Privacy Policy

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.

We collect personal information from the following categories of sources:

• Directly from you: when you opt in to SMS communications, submit a waitlist form, or contact us
• Event organizers and clients: registration data, guest lists, and event logistics information provided by the event organizer deploying Agent Analog
• Automatically: device and usage data collected when you interact with our services
• Third-party service providers: photo processing and SMS delivery partners operating under data processing agreements with Agent Analog LLC

Agent Analog LLC may disclose personal information to the following categories of third parties for the following business purposes:

• SMS delivery providers: to transmit concierge messages and photo delivery notifications to attendees
• Photo processing services: to perform facial matching and deliver event photographs
• Cloud hosting and infrastructure providers: to store and process data securely
• Analytics platforms: aggregated, de-identified data only; no individual-level data is shared
• Law enforcement or government agencies: when required by law, court order, or to protect rights and safety
• Event organizers/clients: aggregate analytics and event-level reporting; personally identifiable attendee data is not shared with organizers beyond what is necessary for service delivery

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.

The Company may collect the following categories of personal information, as further described in the Notice at Collection matrix above:

• Identifiers: name, email address, phone number, IP address
• Event registration and attendance information
• SMS message content, delivery metadata, and interaction history
• Concierge-style SMS requests and responses
• Photographs and images captured at events
• Facial images and biometric identifiers used solely for consent-based photo matching and delivery
• Device and usage data (IP address, browser type, timestamps)

The Company does not intentionally collect demographic information such as age, gender, race, religion, or political affiliation. Photographs and facial images are not analyzed to infer demographic characteristics.

How We Obtain Consent

Agent Analog collects express written consent from event attendees prior to sending any SMS communications. Consent is obtained through: (a) event registration forms that include a clearly disclosed opt-in checkbox separate from general terms; (b) on-site QR code or keyword opt-in prompts at events; or (c) event organizer registration processes that include Agent Analog consent language. Consent to receive SMS is always obtained separately and is never bundled as a condition of event attendance or general terms acceptance.

What You Consent To

By opting in, you consent to receive automated or AI-assisted text messages from or on behalf of Agent Analog and the applicable event organizer at the mobile number you provide. These messages may include event information, schedules, wayfinding, photo delivery notifications, concierge responses, and post-event follow-ups. Message frequency varies by event. Standard message and data rates may apply.

How to Opt Out

You may revoke consent and opt out of SMS communications at any time by any of the following means:

• Reply STOP to any Agent Analog SMS message
• Email help@agentanalog.ai with a clear request to stop messages
• Visit agentanalog.ai/opt-out
• Any other reasonable means that clearly communicates your desire to stop receiving messages

Consistent with FCC requirements, Agent Analog will honor all opt-out and revocation requests — regardless of the method used — within 10 business days. You will receive one confirmation message following a STOP reply. Opting out does not affect any lawful processing of data that occurred prior to your opt-out.

Purpose

Agent Analog uses facial recognition technology solely to match event photographs to the attendee who appears in them and to deliver those photographs via SMS. This constitutes the collection and processing of biometric identifiers as defined 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).

Consent

Use of Agent Analog's photo delivery feature requires your explicit, informed, standalone consent to the collection and processing of your biometric data. This consent is obtained separately from general terms acceptance and separately from SMS opt-in. You are never required to participate in facial recognition photo delivery as a condition of attending an event or receiving other Agent Analog services.

Retention Schedule

Biometric data is subject to the following retention schedule:

• Facial geometry and biometric identifiers are used only during active photo matching for the applicable event
• All facial geometry data is permanently and irreversibly deleted no later than thirty (30) days following the conclusion of the event
• If you withdraw consent prior to that deadline, your biometric data will be deleted within ten (10) business days of your verified request
• Raw photographs are delivered to you and not retained by Agent Analog beyond the delivery confirmation window

No Third-Party Sale of Biometric Data

Agent Analog does not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information. Biometric data is not shared with third parties except as strictly necessary to provide the photo delivery service under written data processing agreements with equivalent restrictions.

State Biometric Privacy Law Compliance

Agent Analog is committed to compliance with state biometric privacy laws including BIPA (Illinois), CUBI (Texas), and MHMD (Washington). 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.

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.

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.

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.

Personal information is used to:

• Provide concierge-style SMS communications related to event logistics, schedules, wayfinding, recommendations, and guest experience
• Deliver consent-based, personalized photo matching and secure photo delivery
• Operate, maintain, and improve services
• Respond to inquiries and provide support
• Comply with legal obligations
• Generate aggregated, anonymized event analytics for event organizers (no individually identifiable data is included in analytics reports without your consent)

Agent Analog does not sell personal information. We may share data with trusted service providers who assist in operating the platform under written agreements that prohibit use of data beyond specified services. See the Categories of Third-Party Disclosures section above for a full breakdown by category.

We may disclose personal information if required by law, court order, or in connection with the protection of our legal rights or the safety of our users.

Security measures 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

No data transmission over the Internet can be guaranteed to be 100% secure. While we implement industry-standard safeguards, you acknowledge that security limitations inherent to the Internet are beyond our control.

Retention periods by category are set forth in the Notice at Collection matrix above. Generally, we retain personal information only as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, or as required by applicable event contracts. You may request deletion of your personal information at any time by contacting privacy@agentanalog.ai.

On receipt of a verifiable request, we will delete your personal information from our records and direct our service providers to do the same. To exercise this right, contact us at privacy@agentanalog.ai.

We may decline deletion requests where retention is necessary to: complete a transaction you requested; detect or prevent security incidents; debug existing system functionality; comply with a legal obligation; or for other lawful purposes consistent with your relationship with us.

Agent Analog does not knowingly collect personal information from children under the age of 13. 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.

Personal information may be processed or stored in the United States or other jurisdictions where our service providers operate. For attendees in the European Economic Area (EEA) or United Kingdom, transfers are subject to appropriate safeguards including Standard Contractual Clauses (SCCs) where required. Event organizers who require a Data Processing Agreement (DPA) may request one by contacting legal@agentanalog.ai.

You may opt out of communications at any time by:

• Replying STOP to any SMS message
• Emailing help@agentanalog.ai
• Visiting agentanalog.ai/opt-out
• Any other reasonable method that clearly expresses your desire to stop receiving messages

This Policy may be updated periodically. For material changes, we will notify active users via SMS and post a prominent notice at agentanalog.ai/privacy. Continued use of the services after the effective date constitutes acceptance of the revised Policy.

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

Effective Date: January 20, 2026