Privacy Policy

Last updated: 28 September 2026

This Privacy Policy describes how we process personal information that we collect through the Manus and the products, features and services we make available for individuals from time to time, including but not limited to AI agents; applications, software, browser extensions and websites; connected-account, communication and automation features; local, remote and hosted computing environments; and tools for creating, deploying or operating digital projects

For content-safety, see User Safety & Content Policy.

For Prohibited AI Practices, see the Usage Policy.

We may act as a data processor and process personal information in accordance with the instructions of Space Owners, API Customers, or Team Plan Owners. An "API Customer" is a customer of our API services. A "Team Plan Owner" (also referred to as "Owner" in the context of team roles) is the owner of a Team Plan subscription who determines how team workspace data is processed. This includes: (i) personal information of End Users collected through Spaces or API applications, and (ii) personal information of Team Members generated within Team Plan workspaces. In such cases, the privacy policies of the relevant Space Owner, API Customer, or Team Plan Owner (as applicable) will govern the processing of that data.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.

Index

• Your activity and information that you provide

• How we use your information

• How we share your information

• Retention

• Your choices

• Other sites and services

• Security

• International data transfers

• Children’s Data

• Changes to this Privacy Policy

• How to contact us

• Addendum
  • Notice to European users
  • Notice to users in the State of California
  • Notice to South Korea users
  • Notice to Japan users
  • Notice to Singapore users

Your activity and information that you provide

Information you provide to us. Depending upon the context in which you interact with us, personal information you may provide to us through the Service includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.

• Profile data, such as the username and password that you may set to establish an online account with the Service, any teams you are a part of and your role within the team (e.g., team owner ("Owner”), team administrator (“Administrator”), team member (“Member”), and any other information that you add to your account profile.

• Communications data, based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.

• Transactional data, such as information relating to or needed to complete your subscriptions on or through the Service, including subscription type and transaction history.

• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

• Inputs, prompts and user-generated content, such as messages, photos, images, audio or voice clips, music, videos, comments, questions, files, works of authorship, third party account credentials and other content or information that you upload/use as an input or prompt to, generate, transmit, or otherwise make available on the Service, as well as associated metadata (e.g., how, when, where content was collected or edited; keywords; location info). This content may include the following categories of information, but only to the extent that you choose to provide it to us through prompts, conversations, uploads, or other inputs, or, where supported, direct us to access it through a connected account:
  • Financial Data, such as bills, balances, income, transaction histories, counterparties, spending preferences, and financial analyses or classifications generated from such information. We do not independently collect Financial Data from you outside of the content or connected-account access that you choose to provide or authorize.
  • Health Data, such as personal information that identifies or is reasonably capable of being linked to an individual and reveals information about their past, present, or future physical or mental health, including health-related activity, heart and respiratory health, body measurements, walking and mobility, sleep, mindfulness, workouts, or other health-related information. We process Health Data only to the extent that you choose to provide it through prompts, conversations, uploads, or other inputs, or, where supported, direct us to access it through a connected account. Information generated by the Service that repeats, summarizes, or analyzes Health Data you provide may also constitute Health Data.

• Derived data, if you use certain features of the Services, such as to convert images to videos, videos to new or different videos, or people to avatars, or to upload audio or voice clips, we may derive certain information from images of individual people or from audio or voice clips in order to provide those features. While we do not use such data for purposes of identifying any unique individual, it is possible that some may consider this data biometric data within the meaning of certain U.S. state laws. We will only use and share this derived data for limited purposes, as described in the “How we use your personal information” and “How we share your personal information” sections, below.

• Payment data needed to pay for subscriptions is collected and processed directly by our payment processors, such as Stripe or RevenueCat.

• Third-party purchase data, such as product and merchant details, prices, delivery information, payment-method identifiers and transaction results, which we process to carry out purchases you request from third-party merchants and provide the resulting transaction records.

• Third-Party Credentials. If you choose to use a supported feature that allows you to save credentials for a third-party account, we collect the account identifier or username and password or other authentication credential that you provide for that account (“Third-Party Credentials”). We use Third-Party Credentials only to authenticate with the applicable third-party account and to carry out the specific functionality or actions you request through the Service.

• Space end-user account data, such as email address and login credentials where a Space uses our built-in authentication. We process this data on behalf of the Space Owner orAPI Customer to operate their sign-in and account features.

• Other data, not specifically listed here, including but not limited to data you submit to us or otherwise permit us to collect through or in connection with the Services, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information that we obtain from other sources, such as:

• Public sources, such as public records, social media platforms, and other publicly available sources.

• Third-Party AI Providers. Parts of the Service are integrated with third-party AI platforms (“Third-Party AI Providers”) that help generate outputs (i.e., responses) to your inputs and prompts. These Third-Party AI Providers may infer information about you and share information with us as part of their processing of your inputs and prompts to the platform.

• Service providers that provide services on our behalf or help us operate the Service or our business.

• Third-party login/linked services, such as Google or Apple that you use to log into, or otherwise link to, your Service account, including when you utilize or direct the Service to utilize your third-party accounts. This data may include your username and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

• At your direction. Where you consent or direct us to interact with a third party, we may receive only the information needed to carry out the actions you request and consistent with the permissions you grant. This includes data made available to us through Connectors you enable. A “Connector” is a pre-built integration module that allows our AI tool or system to connect to an external data source, application, or service designated by you. Our Connector processes data solely from user-authorized sources and only as instructed by you. Content obtained through a connected account may be retained in conversations, task files, object storage or enabled memory in accordance with this Privacy Policy. This also includes third-party contact details and information exchanged or generated in connection with such communications, such as message or communication content, delivery or call status, call or meeting audio, recordings, transcripts, notes and summaries, where you use or direct our Service to call or otherwise communicate with a third party on your behalf. We only access the categories of data you authorize and we follow the applicable provider policies. For example, when you connect Google services, we comply with the Google API Services User Data Policy, including the Limited Use requirements.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

• Communication interaction data, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

• Sandbox environment data. When the Service executes tasks on your behalf, it operates within isolated sandbox environments (virtual machines). We may collect: (i) files you upload or that our Services creates during task execution; (ii) shell commands executed and their outputs; (iii) code you provide or that the Service generates; and (iv) task execution logs for debugging and security purposes.

• Browser Operator data. When you enable the Browser Operator extension and the "My Browser" Connector, you grant us access to interact with web pages in your local browser environment. This includes: (i) page content that the Services reads, extracts, and processes from web pages you authorize, including content from premium or authenticated services you are logged into; (ii) browser actions such as clicking, scrolling, form filling, and navigation performed on your behalf; and (iii) session context leveraging your existing browser sessions and login states. Data collected through Browser Operator is transmitted to our servers for task processing. You can revoke Browser Operator access at any time by disabling the "My Browser" Connector or uninstalling the browser extension.

Personal Information of End Users and Team Members. When we process personal information to help Space Owners operate their Spaces, API Customers operate their applications, or Team Plan Owners manage their team workspaces, we do so solely at their direction, in our capacity as a data processor. The purposes and means of processing such personal information are determined by the relevant Space Owner, API Customer, or Team Plan Owner.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by cookies and other technologies.

For more information see our Cookie Policy.

How we use your information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide the Service;

• transmit your inputs to our Third Party AI Providers for processing and to receive outputs, as necessary to fulfill your requests;

• enable security features of the Service;

• establish and maintain your user profile on the Service;

• form persistent memory; where memory is enabled, we may retain information provided by you related to the memory to support later tasks and other Agents acting for you;

• facilitate team collaboration within the Team Plan, including managing team member access permissions, synchronizing session data among authorized members, and monitoring team-wide resource usage;

• operate built-in Space authentication and Space-owner analytics on the Space owner’s instructions, and provide related hosting and support.

• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;

• communicate with you about events or contests in which you participate;

• provide support for the Service, and respond to your requests, questions and feedback;

• execute tasks asynchronously in the cloud, including Scheduled Tasks and background operations that continue running even when you close your browser or device, with task execution logs retained to enable replay and debugging; and

• deploy multiple parallel agents (Wide Research) to process complex, large-scale tasks, where all agents operate under the same data protection controls.

Service personalization, which may include using your personal information to:

• understand your needs and interests;

• personalize your experience with the Service and our Service-related communications; and

• remember your selections and preferences as you navigate webpages.

Service improvement and analytics We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For more information on analytics, see our Cookie Policy.

Marketing and advertising. We, our service providers and our third party marketing partners may collect and use your information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt out of communications section below.

• Where permitted by law and with your permission where required, we process certain online identifiers to (i) show you more relevant ads, (ii) measure ad performance, and (iii) build or refine audiences.

• No mobile information collected through our Service will be shared with third parties/affiliates for marketing/promotional purposes.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

• audit our internal processes for compliance with legal and contractual requirements or our internal policies;

• enforce the terms and conditions that govern the Service; and

• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and that of other individuals whose personal information we collect. We may make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use such data to analyze, improve, develop and protect the Service, including to develop and improve our models and related technologies. We may share such data with service providers that process it on our behalf, and with other third parties where the data has been aggregated, de-identified and/or anonymized in accordance with applicable law. Depending on your jurisdiction, you may opt out by contacting us at the email address provided below.

Processor services for Spaces and API. When you create and operate a Space or use the API to process personal information about your End Users, you (or your organization), as a Space Owner or an API Customer, act as the data controller for that processing activities and we act as your data processor, handling such personal information only on your documented instructions and our Data Processing Addendum (”DPA”), to host your Space, or execute your API requests.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Retention

We’ll retain your personal data for only as long as we need in order to provide our Services to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain personal data depends on the type of data, how we use it, and in many cases your settings:

• Information we retain until you delete it: Some of our Services allow you to delete personal data stored in your account. For example, you can delete your account. Once you choose to delete, we will remove it from our systems within 30 days unless we need to retain it for longer as described below, or it has already been de-identified and disassociated from your account when you allow us to use your content to improve our models⁠.

• Information we delete automatically: In some cases, personal data will be automatically deleted. For example, if you use the Browser’s sandbox (virtual machine) mode (the “Sandbox”), it operates as an ephemeral, isolated environment that may be reset. Sandbox data is stored separately from your regular sessions and is retained for up to 7 days from your last activity for free plans and up to 21 days for paid plans, after which it is automatically deleted (or sooner if the Sandbox is reset).

• Information we retain for longer for legitimate security, safety, or legal reasons: In some cases, we need to retain personal data for longer even after you delete it, for example because we are legally required to, to address fraud and abuse, for security reasons, or for financial record-keeping purposes. For instance:
  • If we are legally required to retain your data (for instance, we receive a lawful subpoena) then we may retain it for the duration of the relevant legal or regulatory obligation;
  • If specific feature, or your account, is banned because of violations of our policies⁠, we may retain that data for to protect our Services from fraud, abuse, or other violations of our policies;
  • We may retain payment and transaction related information to meet our accounting, dispute resolution, and regulatory compliance purposes;
  • When you ask us to delete your personal data, we retain the audit record of the erasure request to be able to verify that we have complied with the request.

Note the following concerning how we retain and handle personal information for particular Services:

• For Team-related data (e.g., session logs, credit usage records), retention periods are also determined by the team Owner or Administrator in accordance with organizational needs and applicable laws.

• Retention of End Users’ Personal Information. We store and retain End Users’ personal information collected by a Space Owner or an API Customer solely in accordance with their instructions. In such cases, the applicable retention period is determined by the relevant Space Owner or API Customer. We act only as a data processor and retain such personal information on their behalf. For Members in a Team Plan seeking to delete personal information related to team activities, please contact your team Owner or Administrator.

• Team Member Rights. If you are a Team Member and wish to exercise data subject rights (access, correction, deletion) regarding data processed within your Team Plan workspace, you should first contact your Team Owner or Administrator. If you do not receive a response within 30 days, or if your request relates to data that we control independently (such as billing information or service usage data), you may contact us directly at privacy@manus.im and we will assist you to the extent permitted.

How we share your information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

• Sharing of Health Data. We share Health Data only with service providers acting on our behalf as necessary to provide the health-related features you request, with third parties you specifically authorize to receive it for those purposes, or as required by applicable law. We obtain your consent before sharing where required by applicable law or applicable platform rules.

• Our corporate parent, subsidiaries, and affiliates.

• Service providers. Third parties that provide services on our behalf or help us operate or promote the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

• Third party AI providers. We use third party AI providers to power certain aspects of our Services, such as operating the chat and/or processing user inputs/prompt features, data analytics and recommendations.

• Payment processors. Payment card information used to pay for subscriptions is collected and processed directly by our payment processors, such as Stripe and RevenueCat. Our payment processors may use payment data in accordance with their privacy policy. For purchases from third-party merchants, the designated payment provider collects your underlying card details directly. Depending on the payment flow, we may process payment-method identifiers and transaction results to carry out your purchase.

• Merchants and other payment participants. For purchases you request, we share the order, delivery and payment information needed to complete them with the relevant merchant, payment provider and, where applicable, card issuer. To the extent these parties determine their own processing purposes, such as payment authorisation, fraud prevention or fulfilment, their own privacy policies apply.

• Marketing and measurement vendors and service providers. We share information about you with our marketing and measurement vendors and service providers and partners to help us promote the Service to you on apps and websites, and to measure the effectiveness of those promotions.

• Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

• Space Owners and API Customer.If you interact with a Space or an application built on our API, information you submit may be shared with, or directly collected by, the Space Owner or the customer of the API (” API Customer”) operating that experience, in accordance with their privacy policies.

• Linked third party services.If you log into the Service with, or otherwise link your Service account to, a social media or other third party service, we may share your personal information with that third party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third party service.

• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

• Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments and financing of Butterfly Effect, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Butterfly Effect as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

• Other users and the public. At your election, user-generated content data may be visible to other users of our Services and the public. For example, other users of the platform or the public may have access to your information if you choose to make information available to them, such as when you share content. In addition, we offer users the ability to join a team, and certain of their information may be visible to other team members based on role permissions:

• Sharing under Team Plan: if you, as a Member, join a team set up by its Owner, the Owner of such team may access all session data of team members (including task steps and content), monitor individual and team credit usage, export session data, and view content created during Members' sessions; the Administrator of such team may access a subset of session data, manage credit allocation across the team, but cannot view personal account details or detailed individual session information.

This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Personal and organizational data. The Team access rights described above apply only to data within the relevant Team workspace. Joining a Team or enterprise workspace does not by itself give the organization access to Health Data held in your personal account. If you choose to share Health Data with an organizational workspace, its visibility will depend on the applicable workspace permissions, subject to this Policy’s Health Data restrictions.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.

• Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

• Depending on where you live, you might have the right to object, e.g. to our processing based on legitimate interests. To exercise this right, contact us at privacy@manus.im.

• Opt out of communications. You may opt out of marketing related emails by following the opt out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt out of marketing related emails, you may continue to receive service related and other non-marketing emails.

• For information about cookies and other technologies employed by the Service and how to control them, see our Cookie Policy.

• Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

• Exercise the right to opt out of the sharing of your personal information for targeted advertising purposes. You may also see ads on other apps and websites about our Products which use your activity on our Products to tailor the ad. Where applicable, if you have a Service account, you can visit the section titled “Ads About Manus” in your Settings to control whether we share your Personal Information for purposes of targeted advertising.If you do not have an account, you can use the Digital Advertising Alliance and/or the NAI industry opt-out platforms, along with your mobile device advertising settings offered by the device manufacturer. Certain ad blockers and tools to restrict cookies can interfere with your ability to opt out. Different device manufacturers provide different ways to opt out.

• Depending on where you live, you may have the right to opt out of targeted advertising through a Global Privacy Control (GPC) enabled browser setting. If you have this right, when you visit and log in to our websites in a GPC-enabled browser, we will treat our initial receipt of the GPC signal as a valid request to opt-out of targeted advertising, as defined by applicable U.S. privacy laws granting this right. Please note that if you are logged out, our processing of the signal will be limited to the specific browser that you are using. You may need to renew your opt‑out choice if you use a different browser to access our websites. Other than GPC, we do not recognize any "do not track" signals.

• Declining to provide information.We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

• Linked third party platforms. If you choose to connect to the Service through your Google, or Apple account, or other third party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third party platform, that choice will not apply to information that we have already received from that third party

• Delete your content or close your account. If you are an individual user, you can choose to close your account and the personal information contained within which we hold. If you wish to request to close your account, please contact us at privacy@manus.im. You can also ask us to delete Stored Credentials by instructing the Service to do so (for example, in chat).

• Team-related privacy controls. As a member of a team, you have the ability to manage your privacy settings through the team management features, such as restricting the sharing of non-collaborative content with other members. However, certain information (e.g., aggregate credit usage, task progress visible to the team) may still be accessible to Owners or Administrators as required for team operation.

• Connector and Browser Operator controls. You can view, manage, and revoke access to any Connector at any time through your settings. For Browser Operator, you can disable the "My Browser" Connector or uninstall the browser extension to immediately stop local browser access. Removing a Connector stops future access through that connection but does not by itself delete content already retained in conversations, task files or memory; that content remains subject to this Policy’s retention and deletion provisions.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. Security procedures are in place to protect the confidentiality of your data. Despite commercially reasonable safeguards, online and email transmissions are not fully secure. Please submit information at your own discretion; we accept no liability for any unauthorized circumvention of the Services’ or third-party privacy or security measures. Without prejudice to the foregoing, we maintain technical and organizational safeguards appropriate to the sensitivity of the personal information we process. For Health Data, these include encryption in transit and at rest, access limited to authorized personnel who need it for permitted purposes, and safeguards for processing by our service providers. We do not store personal health information in iCloud. If a personal data breach occurs, we will notify affected individuals, relevant authorities, and any other required recipients where required by applicable law and within the applicable time limits.

International data transfers

We are headquartered in Singapore and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should read the important information provided below about transfer of personal information outside of Europe.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Depending on the change that we make to this policy, we might notify you of the change or ask for your consent to it. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).

Privacy Policy Changes Related to End Users. Space Owners and/or API Customers may update their own privacy policies from time to time with respect to their processing of End Users’ personal information. As a data processor, we may adjust our processing activities related to such personal information in accordance with the updated privacy policies and instructions of the relevant Space Owner and/or API Customer.

How to contact us and our Data Protection Officer

We have appointed a Data Protection Officer responsible for overseeing privacy compliance.

Contact: privacy@manus.im.

Addendum

Notice to European users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.

Controller. Butterfly Effect is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the ‘How to contact us’ section above for our contact details.

Processor. For personal data that we process on behalf of Space Owners or API Customer, the Space Owner or API Customer is the controller and we are their processor under the GDPR. For processor-context questions or to exercise your rights, please contact the relevant Space Owner or API Customer.

Team Plan Processing. For personal data that we process on behalf of Team Plan Owners, the Team Plan Owner (typically the employer organization) is the controller and we are their processor under the GDPR. Team Members should direct data subject requests to their Team Plan Owner in the first instance.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:

• Our Representative in the EU.Our EU representative appointed under the EU GDPR is EDPO. You can contact them:

• via: https://edpo.com/gdpr-data-request/

• by post: Avenue Huart Hamoir 71, 1030 Brussels, Belgium
  • Our Representative in the UK.Our UK representative appointed under the UK GDPR is EDPO. You can contact them:

• via: https://edpo.com/gdpr-data-request/

• by writing to EDPO UK at Unit 33, Waterside, Schooner Court, 44-48 Wharf Road, London, N1 7UX, United Kingdom

Our Data Protection Officer. We have appointed a Data Protection Officer (DPO). The DPO independently performs their duties—informing and advising us and monitoring our compliance with the EU GDPR and the UK GDPR (as applicable). The DPO’s contact details are provided in the “How to contact us and our Data Protection Officer” section.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

• Consent. We process information for certain purposes as described below only when you have given us your consent to do so.

• Contractual Necessity.Where we need to perform a contract, we are about to enter into or have entered into with you.

• Legitimate Interests.Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

• Compliance with Law.Where we need to comply with a legal or regulatory obligation.

• Where we have your specific consent to carry out the processing for the Purpose in question.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’

Other info

We may use limited profiling to personalise advertisements and measure performance.

Your rights

European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Access– Provide you with information about our processing of your personal information and give you access to your personal information.

• Correct– Update or correct inaccuracies in your personal information.

• Delete– Delete your personal information where there is no good reason for us continuing to process it.

• Transfer– Transfer a machine-readable copy of your personal information to you or a third party of your choice.

• Restrict– Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.

• Object– Object to our processing of your personal information where we are relying on Legitimate Interests; also object to direct marketing at any time.

• Withdraw Consent– When we use your personal information based on your consent, you may withdraw that consent at any time.

Exercising these rights. You may submit requests by email to our email address provided below. We may request specific information from you to help confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on several factors (e.g., why and how we are processing your personal information). If we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en

For users in the UK – the contact information for the UK data protection regulator is below:

The Information Commissioner’s Office

Water Lane, Wycliffe House

Wilmslow - Cheshire SK9 5AF

Tel. +44 303 123 1113

Website: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

We may share your personal information with third parties who are based outside Europe.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by implementing one of the following mechanisms:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time).

Transfers to territories without an adequacy decision.

We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g. the United States, Singapore).

However, in these cases:

we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us.

Notice to users in the State of California

This section applies to individuals in the State of California and, where applicable, to our provision of Services that is subject to the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (”CPRA”). We may disclose personal information to third-party service providers or contractors for the purpose of providing our Services, subject to written contracts restricting their use of the information.

Health information. Health information is sensitive personal information under the CCPA. We use Health Data only for the health features you request and other purposes in accordance with this Policy.

You have the Right to Opt Out of Sharing for Advertising Purposes: The right to opt out of the processing of your Personal Information for purposes that may be considered “sharing” as defined by the CCPA for marketing purposes, such as sharing identifiers about you with our marketing vendors to promote Meta products and services on other platforms.

Here’s how you can exercise the right to opt out of sharing of your Personal Information for purposes of marketing: Where applicable, you can visit the section titled “Ads About Manus” in your Settings in your settings to control whether we share your Personal Information for purposes of targeted advertising. You may also access this control by clicking on Your Privacy Choices, which is located in the footer of our websites.

Notice to South Korea users

This section applies to individuals in the Republic of Korea and, where applicable, to our provision of services that is subject to Korea’s Personal Information Protection Act (PIPA).

We have appointed a Personal Information Protection Officer under the PIPA—see How to contact us for contact details. Other PIPA disclosures are set out in this Privacy Policy.

We transfer personal information to service providers outside of South Korea for hosting, storage, customer support and security. Because these transfers are necessary to provide the Service, we rely on the bases permitted under the PIPA for cross-border outsourcing/storage and we supervise such providers.

For the Korean translation of the Privacy Policy, please see: 개인정보처리방침

Notice to Japan users

This section applies to individuals in Japan under the Act on the Protection of Personal Information (APPI), including APPI’s extraterritorial provisions where applicable. Butterfly Effect is the “personal information handling business operator” for the processing covered by this Privacy Policy.

For the Japanese translation of the Privacy Policy, please see:プライバシーポリシー

Notice to Singapore users

This section applies to individuals in Singapore and is subject to the Personal Data Protection Act 2012 (PDPA) and its regulations and guidelines.

Butterfly Effect is a company incorporated in Singapore, act as data controller and is responsible for the collection, use, and disclosure of your personal data as described in this Privacy Policy.

If a notifiable data breach occurs, we will notify the Personal Data Protection Commission (PDPC) and affected individuals where required, within the timelines prescribed by law.

When transferring personal data outside Singapore, we ensure that the recipient provides a standard of protection that is comparable to the PDPA.