30) days post event. However, this retention period is set by Customers prior to the event and can be extended as requested in accordance with their privacy practices.

Residents of the United Kingdom (“UK”) and the European Economic Area (“EEA”) are provided certain privacy rights under the UK and EU General Data Protection Regulations (“GDPR”).

Legal Basis

Under the GDPR, we process Personal Data under the following legal basis.

Controller and Processor Designation

Under the GDPR, we are designated as a Controller of Customer personal data, and a Processor of Event Attendee personal data.

Cross-Border Data Transfers

We may transfer to, and store the data we collect about you in, countries other than the country in which the data was originally collected, including the United States, Canada, or other destinations outside the EEA and the UK. Those countries may not have equivalent data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and applicable supplemental product privacy policy, and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA or UK.

If you are located in the EEA or UK, we will only transfer your Personal Data if:

• The country to which the Personal Data will be transferred has been granted a European Commission adequacy decision; or
• We have put in place appropriate safeguards in respect of the transfer, for example we have entered into the Standard Contractual Clauses adopted by the European Commission and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by a supervisory authority.

Additional Rights for UK or EEA Residents

In addition to the rights granted above, if you are a UK or EEA resident, the GDPR grants you the right to lodge a complaint against us with your local data protection authority. You can find your data protection authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

The following disclosures apply to residents of US states that provide statutory privacy rights, including California and Washington. Where these state-specific provisions conflict with the general terms above, the state-specific provisions control for residents of the applicable state.

Notice at Collection — California Residents

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), Agent Analog LLC is required to provide notice at or before the point of collection of the categories of personal information collected, the purposes for which each category is used, whether each category is sold or shared, and the retention period or criteria used to determine retention. The following matrix satisfies that requirement.

Agent Analog LLC does not sell personal information as defined under the CCPA/CPRA. Agent Analog LLC does not share personal information for cross-context behavioral advertising.

California Privacy Rights (CCPA / CPRA)

If you are a California resident, you have the following rights:

• Right to Know: request details on what personal data we collect, use, disclose, and sell
• Right to Delete: request deletion of your personal data, subject to legal exceptions
• Right to Correct: request correction of inaccurate personal information
• Right to Opt-Out: opt out of the sale or sharing of personal data (we do not sell or share for advertising)
• Right to Limit Use of Sensitive Personal Information: limit our use of sensitive PI, including biometric identifiers, to purposes necessary to perform the services
• Right Against Retaliation: we will not discriminate against you for exercising any of these rights

To exercise any of these rights, contact us at privacy@agentanalog.ai or visit agentanalog.ai/opt-out. We will respond to verifiable requests within 45 days, with a possible 45-day extension where reasonably necessary.

Privacy Risk Assessments

Under CCPA regulations effective January 1, 2026, businesses that process personal information presenting “significant risk” to consumer privacy are required to conduct and document privacy risk assessments. Agent Analog’s processing of biometric data (facial recognition) and sensitive personal information constitutes significant-risk processing under this standard. Agent Analog LLC is committed to completing the required risk assessment for all covered processing activities by December 31, 2027, with the initial summary submission to the California Privacy Protection Agency (CPPA) due by April 1, 2028.

Washington My Health My Data Act — Important Notice

The Washington My Health My Data Act (MHMD), in effect since March 31, 2024, classifies biometric data as consumer health data and imposes requirements that go significantly beyond standard biometric privacy laws. Key points for Washington residents and attendees at Washington-based events:

• Biometric data under MHMD includes facial photographs from which an identifier template can be extracted — meaning photo capture alone may qualify even before facial matching occurs
• MHMD consent must be a clear, specific, informed, opt-in, voluntary, and unambiguous affirmative act. Consent cannot be inferred from general Terms of Service acceptance, event attendance, or inaction
• MHMD provides a private right of action, meaning Washington consumers may sue Agent Analog directly for violations in addition to enforcement by the Washington Attorney General — with penalties up to $7,500 per incident and potential treble damages
• You have the right to access your consumer health data, receive a list of all third parties who received your data, withdraw consent at any time, and request deletion from all systems including backups
• Agent Analog does not sell consumer health data

IMPORTANT: Washington's MHMD requires a standalone Consumer Health Data Privacy Policy separate from this general Privacy Policy. Agent Analog LLC has published a Washington Consumer Health Data Privacy Policy available at agentanalog.ai/privacy/washington, which governs all consumer health data (including biometric data) collected from Washington residents or at Washington-based events. That policy controls in the event of any conflict with this general Privacy Policy with respect to Washington consumer health data. If you are a Washington resident with questions, contact privacy@agentanalog.ai.

We do not intentionally collect any personal information from children under the age of 18. In limited cases, minors may appear incidentally in event photography; such images are processed solely for event-related purposes, and facial recognition is not applied to minors without verifiable parental consent. If you believe we have obtained personal information associated with a child under the age of 18, please contact us at privacy@agentanalog.ai and we will delete it.

The Website and Services may contain links to other websites or services. We do not exercise control over the information you provide, or that is collected by these third party websites. We encourage you to read the privacy policies or statements of the other websites you visit.

We may update this Privacy Policy from time to time as we update or expand our Website and Services. If we make material changes, we will post the updated Privacy Policy on this page with a “Last Updated” effective date of the revisions and, where appropriate, notify active users. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Website and Services.

If you have any questions about our privacy or security practices, or if you would like to submit a privacy request, you can contact us by email or at the address below:

Agent Analog LLC
311 N Robertson Blvd. #250
Beverly Hills, California 90211

General inquiries: hello@agentanalog.ai

Attendee support: help@agentanalog.ai

Privacy & data requests: privacy@agentanalog.ai

Legal & contracts: legal@agentanalog.ai

Last Updated: July 14, 2026