Privacy Policy

Last updated: September 1, 2025

This privacy notice (“Privacy Notice”) for Licensing, Inc. DBA Reasoner (“Company,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our Services. This Privacy Notice is incorporated into and forms part of Company’s Terms of Use (“Terms”), and incorporates the definitions therein. 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 legal@reasoner.com.

As we release services and features, this Privacy Notice may be updated per the provisions below.

TABLE OF CONTENTS

• 1. INFORMATION WE COLLECT
• 2. PERSONAL DATA
• 3. HOW WE DISCLOSE YOUR PERSONAL DATA
• 4. TRACKING TOOLS AND OPT-OUT
• 5. DATA SECURITY
• 6. DATA RETENTION
• 7. PERSONAL DATA OF CHILDREN
• 8. OTHER STATE LAW PRIVACY RIGHTS
• 9. EUROPEAN UNION, UNITED KINGDOM DATA SUBJECT RIGHTS, AND SWISS DATA SUBJECT RIGHTS
• 10. CONTACT INFORMATION

1. INFORMATION WE COLLECT

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

2. PERSONAL DATA

We process your personal information for a variety of reasons, depending on how you interact with our Services. The categories of Personal Data that we may collect and may have collected over the past 12 months:

Categories of Source of Personal Data. We may collect Personal Data about you from the following categories of sources:

• You
  1. When you provide such information directly to us.
  1.1. When you create an account or use our interactive tools and Services.
  1.2. When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  1.3. When you send us an email or otherwise contact us.
  
  2. When you use the Services and such information is collected automatically.
  2.1. Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
  2.2. If you use a location-enabled browser, we may receive information about your location.
  2.3. If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
  
• Third Parties
  1. Vendors.
  1.1. We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
  1.2. We may use vendors to obtain information to generate leads and create user profiles.
  
  2. Third Party Accounts
  2.1. If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

• Providing, Customizing and Improving the Services
  1. Creating and managing your account or other user profiles.
  2. Processing orders or other transactions; billing.
  3. Providing you with the products, services or information you request.
  4. Meeting or fulfilling the reason you provided the information to us.
  5. Providing support and assistance for the Services.
  6. Improving the Services, including testing, research, internal analytics and product development.
  7. Personalizing the Services, website content and communications based on your preferences.
  8. Doing fraud protection, security and debugging.
  9. Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”).
  
• Marketing the Services
  1. Marketing and selling the Services.
  
• Corresponding with You
  1. Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about the Company or the Services.
  2. Sending emails and other communications according to your preferences or that display content that we think will interest you.
  
• Meeting Legal Requirements and Enforcing Legal Terms
  1. Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  2. Protecting the rights, property or safety of you, the Company or another party.
  3. Enforcing any agreements with you.
  4. Responding to claims that any posting or other content violates third-party rights.
  5. Resolving disputes.
  

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

3. HOW WE DISCLOSE YOUR PERSONAL DATA

We may disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  1. Hosting, technology and communication providers.
  2. Security and fraud prevention consultants.
  3. Support and customer service vendors.
  4. Product fulfillment and delivery providers.
  5. Audio transcription providers and processors.
  6. Payment processors.
  6.1. Our payment processing partner Chargebee, Inc. (“Chargebee”) collects your voluntarily-provided payment card information necessary to process your payment.
  6.2. Please see Chargebee's terms of service and privacy policy for information on its use and storage of your Personal Data.
  
• Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
  1. Companies that track how users found or were referred to the Services.
  2. Companies that track how users interact with the Services.
  
• Parties You Authorize, Access or Authenticate
  1. Organizations through which you access our Services (such as your employer)
  2. Third parties you access through the services.
  3. Social media services.
  4. Other users.
  

Legal Obligations. We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers. All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data. We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

4. TRACKING TOOLS AND OPT-OUT

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings in your browser settings. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://allaboutcookies.org or http://ico.org.uk/for-the-public/online/cookies if you are located in the European Union.

5. DATA SECURITY

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Psychometric analysis data receives additional security protections including encryption at rest, limited access controls, and expedited deletion schedules. Data breaches involving analysis data will result in expedited notification procedures. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

6. DATA RETENTION

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

• We retain your profile information, credentials, and User Data for as long as you have an account with us.
• We retain your payment data for as long as we need to process your purchase or subscription.
• We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
• We retain Aggregated Data in order to improve the Company's products, software and services, including after termination of your account or the Services.

7. PERSONAL DATA OF CHILDREN

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at legal@reasoner.com.

8. OTHER STATE LAW PRIVACY RIGHTS

California Resident Rights. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at legal@reasoner.com.

​Nevada Resident Rights. If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by contacting us at legal@reasoner.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

9. EUROPEAN UNION, UNITED KINGDOWN, AND SWISS DATA SUBJECT RIGHTS

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. The Company will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at legal@reasoner.com.

• Personal Data We Collect. The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
• Personal Data Use and Processing Grounds. The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
• Contractual Necessity:We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
  - Profile or Contact Data
  - Payment Data
  - Professional or Employment-Related Data
  - Photos, Videos and Recording
  - Other Identifying Information that You Voluntarily Choose to Provide
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties: - Profile or Contact Data
  - Payment Data
  - Device/IP Data
  - Web Analytics
  - Professional or Employment-Related Data
  - Photos, Videos and Recording
  - Other Identifying Information that You Voluntarily Choose to Provide
  - We may also de-identify or anonymize Personal Data to further our legitimate interests. Examples of these legitimate interests include (as described in more detail above):
  - Providing, customizing and improving the Services.
  - Marketing the Services.
  - Corresponding with you.
  - Meeting legal requirements and enforcing legal terms.
  - Completing corporate transactions.
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. 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 unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your 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.

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at legal@reasoner.com with the subject line: “GDPR Request: [nature of request]”. Your request must include enough information for us to verify your identity, relationship with the Company, and the nature of your request. In some circumstances, we may not be able to fully comply with your request, such as if we are unable to verify your identity, your request it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. Lastly, please note that where we process your Personal Data as a data processor on behalf of another organization, you may need to submit your request directly to that organization.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please note that due to the nature of our Services, transcripts cannot be modified after creation. However, you can modify summaries of transcripts.
• Erasure: You can delete certain account-related information within your account settings. You can request that we erase other Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about the Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here.

The Services are hosted and operated in the United States (“U.S.”) through the Company and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to the Company in the U.S. and will be hosted on U.S. servers, and you authorize the Company to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.

10. CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

Licensing Inc.
6 Liberty Square
PMB 91559
Boston, MA 02109
United States of America
legal@reasoner.com

We have appointed Euverify Ltd to act as our GDPR Representative in both the EU and the UK under Article 27 of the General Data Protection Regulation (GDPR). If you wish to exercise your rights or have any questions regarding your personal data, you may contact our representatives at:

‍EU Representative
Euverify Ltd
Unit 3D, North Point House
North Point Business Park
New Mallow Road, Cork, T23 AT2P
Ireland
gdpr@euverify.com

‍UK Representative
Euverify Ltd
3rd Floor, 86-90 Paul Street
London, EC2A 4NE
United Kingdom
gdpr@euverify.com

For users of the Unmask site, the following Addendum applies in addition to this Privacy Policy.

Addendum: Privacy Policy for Unmask

Last updated: August 29, 2025

This Addendum supplements the Reasoner Privacy Policy (the "Privacy Policy") and applies specifically to your use of the Unmask site and related content (the "Unmask Services"). If there is any conflict between this Addendum and the Privacy Policy, this Addendum controls with respect to the Unmask Services.

1. Public Figure Data

• Unmask content is derived from publicly available information, including interviews, speeches, and other public communications by public figures.
• This information is processed solely for purposes of commentary, criticism, and analysis, and is not collected from or linked to user accounts.
• Unmask does not seek to process or analyze personal data of private individuals who are not public figures.

2. Sensitive or Explicit Material

• Unmask content may include analysis of sensitive or explicit subject matter appearing in public statements (e.g., addiction, drug use, alleged misconduct).
• Such content is included solely as part of commentary on public statements and is not intended as instruction, medical advice, or endorsement.

3. Automated Processing

All analyses may undergo multi-stage editorial review: (1) Automated content generation, (2) Human editorial review for accuracy and compliance, (3) Legal review for defamation risk, (4) Final publication approval. No content is published without human verification and approval. These analyses do not involve automated decision-making that produces legal effects or similarly significant effects for any individual. Analyses reflect interpretive perspectives only and are not presented as neutral or balanced reporting.

4. Collection of User Data on Unmasked

Viewing content on Unmask does not require you to submit personal data beyond standard website usage data (e.g., cookies, analytics, IP addresses).

Unmask does not collect transcripts, calendar data, or other sensitive personal data from site visitors.

Any cookie or analytics data collected is handled under the Company's Privacy Policy.

5. Attribution of Quotes and Third-Party References

Quotations reproduced on Unmask are included only for purposes of commentary, criticism, and analysis.

The Company makes no representation as to their accuracy or completeness beyond their source.

References to third parties within analysis (including claims made by the subject about others) do not constitute endorsement or adoption by the Company.

6. Series and Episodic Content

Unmask may publish analyses as stand-alone pieces or part of an ongoing series.

Publication of one or more analyses does not imply comprehensive coverage or editorial endorsement of the subject or source.

7. Jurisdiction

Claims arising from or relating to Unmask are subject exclusively to U.S. law and U.S. venue, regardless of the location of access or residence of the user. For users accessing content outside the United States, Company's sole obligation is compliance with U.S. law.

‍

8. Algorithmic Fairness

Our analysis systems undergo bias testing across protected characteristics. Analysis is limited to linguistic and rhetorical patterns only, not personal characteristics protected under civil rights laws. Any identified bias is immediately addressed through system updates.

‍

9. Cognitive Analysis

Cognitive analysis represents computational interpretations only, not biometric identification or personal data storage. All cognitive analysis data constitutes algorithmic interpretations of communication patterns and is not stored as personal identifiers, used only for published commentary, and deleted after publication.

‍

10. Public Figure Notification

Subjects of analysis may request notification of published content by contacting legal@reasoner.com. While no consent is required for analysis of public statements, we provide courtesy notification upon request as a professional courtesy.

Note: This Addendum is intended to supplement, not replace, the existing Privacy Policy. Continued use of Unmask constitutes acceptance of both this Addendum and the Privacy Policy.