Effective from 2026-05-25 (228868b)

PRIVACY POLICY

Effective Date: 05/25/2026

This Privacy Policy explains how CampusAI Global LLC ("CampusAI," "we," "our," or "us") collects, uses, shares, and processes personal information in connection with the CampusAI ecosystem, including CampusAI, District, DistrictOS, MultiBot, Loft, Digital Doubles, AI-powered systems, applications, virtual environments, collaboration tools, and related products, services, websites, applications, and technologies (collectively, the "Services").

The Services are designed to support AI-native education, collaboration, workflows, experimentation, virtual environments, digital identity systems, and interactions with artificial intelligence systems and AI-powered functionality.

Certain Services may involve:

CampusAI may process personal information directly or through third-party service providers, infrastructure providers, AI Providers, and subprocessors located in multiple jurisdictions, including outside the European Economic Area.

Additional terms, policies, or product-specific disclosures may apply to certain Services or functionality, including MultiBot, Loft, Affiliate Programs, Data Avatar functionality, AI-powered systems, or enterprise features ("Additional Terms"). In the event of a conflict between this Privacy Policy and applicable Additional Terms, the Additional Terms control with respect to the applicable Service or functionality.

CampusAI does not intentionally use Customer Content submitted through the Services to train proprietary AI models owned by CampusAI. However, certain third-party AI Providers may process data in accordance with their own policies, terms, retention practices, and model improvement procedures depending on the AI Systems or functionality selected or used by users.

By accessing or using the Services, you acknowledge that your information may be processed as described in this Privacy Policy.

1. What Information We Collect

Depending on how you access or use the Services, CampusAI may collect and process the following categories of information:

Account and Profile Information

Information such as:

Content, Inputs, and Communications

Information submitted through the Services, including:

AI Interactions and Generated Content

Information relating to interactions with AI Systems, including:

Device, Technical, and Usage Information

Information relating to devices, systems, infrastructure, and interactions with the Services, including:

Payment and Transaction Information

Information relating to subscriptions, purchases, billing, and transactions, including payment-related metadata and subscription status information. Payment card information may be processed by third-party payment providers.

Information From Third Parties

We may receive information from:

2. District and DistrictOS Specific Processing

Certain Services, including District and DistrictOS, involve AI-native virtual environments, orchestration systems, collaboration systems, digital identity systems, and interactive functionality that may require additional categories of Processing.

Depending on the functionality used, CampusAI may process:

DistrictOS and related functionality may also process technical and telemetry information necessary for:

Certain District environments, collaboration spaces, Digital Doubles, workflows, signals, profiles, summaries, or AI-generated representations may be visible to other users depending on user settings, permissions, collaboration features, participation in communities, or the functionality used.

Certain Services may include reputation systems, rankings, activity indicators, contribution metrics, gamification systems, public profiles, community participation systems, badges, signals, District Points, levels, or similar community and ecosystem functionality.

Depending on the functionality used and applicable settings, certain profile information, usernames, rankings, activity indicators, reputation signals, contributions, achievements, or community-related information may be visible to other users or participants within the Services.

3. AI Systems and Processing

The Services may include artificial intelligence systems, AI-powered workflows, orchestration systems, Digital Doubles, contextual AI representations, automation systems, and integrations with third-party AI models and providers ("AI Systems").

AI Systems may process:

AI Systems may generate:

Certain Services may enable the creation or use of Digital Doubles, AI-generated representations, contextual AI profiles, avatars, summaries, or AI-assisted collaboration systems based on information submitted through the Services.

AI Systems and Outputs may:

Outputs generated through the Services do not constitute legal, financial, medical, psychological, investment, employment, compliance, or other professional advice.

Users are solely responsible for evaluating Outputs and determining whether Outputs are appropriate for their intended use.

CampusAI does not intentionally use Customer Content submitted through the Services to train proprietary AI models owned or controlled by CampusAI unless expressly stated otherwise in applicable Additional Terms, Service settings, enterprise agreements, or specific functionality disclosures.

However, certain third-party AI Providers may process, retain, analyze, improve, or use information in accordance with their own policies, terms, retention practices, and model improvement procedures depending on the AI Systems or functionality selected or used by users.

Certain Services may involve the Processing of profile information, behavioral patterns, psychometric information, personality-related information, assessment results, preferences, strengths, working styles, collaboration patterns, contextual signals, or similar information submitted by users or generated through interactions with the Services, including in connection with Digital Doubles, Data Avatars, assessments, AI-assisted profiling, collaboration systems, or workflow-related functionality.

4. AI Providers and Third-Party Models

Certain Services, including MultiBot and other AI-powered functionality, may involve integrations with third-party artificial intelligence providers, model providers, inference systems, orchestration systems, cloud providers, hosting providers, and related infrastructure providers ("AI Providers").

Depending on the functionality used by users, information submitted through the Services may be processed by one or more AI Providers located in multiple jurisdictions, including outside the European Economic Area.

AI Providers may include providers of:

Depending on the AI Systems or functionality selected or used by users, information submitted through the Services may be:

CampusAI does not control the independent policies, retention practices, model improvement procedures, security practices, or operational decisions of third-party AI Providers.

Users are responsible for determining whether specific AI Systems, AI Providers, workflows, or functionality are appropriate for their intended use cases.

CampusAI recommends that users do not submit:

through AI-powered functionality unless expressly authorized or supported by the applicable Services.

CampusAI may make information regarding certain Sub-Processors, AI Providers, infrastructure providers, or integrations available through its legal documentation, DPA, support materials, or website.

5. How We Use Information

CampusAI may use personal information and other information processed through the Services for the following purposes:

CampusAI may use aggregated, anonymized, de-identified, or statistical information for operational, analytical, research, security, business, or product development purposes provided such information does not reasonably identify individual users.

Certain processing activities may be performed automatically using AI Systems, analytics systems, orchestration systems, security systems, moderation systems, or automated infrastructure and operational tooling.

6. Sharing and Disclosure

CampusAI may share, disclose, transfer, or make information available in the following circumstances:

Service Providers and Infrastructure Providers

We may share information with vendors, contractors, subprocessors, infrastructure providers, cloud providers, hosting providers, analytics providers, authentication providers, payment processors, support providers, security providers, and other service providers that support the operation of the Services.

AI Providers and AI Systems

Information submitted through AI-powered functionality may be shared with or processed by AI Providers and third-party AI systems as described in this Privacy Policy, the DPA, applicable Additional Terms, or functionality-specific disclosures.

Subject to applicable law, the Agreement, Additional Terms, and the policies or terms of applicable AI Providers, users may generally use Outputs generated through the Services for their own lawful purposes.

However, CampusAI does not guarantee that Outputs will be unique, protectable, non-infringing, available for exclusive use, or free from third-party rights, restrictions, similarities, inaccuracies, or provider-imposed limitations.

Collaboration and Community Functionality

Depending on user settings, permissions, workflows, collaboration environments, communities, District environments, Loft functionality, Digital Doubles, or other functionality used, certain information, profiles, summaries, Outputs, activity signals, contextual information, avatar-related information, or collaboration-related information may be visible to or shared with other users.

Certain Services may involve the Processing of a user's image, likeness, voice, recordings, audiovisual participation, webinar participation, presentations, live sessions, avatar-related content, or AI-generated representations derived from such materials in connection with collaboration systems, Digital Doubles, educational functionality, events, recordings, or AI-powered features.

Enterprise Customers and Organizations

Where users access the Services through an organization, enterprise customer, educational institution, workspace, team, or other managed environment, certain information may be accessible to administrators, operators, managers, or authorized representatives of such organizations in accordance with applicable agreements, settings, or organizational controls.

CampusAI may disclose information:

Business Transactions

Information may be disclosed or transferred in connection with:

Aggregated and De-Identified Information

CampusAI may share aggregated, anonymized, statistical, or de-identified information that does not reasonably identify individuals.

CampusAI does not sell personal information in exchange for monetary compensation and does not intentionally disclose personal information to third parties for cross-context behavioral advertising purposes.

Certain integrations, analytics, infrastructure, or platform functionality may involve limited data sharing or Processing that could be characterized differently under certain privacy laws depending on the jurisdiction and applicable legal interpretation.

7. International Transfers

CampusAI operates globally and may process information in multiple jurisdictions, including the United States and other countries where CampusAI, its affiliates, service providers, Sub-Processors, AI Providers, infrastructure providers, or partners operate.

As a result, information submitted through the Services may be transferred to, stored in, accessed from, or processed outside the jurisdiction in which users reside, including outside the European Economic Area, the United Kingdom, or Switzerland.

Certain Services, AI Systems, workflows, Digital Doubles, MultiBot functionality, integrations, orchestration systems, or AI Providers may involve cross-border Processing and international infrastructure.

Where required under applicable Data Protection Laws, CampusAI implements appropriate safeguards for international transfers of personal information, including:

Users acknowledge that data protection, privacy, and regulatory standards in jurisdictions outside their own may differ from those applicable in their jurisdiction.

By using the Services, users understand and acknowledge that information may be transferred and processed internationally as described in this Privacy Policy.

8. Retention

CampusAI retains personal information for as long as reasonably necessary to:

Retention periods may vary depending on:

Certain information may be retained for longer periods where necessary for:

Information processed through AI Systems, orchestration systems, telemetry systems, collaboration systems, or third-party AI Providers may be subject to different retention practices depending on:

When personal information is no longer reasonably necessary for the purposes described in this Privacy Policy, CampusAI will delete, anonymize, de-identify, aggregate, or otherwise dispose of such information in accordance with applicable law and operational practices.

Users may request deletion of certain information subject to:

9. Security

CampusAI implements and maintains reasonable and appropriate technical, organizational, administrative, and security measures designed to protect information processed through the Services against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

Such measures may include:

CampusAI may use third-party infrastructure providers, cloud providers, hosting providers, security providers, AI Providers, subprocessors, and integrations as part of the operation of the Services.

While CampusAI takes reasonable measures designed to protect information, no method of transmission, storage, processing, AI interaction, orchestration system, virtual environment, or electronic system can be guaranteed to be completely secure, uninterrupted, or immune from unauthorized access, misuse, interception, loss, or security incidents.

Certain Services involving:

may involve additional technical, operational, or security risks outside CampusAI's reasonable control.

Users are responsible for:

CampusAI encourages users not to submit highly sensitive, regulated, confidential, or high-risk information through AI-powered functionality unless expressly authorized or supported by the applicable Services.

In the event CampusAI becomes aware of a security incident affecting personal information, CampusAI may take reasonable steps to investigate, mitigate, respond to, and notify affected parties where required by applicable law.

10. Your Privacy Rights

Depending on the jurisdiction in which you reside and subject to applicable law, you may have certain rights regarding your personal information.

These rights may include the right to:

CampusAI may require verification of identity before responding to requests.

Certain rights may be limited or unavailable depending on:

Certain information may remain visible, retained, archived, logged, backed up, cached, de-identified, or otherwise preserved where necessary for:

Users located in the European Economic Area, the United Kingdom, or Switzerland may have additional rights under applicable data protection laws, including GDPR and related legislation.

Requests relating to personal information or privacy rights may be submitted using the contact information provided in this Privacy Policy.

Where applicable under GDPR, UK GDPR, Swiss data protection laws, or similar laws, CampusAI processes personal information on one or more of the following legal bases:

Legitimate interests pursued by CampusAI may include:

Where CampusAI processes special categories of personal data under Article 9 GDPR, including certain psychometric, personality-related, assessment, behavioral, profiling, or Data Avatar-related information, CampusAI will do so on the basis of explicit consent, user instructions, or another lawful basis permitted under applicable Data Protection Laws.

12. U.S. State Privacy Rights

Depending on the U.S. state in which you reside, including California and other jurisdictions with applicable privacy laws, you may have additional rights regarding your personal information.

Such rights may include:

CampusAI does not sell personal information in exchange for monetary compensation in the traditional sense. However, certain analytics, advertising, integrations, platform functionality, or data-sharing practices may be considered "sharing" or similar Processing under certain privacy laws.

Authorized agents may submit requests on behalf of users where permitted by applicable law.

CampusAI may require reasonable verification before responding to requests.

Users may exercise applicable privacy rights by contacting CampusAI using the contact information provided in this Privacy Policy.

13. Children and Age Restrictions

The Services are not intended for children under the age of thirteen (13) or such higher minimum age required under applicable law in the user's jurisdiction.

Certain Services, functionality, AI Systems, Digital Doubles, avatars, workflows, collaboration environments, or Experimental Features may require users to be at least eighteen (18) years old.

CampusAI does not knowingly collect personal information from children in violation of applicable law.

If CampusAI becomes aware that personal information has been collected from a child in violation of applicable law, CampusAI may take reasonable steps to delete such information and restrict access to the applicable Services.

Parents, guardians, or individuals who believe a child may have provided personal information in violation of applicable law may contact CampusAI using the contact information provided in this Privacy Policy.

14. Cookies and Tracking Technologies

CampusAI and its service providers may use cookies, SDKs, local storage, pixels, analytics technologies, telemetry systems, identifiers, and similar tracking technologies ("Tracking Technologies") in connection with the Services.

Tracking Technologies may be used to:

Depending on the Services used, Tracking Technologies may collect:

Certain third-party providers, including analytics providers, infrastructure providers, authentication providers, payment providers, advertising providers, integrations, and AI Providers may also use Tracking Technologies in connection with the Services.

Users may control certain Tracking Technologies through browser settings, device settings, cookie banners, consent tools, operating system controls, or other available mechanisms. However, disabling certain Tracking Technologies may affect functionality, availability, performance, or operation of certain Services.

Where required by applicable law, CampusAI will obtain consent prior to using non-essential cookies, tracking technologies, analytics technologies, advertising technologies, or similar technologies on a user's device.

Additional information regarding cookies and Tracking Technologies may be made available through cookie notices, consent mechanisms, support documentation, or additional policies.

15. Changes to this Privacy Policy

CampusAI may modify or update this Privacy Policy from time to time to reflect:

Updated versions of this Privacy Policy may be posted through the Services, legal documentation, websites, applications, onboarding flows, District environments, or other reasonable means.

Where required by applicable law, CampusAI may provide additional notice regarding material changes.

The "Effective Date" at the top of this Privacy Policy indicates when this Privacy Policy was last updated.

Continued access to or use of the Services after updates become effective may constitute acknowledgment of the updated Privacy Policy where permitted by applicable law.

16. Contact Information

If you have questions, requests, concerns, or inquiries relating to this Privacy Policy, privacy practices, personal information, data protection matters, or applicable privacy rights, you may contact:

CampusAI Global LLC Delaware, USA legal@campus.ai www.campus.ai | www.district.org

Where required under applicable law, CampusAI may designate representatives, contact points, or data protection contacts for specific jurisdictions or regulatory purposes.

Additional privacy, legal, compliance, or support information may be made available through CampusAI's websites, legal documentation, support systems, or Services.

EU Representative (EEA)

For purposes of Article 27 GDPR and applicable European data protection laws, CampusAI P.S.A. may act as CampusAI Global LLC's representative within the European Economic Area for certain Services and Processing activities.

CampusAI P.S.A. may be contacted regarding GDPR-related inquiries, regulatory matters, or data protection requests concerning applicable Services.

CampusAI P.S.A. Chmielna 73 00-801 Warszawa legal@campus.ai | www.campus.ai