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Privacy Thank you for your interest in Panorama Artificial Intelligence Inc. (doing business as Gradial) (“Gradial”) and our Gradial websites located at https://gradial.com, https://gradi.al, and https://gradial.ai (the “Websites”) and our associated service. Your use of the Gradial service, through the Websites or otherwise, is subject to this Privacy Policy. The Gradial service and Websites are collectively referred to in this Privacy Policy as the “Service.” We are pleased to provide this privacy policy to inform you of our practices with respect to how we collect and use personally identifiable information in connection with your use of the Service. Notwithstanding the policy described herein, in the event that Gradial is collecting data on behalf of a Gradial customer as a data processor, then that customer's own privacy policy and Gradial's agreement with that customer will control with respect to use of such data by Gradial. Gradial's plugin and connected AI assistants (ChatGPT, Claude, Grok, Muse, etc.) Last updated: November 10, 2026 This section explains how Panorama Artificial Intelligence Inc., doing business as Gradial (“Gradial”), handles information when you connect your Gradial account to ChatGPT, Claude, or another supported AI assistant through Gradial’s Model Context Protocol (MCP) integration. For information processed through these connections, the specific disclosures in this section govern over conflicting general statements elsewhere in this Privacy Policy. Where Gradial processes Customer Content on behalf of an organization, the organization’s agreement with Gradial and applicable data processing terms govern that processing. Connecting an assistant does not expand the permissions granted under those agreements. Information processed through the integration The integration connects the assistant to your authenticated Gradial account. Gradial processes account identification, authorization information, and organization and workspace permissions to determine which resources you can access and which actions you can perform. You sign in to Gradial and approve the connection on a consent screen that identifies the assistant and the access requested. The assistant does not receive your Gradial password. The integration supports the following tools: List workspaces (gradial_list_workspaces): Retrieves workspaces available to your authenticated account and returns workspace identifiers and names, organization information, and available environments to the connected assistant List task groups (gradial_list_threads): Receives a workspace identifier and, optionally, a grouping filter and parent thread identifier. It returns information about accessible campaigns, folders, and other supported groups, including identifiers, titles, types, display groupings, and parent-child relationships Create a task or thread (gradial_create_thread): Receives the destination workspace and title, together with any supplied environment, record type, parent thread, initial message or task description, objective, and instruction to start processing. Initial content is submitted as HTML. Supported records include conversations, tickets, campaigns, folders, batches, and migrations. Gradial uses these inputs to create the requested record and communicates the outcome to the connected assistant Titles, descriptions, objectives, and other supplied content may contain personal information, business information, links, or other material you include in your request. That information becomes part of the requested Gradial record. The tools receive information passed to them for the requested operation. Connecting the integration does not itself provide a tool for retrieving your entire ChatGPT conversation history. Information from a conversation can nevertheless be transmitted when included in a title, description, objective, or another tool input. How information is used Gradial uses integration information to authenticate requests, enforce permissions, identify requested resources, list workspaces and task groups, create records, return results, and execute work you authorize. Creating a record and starting AI processing are separate actions. When a ticket includes content and the startThread option is enabled, Gradial begins AI processing of that ticket. The default value is false. During execution, Gradial may process task instructions, relevant business context, connected-system content, and generated outputs to carry out the requested work. Depending on your organization’s configuration, this can involve AI model providers and connected content management, asset management, project management, or other business systems. Applicable permissions and approval requirements continue to apply. When workspace Memory is enabled, completed work may contribute summaries and reusable workspace knowledge to later Tasks. Gradial may also apply your organization’s configured rules, skills, and feedback to subsequent work. Retaining and applying this context to deliver your organization’s requested work is distinct from training an AI model. Gradial also processes service activity and technical information for operation, troubleshooting, support, security, and auditing. This may include request timing, network information, actions performed, affected resources, and success or error information. AI processing, training, and advertising Gradial uses AI services to execute requested work. Gradial does not use information received through these assistant connections to train AI models or for product improvement, and does not share this information for advertising purposes. General statements elsewhere in this Privacy Policy about AI development, product improvement, marketing, or advertiser sharing do not authorize those uses of information covered by this section. Information held independently by an assistant provider is also subject to that provider’s terms, privacy policy, and your account or workspace settings. This section describes Gradial’s practices and does not change the practices or settings of an independently operated assistant. Who receives information and what is returned OpenAI or the connected assistant provider: Receives tool results needed to present information and respond to your request. Results can include accessible workspace and task-group information, confirmation of created records, and links to open the work in Gradial. The assistant connection does not currently retrieve a Task’s progress or completed results; you open the Task in Gradial to follow its execution and review its output Your organization: Administrators and other authorized users may access records created through the integration according to Gradial’s organization and workspace permissions Service providers: AI processing providers, including OpenAI and Anthropic, and hosting, cloud infrastructure, identity, security, and support providers may process information needed to deliver their services to Gradial. Information about Gradial’s subprocessors is available in the Gradial Trust Center Connected business systems: Information may be exchanged with systems your organization has connected when required to execute a task you authorize Other legally permitted recipients: Disclosures may occur for legal obligations, protection against harm, or corporate transactions as described elsewhere in this Privacy Policy A record created through the integration belongs to a Gradial workspace. Its visibility is governed by your organization’s access settings, rather than solely by the visibility of the original assistant conversation. The assistant acts with your existing Gradial permissions and cannot access workspaces you cannot access. Retention and deletion Gradial retains personal information only for as long as needed to provide the service and fulfill the purposes described in this section, including maintaining requested work and associated operational, security, and audit records. Retention depends on the type of information, its use, applicable customer agreements, organizational settings, and legal obligations. You may request deletion by emailing privacy@gradial.com. Gradial deletes personal information covered by your request from its systems within 30 days of receiving the request, unless continued retention is necessary to comply with a legal obligation, address fraud or abuse, protect security, or resolve a dispute. Information retained for these reasons is kept only for as long as the applicable reason requires. Gradial may retain a record of the deletion request to document compliance. Operational records, audit records, backup copies, and derived workspace context are subject to the applicable retention purposes and deletion requirements described in this section. Where information is controlled by your organization, Gradial may coordinate a request with its authorized administrator. Requests are subject to identity verification and applicable legal and contractual requirements. Under Gradial’s standard Terms of Service, customers may request return of Customer Content stored at termination or expiration by making that request within 30 days. This is a content-return request window, not a statement that all copies are automatically deleted on day 30. Different terms may apply under a customer’s signed agreement. Disconnecting the assistant does not itself delete existing Gradial Tasks, campaigns, descriptions, objectives, or other workspace records. Deleting a conversation in the assistant does not automatically delete a record previously created in Gradial. Information already returned to an assistant provider or transferred to a connected business system is also subject to that recipient’s retention practices; deletion from Gradial does not itself delete independently held copies. Your choices and controls You can choose not to authorize an assistant connection. You can choose the information included in a request, the destination workspace, and whether a supported ticket should begin processing immediately. Include only information needed for the task. Do not include payment-card information, protected health information, government identifiers, passwords, authentication codes, or API secrets in task descriptions or assistant messages. You can stop using the integration and use any disconnection controls offered by your assistant. To end the assistant’s Gradial access immediately, sign out of Gradial in the browser used to establish the connection. Your organization’s administrators can manage Gradial membership and organization and workspace permissions. To request access, correction, export, or deletion of personal information, exercise other applicable privacy rights, or raise a privacy concern, contact privacy@gradial.com. For information held independently by OpenAI or another assistant provider, use that provider’s privacy controls and request process. Security Gradial’s published security program includes SOC 2 Type 2 compliance, AES-256 encryption at rest, TLS 1.2 or higher in transit, role-based permissions, enterprise identity controls, and audit trails. These safeguards support protection of information processed through the service, but no security measure eliminates all risk. Further information is available on Gradial’s security page and in the Gradial Trust Center. Information We Collect The data that we regularly collect about visitors to the Websites (e.g., IP address, browser type, pages accessed, duration of visit, pages visited, clicks, etc.) may not necessarily enable us to personally identify you. We do collect personally identifiable information about you, such as your name, email address and/or phone number, when you voluntarily provide it by registering with us or using the Service or you post an inquiry or comment on the Website. To facilitate your use of the Service, we may automatically collect certain types of information when you access or use the Service. In order to collect this data, we may utilize automated tools and files such as “cookies” and may share that information with third parties through the use of pixels and analytics tools. Such cookies and tools include user navigation and interaction tracking as well as security mechanisms. These automated tools and files may reside on our servers or on your computer or device, as described below. If you have questions about our use of these automated tools please contact us at privacy@gradial.com. We also collect statistical data and other, including personal, information regarding your use of the Service. We also may collect the following categories of personal information enumerated in the CCPA: Identifiers, including name, alias, postal address, email address, phone number, account name, IP address, geolocation information other similar identifiers and demographic information, including your age and gender. If you subscribe to one or more of our Services, we may collect information on your use of the Services by monitoring your utilization of the software. Except for information processed through connected AI assistants, whose recipients are described in the Privacy for ChatGPT and connected AI assistants section, this information is not shared with parties outside Gradial unless such sharing is required by applicable laws or regulations. Use of Information We use your personally identifiable information primarily to provide you with the Service, to assess how users are utilizing the Service, to monitor uses of the Service's software for quality assurance and quality control and to provide customized content on the Service that is of interest to you. The information is also used to verify your authority to access the Service, to contact you when reasonably necessary, and for the purpose of improving our products and services. We may also monitor your interactions with our website for marketing purposes and to assess the performance of the website in order to determine whether updates or other modifications are necessary, and may also use your personal information to train AI algorithms and develop AI tools and platforms. The AI-training and product-improvement uses described above do not apply to information covered by the Privacy for ChatGPT and connected AI assistants section. Share your concerns Gradial is committed to lawful and ethical behavior in all our activities. We expect our stakeholders to conduct themselves in compliance with all applicable laws and regulations and with the highest integrity. If you are aware of any improprieties or have any concerns, please report them on the following email addresses: privacy@gradial.com Every effort will be made to investigate a report as discreetly as possible and to protect confidentiality as best as possible under the circumstances. Controlling Your Personal Information We may make available to users messaging and other interactive features. You should be aware that when you voluntarily disclose personally identifiable information (e.g. user name, e-mail address) to third parties via the Service, that information, along with any substantive information disclosed in your communication, can be collected, correlated and used by third parties. Such activities are beyond the control of Gradial. Disclosure: Parties With Whom We May Share Your Information We may disclose your personal information to third party business partners including advertisers and others from time to time, as discussed within this Policy, in our sole discretion. We may also share information regarding your visits to our website with analytics providers, such as Google and Microsoft, and social medial platforms through uses of pixels such as the Meta Pixel. For this reason, you should not disclose information to us that you do not want shared with third parties. In addition to the forgoing, we will disclose your personally identifiable information as we believe is reasonably necessary to comply with law, regulation or other governmental authority or to prevent harm to yourself or others. We may also contract with various third parties who help us provide and maintain the Service. For example, we use a third party to host the Websites, the Service and associated databases, and may subcontract out production, fulfillment, or other operations. In these cases, we will use commercially reasonable efforts to prevent such third parties from disclosing your personal information, except for the purpose of providing the services in question. Finally, we may disclose your personally identifiable information upon a transfer or sale to another entity of all or substantially all of Gradial's stock or assets related to the Service, or upon any bankruptcy or other corporate reorganization. Sharing for advertising purposes does not apply to information covered by the Privacy for ChatGPT and connected AI assistants section. Recipients of information processed through these assistant connections are described in that section. Security Our Service uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content. You can recognize an encrypted connection in your browser's address line when it changes from “http://” to “https://” and the lock icon is displayed in your browser's address bar. In addition, we will maintain any personally identifiable information you upload or otherwise provide to us to commercially appropriate standards of security, but no on-line platform or service is free from cybersecurity risks. If you do not wish your personally identifiable information to be at any risk then you should not use the Service or upload personally identifiable information to the website or Service platforms. Links For your convenience, we may provide links to certain third party websites or referrals to certain third parties' products or services. We are not responsible for the privacy or security of information you may share with these third-party websites or providers. If you choose to visit a third party's website or use its products or services, please be aware that the third party's privacy policy, and not the Gradial privacy policy, will govern your activities and any information you disclose while interacting with the third party. Collection of Information From Children Our services are not intended for use by individuals under the age of 16 (minors). We comply with the Children's Online Privacy Protection Act (COPPA), which requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13 years of age. We do not knowingly collect personally identifiable information relating to children. In the event that we learn that we have collected personally identifiable information from anyone under 13 years of age without prior parental consent, we will take steps to promptly delete such information. Notification If an electronic or physical security incident is suspected to have resulted in the loss of third-party/customer data, Gradial will notify affected individuals and government agencies as required by applicable law. If required per applicable law, as soon as practicable and as conditions and the incident diagnosis permit, the company may post preliminary details about the incident on their public system status page. Gradial may pro-actively notify customers via email or other means. European Users If you are located in the European Economic Area, the United Kingdom or Switzerland, you may have the right to: 1. Request access to and receive information about the Personal Information we maintain about you for our own purposes, to ask us to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate subject to exceptions in applicable laws, or to obtain an electronic copy of the Personal Information we have collected pertaining to you and to exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place. 2. Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal. Those rights may be limited in some circumstances by local law requirements or derogations (exceptions). You may exercise your rights by contacting Suprama Singh at privacy@gradial.com. International Visitors and Customers The Service is hosted in the United States. If you are visiting from the European Union (EU) or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal data to the United States which does not have the same data protection laws as the EU and by providing your personal data or using the Service you consent to: 1. The use of your personal data for the purposes identified above in accordance with this Privacy Policy; and 2. The transfer of your personal data to the United States as indicated above. Canadian Residents If you are a resident of Canada, you are advised that your Personal Information may be transferred outside Canada and stored in countries in which Canadian federal and provincial laws do not apply. No Error-Free Performance Gradial does not guarantee error-free performance of the Service or our privacy controls as set out in this Privacy Policy. We may not always catch an unintended privacy issue, despite our efforts to do so. Accordingly, we welcome your feedback regarding any privacy concerns that you may have, including how we can improve this Privacy Policy. We will use reasonable efforts to assess the issue and will take prompt corrective action when we learn of any failure to comply with this Privacy Policy. Disclosures for California Residents Residents of California have the right to request a disclosure describing what types of Personal Information we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year. You may request a copy of that disclosure by contacting us at privacy@gradial.com. Do Not Sell My Personal Information Gradial does not sell Personal Information, but the CCPA defines sale more broadly than the traditional sense of an exchange of data for money and may encompass transactions in which we may disclose your Personal Information. Similarly, the California Privacy Rights Act (“CPRA”) provides that a consumer may opt out of uses of personal information for cross-contextual advertising, defined within CPRA as “sharing.” Accordingly you may, subject to exceptions in CCPA and the CPRA, request that Gradial not “sell” or “share” your Personal Information by submitting this request to us at privacy@gradial.com. Please be aware that certain sharing of your Personal Information may not be considered a “sale” of personal information under CCPA. CCPA comprises provisions that explicitly prohibit us from making any adverse decisions about you or your account based upon your exercise of this right (“non-discrimination”). To exercise these rights, you may contact us at (privacy@gradial.com or call our toll free number at 1-866-I-OPT-OUT and enter Service Code 1100 to leave us a message. Consistent with California law, you may designate an authorized agent to make a request on your behalf. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights. Notice of Collection In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA: Identifiers, including name, alias, postal address, email address, phone number, account name, IP address, and other similar identifiers. Demographic information, including your age and gender. Right to Know and Delete If you are a California resident, you have the right, subject to certain exceptions in the law, to ask us to delete the personal information we have collected from you and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us: To exercise any of these rights, email us at privacy@gradial.com to leave us a message. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete. Right to Opt-Out You have the right to opt-out of receipt of communications from us. You may submit a request to opt-out to privacy@gradial.com. Authorized Agent You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent's permission to do so and verify your identity directly. Right to Non-Discrimination You have the right not to receive discriminatory treatment by us for the exercise of any of your rights. Minors We do not knowingly “sell” the personal information of minors under 16 years old who are California residents without their affirmative authorization. Shine the Light Customers who are residents of California have the right to request a disclosure describing the categories of personal information we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year. You may request a copy of that disclosure by contacting us as set out in the “Contact Us” section above and specifying that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. Policy Changes Gradial reserves the right to change this Privacy Policy, and will post any revisions on the Service and/or this website. We encourage you to review this policy regularly for any changes. Your continued use of the Service will be subject to the then-current Privacy Policy.