sundae_bar Privacy Policy

Introduction

This privacy policy sets out how Sundae Bar AI PLC uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can view the full version of the privacy policy here: sundaebar.ai/privacy-policy

1. IMPORTANT INFORMATION AND WHO WE ARE
2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. SCOUT, AI FEATURES AND YOUR CONVERSATIONS
6. INTERNAL REVIEW OF CONVERSATIONS
7. USING SUNDAE_BAR WITHOUT AN ACCOUNT
8. DISCLOSURES OF YOUR PERSONAL DATA
9. INTERNATIONAL TRANSFERS
10. COOKIES AND SIMILAR TECHNOLOGIES
11. DATA SECURITY
12. DATA RETENTION
13. YOUR LEGAL RIGHTS
14. CONTACT DETAILS
15. COMPLAINTS
16. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
17. THIRD PARTY LINKS

1. Important information and who we are

Privacy policy

This privacy policy gives you information about how Sundae Bar AI PLC collects and uses your personal data through your use of this website/platform, including any data you may provide when you register with us, chat with Scout, run an agent, or purchase a product or service.

This website/platform is not intended for children and we do not knowingly collect data relating to children.

Controller

Sundae Bar AI PLC is the controller and responsible for your personal data (referred to as "sundae_bar", "Company", "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights (13), please contact us using the information set out in the contact details section (14).

Two lists that sit alongside this policy

We use a number of third-party companies to run sundae_bar, and agents on our platform can use tools that send data outside our systems. Both of those change over time.

Rather than rewriting this policy every time, we maintain two pages that we keep current:

• Sub-processors, listing every company that handles personal data on our behalf and what each one receives.
• Connected services and agent tools, listing every tool an agent can use, what it sends out and what it sends back.

Those pages form part of this policy. We update them before we add a new provider or tool.

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes payment card details, and where you provide one, your VAT or other tax registration number.
• Transaction Data includes details about payments to and from you, your subscription and credit balance, and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website/platform.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Conversation Data includes the messages you send to Scout and to agents you run, the replies they generate, the results of any tool an agent uses while answering you, and the information an agent retains about you between conversations so that it does not have to ask you the same things twice.
• Agent Data includes the agents and skills you create or configure, their instructions and settings, and any schedules you set for them to run.
• Usage Data includes information about how you interact with and use our website/platform, products and services, including a record of the agent activity you have used for billing purposes.
• Blockchain Data includes wallet addresses and related identifiers, where you take part in sundae_bar Lab and Subnet 121.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website/platform feature in order to analyse general trends in how users are interacting with our website/platform to help improve the website/platform and our service offering.

Please think about what you put into a conversation

Scout and the agents you run are conversational, so it is easy to include information about yourself or other people without meaning to. Anything you type becomes Conversation Data, and section 5 explains where it goes.

We ask agents not to retain sensitive details such as credentials, verification codes, financial information or health information, but that is an instruction to a language model rather than a technical guarantee. Please do not put information into a conversation that you would not want stored.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for use of the sundae_bar platform, our products or services;
  • create an account on our website/platform;
  • subscribe to our service or publications;
  • chat with Scout, create an agent, or run an agent;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website/platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. See section 10.
• Third parties. We will receive personal data about you from the following third parties:
  • Technical and Usage Data from analytics providers, where you have accepted analytics cookies.
  • Technical and Usage Data from advertising networks, where we are running advertising campaigns and you have accepted marketing cookies. We do not always run advertising, and no advertising provider receives anything about you unless you have accepted marketing cookies.
  • Contact, Financial and Transaction Data from our payment processor.
  • Identity and Contact Data from a sign-in provider, if you choose to sign in using an existing account with them.

The companies concerned are named on our sub-processors page.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter or accept analytics cookies.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

We do not use the content of your conversations with Scout or with the agents you run to decide what to market to you.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by logging into the website/platform and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links within any marketing communication sent to you or by contacting us.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example updates to our Terms and Conditions, notifications about your subscription or balance, and checking that your contact details are correct.

5. Scout, AI features and your conversations

Scout, and the agents you build and run on sundae_bar, are powered by artificial intelligence models. We do not build these models ourselves. We access them through an AI gateway, which passes your request to a model provider and returns the reply.

What is sent to a model provider

When you send a message, the following is sent to whichever model provider handles that request:

• Your message.
• The earlier messages in that conversation. Conversations are sent in full each time so that the agent can follow what has already been said.
• What the agent has retained about you, described below.
• The instructions that define the agent, and the definitions of any tools it can use.
• The results of any tool the agent uses while answering, for example web search results.

Which provider receives it

We use more than one model provider, and requests can move between them automatically, for example if one is unavailable. That means we cannot tell you that a particular conversation went to a particular provider. The providers we currently use are named on our sub-processors page.

We do not permit model providers to use your conversations to train their models. Model providers may retain data briefly for their own security and abuse-monitoring purposes, in line with their terms.

What agents remember about you

So that you do not have to repeat yourself, an agent can retain a short profile about you between conversations. This can include your name, time zone, the kind of work you do, the tools and services you have said you use, routines you have described, and how you like replies written.

You can see and change this at any time by asking the agent directly, and it is deleted when you delete your account.

Searching for skills and agents

When you ask Scout to find you a skill or an agent, it writes a search query based on your conversation and sends it to our search index. That query is converted into a numerical form by a model provider so it can be matched against our catalogue. The query may reflect what you have told the agent, so it can contain information from your conversation.

Web search

If an agent searches the web, the query is written by the agent from your conversation and sent to a search provider. The providers are listed on our connected services and agent tools page, which also explains what changes when we introduce tools that connect to your other accounts.

Automated decision-making

We do not make decisions that produce legal effects concerning you, or similarly significantly affect you, based solely on automated processing.

6. Internal review of conversations

We think you should know this plainly rather than find it in a list.

Our staff can read conversations between you and Scout or the agents you run. We do this to fix faults, to understand how the product is performing and where it is failing people, and to answer support requests.

• Access is restricted to administrators and is not available to staff generally.
• We use it to improve the product and to support you, not to build a profile of you and not for marketing.
• Conversations may also appear in our fault-monitoring records when something goes wrong while an agent is running.

If you would prefer your conversations were not reviewed, please contact us using the details in section 14 and we will discuss what we can do.

7. Using sundae_bar without an account

You can browse sundae_bar and ask Scout for recommendations on the Explore page without creating an account. Chatting with Scout on its own page, and using agents, needs an account and a subscription.

The Scout panel on the Explore page keeps its conversations against a randomly generated identifier stored in your browser, not against your account, so that a conversation can continue across page loads. This is the same whether or not you are signed in. The identifier is not linked to your name or email address, and it lasts for up to 30 days.

Two things are worth knowing:

• These conversations stay separate from your account. Creating an account or signing in does not move them into it, and they are deleted in the normal course.
• Signing out does not remove the identifier. If you use a shared or public computer, use a private browsing window, or clear this site's cookies and data when you finish.

Conversations on the Explore page are deleted after 30 days of inactivity.

8. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table in section 4 above. The specific companies are named on our sub-processors page.

• Sub-processors and service providers: We use third parties to provide services on our behalf, including hosting, our database, AI model access, payment processing, email delivery, analytics, fault monitoring and security services. They are bound by contractual obligations to ensure the security, privacy and confidentiality of your information.
• AI model providers: As described in section 5.
• Tool providers, on your instruction: Where you ask an agent to use a tool, the data needed for that tool is sent to its provider. See our connected services and agent tools page.
• Abuse and fraud prevention entities: We may disclose personal data based on a good faith belief it is needed to prevent fraud, abuse, or attacks on our services, or to protect the safety of sundae_bar and our users.
• Affiliates: personal data may be shared with sundae_bar affiliates to facilitate customer service, marketing and advertising, order fulfilment, billing, technical support, and legal and compliance obligations. Our affiliates may only use the personal data in a manner consistent with this privacy policy.
• Competent Authorities: We may disclose personal data to authorised law enforcement, regulators, courts, or other public authorities in response to lawful requests or to protect our rights and safety.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Other users and the public: Where you publish an agent, a skill or a review, that content and the identity you publish it under are visible to others. You control what you publish.
• sundae_bar Lab participants: If you submit to a Lab challenge, your submission is evaluated by independent validator operators and by AI providers, as described on our sub-processors page. Scores and rewards are recorded on a public blockchain and cannot be deleted.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as UK law. This includes the United States, where several of our providers operate.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place. We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely The International Data Transfer Addendum to the European Commission's standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us (see Contact details (14)).

10. Cookies and similar technologies

Cookies are small files stored on your device. We also use similar technologies such as your browser's local storage. We group them as follows.

Strictly necessary. These are needed for the site to work and are always active. They cannot be switched off. They keep you signed in, let a conversation with Scout continue across page loads, remember that you finished the Explore introduction, remember your cookie choice, and protect card payments from fraud.

Analytics. These help us understand how the site is used so we can improve it. They are switched off unless you accept them. No analytics cookie is set and no analytics provider receives anything about you until you do. This includes the cookie our video player uses to measure whether videos play smoothly.

Marketing. We do not set marketing cookies at the moment. If we advertise sundae_bar on other websites again, we will add a separate Marketing choice to our cookie banner, switched off unless you accept it, before any marketing cookie is set.

When you first visit, we ask whether you accept analytics cookies. You can change your mind at any time through Cookie settings, linked in our footer and at the bottom of this page. If you refuse, we remove any analytics cookies already on your device. Refusing does not restrict your use of sundae_bar in any way.

We also use your browser's local storage to remember things on your device, such as your answers to the Explore introduction and which agent conversations you have read. That information stays on your device.

Refusing cookies does not switch off personalisation. Recommending agents and skills that suit you is based on what you do on the Platform itself, held in your account, and does not rely on cookies. It is described in section 4 and continues whatever you choose here. If you would prefer we did not do it, you can object, and section 13 explains how.

We do not sell your personal data.

11. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

12. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

The periods we apply are:

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

What happens when you delete your account

Deleting your account removes your profile, your conversations, what agents have retained about you, the agents and skills you created, your schedules, and your uploaded files. Any third-party accounts you connected are disconnected.

Two things survive, and we would rather say so:

• Records of agent activity and payments. These are kept as described above because we need them for our accounts and our tax obligations. They identify you only by an internal reference number, not by name or email address.
• Anything recorded on a public blockchain, if you took part in sundae_bar Lab. Blockchain records are permanent and cannot be deleted by us or by anyone else.

In some circumstances you can ask us to delete your data: see 13 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

13. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Information recorded on a public blockchain cannot be erased by anyone.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details (14)).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

14. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

Email address: support@sundaebar.ai

Postal address: Salisbury House, London Wall, London, United Kingdom, EC2M 5PS

15. Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

16. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 11 September 2026, and replaces the version of 2 June 2025. Historic versions can be obtained by contacting us.

The sub-processors and connected services pages referred to in section 1 are updated more often than this policy. We update them before adding a new provider or tool.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

17. Third party links

This website/platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website/platform, we encourage you to read the privacy policy of every website you visit.