ARKION
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    Contents
    Effective Date11 March 2026
    Version1.0
    IncorporatedOntario, Canada
    Privacy Enquiriesprivacy@arkion.ai
    Legal Document

    Privacy Policy

    Effective 11 March 2026·Version 1.0·Arkion Identity Systems Inc.

    This document describes how Arkion Identity Systems Inc. collects, uses, and protects personal information in connection with the Arkion platform and associated services, in accordance with applicable United States and Canadian privacy laws.

    01

    About Us

    Arkion Identity Systems Inc. (“Arkion,” “we,” “us,” or “our”) is incorporated in Ontario, Canada and operates across the United States and Canada. We provide a Non-Human Identity Governance (NHIG) platform that helps enterprises discover, classify, and govern machine identities including AI agents, certificates, API keys, and service accounts.

    For purposes of applicable privacy laws, Arkion operates as an “organization” under PIPEDA and applicable provincial privacy legislation, and as a “business” under applicable US state privacy laws, that determines the purposes and means of processing personal information.

    Privacy Enquiriesprivacy@arkion.ai
    IncorporatedOntario, Canada
    02

    Scope

    This policy applies to:

    • Website visitors
    • Prospective customers requesting scans or enquiries
    • Platform customers
    • Authorised users of the Arkion platform
    Where Arkion processes personal information on behalf of customers as a service provider or processor, that processing is governed by the Data Processing Agreement (DPA), not this Privacy Policy.
    03

    Personal Information We Collect

    3.1 Information You Provide

    Full name, work email address, job title, organisation, technology stack preferences, and communication records created when you contact us or register for the platform.

    3.2 Information Collected Automatically

    IP address, browser and device type, pages visited, referral source, session duration, and cookies or similar tracking technologies.

    3.3 Platform Usage Data

    Login events, session data, feature usage analytics, configuration settings, and support records generated through your use of the Arkion platform.

    3.4 Infrastructure Scan Data

    Our platform performs read-only scans of customer infrastructure to identify and inventory non-human identities.

    Scan output typically does not constitute personal information. Where infrastructure metadata incidentally includes personal information, it is processed under the customer DPA as processor activity. Arkion never writes to or modifies customer infrastructure.
    04

    Legal Bases for Processing

    Legal BasisProcessing ActivityApplicable Law
    Performance of a contractOnboarding, platform access, scan deliveryUS (all states) · Canada (PIPEDA)
    Legitimate business interestSecurity, fraud prevention, product improvementUS (all states) · Canada (PIPEDA)
    Legal obligationRegulatory compliance, tax records, lawful requestsUS (all states) · Canada (PIPEDA/Law 25)
    ConsentMarketing communications, optional cookiesCanada (CASL) · US (where required)
    05

    How We Use Personal Information

    • Deliver the Arkion platform and infrastructure discovery scans
    • Communicate about your account, findings, and support requests
    • Onboard and verify customers and authorised users
    • Ensure the security, integrity, and availability of our services
    • Send product updates and marketing communications (where consent is obtained or not opted out)
    • Fulfil legal and regulatory obligations
    • Improve the platform through aggregated and de-identified analytics
    We do not sell personal information. We do not engage in cross-context behavioral advertising. We do not use personal information for automated decision-making that produces legal or similarly significant effects without human review.
    06

    Disclosure of Personal Information

    We may disclose personal information to the following categories of recipients:

    • Cloud infrastructure providers (e.g. AWS, Azure)
    • Identity and access management tooling providers
    • Support and communication platform providers
    • Analytics and product improvement services
    • Professional advisors under confidentiality obligations
    • Regulators, courts, and law enforcement where required by applicable law

    A current list of sub-processors is available upon request at privacy@arkion.ai. Material changes to sub-processors are notified per contractual obligations.

    07

    Cross-Border Data Transfers

    Arkion is incorporated in Ontario, Canada and operates across both the United States and Canada. Personal information collected in one jurisdiction may be transferred to and processed in the other jurisdiction. As a Canadian company doing business in the United States, data may flow from Canada to the US and vice versa. We ensure that appropriate contractual and organizational safeguards are in place for all cross-border transfers.

    Where personal information is transferred between Canada and the United States, we rely on contractual protections and our internal privacy practices to ensure an adequate level of protection.

    Quebec residents: Transfers of personal information outside Quebec are conducted in compliance with Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (Law 25), including a privacy impact assessment where required.
    08

    Data Retention

    Data CategoryRetention Period
    Customer account dataContract duration + 7 years
    Scan data and findingsPer customer contract and DPA
    Website and analytics dataUp to 13 months
    Marketing contact dataDeleted within 30 days of opt-out
    Support recordsUp to 3 years after case closure

    On expiry: personal information is securely deleted or de-identified per our data destruction procedures.

    09

    Cookies & Tracking

    • Strictly necessary cookies — Cannot be disabled; required for session management and core functionality.
    • Analytics cookies — Help us understand visitor behavior and improve the platform. Consent required where applicable.
    • Preference cookies — Remember your settings and preferences across sessions.

    Manage your cookie preferences via the cookie banner on first visit or through your browser settings.

    California residents: Certain cookies may constitute “sharing” of personal information under the CCPA/CPRA. You may opt out of non-essential cookies at any time using the cookie banner or by contacting privacy@arkion.ai.

    10

    Your Privacy Rights

    Depending on your jurisdiction, you may have the following rights with respect to your personal information:

    Know / Access
    Deletion
    Correction
    Portability
    Opt Out of Sale / Sharing
    Non-Discrimination
    Withdraw Consent
    Lodge a Complaint
    To exercise your rights, contact privacy@arkion.ai. Under US state laws, we respond within 45 calendar days (with a possible 45-day extension). Under PIPEDA, we respond within 30 calendar days.
    11

    California Residents (CCPA/CPRA)

    If you are a California resident, the California Consumer Privacy Act and the California Privacy Rights Act (collectively, “CCPA/CPRA”) provide you with specific rights regarding your personal information.

    Categories of Personal Information Collected

    We collect the following categories as defined by the CCPA/CPRA: identifiers (name, email, IP address), commercial information (transaction records, service usage), internet or other electronic network activity (browsing history, interactions with our website and platform), and professional or employment-related information (job title, organisation).

    No Sale or Sharing

    Arkion does not sell your personal information as defined under the CCPA/CPRA. We do not share your personal information for cross-context behavioral advertising purposes.

    Shine the Light

    Under California Civil Code Section 1798.83, California residents may request information regarding the disclosure of personal information to third parties for direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

    Authorized Agent

    You may designate an authorized agent to make a request on your behalf. To do so, provide the agent with written permission and verify your identity directly with us. Contact privacy@arkion.ai.

    California residents may submit verifiable consumer requests by emailing privacy@arkion.ai. We will verify your identity before fulfilling any request. We will not discriminate against you for exercising your CCPA/CPRA rights.

    Other US State Privacy Laws

    Residents of the following states have additional rights under their respective privacy laws:

    • Virginia (VCDPA) — Right to access, correct, delete, obtain a copy, and opt out of targeted advertising, sale, or profiling.
    • Colorado (CPA) — Right to access, correct, delete, data portability, and opt out of targeted advertising, sale, or profiling.
    • Connecticut (CTDPA) — Right to access, correct, delete, obtain a copy, and opt out of targeted advertising, sale, or profiling.
    • Texas (TDPSA) — Right to access, correct, delete, data portability, and opt out of targeted advertising, sale, or profiling.

    To exercise rights under any US state privacy law, contact privacy@arkion.ai. If your request is denied, you may appeal by replying to the denial notice.

    12

    Canadian Residents

    Canadian residents have rights under federal and provincial privacy legislation. The following laws may apply depending on your province of residence:

    PIPEDA
    Personal Information Protection and Electronic Documents Act — Federal
    Quebec Law 25
    Act Respecting the Protection of Personal Information in the Private Sector — Quebec
    Alberta PIPA
    Personal Information Protection Act — Alberta
    BC PIPA
    Personal Information Protection Act — British Columbia

    Consent

    We collect, use, and disclose your personal information with your knowledge and consent, except where permitted or required by law. Consent may be express or implied depending on the sensitivity of the information and your reasonable expectations. You may withdraw consent at any time by contacting privacy@arkion.ai, subject to legal or contractual restrictions.

    Accountability

    Arkion has designated a Privacy Officer responsible for our compliance with applicable Canadian privacy legislation. Our Privacy Officer can be contacted at privacy@arkion.ai.

    Right to Complain

    If you are not satisfied with our response to your privacy concern, you have the right to file a complaint with the applicable privacy commissioner or oversight body (see Section 16 for details).

    Canada’s Anti-Spam Legislation (CASL) applies to commercial electronic messages sent to Canadian recipients. We only send marketing emails with express or implied consent as defined by CASL. You may unsubscribe at any time using the link in any marketing email.
    13

    Security

    We implement appropriate technical and organizational measures to protect personal information, including:

    • TLS 1.2+ encryption in transit
    • AES-256 encryption at rest
    • Role-based access control (RBAC) and least privilege
    • Multi-factor authentication (MFA) for all platform access
    • Regular vulnerability assessments and penetration testing
    • Documented incident response procedures
    In the event of a personal information breach that poses a real risk of significant harm, we notify affected individuals and applicable regulatory authorities as required by law — including notification to the Office of the Privacy Commissioner of Canada under PIPEDA, the Commission d’accès à l’information du Québec under Law 25, and applicable US state attorneys general or agencies as required by state breach notification laws.
    14

    Children

    Arkion is an enterprise product designed for business professionals. We do not knowingly collect personal information from children under the age of 13, in compliance with the Children’s Online Privacy Protection Act (COPPA). We also do not knowingly collect personal information from individuals below the age of majority in their applicable Canadian province. If we become aware that we have inadvertently collected personal information from a child, we will promptly delete that information.

    15

    Changes to This Policy

    We may update this Privacy Policy from time to time. Material changes will be notified by email or in-platform notification at least 30 days before taking effect. Continued use of the Arkion platform or website after the effective date of any update constitutes acceptance of the revised policy. The current version is always available at arkion.ai/privacy.

    16

    Contact

    Data Controller / Business
    Arkion Identity Systems Inc.
    Privacy Officer
    privacy@arkion.ai
    Incorporated
    Ontario, Canada

    Supervisory Authorities

    If you are not satisfied with our response, you may contact the following authorities:

    • US — California Privacy Protection Agency (CPPA) — cppa.ca.gov
    • Canada — Office of the Privacy Commissioner (OPC) — priv.gc.ca
    • Canada — Commission d’accès à l’information du Québec (CAI) — cai.gouv.qc.ca
    Arkion Identity Systems Inc. · Privacy Policy · Version 1.0 · Effective 11 March 2026 · US & Canada
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