Privacy Policy

1. Scope, Geography, and Eligibility

1.1 United States Only

The Services are intended solely for use by individuals located in the United States. We do not offer or target the Services to individuals located in the European Union, European Economic Area, or the United Kingdom. If you are located in those regions, you are not authorized to access or use the Services, and you are doing so at your own risk.

1.2 Professional Use Only

The Services are designed exclusively for licensed mental health therapists, mental health professionals, mental health students under appropriate supervision, students in an educational institution pursuing a degree in mental health or a related field, and related professionals using the Services for educational and training purposes.

1.3 No Patient Data / No HIPAA Services

The Services are not intended to process real patient data or Protected Health Information ("PHI") as defined by HIPAA. We are not a HIPAA-covered entity or a Business Associate.

Users are strictly prohibited from submitting PHI or information that identifies or could reasonably identify a real individual or patient. Any such submission is a violation of our Terms and this Privacy Policy.

Any PHI submitted in violation of this policy is handled solely for incident response, compliance, or remediation purposes and is not incorporated into AI training datasets.

Any such handling is discretionary and does not create an obligation for Noesis Dynamics to monitor, proactively detect, or routinely review user-submitted content for PHI.

2. Information We Collect

We collect information that identifies, relates to, or could reasonably be linked to you ("Personal Information"). The categories of Personal Information we collect may include:

2.1 Identifiers

• Name
• Email address
• Username and authentication information

2.2 Professional Information

• License type or professional role
• Area of specialty
• Organizational or institutional affiliation

2.3 Commercial Information

• Billing address
• Subscription status and transaction history
• Payment card information is processed by third-party payment processors; we do not store full credit card numbers.

2.4 Internet or Electronic Activity

• IP address
• Browser type and device information
• Log data and interactions with the Services (e.g., pages viewed, features used, time spent)

2.5 Interaction Data

"Interaction Data" (as defined in our Terms and Conditions) includes data and information generated through a user's interaction with the Services, such as prompts, inputs, responses, annotations, feedback, simulated training scenarios, conversation flows, training exercises, and associated usage, system, and technical metadata generated during AI-based training simulations and other interactions with the Services.

Supervisors may have access to the training data associated with their interns only when a supervisor-intern relationship exists. Noesis Dynamics does not facilitate or establish any supervisor-intern relationship and is not responsible for such relationships.

Access to or use of Interaction Data by any user does not constitute oversight, endorsement, or responsibility by Noesis Dynamics for how such data or any resulting outputs are interpreted or used.

Interaction Data may contain personal information only if a user includes it. Users are instructed and contractually required not to include real patient data, Protected Health Information (PHI), or unnecessary personal details when using the Services.

2.6 Demographic and Statistical Information

We may collect limited demographic attributes such as age range, gender, race, or similar characteristics solely for statistical, research, product improvement, fairness, and bias-evaluation purposes.

This information is collected and analyzed only in de-identified and aggregated form and is not used to identify individual users or linked to user accounts in a way that reasonably identifies a person.

3. How We Use Personal Information

We use Personal Information for the following purposes:

3.1 Providing and Operating the Services

• Creating and managing user accounts
• Delivering training content and simulations
• Processing payments and subscriptions
• Communicating with users about their accounts
• Analyzing interaction patterns to provide users with automated recommendations on clinical communication and style.

3.2 Data Model Training and Improvement

We use Interaction Data to train, tune, evaluate, and improve our AI models, underlying datasets, and machine learning architectures (including the large language models and simulation engines that power our Services). This processing is conducted within a therapist-training context and other associated contexts where emotional modeling, professional communication, and clinical style recommendations are relevant.

Interaction Data used for general model improvement is subject to technical and administrative safeguards intended to remove or obscure direct identifiers and is typically de-identified or aggregated.

We may use aggregated and de-identified demographic and statistical data to understand usage patterns across diverse groups, evaluate model performance across populations, and improve fairness, safety, and effectiveness of the Services.

No de-identification process is risk-free, but we take reasonable steps to reduce the likelihood that individuals can be identified. We do not authorize any attempt to re-identify data that has been de-identified or aggregated for model training purposes.

By accessing or using the Services, you expressly acknowledge and consent to the use of Interaction Data for the purposes described in this section, including training, tuning, evaluation, and improvement of our AI models and Services.

If you do not agree to this use of Interaction Data, you must not access or use the Services.

3.3 Human-in-the-Loop Review (Limited)

In limited circumstances, Interaction Data or account information may be reviewed by authorized personnel for:

• Technical troubleshooting
• Quality assurance
• Cybersecurity evaluation
• User support

Such review does not constitute clinical supervision, therapeutic oversight, or monitoring for real-world patient care. The Services are not designed to detect, assess, or respond to real-world mental health emergencies, self-harm, or threats to others.

Any human review conducted for quality assurance, safety, or support purposes does not create responsibility or liability for Noesis Dynamics with respect to user actions or decisions taken in reliance on the Services or their outputs.

3.4 Security and Integrity

• Detecting and preventing fraud, misuse, or unauthorized access
• Enforcing our Terms and acceptable-use policies

3.5 Legal and Compliance Purposes

• Complying with applicable laws and lawful requests
• Protecting our rights, users, and Services

3.6 Marketing and Promotion

We may use de-identified, aggregated, or anonymized Interaction Data, including excerpts, snippets, or full transcripts of training sessions, for marketing, promotional, illustrative, and educational purposes, including but not limited to case studies, presentations, website content, social media, and advertisements.

All such data will be stripped of direct and indirect identifiers such that it cannot reasonably be used to identify a specific user, or individual.

This allows us to demonstrate the capabilities of our platform to the professional community. Before using any such data, we apply technical and administrative measures to ensure all personal identifiers are removed so that the information can no longer be associated with you.

4. No Patient Data (PHI) Policy

4.1 Strict Prohibition

Users must not input real patient names, records, identify health information, or other PHI into the Services.

4.2 Required Training Content

All training scenarios must be fictionalized or fully de-identified to the greatest extent feasible.

4.3 Handling of Prohibited Data

If PHI or prohibited information is detected, reported, or reasonably suspected:

• We may remove or restrict access to the content
• We may suspend or terminate the associated account
• Such data will not be used for AI model training
• We do not assume responsibility for user violations of this policy.

5. Disclosure of Personal Information

We do not sell or share personal information as those terms are defined under applicable privacy laws.

We may disclose Personal Information to the following categories of recipients:

5.1 Service Providers

Third-party vendors that provide services on our behalf, such as:

• Cloud infrastructure and hosting
• Payment processing
• Customer support and internal analytics used solely to operate and improve the Services

These providers are authorized to use Personal Information only as necessary to perform services for us.

5.2 Legal and Safety Purposes

To comply with applicable law, regulation, legal process, or governmental request, or to protect the rights, safety, and security of Noesis Dynamics, our users, or others.

5.3 Business Transfers

In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to appropriate confidentiality protections.

5.4 Supervisors

Supervisors, as part of their role, may have access to the training data generated by interns using the Services. This access is limited to when a supervisor-intern relationship exists, and both the Supervisor and Intern agree to be bound by these Terms and Privacy Policy regarding the use of such data. Supervisors are prohibited from using this information for any purposes outside of training and supervision. Noesis Dynamics does not establish or facilitate the supervisor-intern relationship.

For clarity, all supervision, feedback, evaluations, and related decisions or actions taken by supervisors or interns, whether within or outside the Services and whether or not based on or influenced by AI‑generated content, are solely the responsibility of the supervisor and intern, and Noesis Dynamics will not be responsible or liable for any such decisions, actions, omissions, or outcomes.

5.5 Research Partners

We may disclose de-identified or aggregated data that does not reasonably identify any individual to university partners, academic institutions, or other third-party researchers. These disclosures are made for the purpose of professional study, peer-reviewed publication, and the advancement of therapist-training standards. We require these partners to agree not to attempt to re-identify any individuals from the data provided.

6. California Privacy Rights (CCPA / CPRA)

If Noesis Dynamics is subject to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA, and together, the "California Privacy Laws"), and you are a California resident, you may have the following rights regarding your Personal Information:

6.1 Your Rights

Subject to applicable law, these rights may include:

• Right to Know: The right to request disclosure of the categories and specific pieces of Personal Information collected about you.
• Right to Delete: The right to request deletion of Personal Information, subject to legal exceptions.
• Right to Correct: The right to request correction of inaccurate Personal Information.
• Right to Opt-Out of Sale or Sharing: Noesis Dynamics does not sell Personal Information and does not engage in cross-context behavioral advertising as those terms are defined under the California Privacy Laws.
• Right to Limit Use of Sensitive Personal Information: We collect limited Sensitive Personal Information (such as race) solely for purposes of analyzing service utilization across professional groups and auditing model fairness, safety, and performance. This information is not used to infer characteristics about you for purposes other than those described in this Privacy Policy. Because our use of Sensitive Personal Information is limited to these internal analytical and quality-improvement purposes, we may not be required to provide a "Limit the Use of My Sensitive Personal Information" option under applicable law.
• Right to Non-Discrimination: We will not discriminate against you for exercising any rights you may have under applicable privacy laws.

6.2 How to Exercise Your Rights

If applicable under the California Privacy Laws, you may submit a request by emailing info@noesisdynamics.com with the subject line "California Privacy Request."

We will verify your identity before fulfilling the request. Authorized agents may submit requests on your behalf where permitted by law. We will respond within 45 days, or as otherwise permitted by law.

7. Data Retention

Account and billing information is retained for as long as your account is active and as required for legal or business purposes.

Interaction Data used for AI training is typically de-identified. Once de-identified, such data may be retained for extended periods, including indefinitely, to support model safety, integrity, and performance.

We periodically review retained data to ensure it remains appropriately protected and necessary. We prohibit any attempt to re-identify data that has been de-identified or aggregated for model training purposes. Training data generated by interns may be accessed and reviewed by their supervisors for the purpose of educational critique. This applies only when a supervisor-intern relationship exists. Such data will be retained as necessary to support the intern's development and training. Supervisors are granted access to this data for the duration of the internship or supervisory relationship and are responsible for maintaining the confidentiality of this data. Noesis Dynamics is not responsible for establishing or managing supervisor-intern relationships.

Additionally, de-identified excerpts used for marketing or promotional materials may be retained and used indefinitely for those specific public-facing purposes.

8. Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect Personal Information, including encryption of data in transit and at rest where appropriate.

However, no system can be guaranteed to be 100% secure, and we cannot ensure or warrant absolute security.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date at the top of this policy and may provide additional notice where appropriate. Continued use of the Services after changes become effective constitutes acceptance of the updated policy.

10. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact:

Noesis Dynamics Inc.

131 Continental Drive, Suite 305, Newark, DE 19713

info@noesisdynamics.com