Privacy Policy

Last Updated on July 23rd 2026. Effective Date: July 23, 2026

1. Introduction and Scope

Numly, Inc., a Delaware corporation with its principal place of business at 12400 SE 38th Street, Unit 52690, Bellevue, Washington 98015-5101, USA (“Numly,” “we,” “us,” or “our”), provides a workforce performance development and upskilling platform for organizations and individuals worldwide, combining human coaching methodologies with agentic artificial intelligence coaching, algorithms, and data and analytics to support continuous learning, continuous coaching, and professional development (the “Numly™ Platform”).

The Numly™ Platform includes all current and future editions, modules, and configurations of EngageAI™, together with any other Numly-branded or co-branded product, application, or service that links to or references this Privacy Policy (collectively, the “Services”).

The Services are designed to function as an always-on coaching resource that Users can turn to as part of their everyday work, and we build privacy protections into that experience by design — including access controls, confidentiality safeguards, and data minimization — so Users can engage candidly and securely. This Privacy Policy explains what personal information we collect through the Services and our associated websites, how we use and share that information, the choices available to you, and how we protect your data. This Privacy Policy applies to visitors, registered users, Customers, and Authorized Users of the Services
(each, a “User,” and collectively, “Users,” “you,” or “your”), and it is incorporated into and governed by the Numly Terms and Conditions. If you access the Services through your employer or another organization (a “Customer”), that organization’s own policies may also govern your use, and certain choices regarding your information may need to be
directed to your organization’s Numly administrator rather than to Numly directly.

2. Information We Collect

2.1 Information You Provide

We collect information that you or your organization provide when you create an account, complete a profile, participate in coaching or learning activities, register for an event, contact support, or otherwise interact with the Services. This may include your name, business email address, job title, company affiliation, phone number, profile photograph, and areas of professional interest or development.

2.2 Coaching, Learning, and AI-Interaction Data

Because the Services are built around AI-powered coaching, mentoring, and learning workflows, we collect the content you generate while using them. This includes goals, notes, prompts, messages, feedback submissions, assessment responses, session summaries, and any text, audio, or video that you submit for the purpose of receiving AI-generated or human coaching insights (“Platform Content”). Where a Service feature uses artificial intelligence to analyze Platform Content and generate suggestions, summaries, or recommendations, we refer to the resulting output as “AI-Generated Output.” Section 4 (Artificial Intelligence Features) describes how we handle this category of data in more detail.

2.3 Usage, Device, and Log Data

We automatically collect technical information when you use the Services, including IP address, browser and device type, operating system, referring and exit pages, timestamps, clickstream data, and diagnostic and performance logs. We use this information to operate, secure, and improve the Services.

2.4 Cookies and Similar Technologies

We and our service providers use cookies, pixels, and similar technologies to authenticate sessions, remember preferences, measure engagement, and, where applicable, support advertising. You can manage cookie preferences through your browser settings or, where available, through the cookie preference tool on our websites.

3. How We Use Information

We use the information described above for the following purposes:

• To provide, operate, personalize, and support the Services, including account provisioning, coaching workflows, and AI -Generated Output;
• To communicate with you regarding your account, transactions, security notices, product updates, and, where permitted, marketing communications;
• To monitor, analyze, and improve the performance, reliability, and safety of the Services, including diagnosing technical issues;
• To detect, investigate, and prevent fraud, abuse, security incidents, and violations of the Numly Terms and Conditions;
• To comply with applicable law, respond to lawful requests from public authorities, and enforce our agreements; and
• To evaluate and complete a corporate transaction, such as a merger, financing, reorganization, or sale of assets.

4. Artificial Intelligence Features

The Numly™ Platform, including EngageAI™ , uses agentic artificial intelligence and machine-learning technologies to help generate coaching insights, learning recommendations, and related content. Agentic and generative AI can occasionally produce responses that are incorrect, incomplete, or misleading, so we encourage Users to review and verify AI-Generated Output before relying on it. We are committed to transparency about how these features handle your information, consistent with practices adopted by leading AI providers such as Microsoft, OpenAI, Meta, and Anthropic.

4.1 Use of Platform Content to Provide the Services

We and our AI model and infrastructure providers process Platform Content to generate AI-Generated Output and to deliver the Services you have requested. We limit access to Platform Content to personnel and service providers who need it to operate, secure, or support the Services.

4.2 Model Improvement and Opt-Out

Unless a Customer’s applicable order form or subscription plan states otherwise, Numly does not use a Customer’s Platform Content to train foundation AI models made available to other, unaffiliated organizations. Where Numly or its Customer elects to use de-identified or aggregated Platform Content to improve the Services, Customers and, where applicable, individual Users may object to such use by contacting EngageAI-Support@numly.io. Enterprise Customers may negotiate specific data-use terms in a
separate order form or master agreement, which will control over this Section 4.2 to the extent of any conflict.

4.3 Human Oversight and Limitations of AI-Generated Output

AI-Generated Output is produced using automated, probabilistic technology and is intended to support, not replace, your own professional judgment. AI-Generated Output may be incomplete, inaccurate, or unsuitable for a particular purpose, and it does not constitute medical, psychological, legal, financial, or other professional advice. We encourage Users and Customers to apply independent human review before relying on AI-Generated Output for consequential personnel, business, health, or legal decisions. Additional disclaimers and limitations applicable to AI-Generated Output are set out in the Numly Terms and Conditions.

4.4 Data Minimization in AI Processing

We apply reasonable technical and organizational measures designed to minimize the personal information processed by our AI features to what is reasonably necessary to deliver the requested functionality, and we work with AI infrastructure providers that maintain confidentiality and security commitments consistent with this Privacy Policy.

5. How We Share Information

We do not sell personal information. We may share information as follows:
• With Numly affiliates and subsidiaries for purposes consistent with this Privacy Policy;
• With third-party service providers and subprocessors who perform functions on our behalf, including cloud hosting, AI model inference, analytics, customer support, and payment processing, under contractual confidentiality and data-protection obligations;
• With your Customer organization and its designated administrators, where you access the Services through an employer or other organization;
• With professional advisors, auditors, and regulators as required to comply with law or to protect our legal rights;
• In connection with a merger, acquisition, financing, or sale of some or all of our business or assets; and
• With your consent or at your direction.

6. International Data Transfers

Numly serves a global community of organizations and individual Users. Personal information may be collected, stored, and processed in the United States and in other countries where Numly, its affiliates, or its service providers maintain facilities. Where required by applicable law, we implement appropriate safeguards for cross-border transfers of personal information, such as standard contractual clauses or comparable mechanisms recognized under applicable data protection law.

7. Data Security

Numly maintains a security program that includes administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit, access controls based on the principle of least privilege, network monitoring, and periodic security assessments. No method of transmission or storage is completely secure, and we cannot guarantee absolute security; however, we work continuously to
align our practices with recognized industry standards for privacy and cybersecurity.

8. Data Retention

We retain personal information for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Privacy Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. Data that a Customer enters into the Services is generally retained in accordance with the applicable Customer subscription plan or order form, and is deleted or returned upon termination of that agreement in accordance with its terms.

9. Your Privacy Rights

Depending on your location, you may have rights to access, correct, delete, or receive a copy of your personal information, to object to or restrict certain processing, and to withdraw consent where processing is based on consent. These rights may arise, among other sources, under the EU and UK General Data Protection Regulation, the California Consumer Privacy Act as amended by the California Privacy Rights Act, and comparable data protection laws in other jurisdictions where Numly operates.

To exercise any of these rights, please contact us using the information in Section 14 (Contacting Numly). If you are an individual User accessing the Services through your employer, we may direct your request to your organization’s Numly administrator, who is often best positioned to process it. We will respond to verified requests within the timeframe required by applicable law.

10. Children’s Privacy

The Services are intended for business and professional use by adults and are not directed to children. We do not knowingly collect personal information from individuals under the age of sixteen. If we learn that we have inadvertently collected personal information from a child, we will take reasonable steps to delete it.

11. Third-Party Links and Integrations

The Services may link to, or integrate with, third-party websites, applications, or services that are not owned or controlled by Numly, including single sign-on providers and productivity integrations you choose to connect. This Privacy Policy does not apply to those third-party offerings, and we encourage you to review their privacy policies before providing them with information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Services, or applicable law. We will post the revised policy on this page with an updated “Last Updated” date. For material changes, we will provide additional notice as required by applicable law. Your continued use of the Services after a revised Privacy Policy takes effect constitutes your acceptance of the changes.

13. Numly™ and EngageAI™ Trademarks and Intellectual Property

“Numly™” and “EngageAI™” are trademarks of Numly, Inc. All content, software, and technology made available through the Numly™ Platform, including the underlying artificial intelligence models, algorithms, methodologies, user interfaces, and Documentation, are the intellectual property of Numly or its licensors and are protected under applicable copyright, trademark, trade secret, and other intellectual property laws.

Nothing in this Privacy Policy grants any license or right in Numly’s trademarks, copyrights, or other intellectual property. Additional intellectual property terms applicable to your use of the Services are set out in the Numly Terms and Conditions.

14. Contacting Numly

If you have questions about this Privacy Policy or wish to exercise a privacy right described above, please
contact us with your full name and detailed contact information at:

• Email: EngageAI-Support@numly.io
• Numly, Inc., 12400 SE 38th Street, Unit 52690, Bellevue, WA 98015-5101, USA
• Telephone: +1-425-842-2232

This Privacy Policy, and any dispute arising from it, is governed by the laws of the State of Washington and is subject to the exclusive jurisdiction of the state and federal courts located in King County, Washington, as further described in Section 17 (Governing Law and Dispute Resolution) of the Numly Terms and Conditions.