Privacy Policy – Pantheon AI

Privacy Notice

PRIVACY NOTICE

Last updated: April 28, 2026

This Privacy Notice for Pantheon Atlas LLC (doing business as PantheonAi) (‘we‘, ‘us‘, or ‘our‘), describes how and why we might access, collect, store, use, and/or share (‘process‘) your personal information when you use our website, services, tools, and features, or otherwise interact with us (collectively, the ‘Services‘), including when you:

Visit our website at https://www.pantheonai.com/ or any website of ours that links to this Privacy Notice; and

Engage with us in other related ways, including any marketing or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@pantheonai.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered ‘special’ or ‘sensitive’ in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third-party vendors, service providers, contractors, or agents (‘third parties’)? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

On which laws is this Privacy Notice based? This Privacy Notice is based on the GDPR and the UK GDPR, as well as on other laws that may apply to our processing of your personal information. These laws are often similar to the (UK) GDPR, but with notable differences. Which laws apply depends on a number of factors including your place of residence. If you have any questions in this regard, feel free to contact us. In general, references to the (UK) GDPR throughout this Privacy Notice should be read as references to equivalent provisions of applicable law. 

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. DO WE COLLECT INFORMATION FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. CALIFORNIA RESIDENTS

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. Where you provide personal information to us about other individuals, such as agents or related parties, you must ensure that these individuals are aware and understand how we process their data, for example by providing a copy of this Privacy Notice to them.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: pantheonai.com/cookie-policy.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

We collect your personal data primarily from you directly. However, we may receive some information about you from our third-party data analytics services (such as Google Analytics). You are not required by contract or by law to provide your personal data.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your personal information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services including:

  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
  • Inform potential/customers investors. Provide insights to support overall business activities
  • Ensure a safe and stable operation of our website. Ensure users are not encountering errors or issues on the website.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so if and as necessary under applicable law, like, depending on your jurisdiction, with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information.

  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Legitimate interests. In jurisdictions where legitimate interest is recognized as a legal basis, we may process your information where we believe it is necessary to protect our legitimate interests or the vital interests of a third party. Our legitimate interests are outlined in Section 2 above. 

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations
  • We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

If you are located in People’s Republic of China (PRC), this section applies to you.

The Personal Information Protection Law (PIPL) permits us to process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent. In addition, the PIPL provides that we may process your information without your consent under the following circumstances:

  • Contract: Where it is necessary for concluding or performing a contract to which you are a party
  • Legal obligations: Where it is necessary for performing statutory duties or statutory obligations
  • Public disclosure: Where the personal information disclosed by yourself or otherwise lawfully disclosed is processed within a reasonable scope

PRC laws: Other circumstances as provided by PRC laws or administrative regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third parties who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

  • Data Analytics Services
  • Website Hosting Service Providers
  • Performance Monitoring Tools

We also may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a ‘sale’/’sharing’ (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section ‘CCPA RIGHTS’

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: pantheonai.com/cookie-policy.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. The Google Analytics Advertising Features that we may use include: Remarketing with Google Analytics and Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and commercially reasonable technical and organisational security measures designed to protect your personal information from unauthorized access, use or disclosure. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your personal information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at mailto:info@pantheonai.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (‘EEA’), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, Canada, and the PRC), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to object to or restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. You may also complain to us directly by contacting us through the avenues described in the section below ‘HOW TO EXERCISE YOUR RIGHTS’, without prejudice to your right to lodge a complaint with the two aforementioned authorities.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: pantheonai.com/cookie-policy.

If you have questions or comments about your privacy rights, you may email us at mailto:info@pantheonai.com

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

Global Privacy Control: Depending on where you live, we recognize and honor Global Privacy Control (‘GPC’) signals. If you use a browser or extension that supports GPC, we will treat this as a valid request to opt out of the sale or sharing of your personal information for targeted advertising purposes under the California Consumer Privacy Act (‘CCPA’) for California Residents. When we detect a GPC signal from your browser, we will automatically apply your opt-out preference without requiring you to take any additional action. For more information about GPC and how to enable it, visit globalprivacycontrol.org.

12. CALIFORNIA RESIDENTS

This section applies to you if you are a resident of California and we process personal information about you that is subject to the CCPA. For purposes of this section, references to “personal information” shall include “sensitive personal information” as defined under the CCPA.

Categories of Personal Information We Process

The table below shows the categories of personal information we have collected in the past 12 months. For a comprehensive inventory of all personal information we process, please refer to the section ‘WHAT INFORMATION DO WE COLLECT?’

  • Internet or other similar network activity such as information regarding your interaction with the Services; and 
  • Geolocation data such as general location derived from your IP address.

The criteria we use to determine how long to retain your personal information is described in the section above, How Long Do We Keep Your Information?

Sources of Personal Information

Learn more about the sources of personal information we collect in ‘WHAT INFORMATION DO WE COLLECT?‘

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, ‘HOW DO WE PROCESS YOUR INFORMATION?’

We collect and share your personal information through:

  • Targeting cookies/Marketing cookies
  • Beacons/Pixels/Tags

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?‘

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration.

While we do not sell personal information in the traditional sense, we disclose, and have disclosed in the preceding 12 months, the following categories of personal information about individuals for [marketing and advertising purposes], in a manner that may be considered “selling” and “sharing” under applicable law. We have no actual knowledge that we have “sold” or “shared” the personal information of individuals under 16 years of age.

Category of Personal InformationCategories of Recipients
 Internet or similar network activity, such as information automatically collected through Tracking Technologies about your interactions with the Services, Geolocation information, such as your IP addressMarketing, advertising and remarketing partners, Tracking Technology providers, Ad networks

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?’

Your CCPA Rights

As You may have rights under California law However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

However, please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. 

  • Access / Know: : You may have the right to request access to the personal information we hold about you and to obtain details about what personal information we have collected about you, including the categories of personal information, the categories of sources from which the information was collected, the business or commercial purposes for collecting, selling or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
  • Deletion: You may have the right to request that we delete personal information we hold about you. 
  • Correction: You may have the right to request that we correct inaccurate personal information we hold about you. 
  • Portability: You may have the right to receive a copy of the personal information we hold about you in a portable and, to the extent technically feasible, readily usable format. 
  • Opt-Out of Marketing: You may opt out of marketing at any time by using the unsubscribe / opt-out instructions provided in our communications to you. If you opt out, we may still send you transactional or administrative messages, such as emails about your account.
  • Opt out of Sale or Sharing/Processing for Targeted Advertising. You may have a right to direct us not share or process your personal information for targeted advertising. To exercise this right, please submit a request through the following form. For information on how we process opt-out preference signals, see the section above, CONTROLS FOR DO-NOT-TRACK FEATURES. 

How to Exercise Your Rights

To make a request described in this section, you can contact us by making a data subject access request, by emailing us at info@pantheonai.com, by calling toll-free at 555-555-5555, or by referring to the contact details at the bottom of this document. 

We will not retaliate or discriminate against you for exercising any of these rights. Further information may be needed to verify your identity before exercising these rights, such as your email address or government issued ID. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. 

12. WHERE WE STORE YOUR INFORMATION

In Short: We transfer your personal data to countries outside your country of residence and of the EEA. We will implement additional adequate safeguards for such data transfers where necessary (such as the European Commission’s standard contractual clauses for the transfer of personal data to third countries or the UK Information Commissioner’s international data transfer addendum to the EU standard contractual clauses, as relevant) and, where required by applicable law, obtain your separate consent for cross-border transfers. 

The personal data that we collect from you will be transferred to, and stored at/processed in countries outside the EEA and UK or outside your country of residence, for example to third-party vendors, which may use subcontractors in other countries. These include the United States, but the personal data about you may potentially be stored or processed globally. We will ensure that we implement additional and adequate safeguards for such data transfers where necessary. Please note that when your personal information is located outside of your jurisdiction of residence it will be subject to the laws of the country in which it is situated Please contact info@pantheonai.com if you would like to receive further information on our data residency practices or would like to receive a copy of the implemented additional safeguards. In some cases, we may be able to rely on a derogation, allowing a transfer to a country without entering into additional safeguards. This may apply, for example, where the transfer is necessary for the establishment, exercise or defence of legal claims, for the performance of a contract with you, or where you have explicitly consented to the transfer

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may modify this Privacy Notice from time to time. The updated version will be indicated by an updated ‘Revised’ date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, to how we use or disclose personal information we collect, we will use reasonable efforts to notify you (by prominently posting a notice of such changes or by sending you a notification) and will take additional steps as required by applicable law. We encourage you to review this Privacy Notice frequently to be informed of how we are processing your information. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at info@pantheonai.com or contact us by post at:

Pantheon Atlas LLC
4476 Main Street
Suite 104
Amherst, NY 14226
United States