Privacy Policy

Effective Date: August 12, 2026

Conduit Intelligence PBC (“Conduit,” “we,” “us,” or “our”) develops brain-computer interface, artificial intelligence, and human-computer interaction technologies. This Privacy Policy explains how we collect, use, disclose, retain, and protect information when you visit our website, communicate with us, book or attend a study session, use our services, participate in research or data collection activities, or otherwise interact with Conduit.

This Privacy Policy applies to our website, online forms, booking workflows, communications, study participation, research activities, product development activities, and related services. If you participate in a Conduit study, your participation may also be governed by a separate consent form, data authorization, release, or study-specific notice that describes the Study Data collected, the purposes of collection and use, retention, disclosures, and participant choices. If there is a conflict between this Privacy Policy and a signed study consent form about Study Data, the study consent form will control to the extent permitted by law.

Conduit Is Not Providing Medical Care

Conduit is not a health care provider. Our website, studies, products, software, devices, models, and services are not intended to provide medical advice, diagnosis, treatment, monitoring, emergency services, or health care services unless we expressly state otherwise in a separate written agreement or regulatory notice.

Information collected by Conduit is not necessarily protected health information under HIPAA. If HIPAA, clinical trial rules, device regulations, or other health-specific requirements apply to a particular activity, we will provide any additional notices or consents required for that activity.

Information We Collect

We may collect information directly from you, automatically through technology, from study equipment, from service providers, from collaborators, and from other sources.

Contact and Identity Information

We may collect your name, email address, phone number, mailing address, date of birth or age confirmation, government-issued identification information, signature, and other information used to identify, contact, verify, or communicate with you.

Booking, Scheduling, and Communications Information

We may collect information related to appointment requests, bookings, study screening, session scheduling, confirmations, reminders, intake forms, support requests, emails, SMS messages, phone calls, and other communications with us.

Study and Research Data

If you participate in a Conduit study, pilot, test, evaluation, interview, research session, or data collection activity, we may collect data associated with your participation as described in the applicable study materials, including:

• Neural signals, nervous-system activity data, and related measurements;
• Biometric, physiological, behavioral, and sensor data;
• Headset movement, head position, movement patterns, calibration data, and device data;
• Voice, audio recordings, vocal inputs, speech-to-text outputs, and transcriptions;
• Video recordings, images, and footage of you during a study session;
• Keystrokes, typed text, commands, screen recordings, screenshots, mouse movements, cursor activity, click activity, application usage, task performance, and timing data;
• Study metadata, timestamps, session identifiers, device identifiers, quality-control data, annotations, labels, derived features, embeddings, transformations, model inputs, model outputs, and related analytical data;
• Optional personal information that you choose to provide during study tasks; and
• Other information described in the applicable study consent form.

We refer to this information as “Study Data.” Unless expressly requested in study materials, you should not provide employer confidential information, third-party personal information, passwords, financial account data, medical records, or other non-requested sensitive content during a study session or through study-related tools.

Sensitive Information

Some information we collect may be sensitive, including neural data, biometric information, voice recordings, video recordings, government identification information, precise location information, information that may reveal health-related characteristics, and optional personal information you choose to provide. We collect and use sensitive Study Data as described in the applicable participant consent and data authorization form, or study-specific notice.

Neural, biometric, voice, video, interaction, and behavioral data may reveal or permit inferences about identity, physiology, behavior, cognition, preferences, performance, reactions, or interaction patterns.

Website, Device, and Internet Activity Information

When you visit our website or interact with online services, we may collect IP address, device identifiers, browser type, operating system, pages viewed, referring URLs, timestamps, click activity, form interactions, approximate location, cookie identifiers, analytics data, and other internet or electronic network activity information.

Cookies, Analytics, and Similar Technologies

We may use cookies, pixels, tags, SDKs, local storage, analytics tools, and similar technologies to operate our website, measure usage, understand traffic, improve performance, remember preferences, prevent fraud, debug errors, and support security.

If we use third-party analytics, advertising, session replay, chat, search, or similar tools, those tools may collect information about your interaction with our website. We will configure these technologies to match our disclosures and consent flows.

Payment and Tax Information

If we pay you a participant honorarium or other amount, we may collect information needed to process payment and satisfy tax, accounting, fraud-prevention, and compliance obligations. Payment processors may collect additional information under their own privacy terms.

Applicant, Contractor, and Business Contact Information

If you apply for a job, provide services to Conduit, communicate with us in a professional capacity, or interact with us as a vendor, investor, collaborator, partner, advisor, or business contact, we may collect information relevant to that relationship.

Inferences and Derived Information

We may create inferences, analytics, derived data, scores, classifications, annotations, labels, features, embeddings, model inputs, model outputs, and other information derived from the information we collect.

Sources of Information

We may collect information from:

• You;
• Your devices and browsers;
• Study equipment, software, and sensors;
• Booking and scheduling providers;
• Communications providers;
• Payment processors;
• Analytics and security providers;
• Research collaborators and service providers;
• Vendors, contractors, and business partners;
• Publicly available sources; and
• Other sources with your consent or as permitted by law.

How We Use Information

We may use information for the purposes described below.

Providing and Operating Services

We use information to operate our website, respond to inquiries, manage bookings, provide confirmations and reminders, administer study sessions, verify identity, provide support, and manage our relationships with participants, users, vendors, collaborators, and business contacts.

Research and Development

We use information, including Study Data, to conduct research and development; build, train, test, validate, improve, and evaluate artificial intelligence systems, BCI systems, algorithms, software, models, devices, datasets, and related technologies; assess feasibility, accuracy, reliability, safety, usability, and performance; and create derived data, labels, annotations, embeddings, analytics, and technical documentation.

Product Development and Commercialization

We use information to develop, improve, support, commercialize, license, sublicense, and operate Conduit products, services, datasets, models, software, algorithms, interfaces, devices, and technologies, subject to the limitations in this Privacy Policy, the applicable study materials, and any written agreement that applies to the information at issue.

De-Identification and Aggregation

We may de-identify, aggregate, transform, or otherwise process information so that it is not reasonably capable of identifying you. We may use, retain, disclose, license, transfer, commercialize, publish, and otherwise exploit de-identified data, aggregated data, derived data, analytics, model outputs, and related materials for lawful research, development, product, commercial, regulatory, safety, security, and business purposes. We will not attempt to re-identify de-identified information except where permitted by law for validation, security, compliance, or similar purposes, and we will not license or transfer identifiable Study Data except as permitted by applicable consent, law, or written agreement.

Communications

We use information to send appointment confirmations, reminders, administrative messages, service updates, study-related communications, support responses, policy updates, and other communications.

With your consent where required, we may send promotional, recruiting, or product-related communications. You may opt out of marketing emails by using the unsubscribe instructions in the email. You may opt out of SMS messages by replying STOP. For SMS assistance, reply HELP.

Safety, Security, and Fraud Prevention

We use information to protect safety, prevent fraud, verify identity, detect and prevent unauthorized access, debug errors, maintain security, protect Conduit systems, enforce our terms, investigate misconduct, and preserve study integrity.

Legal, Compliance, and Business Operations

We use information to comply with law, regulation, legal process, contractual obligations, tax requirements, accounting requirements, audits, insurance requirements, recordkeeping obligations, corporate governance, dispute resolution, and other business operations.

Transactions

We may use information in connection with an actual or proposed merger, acquisition, financing, investment, reorganization, sale of assets, change of control, bankruptcy, diligence process, or similar transaction.

How We Disclose Information

We may disclose information to the following categories of recipients.

Service Providers and Contractors

We may disclose information to vendors, service providers, contractors, consultants, and other third parties who help us operate our business, including hosting providers, cloud infrastructure providers, analytics providers, security providers, payment processors, communications providers, booking providers, data-processing providers, and professional advisors.

Research Collaborators and Business Partners

We may disclose information, including Study Data where permitted by applicable consent and law, to research collaborators, technology partners, product partners, contractors, advisors, licensees, sublicensees, customers, and other third parties involved in research, development, validation, commercialization, licensing, support, regulatory, or business activities. Where we disclose identifiable Study Data to these recipients, we require appropriate confidentiality, data-use, security, or similar restrictions unless the disclosure is directed by you or otherwise permitted by applicable consent, law, or written agreement.

Legal and Compliance Recipients

We may disclose information to courts, regulators, law enforcement, government agencies, auditors, insurers, lawyers, accountants, banks, and other parties where we believe disclosure is necessary or appropriate for legal, compliance, safety, security, dispute, or enforcement purposes.

Transaction Recipients

We may disclose information to potential or actual acquirers, investors, lenders, financing sources, advisors, successors, or assigns in connection with an actual or proposed merger, acquisition, financing, investment, reorganization, sale of assets, change of control, bankruptcy, diligence process, or similar transaction.

With Your Consent

We may disclose information with your consent or at your direction.

Mobile Information

We do not share, sell, rent, or otherwise disclose mobile phone numbers or SMS opt-in data to third parties or affiliates for their marketing or promotional purposes.

We may disclose mobile phone information to service providers who help us send, receive, manage, or support SMS messages, appointment reminders, study communications, and service-related communications.

Sale, Sharing, and Targeted Advertising

We do not sell mobile phone numbers or SMS opt-in data.

We do not currently sell or share personal information collected through our website for cross-context behavioral advertising. If we begin doing so, we will update this Privacy Policy and provide any required opt-out mechanism.

For Study Data, Conduit may disclose, license, sublicense, transfer, or otherwise make available data, de-identified data, aggregated data, derived data, analytics, models, model outputs, or related materials as described in the applicable study consent form, this Privacy Policy, or another written agreement that applies to the information at issue. To the extent applicable law treats any disclosure of personal information as a “sale” or “sharing,” we will provide rights and choices required by applicable law, subject to legal exceptions, research-related exceptions, consent-based processing, de-identified data treatment, aggregated data treatment, and other applicable limitations. Whether a disclosure is treated as a sale, sharing, targeted advertising, or another regulated disclosure may depend on the type of information, whether it is identifiable, de-identified, aggregated, or derived, the applicable study materials, and the legal rules that apply to the disclosure.

Cookies and Tracking Choices

You can control cookies through your browser settings. Some browsers or devices allow you to block or delete cookies, disable certain tracking technologies, or send privacy preference signals.

If we use a cookie banner, consent management tool, or similar mechanism, your choices will apply as described in that tool. Some technologies are necessary for website functionality, security, fraud prevention, debugging, and service delivery and may not be subject to opt-out.

If your browser sends a legally recognized opt-out preference signal and Conduit is required to honor that signal, we will process it as required by applicable law.

Retention

We retain information for as long as reasonably necessary for the purposes described in this Privacy Policy, the applicable study consent form, or another applicable notice or agreement. We retain identifiable raw Study Data only as long as reasonably necessary for the disclosed study, research, legal, safety, security, audit, regulatory, product, or business purposes.

Retention periods vary depending on the type of information, the purpose of collection, study integrity needs, legal requirements, security needs, backup practices, regulatory obligations, dispute needs, and business requirements.

Study Data may be retained for long periods, including indefinitely, where permitted by the applicable consent and law, particularly where it has been de-identified, aggregated, transformed, incorporated into datasets or models, included in analyses, retained for compliance or audit purposes, or used for research, development, product, commercial, regulatory, safety, or security purposes. Where feasible, Conduit may retain de-identified, aggregated, transformed, derived, or model-incorporated information separately from directly identifying information.

Security

We use administrative, technical, and organizational safeguards designed to protect information from unauthorized access, disclosure, alteration, loss, misuse, and destruction.

No security system is perfect. We cannot guarantee that information will never be accessed, disclosed, altered, lost, or misused.

Children and Minors

Our website and services are not directed to children under 13. We do not knowingly collect personal information from children under 13.

Our research and study sessions are intended for participants who are at least 18 years old unless we provide a separate written process for minors with any required parental or guardian consent.

If you believe a child has provided personal information to us without appropriate consent, contact us at booking@condu.it.

California and Other State Privacy Rights

Depending on where you live and whether a particular privacy law applies to Conduit or to the information at issue, you may have rights to:

• Know or access categories and specific pieces of personal information we maintain about you;
• Receive information about the categories of sources, purposes, and recipients of personal information;
• Request deletion of personal information;
• Request correction of inaccurate personal information;
• Request portability of certain personal information;
• Opt out of certain sales, sharing, targeted advertising, or profiling activities;
• Limit certain uses or disclosures of sensitive personal information;
• Withdraw consent where processing is based on consent and withdrawal is required by applicable law;
• Appeal certain decisions where applicable law requires an appeal process; and
• Be free from unlawful discrimination for exercising privacy rights.

These rights are subject to exceptions and limitations. For example, rights may not apply to de-identified information, aggregated information, information we cannot reasonably associate with you, information retained for legal or security purposes, information incorporated into models or derived datasets in a manner that is not reasonably reversible, information subject to research-related exceptions, or information governed by a separate study consent.

How to Exercise Privacy Rights

To submit a privacy request, contact us at:

booking@condu.it

Please include your name, contact information, the nature of your request, and enough information for us to reasonably verify your identity and locate relevant records.

We may ask you to provide additional information to verify your identity. We may deny or limit a request if we cannot verify your identity, if the request is subject to an exception, or if the request is not required by applicable law.

You may use an authorized agent to submit a request where permitted by law. We may require proof that the agent is authorized to act on your behalf and may require you to verify your identity directly with us.

Access and Deletion Requests for Study Data

If you participated in a Conduit study, access and deletion requests for Study Data may be limited by the applicable study consent form and by law.

We may deny, limit, or delay a request where:

• We cannot reasonably verify your identity;
• The data is not reasonably associated with you in an identifiable form;
• The data has been de-identified or aggregated;
• The data has been transformed, derived, annotated, labeled, or incorporated into datasets or models in a way that is not reasonably reversible;
• Deletion would impair research integrity, study integrity, safety records, security records, audit records, legal records, or regulatory records;
• Retention is reasonably necessary for legal, security, backup, audit, tax, regulatory, dispute, or compliance purposes;
• Retention is necessary to detect, investigate, prevent, or address security incidents, misconduct, fraud, or technical issues;
• Retention is required or permitted by law; or
• Another legal exception applies.

International Users

Conduit is based in the United States. If you access our website, communicate with us, or participate in Conduit activities from outside the United States, your information may be processed in the United States and other jurisdictions where privacy laws may differ from those in your location.

Third-Party Links and Services

Our website and communications may link to third-party websites, platforms, services, or tools. This Privacy Policy does not apply to third-party privacy practices. Review the privacy policies of third parties before providing information to them.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be posted on our website with a new effective date. Changes apply as described in the updated policy and as permitted by law.

Contact Us

If you have questions about this Privacy Policy or want to submit a privacy request, contact us at:

Conduit Intelligence PBC 660 Oak Street San Francisco, CA United States

Email: booking@condu.it