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TOUCHMARK MARKETPLACE PRIVACY POLICY

Version 2026-08-16

Introduction

Touchmark Technologies, Inc.

Effective as of August 16, 2026.

Touchmark Technologies, Inc. ("Touchmark," "we," "us," or "our") operates an online marketplace (the "Marketplace") on which providers list standardized, prepaid contracts for AI model-inference capacity, and business customers ("Buyers") purchase and use that capacity. Touchmark lists provider offerings, routes and meters Buyer usage traffic to the provider's endpoint, and facilitates payment collection through a third-party payment processor. This Privacy Policy describes how Touchmark processes personal information that we collect through our website, application, application programming interfaces, and other digital properties and activities that link to this Privacy Policy (collectively, the "Service").

Our Service is designed for enterprise customers and their representatives. We do not offer products or services for use by individuals for their personal, family, or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise and not in their individual capacities.

This Privacy Policy does not apply to information we process on behalf of Buyers when providing the Marketplace to them, including the content of prompts, inputs, and outputs that a Buyer routes through the Marketplace to a provider. Our processing of that information is governed by our agreement with the relevant Buyer. If you are an individual whose personal information a Buyer has included in traffic routed through the Marketplace, please direct any privacy request to that Buyer.

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service includes: • Contact data — such as your first and last name, business email address, phone number, employer/company name, and company website. • Account data — the username and password (credentials) you use to establish and access an account on the Service. • Transactional and usage data — the contracts you purchase, the models you use, usage metered in tokens, order records, timestamps, and amounts paid. • Payment data — to purchase capacity, you pay at checkout through our third-party payment processor, which collects payment and settles it to the provider net of Touchmark's fee, and does not take custody of or hold a balance of your funds. We maintain records of your purchases, order history, and amounts paid, along with your contact email and phone number. Your payment card or bank-account details are entered into the processor's secure checkout and are handled by the processor rather than stored by us. • Business verification data — if your business completes verification in order to transact, the information our banking and verification partners require, such as your company's details and registration numbers and, for beneficial owners and control persons, names, dates of birth, addresses, government-issued identification numbers, and identification documents. We store this information encrypted, do not display it back after saving, and share it with those partners to perform the verification. • Communications data — information you provide when you contact us for support or otherwise communicate with us. • Other data — any other information you choose to provide, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. When you access the Service, we and our service providers may automatically log: • Device data — such as your device and browser type, operating system, IP address, and identifiers. • Online activity data — such as pages or screens viewed, access times, and navigation activity on the Service.

Information from third parties. We may receive personal information about you from our payment processor, from providers in connection with delivering capacity you purchase, and from service providers that help us operate the Service. We may also receive personal information in connection with an actual or prospective business transaction (for example, a financing, merger, or sale of assets).

We do not request or intentionally collect special categories of information such as health, biometric, or demographic data.

Tracking & other technologies

Cookies and other technologies. Some of our automatic data collection is facilitated by cookies and similar technologies, which are small data files stored on your device that help operate the Service, remember your preferences and login status, and understand how the Service is used. We also use product analytics services, which collect information such as your email address and your activity on the Service (including on servers in the United States) to help us understand and improve the Service. Most browsers let you remove or reject cookies through your browser settings; if you disable cookies, parts of the Service may not work properly.

Session replay. Our product analytics service includes a session replay feature that records how the Service's interface is used — pages or screens viewed, clicks, scrolling, and the structure of what is displayed. Recordings are masked in your browser before they are sent: text you type and text displayed on the page (including prompts, responses, and API keys) is replaced with placeholders, so replays show interface interactions rather than your content. We use replays to diagnose problems and improve the Service.

Routing, metering, and AI capacity. The Marketplace routes your usage traffic (the requests you send and the responses you receive) to the provider's endpoint and meters that usage. Today, our router passes this traffic through and records only usage metadata (such as token counts, timestamps, model, and technical identifiers) — it does not read, log, or store the content of your prompts or the responses — and providers process that content on a zero-data-retention basis. Any prompt caching occurs on the provider's side. The provider processes the content of routed traffic under its own terms and privacy practices.

When we route your traffic to a provider, limited technical identifiers may accompany that traffic to enable delivery and metering.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. To provide, operate, and secure the Service; create and maintain your account and authenticate users; list provider offerings and enable purchases; route and meter your usage; process payments and maintain your order and transaction records; and provide customer support and respond to your requests.

Service improvement and analytics. To understand how the Service is used, analyze and improve the Service and our business, and develop new features, including through product analytics services.

Communications and marketing. To send you service, administrative, and transactional messages, and to send you product updates and marketing communications, which you can opt out of as described in the "Your choices" section below.

We do not use your personal information for interest-based or targeted advertising, and we do not serve third-party advertising on the Service.

Compliance and protection. To comply with applicable laws, lawful requests, and legal process; protect our, your, or others' rights, privacy, safety, or property; enforce the terms that govern the Service; and prevent, detect, investigate, and deter fraudulent, harmful, unauthorized, or illegal activity.

To create aggregated, de-identified, or anonymized data. We may create aggregated, de-identified, or anonymized data from personal information and use it for our lawful business purposes, such as analyzing and improving the Service. We will maintain such data in de-identified form and will not attempt to re-identify it, and we do not use the content of Buyer traffic to train, fine-tune, or improve AI models.

Further uses. We may use your personal information for other purposes with your consent or as otherwise permitted by applicable law.

Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including to provide the Service, satisfy any legal, accounting, or reporting requirements, resolve disputes, and enforce our agreements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and applicable legal requirements. When we no longer need personal information, we will delete, anonymize, or isolate it from further processing.

How we share your personal information

We may share your personal information with the following categories of recipients (or as otherwise described at the time of collection): • Providers (sellers) — the provider from whom you purchase capacity, as necessary to deliver that capacity, including by routing your usage traffic to the provider's endpoint. Providers process routed traffic under their own terms and privacy practices. • Service providers — third parties that provide services on our behalf or help us operate the Service or our business, such as cloud hosting and infrastructure, information technology, customer support, and product analytics. • Payment processor — payment card and bank-account information you use to pay for capacity is collected and processed by our third-party payment processor, which may use that information in accordance with its own privacy policy. • Professional advisors — lawyers, auditors, bankers, and insurers, in the course of the professional services they render to us. • Authorities and others — law enforcement, government authorities, and private parties where we believe in good faith it is necessary or appropriate for the compliance and protection purposes described above. • Business transferees — parties to an actual or prospective corporate transaction (such as a financing, merger, acquisition, sale of assets, or insolvency) in which personal information is among the assets transferred or evaluated. • Third parties you designate — parties with whom you instruct us or consent to share your personal information.

We do not share your personal information with advertising partners, and we do not make your profile or content available to other users or the public.

Your choices

Access or update your information. You may review and update certain account information by logging into your account.

Opt out of marketing. You may opt out of marketing communications by following the unsubscribe instructions in the message or by contacting us. You may continue to receive service-related and other non-marketing messages.

Cookies. Most browsers let you remove or reject cookies through your browser settings, as described above.

Do Not Track. Some browsers offer a "Do Not Track" signal. We currently do not respond to such signals. To learn more, visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect certain personal information to provide the Service. If you do not provide information we identify as required, we may not be able to provide the Service.

Close your account. You can request to close your account by contacting us.

Other sites and services

The Service may contain links to, or interoperate with, websites and services operated by third parties, including providers and our payment processor. We do not control, and are not responsible for, the privacy practices of those third parties, and we encourage you to review their privacy policies.

Security

We employ technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States, and we and our service providers (including our cloud hosting provider) process personal information in the United States. Your personal information may be transferred to, and processed in, the United States or other locations where privacy laws may not be as protective as those in your jurisdiction.

Children

The Service is a business service and is not directed to, or intended for use by, children. We do not knowingly collect personal information from anyone under 18 years of age. If you believe we have collected personal information from a child in a manner prohibited by law, please contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by updating the date of this Privacy Policy and posting it on the Service or by other appropriate means. Your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgment that the modified Privacy Policy applies to your interactions with the Service.

How to contact us

If you have questions about this Privacy Policy or our privacy practices, or wish to exercise a privacy right, please contact us: • Email: privacy@touchmark.ai • Mail: Touchmark Technologies, Inc., #91446 1111B South Governors Ave, Dover, DE 19904, US • Phone: +1 (947) 777-7239