VALKYREE, INC.
PRIVACY POLICY

Effective Date: February 15, 2026

1. INTRODUCTION

Valkyree, Inc. ("Valkyree," "we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at valkyree.com and any associated subdomains (the "Website").

As a company focused on ethical AI transformation, we believe in practicing the same transparency and responsibility that we advocate for our clients. Please read this Privacy Policy carefully. By accessing or using our Website, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

We collect information that youvoluntarily provide to us, including:

Contact Information: Name, email address, phone number, company name job title, and other contact details submitted through our contact forms

Assessment Information: Business information, technical environment details,Salesforce configuration data, and other information submitted through our VALAassessment tools

Account Information: Username, password, and account preferences if you createan account

Communication Data: Information contained in your communications with us,including blog comments, inquiries, and feedback

Event Registration: Information provided when registering for webinars, events, or downloading resources

2.2 Information Collected Automatically

When you visit our Website, weautomatically collect certain information, including:

Device Information: IP address, browser type and version, operating system, device type, and unique device identifiers

Usage Information: Pages visited, time spent on pages, click patterns, referring URLs, and other analytics data

Location Information: General geographic location based on IP address

Cookie Data: Information collected through cookies, pixels, and similartechnologies (see Section 5)

3. HOW WE USE YOUR INFORMATION

We use the information wecollect for the following purposes:

Service Delivery: To respond to your inquiries, provide assessment results,and facilitate consulting engagements

Website Operation: To operate, maintain, and improve our Website and services

Communication: To send you information about our services, respond tocomments and questions, and provide customer support

Marketing: To send promotional communications about our services, events, and industry insights (with your consent where required)

Analytics: To analyze usage patterns, understand user preferences, andimprove user experience

Security: To detect, prevent, and address technical issues, fraud,and security threats

Legal Compliance: To comply with applicable laws, regulations, and legalprocesses

4. LEGAL BASIS FOR PROCESSING (FOR EEA, UK, AND SWISS USERS)

If you are located in theEuropean Economic Area (EEA), United Kingdom, or Switzerland, we process yourpersonal data based on the following legal grounds:

Consent: Where you have given clear consent for us to process yourpersonal data for a specific purpose

Contractual Necessity: Where processing is necessary to perform a contract withyou or to take steps at your request before entering into a contract

Legal Obligation: Where processing is necessary to comply with a legalobligation

 Legitimate Interests: Where processing is necessary for our legitimate interestsor those of a third party, provided those interests are not overridden by yourrights and interests

5. COOKIES AND TRACKING TECHNOLOGIES

5.1 Types of Cookies We Use

We use the following types ofcookies:

Essential Cookies: Required for the Website to function properly and cannot bedisabled

Analytics Cookies: Help us understand how visitors interact with our Websiteby collecting anonymous information

Functional Cookies: Enable enhanced functionality and personalization

Marketing Cookies: Used to deliver relevant advertisements and track campaigneffectiveness

5.2 Cookie Management

You can control and managecookies through your browser settings. Please note that disabling certaincookies may affect the functionality of our Website. Most browsers allow you torefuse to accept cookies, delete cookies, and be notified when a cookie is set.

6. HOW WE SHARE YOUR INFORMATION

We may share your informationin the following circumstances:

Service Providers: With third-party vendors who perform services on ourbehalf, such as hosting, analytics, email delivery, and customer relationship management. These providers are contractually obligated to protect yourinformation and use it only for the purposes we specify.

Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of thattransaction

Legal Requirements: When required by law, regulation, legal process, orgovernmental request

Protection of Rights: To protect our rights, privacy, safety, or property, orthat of our users or others

With Your Consent: In other circumstances with your explicit consent

We do not sell your personalinformation to third parties.

7. INTERNATIONAL DATA TRANSFERS

Valkyree is based in the UnitedStates. If you are accessing our Website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other countries where our service providers maintain facilities.

For transfers from the EEA, the UK, or Switzerland to the United States, we rely on appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, to ensure your personal data receives an adequate level of protection.

8. DATA RETENTION

We retain your personalinformation for as long as necessary to fulfill the purposes for which it wascollected, including to satisfy any legal, accounting, or reportingrequirements. To determine the appropriate retention period, we consider theamount, nature, and sensitivity of the personal data, the potential risk ofharm from unauthorized use or disclosure, the purposes for which we processyour personal data, and applicable legal requirements.

When personal data is no longerneeded, we will securely delete or anonymize it in accordance with our dataretention policies.

9. DATA SECURITY

We implement appropriatetechnical and organizational security measures designed to protect yourpersonal information against unauthorized access, alteration, disclosure, ordestruction. These measures include encryption, secure socket layer (SSL)technology, access controls, and regular security assessments.

However, no method oftransmission over the Internet or electronic storage is 100% secure. While westrive to use commercially acceptable means to protect your personalinformation, we cannot guarantee its absolute security.

10. YOUR PRIVACY RIGHTS

10.1 General Rights

Depending on your location, youmay have certain rights regarding your personal information, including:

Access: The right to request access to your personal data

Correction: The right to request correction of inaccurate personal data

Deletion: The right to request deletion of your personal data

Portability: The right to receive your personal data in a structured,commonly used format

Objection: The right to object to processing of your personal data

Withdraw Consent: The right to withdraw consent where we rely on consent forprocessing

10.2 European Economic Area, UK, and Swiss Residents

If you are located in the EEA,UK, or Switzerland, you have additional rights under the General DataProtection Regulation (GDPR) or equivalent legislation, including the right tolodge a complaint with your local supervisory authority.

10.3 California Residents

California residents havespecific rights under the California Consumer Privacy Act (CCPA) and CaliforniaPrivacy Rights Act (CPRA), including the right to know what personalinformation is being collected, the right to know whether personal information is sold or disclosed, the right to opt-out of the sale of personal information, the right to access and delete personal information, and the right tonon-discrimination for exercising privacy rights.

To exercise these rights,please contact us using the information provided in Section 14.

11. CHILDREN'S PRIVACY

Our Website is not intended for children under the age of 16 (or 13 in the United States). We do not knowinglycollect personal information from children under these ages. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately, and we will take steps to delete such information.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. When we make material changes, we will notify you by posting the updated Privacy Policy on this page with a new "Effective Date." We encourage you to review this Privacy Policy periodically.

14. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Valkyree, Inc.

Email: info@valkyree.com

Website: www.valkyree.com

For data subject access requests or to exercise any of your privacy rights, please email us at info@valkyree.com with the subject line "Privacy Rights Request."

15. DATA PROTECTION OFFICER

For questions specificallyrelated to GDPR compliance or to contact our designated data protectionrepresentative, please email: info@valkyree.com

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