Effective Date: Oct 1st, 2025
101GenAI, Inc., having its registeredoffice at Delaware at 10080 N Wolfe Rd SW3 200, Cupertino, CA 95014, UnitedStates of America (“Us”, “We”, “Company” or “Our”) owns,operates and manages a website under the name and style of Gen101 accessible at https://www.101gen.ai/, (referred to as “Platform”). The Company provides accessto its software as a service in relation to development of Co-pilot and includelimited access and use rights to the (a) hosted Service, (b) API service, (d)Platform, (c) support service, and (d) any other similar generally applicableservices that the Company provides to its customers in accordance with thedocumentations (“Services”).
For the purpose of this privacy policy (“Privacy Policy”), wherever the contextso requires the term “You”, “you”, “Your”, “your”, or “User”, shall mean and include: (i) anyperson who visits, uses or accesses the Platform; and (ii) anyone who signs-upon the Platform and uses the Platform to avail the Services or provideServices.
Please note the Company does not allowUser under 18 years of age, to use or access the Platform and avail theServices on the Platform. The Services can be accessed, used and availedthrough the Platform in accordance with Our terms of use (“Terms of Use”).
This Privacy Policy, inter alia, coversthe following
This Privacy Policy shall apply to anyperson who visits, browses, uses or accesses the Platform or uses any Serviceson the Platform. This Privacy Policy is an electronic record in terms of theGeneral Data Protection Regulation (Regulation (EU) 2016/679) and rules andregulations made thereunder. Further, this electronic record is generated by acomputer system and does not require any physical or digital signatures. Anynew features and/or Services that are added to Our current Services at anypoint in the future shall also be subject to the terms set out in this PrivacyPolicy.
In order to have access to all thefeatures, benefits or Services on Our Platform, a User must first create anaccount on Our Platform. To create an account and avail all the features,benefits or Services on Our Platform, a User is required to provide thefollowing information, as detailed below, which such User recognizes andexpressly acknowledges is Personal Information and / or Sensitive PersonalInformation and shall be shared with/disclosed to the Company for the purposesof facilitating Services to the User. Such information required for the purposeof sign-up on the Platform, identifying the User and availing the Servicesinclude:
PersonalInformation: Information that may be reasonably linkedto you or your household including, name, date of birth, address (includingpostal code, city, state etc.), phone number, email address.
SensitivePersonal Information: details of User’s government ID,social security number, records of purchases, email address, precisegeolocation data, physical conditions (including measures of height andweight), information concerning User’s health, User ID and password chosen by Userfor sign-up on the Platform (however, this would exclude Protected HealthInformation (as defined below)).
Otherinformation/data: User’s pictures, video recordings,and voice recordings.
We may, in future, include other optionalrequests for information from the User to help Us customize the Platform todeliver personalized information to the User.
(All Personal Information, SensitivePersonal Information and other information/data of the User shall hereinafterbe collectively referred to as “PersonalInformation” or “Personal Data”)
We value your concern regarding the handling of yourPersonal Information. We are committed to ensuring transparency in Ourprocesses and the protection of your privacy and Personal Data. This PrivacyPolicy acquaints you with Our practices and reaffirms Our dedication tosafeguarding your Personal Information. It outlines the procedures governingthe processing of your Personal Information when you interact with thePlatform, in strict compliance with relevant data protection regulations.
This Privacy Policy, in conjunction withOur Terms of Use, sets out Our approach to collecting, using, storing,processing and disclosing Personal Information when you engage with OurPlatform. Rest assured, We will not process or disclose your Personal Informationto any third party except as outlined in this Privacy Policy. Furthermore, itprovides guidance on how to reach out to Us for grievance redressal in theevent you have any concerns.
The information contained on thisPlatform and the Personal Information collected by using/ logging in and oraccessing this Platform is stored on a secured server.
Please note that by using and accessingthe Platform and availing the Services, or by providing Us with yourinformation, you will be deemed to have read, understood and agreed to thepractices and policies outlined in this Privacy Policy. You consent to Ourcollection, use, processing and sharing of your Personal Information asdescribed herein. If you disagree with this Privacy Policy, please refrain fromusing Our Services or providing Us with your information. If you are using theServices on behalf of or for the benefit of someone else, you represent thatyou are authorized to accept this Privacy Policy on their behalf and to consentto Our collection, use, and disclosure of their Personal Information. Please beaware that this Privacy Policy is based on the laws of California and the dataprivacy practices adopted by the Company in California. It may not fully complywith the privacy laws of other countries. By visiting the Platform, you agreeto abide by the terms and conditions of this Privacy Policy. If you do notagree with these terms, please refrain from using or accessing Our Platform orServices. By using the Platform, you expressly consent to Our use anddisclosure of your Personal Information in accordance with this Privacy Policy.
We may process your Personal Data for,including without limitation, the following purposes:
Providing Our Services: We collect thePersonal Information (detailed hereinabove) for the purposes of yoursign-up/registration on the Platform and providing Services, i.e. to facilitateservices by a multimodal artificial intelligence functioning as an assistingagent encompassing any software-based assistant, AI chatbot, or digitalcollaborator designed to work in tandem with the primary operator, offeringsupport, insights, or supplementary assistance (“Co-pilot”) and connected Services being provided by the Companyusing the Platform to its Customers.
The Personal Information collected isprocessed for purposes such as: (i) facilitating Services; (ii) facilitatingassistance with regard to Our Services; (iii) tracking and maintaining a recordof your activities on the Platform, with respect to the Services availed byYou; (iv) customer support and feedback Services; (v) providing personalizedcontent on the Platform based on the User preference; and (vi) meeting legal orcontractual obligations, etc.
Customer service: We need to processPersonal Data to ensure the overall quality of the Services availed by a Useron the Platform. Our primary goal in collecting your Personal Data and otherPersonal Information is to provide you with a safe, efficient, smooth, andcustomized experience. We also use your personally identifiable informationtogether with other personally non-identifiable information to help Us betterknow Our Users and to improve the Services, and functionality of the Platform.We do not voluntarily make this information available to third parties, nor doWe use it for any other purpose, except as set out herein.
We might utilize your Personal Information or request specific detailsregarding your account to authenticate any enquiries you make to access,delete, or rectify such information. If you do not have an account with Us, Wewould not possess adequate information to verify your identity and address yourrequests as We do not retain sufficient data to re-identify or connect you to aprior visit to Our Platform for accessing services where data might have beengathered.
Usage Data: We may collect usage dataabout your interactions with Our Service to understand how You use Our Servicesand to help Us improve the Services. For this purpose, We may process thefollowing usage data including but not limited to: (i) IP address; (ii) browsertype and version; (iii) pages of Our Services that you may visit; (iv) time anddate of Your visit; and (v) any other such diagnostic data.
Marketing: We may utilise or process theUsers’ data for marketing purposes. This means that We can contact Users todraw attention to Our products and Services. For this purpose, We process thefollowing Personal Data: (i) IP address; (ii) Platform behaviour; (iii) emailaddress; (iv) account information; (v) phone number; and (vi) such otherinformation as may be required by the Company for providing the Services fromtime to time.
Additionally, We may also use YourPersonal Data for several reasons, including but not limited to: (i) keep Youinformed of the status of the Co-pilot Services; (ii) send You communication inrelation to availing of the Services via SMS, Whatsapp or any other messagingservice; (iii) allow Our customer service and/or representatives to contact Youin relation to the Co-pilot Services, if necessary; (iv) send You verificationmessage(s) or email(s); (v) validate/authenticate Your account and to prevent anymisuse or abuse; (vi) send You important notices and communications regardingOur Services availed or changes to the terms and conditions and/or policies;(vii) to send You marketing related communications; (viii) to deal withenquiries and complaints raised by You and to troubleshoot problems; (ix)ensure compliance with all applicable laws and to ensure safety of the Platformand all Users; (x) to prevent fraud, errors and/or any illegal activity on thePlatform.
We may need to disclose Your PersonalData whether by law, legal process and/or by request from governmentalauthorities within or outside of California.
The Services on the Platform are onlyaccessible post the sign-up/ registration on the Platform which is carried outby providing the requisite details, including but not limited to username,password, one time password (“OTP”),etc. Therefore, We request You to use a safe and secure server to access thePlatform to ensure the safety of Your username, password and other informationas required by Us and shared by You to avail the Services on the Platform. Weshall not hold any responsibility for the security and/or privacy of anyinformation, which may be available to all Users and visitors of the Platformpublicly.
We automatically receive the URL of thesite from which anyone visits. We also receive the Internet Protocol (IP)address of each User’s computer (or the proxy server a User uses to access theWorld Wide Web), the User’s computer operating system and type of web browserthe User is using, email patterns, as well as the name of User’s internetservice provider. This information is used to analyze overall trends to help Usimprove Our Services. The linkage between User’s IP address and User’spersonally identifiable information is not shared with or disclosed to thirdparties. Notwithstanding the above, We may share and/or disclose some aggregatefindings (not the specific data) in anonymized form (i.e., non-personallyidentifiable) with advertisers, sponsors, investors, strategic partners, andother such third party(ies).
Personal Information transfers tocountries outside the United States of America, European Union or India areconducted only as per applicable law when such transfers comply with therelevant data protection legislation, ensuring that the recipient countrymaintains an adequate level of privacy protection. It is clarified that anydata collected from a data subject in the European Union shall only be sharedwith data exporters in regions identified by the European Commission havingadequate data protection frameworks.
You agree that in addition to what may beprovided in this Privacy Policy, We may also disclose Your Personal Informationunder the following circumstance
Third party service providers: We mayengage, retain, or, as necessary and in accordance with the businessrequirements of the Company or the Platform, third-party advertisers, paymentfacilitators, IT support personnel, independent contractors, and otherthird-party service providers to perform Services on behalf of or incollaboration with Us. These engagements will be governed by agreements thatinclude confidentiality obligations and comply with applicable laws pertainingto the Services rendered by Us on the Platform. These third-party serviceproviders may use Your Personal Information to provide their services andassist Us in providing Services, payment facilities, customer support, andadvertising on the Platform. We may engage third-party companies and/orindividuals to help improve or facilitate Our Services, to provide Services onOur behalf, and to perform Platform-related services, including but not limitedto payment processing, maintenance services, fraud detection services, databasemanagement, web analytics, monitoring, and evaluation services. In the event Weengage third-party companies and/or individuals for these purposes, Yourinformation may be shared with such third-party companies and/or individuals.Where applicable, you will be requested to enter into separate agreementsdirectly with such suppliers. We ask you to please note that this PrivacyNotice does not apply to the processing of personal data which takes placethrough these suppliers. In the event we are processing Personal Data providedby you which belongs to a data subject in the EU, we will as per the guidelinesstipulated by the GDPR seek appropriate consent. Your Personal Information could be accessedby Us or transmitted to Us within the United States/EU or to Our affiliates,business partners, or service providers across the globe. By furnishing Us withPersonal Information, You agree to this transfer. We commit to safeguarding theprivacy and security of Personal Information in accordance with this PrivacyPolicy, irrespective of its processing or storage location. Further, We do notauthorize such third-party service providers to use or disclose Your PersonalInformation except in connection with providing their services. In case anythird-party service provider(s) asks for or requests any Personal Data throughthe Platform or any other third-party link/website, the Company shall not beresponsible for such collection of Personal Data or information;
Compliance with laws and protection ofUsers: We may disclose your Personal Information or Sensitive PersonalInformation when it is required in order to comply with the law, in response tocourt orders, court summons, judgments, decrees, injunctions, arbitral awards,administrative orders, governmental investigation, or orders of any governmentauthority, to establish/exercise Our legal rights or defend against legalclaims, We may disclose Personal Information: as required by law, such as tocomply with a subpoena or similar legal process; and to enforce applicableTerms of Use, including investigation of potential violations thereof;
Business transfer and mergers: We maytransfer Your Personal Information if the Company, is acquired by or mergedwith another Company, to the extent permitted by applicable law and/or requiredunder the scheme/arrangement of merger, etc. In such an event We will notifyYou before Your Personal Information is transferred/shared with the otherentity and hence becomes subject to a different Privacy Policy. Further, ifrequired by applicable law we will aid the process of entering into specificagreement with the new entities involved in the processing of Personal Data;
With Your consent: In addition to theaforementioned circumstances, We may share Your Personal Information with thirdparties with Your prior consent and/or at Your request.
Non-personal data is data that can neverbe used to identify an individual. We may collect information regarding Useractivities on Our Platform. This aggregated information shall be used by Us inresearch and/or analysis, to improve and monitor Our Services and for variouspromotional schemes. Such non-Personal Data may be shared in aggregated,non-personal form with a third party to enhance customer experience, offeringsor Services.
The Platform uses cookies, and whilevisiting or using the Platform, You accept Our use of the cookies. We may placetext files in the browser files of Your computer system in order to enable suchcookies. A cookie itself does not contain Personal Information, and it willonly enable Us to relate Your use of the Platform and Your behaviour on thePlatform to information that You have specifically and knowingly provided. Theonly Personal Information that a cookie can contain is the information Yousupply to the cookie. A cookie can’t read data off Your hard disk or readcookie files created by other websites.
We may place both permanent and temporarycookies. A permanent cookie will remain on your web browser until its expirydate, unless deleted prior to such expiry date. However, most cookies are“session cookies” meaning that they automatically get deleted from yourcomputer system at the end of the session. You can refuse cookies by turningthem off in Your browser or alternatively, You can also set your browser towarn You before accepting any cookies. Therefore, You are always free todecline Our cookies if Your browser permits, however, We use certain cookies toauthenticate Users on each page after the User logs on to the Platform oraccesses any Services. If you, as a casual visitor, have inadvertently browsedany other page of this Platform prior to reading this Privacy Policy, and youdo not agree with the manner in which such information is obtained, collected,processed, stored, used, disclosed or retained, merely quitting this browserapplication should ordinarily clear all temporary cookies installed by Us. Allvisitors, however, are encouraged to use the “clear cookies” functionality oftheir browsers to ensure such clearing / deletion, as We cannot guarantee,predict or provide for the behaviour of the equipment of all the visitors ofthe Platform. Note that You are not a casual visitor if you have willinglysubmitted any Personal Data or information to Us through any means, includingemail, post or through the registration process on the Platform. All suchvisitors will be deemed to be, and will be treated as Users for the purposes ofthis Privacy Policy, and in which case, this Privacy Policy applies in itsentirety to such persons.
Every time You visit Our Platform, yourbrowser automatically sends log file information to the Company. This processoccurs independently of cookies and remains unaffected by your choice to opt inor out of cookie usage. These logs may include details such as the internetdomain from which You access Our sites, the date and time of Your visit, thesections You viewed, Your computer's IP address, Your browser and operatingsystem type, and, if applicable, the website You visited prior to Ours.
We utilize this log file information toenhance the design of Our sites, identify popular features, address user,hardware, and software issues, and make the sites more useful for Users andother visitors.
Please note that We may make changes tothis Policy from time to time if We are adding any feature to the website ordue to any change in circumstances. In the event We make such changes, thePrivacy Policy link will include a notation “Revised (date)” indicating thatyou should review the new terms, which will be effective immediately uponposting on this page, with an updated effective date. By continuing to use thePlatform after any modifications have been implemented, you indicate yourprospective agreement to the updated Privacy Policy and any alterationstherein.
We do not control or endorse the content,messages or information placed on the Platform by any User or third party and,therefore, We specifically disclaim any liability with regard to suchinformation and Your participation/ engagement with such third party serviceproviders and services offered by them, and You agree that you waive any claimsagainst Us relating to same, and to the extent such waiver may be ineffective,you agree to release any claims against Us relating to the same.
You are responsible for maintaining theaccuracy, truthfulness, correctness and completeness of the information Yousubmit or provide to Us, on the Platform; and shall hold harmless and indemnifythe Company from and against all claims arising out of or in relation to thewrongful information posted, provided by You to Us, on the Platform.
You are mandated by law to uphold theconfidentiality of Your patients' protected health information (“PHI”) and to inform patients about ourlegal obligations and privacy procedures regarding PHI. We're not obligated tonotify you that state laws concerning the PHI might impose stricter standardsor requirements compared to those stipulated by the Federal Health InsurancePortability and Accountability Act ("HIPAA").
If Your Personal Information changes, Youmay correct, delete inaccuracies, amend information, cancel your account,request that We no longer use your information by contacting Us on the Platformor dpo@101gen.ai.
We do not collect any protected healthinformation/PHI. Furthermore, You are not allowed to use the Company’s Serviceswhich may involve use and disclosure of PHI for treatment, payment, or healthcare operations or otherwise in any manner.
We understand the serious implications ofdata security and take extensive measures to ensure that Your data andinformation is secure. We take extensive technical, and legal measures tosafeguard Your Personal Data. The Platform uses a reliable SSL certificate toensure Your Personal Data is not misused in any manner whatsoever. We use SSLencryption when transmitting certain kinds of information, such as financialservices information or payment information.
Our employees and data processors (ifany), who have access to, and are associated with the processing of sensitivePersonal Data or information, are obliged to respect the confidentiality ofevery User’s Personal Information or sensitive Personal Data and information.We have put in place procedures and technologies as per good industry practicesand in accordance with the applicable laws, to maintain security of allPersonal Data from the point of collection to the point of destruction.
No administrator of the Platform willhave knowledge of your password. It is important for you to protect againstunauthorised access to your password, your computer and your mobile phone.Ensure you log off from the Platform when finished. We do not undertake anyliability for any unauthorised use of your account and password. If you suspectany unauthorised use of your account, you must immediately notify Us by sendingan email to Our grievance officer whose details have been specified below. Youshall be liable to indemnify Us due to any loss suffered by Us due to suchunauthorised use of your account and password. Please note that We make allUser Personal Information accessible to Our employees, agents or partners andthird parties only on a need-to-know basis. However, We are not responsible forthe confidentiality, security or distribution of your Personal Information byOur partners and third parties including third-party service providers outsidethe scope of Our agreement with such partners and third parties.
In case there is any breach of security,We will make all legally required disclosures concerning the breach and theconfidentiality or integrity of your unencrypted electronically stored"Personal Data" to you via email or by posting it on the Platformwithout unreasonable delay, in as far as is consistent with any legitimateneeds of law enforcement and any measures required to determine the scope ofthe breach and to safeguard the integrity of data.
By using the Platform and its Services,you explicitly consent to the collection, retention, and utilization of yourPersonal Data as outlined above. We reserve the right to communicate yourPersonal Information to any third party that makes a legally-compliant requestfor its disclosure. You acknowledge that processing Personal Data is essentialto enable your use of the Platform and its Services, as well as to ensurecompliance with legal obligations.
Notwithstanding anything containedanywhere in this Privacy Policy; We cannot assure absolute security to yourPersonal Data and by entering into or by logging into Our Platform, youexplicitly agree not to sue Us for any data breach.
We ensure that your data and informationshall be protected under the provisions of the General Data ProtectionRegulations, 2016 (GDPR), the California Consumer Privacy Act, 2018 along withany amendments made to these regulations.
We do not keep your Personal Data longerthan necessary for the purpose of processing. This includes, for example, thepurposes of satisfying any legal, regulatory, accounting, reportingrequirements, to carry out legal work, for the establishment or defence oflegal claims. We may aggregate and anonymize your Personal Data (so that it canno longer be associated with you) for research or statistical purposes, inwhich case We may use this information indefinitely without further notice toyou.
Under certain circumstances, You haverights under applicable data protection laws in relation to Your Personal Data.It is Our policy to respect Your rights and We will act promptly and inaccordance with any applicable law, rule or regulation relating to theprocessing of Your Personal Data. Details of Your rights are set out below:
You may exercise any of theabove-mentioned rights by sending a request to Us on Our contact information asdetailed below. We may also, as per our discretion, carry out actions pursuantto the abovementioned rights pertaining to any Personal Data of your clientsstored/processed by Us subject to careful consideration by of Us regarding suchPersonal Data actually being stored or processed by Us. In any case, given thatWe will be processing any Personal Data of your clients pursuant to yourinstructions, We may ask you to intervene and carry out the appropriateprocedures in order to give effect to the abovementioned rights of yourclients. You will not have to pay a fee to access Your Personal Data (or toexercise any of the other rights), however, a reasonable fee may apply in theevent We are required to give effect to any of the abovementioned rights foryour clients.
We may need to request specificinformation from You to help Us confirm Your identity or your Client’s identityand ensure Your right to access Your Personal Data/Your clients’ Personal Data(or to exercise any of Your other rights). This measure is implemented tosafeguard against the unauthorized disclosure of Personal Data to individualslacking the requisite authorization. Additionally, We may reach out to you foradditional details pertaining to your request in order to expedite ourresponse. It is important to note that We reserve the right to decline requeststhat are unreasonably repetitive, necessitate excessive and disproportionatetechnical resources, pose a risk to the privacy of other users or thirdparties, may compromise an ongoing investigation, or are of an impracticalnature.
We try to respond to all legitimaterequests within 30 days. Occasionally it may take Us longer than 60 days ifYour request is particularly complex, or You have made a number of requests. Inthis case, We will notify You and keep You updated.
If you have any questions or complaintsabout the processing of your Personal Data or any grievance regarding OurPrivacy Policy, write to Us at dpo@101gen.ai. Our team will be happy to assistyou.
In the event We have entered into aseparate contract with You for processing data as per applicable law then thisPrivacy Policy along with the contract shall be read conjointly to give effectto this Privacy Policy. Further, in the event there is any discrepancy betweenthe contract executed between You and Us and this Privacy Policy then thecontract shall prevail.
You can also directly contact Us inrelation to your grievances pertaining to the usage of Personal Data asprovided in the Privacy Policy by contacting Our grievance officer, as providedbelow:
Name: Prashanth Aditya Susarla
Address: 10080 N Wolfe Rd SW3 200,Cupertino, CA 95014
Email: dpo@101gen.ai