WEBSITE PRIVACY POLICY

Effective Date: October 5, 2026

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE ACCESSING OR USING THE SIMULQ SERVICE. BY CREATING AN ACCOUNT, CLICKING "I AGREE," OR OTHERWISE ACCESSING OR USING THE SERVICE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE, DO NOT ACCESS OR USE THE SERVICE.

1. INTRODUCTION AND SCOPE

This document is the Privacy Policy of the SimulQ AI website and platform. It governs the collection, use, sharing, retention, and protection of personal information by Alpin Management Partners Ltd Co, a Texas limited liability company doing business as SimulQ ("AMPL," "we," "us," or "our"), located at 39926 Holik Rd, Hempstead, TX 77445, in connection with the SimulQ AI-assisted learning and query platform, website, software, content, and all related services (collectively, the "Service").

This Privacy Policy applies to all individuals who access or use the Service, including visitors to the SimulQ AI website and registered subscribers. It applies to users wherever they are located, subject to applicable law.

This Privacy Policy is incorporated by reference into, and forms part of, the SimulQ Terms and Conditions of Service. By creating an account, clicking "I Agree," "Subscribe," or any equivalent affirmative action, or by otherwise accessing or using the Service, you represent that you have read, understood, and agree to be bound by this Privacy Policy together with the Terms and Conditions of Service.

The Service is offered exclusively to individual users for personal, non-commercial use. No organizational, entity, corporate, group, or multi-seat accounts are available or permitted. Each Subscription authorizes access by one named individual only.

Data Controller: Alpin Management Partners Ltd Co, doing business as SimulQ 39926 Holik Rd, Hempstead, TX 77445 Email: dmca@simulq.ai

2. DEFINITIONS

For purposes of this Privacy Policy, the following terms have the meanings set out below.

• "AMPL," "we," "us," or "our" means Alpin Management Partners Ltd Co, a Texas limited liability company doing business as SimulQ, with its principal place of business at 39926 Holik Rd, Hempstead, TX 77445.
• "Service" means the SimulQ AI-assisted learning and query platform, website, software, content, and related services.
• "User" or "you" means the individual accessing or using the Service.
• "Personal information" or "personal data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular identified or identifiable individual.
• "User Content" means queries, texts, inputs, documents, files, and other content submitted by a User through or in connection with the Service.
• "Subscription" means the individual monthly subscription to the Service at the price of $89.00 per month. No annual subscription price is offered.
• "Service Providers" means third-party vendors and processors that process personal information on AMPL's behalf to provide operational, technical, payment, hosting, identity-verification, security, or other related services.
• "Processing" means any operation or set of operations performed on personal data, whether or not by automated means.
• "TDPSA" means the Texas Data Privacy and Security Act, Tex. Bus. & Com. Code Ch. 541.

3. DATA CONTROLLER IDENTIFICATION AND CONTACT DETAILS

The entity responsible for the processing of personal information under this Privacy Policy is: Alpin Management Partners Ltd Co A Texas limited liability company doing business as SimulQ 39926 Holik Rd, Hempstead, TX 77445 United States Email: support@simulq.ai

For privacy questions, rights requests, complaints, notices, or other privacy-related communications, contact AMPL at the email address or physical address stated above.

AMPL is the data controller, or the equivalent responsible entity under applicable law, for personal information that AMPL collects and determines how to process in connection with the Service, except where a third-party provider independently determines its own processing purposes and means under its own privacy notice.

4. INFORMATION AMPL COLLECTS AND HOW AMPL COLLECTS IT

4.1 Account and Profile Data

When you register for an individual Subscription, AMPL collects your name, email address, account credentials, and age-related information necessary to administer the Service and verify eligibility.

4.2 Payment and Billing Information

AMPL collects billing address, payment-method type, transaction records, subscription status, renewal information, cancellation information, refund information, failed-payment information, and related billing communications. The Service is available at one price: $89.00 per month. No annual Subscription price is offered.

Credit card and other payment-method details are collected and processed directly through Stripe, AMPL's third-party payment processor. These financial transactions are subject to Stripe’s independent privacy practices, available via the Stripe Privacy Policy. AMPL does not store, transmit, or have access to full payment card numbers or security codes (CVV) on its own systems.

No organizational, entity, corporate, group, or multi-seat Subscription is available or permitted.

4.3 User Content

When you submit a query through the Service, your brief is transmitted to AMPL's worker infrastructure and then sent to third-party AI model providers to generate a response. The completed round is stored so that your history, a merged record, and exports can be built from it. The browser call returns before the round finishes; the page polls a job record to retrieve the result. That processing constitutes the session context and the record of the send.

AMPL collects queries, texts, inputs, documents, files, and other content that you submit while using the AI-assisted learning and query platform.

4.4 Feedback Data

AMPL collects suggestions, enhancement requests, bug reports, support communications, and other feedback you voluntarily submit regarding the Service.

4.5 Usage and Technical Data

AMPL collects Internet Protocol (IP) addresses, browser type, device identifiers, operating-system information, pages and features accessed, interactions with the Service, timestamps, session information, error and diagnostic information, authentication events, and other technical or usage data. This information is collected through cookies, server logs, and automated systems.

4.6 AI Interaction and Query Data

To support the operation of AI-assisted features, AMPL processes interaction logs and User Content submitted to AI models. This data is used to generate responses, maintain session context, provide query history, support troubleshooting, prevent abuse, and maintain the integrity and security of the Service. User Content is transmitted directly from our backend worker infrastructure to third-party AI model providers via their secure developer APIs solely to deliver the Service.

Our integrations utilize specific developer API endpoints under commercial terms that strictly prohibit these third-party providers from retaining or utilizing your User Content to train or improve their artificial intelligence models.

4.7 Information Received from Third Parties

AMPL may receive personal information from payment processors, hosting providers, security providers, communications providers, AI model providers, and other Service Providers used to operate the Service.

5. LEGAL BASES FOR PROCESSING

Where applicable law requires a lawful basis for processing, AMPL relies on one or more of the following bases, depending on the data, purpose, and jurisdiction.

• Performance of a Contract: Processing necessary to provide the Service, maintain an account, administer the Subscription at $89.00 per month, process payments, provide customer support, manage cancellations, maintain Service functionality, and perform AMPL's obligations under the Terms and Conditions of Service and applicable payment and subscription documents.
• Consent: Processing for which AMPL obtains prior consent, including marketing consent where required by applicable law. A User may withdraw consent where applicable. Withdrawal does not affect processing that occurred before withdrawal or processing that AMPL may lawfully continue on another basis.
• Legal Obligation: Processing necessary to comply with applicable federal, state, and international laws and regulations, legal process, regulatory requirements, accounting obligations, and record-keeping duties.
• Legitimate Interests: Processing necessary for the security of the Service, fraud prevention, service administration, platform improvement, and the establishment, exercise, or defense of legal claims, where such interests are not overridden by the individual's rights and freedoms.
• Protection of Vital Interests and Safety: Processing necessary to protect users, AMPL, Service Providers, or the public from harm, abuse, fraud, or unlawful activity, where applicable.

6. HOW AMPL USES PERSONAL INFORMATION

AMPL processes personal information for the following purposes.

• Account Management: To create, authenticate, maintain, and secure individual user accounts.
• Service Delivery: To provide, operate, administer, and improve the Service, including executing AI queries, returning outputs, maintaining query history, and delivering related functionality.
• Billing and Subscriptions: To process the $89.00 monthly Subscription through Stripe, manage renewals, administer cancellations, process refunds, address failed payments, and maintain billing and transaction records.
• Communications: To send transactional, security, account-related, billing, technical, and support communications. Marketing communications are sent only where you have opted in or where otherwise permitted by applicable law; you may unsubscribe at any time.
• Platform Improvement and Analytics: To analyze usage patterns, optimize AI algorithms, evaluate User Feedback, implement product upgrades, and conduct related analytics, using de-identified or aggregated data where practicable.
• Security and Fraud Prevention: To detect, prevent, investigate, and respond to fraud, abuse, security incidents, unauthorized access, unlawful conduct, account compromise, and violations of the Terms and Conditions of Service.
• Legal Compliance: To comply with applicable federal, state, and international laws and legal processes, including the TDPSA, consumer protection laws, and financial and accounting obligations.
• Legal Claims: To establish, exercise, or defend legal claims.
• Business Transactions: To evaluate or complete a merger, acquisition, reorganization, financing, bankruptcy proceeding, sale of assets, or similar transaction, subject to applicable notice requirements.

6.1 AI-Specific Processing

AMPL processes User Content to provide requested AI-assisted outputs, maintain the functionality and security of the Service, troubleshoot errors, prevent abuse, support query history and related records, and improve the Service.

AMPL will not use User Content to train AMPL's own AI systems, permit third-party AI model providers to train on User Content for their own general-purpose model development, or otherwise use User Content for model-development purposes, unless AMPL separately discloses that practice and obtains any consent required by applicable law. Whether third-party AI model providers to whom User Content is transmitted train on that content is governed by AMPL's contractual arrangements with those providers. AMPL will negotiate and maintain those contractual arrangements to prohibit use of User Content for third-party model training to the fullest extent otherwise permitted by applicable law.

The phrase "to the fullest extent otherwise permitted by applicable law" means the maximum restriction that AMPL may lawfully impose and enforce under applicable law and its contracts. It does not mean that AMPL may disregard a mandatory legal requirement, court order, regulatory demand, or other legally controlling obligation. It does not guarantee that a provider will be prohibited from retaining or using information where such use is required by law or is expressly permitted by a contract that AMPL has not successfully restricted.

6.2 Account-Level Actions

The account-level actions that affect a user's access to the Service are account approval, suspension, restriction, and termination following a failed or lapsed payment or another basis established in the Terms and Conditions of Service and the applicable subscription and payment documentation. A failed or lapsed payment may result in restricted or suspended access in accordance with those documents.

The Service generates informational and analytical outputs in response to member queries. It does not make decisions producing legal or similarly significant effects concerning any individual.

6.3 Special Categories of Personal Data

AMPL does not seek to collect or process special categories of personal data including health data, biometric data, data concerning racial or ethnic origin, religious beliefs, or sexual orientation as part of its standard Service operations.

Where applicable law requires a general notification ("GN") or written mandate ("WM") before AMPL may process a special category of personal data, AMPL will comply with that requirement. For purposes of this Privacy Policy:

• "General notification" or "GN" means a disclosure or notice to the User that a special category of personal data will be processed, provided in the manner required by applicable law before processing commences.
• "Written mandate" or "WM" means explicit written authorization, consent, or instruction from the User or the User's legally authorized representative, obtained in the form and manner required by applicable law before processing commences.

AMPL will seek a GN or WM only where required by applicable law and only to the minimum extent required by that law. Processing of any special category of personal data not described in this Privacy Policy will not commence without the applicable prior disclosure or authorization.

7. DATA SHARING AND DISCLOSURE

AMPL does not sell personal data. AMPL does not share personal data with third-party advertisers or marketing networks for targeted advertising. AMPL may share personal information in the following circumstances only.

7.1 Service Providers

AMPL may share personal information with trusted Service Providers performing operational services on AMPL's behalf, including providers involved in payment processing; hosting; storage; infrastructure; content delivery; security; fraud prevention; monitoring; customer support; performance measurement; communications; email delivery; identity or eligibility verification; and third-party AI model services necessary to operate the Service. All Service Providers are contractually required to process personal information only as instructed by AMPL and to maintain appropriate confidentiality and security obligations.

7.2 Legal Requirements

AMPL may disclose personal information where required by applicable law, subpoena, court order, regulatory demand, or other valid legal process. AMPL may also disclose personal information where reasonably necessary to establish, exercise, or defend legal claims, to the fullest extent otherwise permitted by applicable law.

7.3 Business Transfers

If AMPL undergoes a merger, acquisition, reorganization, financing, bankruptcy proceeding, or sale of assets, personal information may be transferred as part of the relevant transaction. AMPL will provide notice as required by applicable law and will require, where practicable and appropriate, that a successor entity maintain data-protection standards consistent with this Privacy Policy.

7.4 Safety, Security, and Enforcement

AMPL may disclose personal information where reasonably necessary to detect, prevent, investigate, or respond to fraud, abuse, security incidents, unlawful activity, violations of the Terms and Conditions of Service, or threats to the rights, property, or safety of AMPL, users, Service Providers, or others.

7.5 No Organizational or Entity Accounts

AMPL does not offer organizational, entity, corporate, group, or multi-seat accounts and does not act as a processor for any organizational account under this Privacy Policy.

7.6 Third-Party AI Services and Sub-processors

To provide our AI-assisted features, the Service automatically routes and processes User Content through backend integrations with third-party artificial intelligence infrastructure providers. Users do not have an option to select or choose individual models. The operational and privacy mechanics governing these automated third-party AI sub-processors are as follows:

• What We Share: When you interact with our AI features, the text prompts and files you input are securely transmitted to third-party artificial intelligence infrastructure providers to generate responses.
• No Model Training: We explicitly utilize developer API tiers which guarantee that your data is not used to train or improve future AI models.
• Data Retention: Our API partners temporarily cache or store submission data for a standard window (typically between 0 to 30 days) solely for operational reliability, security monitoring, and anti-abuse enforcement, after which it is permanently deleted.
• Cross-Border Transfers: Because our AI infrastructure partners operate globally, data submitted via these features may be processed on secure servers located outside your home country, primarily in the United States.
• Safety Monitoring and Extended Retention Exception: While standard API inputs are cached temporarily (0–30 days) and never used for training, inputs that trigger third-party safety and anti-abuse filters may be flagged. Flagged content may be exempted from standard deletion timelines and retained by our infrastructure providers for extended periods (up to two years) to ensure platform security and may be subject to human review by those respective providers to investigate policy violations.

8. PAYMENT, SUBSCRIPTION, AND BILLING

The Service is offered only through an individual monthly Subscription priced at $89.00 per month. No annual Subscription price, annual billing option, organizational plan, entity plan, group plan, or multi-seat plan is offered or available.

Stripe processes payment-card and related transaction information on AMPL's behalf. Stripe operates as an independent data controller for certain fraud-prevention and regulatory compliance tasks, and its data processing is governed by the global Stripe Privacy Policy. AMPL does not store full payment card numbers on its own systems.

AMPL collects and retains the following payment and billing information: billing name; billing address; payment-method type; transaction identifiers; subscription status; renewal dates; cancellation dates; refund information; failed-payment information; payment-related communications; and records reasonably necessary to administer the Subscription.

Subscription activation, renewal, cancellation, failed-payment handling, refund procedures, and account access consequences are governed by the Terms and Conditions of Service and the applicable subscription and payment documentation. A failed or lapsed payment may result in suspension or restriction of access in accordance with those documents. Account actions based on payment status are administrative actions taken to administer the Subscription and do not constitute decisions producing legal or similarly significant effects concerning any individual.

AMPL may disclose payment and billing information to Stripe and other operational Service Providers reasonably necessary to process payments, prevent real-time fraud, administer billing, maintain tax records, and resolve transaction disputes. AMPL retains payment, billing, and Subscription records for a period of up to seven (7) years to comply with applicable federal, state, and international tax laws, accounting obligations, financial-reporting rules, and statutory dispute-resolution windows.

9. INTERNATIONAL DATA TRANSFERS

Personal information is processed primarily in the United States, at and through infrastructure associated with AMPL's principal place of business at 39926 Holik Rd, Hempstead, TX 77445, and through AMPL's Service Providers. Our third-party AI model providers and cloud infrastructure hosts maintain secure servers globally, which means personal data may be transferred to, stored, and processed in jurisdictions outside your country of residence (primarily the United States).

If you access the Service from outside the United States, your personal information will be transferred to and processed in the United States or other countries that may not provide the exact same level of data protection as your home jurisdiction.

Where required by local laws (such as the EU/UK GDPR or the Texas Data Privacy and Security Act), we utilize infrastructure partners that maintain compliant cross-border data transfer mechanisms (such as Standard Contractual Clauses under GDPR Article 46(2)(c)), or we utilize regional data residency hosting configurations where available.

Any license or waiver of moral rights concerning User Content or Feedback operates only to the maximum extent permitted under the applicable local law of the User's jurisdiction.

If you have questions about international transfers or the safeguards in place, contact AMPL at support@simulq.ai or by mail at 39926 Holik Rd, Hempstead, TX 77445.

10. DATA RETENTION

AMPL retains personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, maintain active Subscriptions, satisfy legal obligations, resolve disputes, enforce agreements, prevent fraud and abuse, and establish, exercise, or defend legal claims.

10.1 Active Subscriptions

Account infrastructure and personal profile data are retained continuously for the duration of an active Subscription at $89.00 per month.

10.2 Account Termination and Cancellation

Upon account termination or cancellation, AMPL will systematically delete or irreversibly anonymize personal profile information within ninety (90) days, unless a longer retention period is explicitly required by applicable law or necessary to defend legal claims. Once anonymized, data ceases to be personal data under applicable law.

10.3 Payment, Billing, and Subscription Records

Transaction, billing, and accounting records associated with the $89.00 monthly Subscription are retained for a period of seven (7) years from the date of the transaction to comply with applicable IRS guidelines, federal and state tax laws, accounting obligations, and financial-reporting rules.

10.4 User Content and AI Interaction Records

The retention lifecycles for interaction data processed through our infrastructure are configured as follows:

• Worker Records: Operational transient logs and transient polling tasks generated by our worker infrastructure during asynchronous browser queries are deleted within seven (7) days of execution.
• AI-Provider Records: Content transmitted to third-party AI APIs is subject to the data management timelines of those providers, which standardly cache data for up to thirty (30) days strictly for abuse and safety monitoring, as detailed in Section 7.6.
• Query History, Completed Rounds, and Merged Records: To populate your user dashboard, allow review of learning history, and build compilations, text queries and completed interactive rounds are retained for the active life of your individual subscription.
• User Exports: Saved files, reports, or data sets that you explicitly generate and export from the platform are retained on our secure cloud storage servers for ninety (90) days from creation to facilitate active downloading, after which the export cache is purged.

10.5 Ineligible Users

The minimum age for access to and use of the Service is eighteen (18). If AMPL discovers that a person younger than eighteen (18) has accessed or used the Service, AMPL will suspend the account immediately, cease all further collection of personal information from that person, and delete the account and all associated personal information within five (5) business days of discovery unless retention is required by applicable law or reasonably necessary to establish, exercise, or defend a legal claim.

10.6 Definitiveness of Standards

The specific time frames outlined in this Section 10 constitute the exhaustive and complete retention standard for all data categories collected by the Service. No personal information is retained indefinitely unless explicitly mandated by statutory legal frameworks or active regulatory enforcement orders.

11. USER RIGHTS AND HOW TO EXERCISE THEM

Depending on applicable law and your place of residence, including the Texas Data Privacy and Security Act (TDPSA) you may have distinct rights concerning your personal information. These include the right to:

• Confirm whether AMPL processes your personal information and access a copy of that data.
• Request correction of inaccurate personal information.
• Request deletion of personal information obtained about you, subject to legal exceptions.
• Obtain your automated personal data in a portable, readily usable format.
• Opt out of processing for purposes of targeted advertising, the sale of personal data, or profiling that produces legal or similarly significant effects (though AMPL does not engage in these processing types).

11.1 Secure Intake Methods and Identity Verification

In accordance with statutory rules, AMPL provides two secure and reliable methods for submitting privacy rights requests:

1. By sending an email explicitly outlining your request to: support@simulq.ai. 2. By submitting a formal mail request to: Alpin Management Partners Ltd Co,

39926 Holik Rd, Hempstead, TX 77445.

To protect user security, AMPL will subject every request to an identity verification process. AMPL is not required to comply with an unauthenticated request. If you maintain an active account, verification will typically require you to submit the request through your authenticated account email address or confirm specific account transaction metrics that AMPL holds on file. We will never require you to create a new account solely to exercise a privacy right.

11.2 Response Timelines and Extension Disclosures

AMPL will respond to an authenticated consumer request without undue delay, and no later than forty-five (45) days after receipt.

If a request is complex or involves a high volume of operational tasks, AMPL may extend this response window one time by an additional forty-five (45) days. If an extension is required, AMPL will notify you in writing within the initial 45-day window explaining the explicit reason for the delay.

AMPL will fulfil two (2) consumer rights responses per individual free of charge within any twelve-month period. If requests are manifestly unfounded, excessive, or repetitive, AMPL reserves the right to charge a reasonable administrative fee or decline to act.

11.3 Right to Appeal and Regulator Routing

If AMPL declines to take action on your privacy rights request, we will issue a formal written refusal within the initial 45-day response window explaining our legal justification. You have the right to appeal our decision.

To initiate an appeal, you must submit a written request via email to support@simulq.ai within thirty (30) days of receiving our refusal notice, using the subject line "Privacy Request Appeal". AMPL will review the decision and respond to your appeal in writing within sixty (60) days of receipt. If AMPL denies your appeal, we will provide you with the mandatory link and information to access the Texas Attorney General Consumer Complaint Portal so you can submit an official complaint to regulatory authorities.

12. AGE ELIGIBILITY

The Service is available only to individuals who are eighteen (18) years of age or older. The Service is not intended for, and AMPL does not knowingly authorize account access by, any person under eighteen (18).

By creating an account or using the Service, you represent and warrant that you are at least eighteen (18) years old, that the age information you provide is accurate, and that you will not permit another person to use your account.

AMPL may request age-related information reasonably necessary to administer eligibility, security, and account requirements.

If AMPL learns that a person under eighteen (18) has created or used an account, AMPL will suspend or terminate the account and delete associated personal information as described in Section 10.5.

13. COOKIES AND TRACKING TECHNOLOGIES

AMPL uses cookies, server logs, and similar automated technologies exclusively to operate, secure, and analyze the functional performance of the Service. These technologies may collect IP addresses, browser and device information, pages and features accessed, session information, authentication events, and other technical usage data solely to keep your session authenticated and securely route your AI traffic.

To understand how many people visit the website and which pages they view, AMPL uses Vercel Web Analytics, provided by its hosting provider, Vercel Inc. Vercel Web Analytics sets no cookies and stores nothing on your device. Visits are counted in aggregate; visitors are distinguished only by a short-lived hash derived from the request, which is not linked to your identity and is discarded within twenty-four (24) hours.

The platform relies entirely on first-party operational cookies. AMPL does not use third-party advertising cookies, marketing trackers, cookie-based analytics, or targeted-advertising technologies. Your data is never tracked across the web or shared with external analytics brokers.

Your browser or device may provide controls for blocking or deleting cookies. Disabling cookies will break account authentication, security validation, and completely prevent access to the signed-in application features of the Service.

14. SECURITY

AMPL uses administrative, technical, and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, misuse, and destruction, including encryption in transit and access controls.

No method of transmission or storage is completely secure. AMPL cannot guarantee absolute security.

Users are responsible for keeping account credentials confidential, using a secure device and connection, not sharing account credentials, promptly notifying AMPL of suspected unauthorized access, and logging out when using a shared device.

If AMPL identifies a security incident involving personal information, AMPL will respond in accordance with applicable law and its incident-response procedures.

15. CHANGES TO THIS PRIVACY POLICY AMPL

may update this Privacy Policy from time to time to reflect changes in the Service, payment and Subscription arrangements, data practices, legal requirements, security measures, or business operations. When AMPL makes a material change, AMPL will provide notice as required by applicable law. The revised policy will identify its updated effective date. Continued access to or use of the Service after the effective date of a revised policy constitutes acceptance of the revised policy to the extent permitted by law. If you do not agree to a revised policy, you must stop using the Service and may cancel your account in accordance with the Terms and Conditions of Service and applicable payment and subscription documents.

16. CONTACT INFORMATION AND COMPLAINTS

Privacy questions, requests, complaints, and notices should be directed to: Alpin Management Partners Ltd Co Doing business as SimulQ 39926 Holik Rd Hempstead, TX 77445 United States Email: support@simulq.ai

AMPL will review and respond to privacy inquiries within a reasonable period and within any period required by applicable law. If you believe AMPL has violated applicable privacy law, you may also have the right to contact the relevant governmental or regulatory authority in the jurisdiction where you live, work, or believe the alleged violation occurred.