Privacy Policy

Effective Date: September 1, 2025

1. Introduction

Welcome to Steady. Your privacy is a top priority for us, and we are committed to being transparent about how we collect, use, and protect your information. This Privacy Policy outlines the practices of შპს Steady ("Steady," "we," "us," or "our"), a limited liability company registered in Georgia, concerning the information we collect from you when you use our website, AI-powered learning platform, and all related services (collectively, the "Service").

This policy is designed to help you understand:

• What information we collect and why we collect it.
• How we use that information.
• The choices you have regarding your information.

This Privacy Policy is incorporated into and is subject to our Terms of Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

---

2. Information We Collect

To provide and personalize our Service, we collect information in a few different ways.

2.1. Information You Provide to Us

This is the information you knowingly share with us when you interact with our Service.

• Account Information: When you create an account, we collect your name, email address, and password.
• Onboarding Information: To create your personalized learning path, we collect the information you provide during onboarding, such as your professional background, career goals, time commitments, learning preferences, and domain expertise.
• User Content (Inputs): We collect the content you provide while using the Service. This includes the prompts you write, the questions you ask your AI Mentor, the goals you define, and any other text or files you submit.
• Payment Information: When you subscribe to a paid plan, we require you to provide billing information. This data is collected and processed directly by our secure third-party payment processor. We do not store your full credit card information on our servers.
• Communications: If you contact us directly for support, provide feedback, or participate in a survey, we will collect the information you provide in your communications, such as your name, email address, and the content of your message.

2.2. Information We Collect Automatically

This is the information we collect automatically as you use the Service.

• Usage Data: We collect information about your activity on the Service. This includes the features you use, the lessons you take, your performance on missions, the learning tools you engage with, and your overall progress through your Living Syllabus. This data is used to detect skill gaps and to keep your syllabus adapted to your goals.
• Log and Device Data: Like most online services, we automatically collect log and device information when you access and use our Service. This information may include your IP address, browser type, operating system, device identifiers, the pages you visit, and the dates and times of your visits.
• Cookies and Similar Technologies: We use cookies and similar tracking technologies to operate and provide the Service. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and understand how our Service is being used. You can control the use of cookies at the individual browser level.

3. How We Use Your Information

We use the information we collect for several important purposes, all aimed at providing you with a valuable, personalized, and secure learning experience.

3.1. To Provide and Personalize the Service

We use your information to operate and maintain the core functionalities of the Steady platform. This includes:

• Creating and managing your Account and authenticating your access.
• Generating and maintaining your Living Syllabus, and adapting it based on your goals, background, and performance.
• Powering the Translation Engine, which maps new concepts to your existing expertise.
• Processing your User Content (Inputs) to provide you with tailored AI Output, such as personalized lessons and mission results.
• Tracking your progress through the Four Arcs and displaying it on your dashboard.
• Processing your payments for subscription services.

3.2. To Improve and Develop Our Service

Continuous improvement is at the heart of what we do — but we do not use your personal content to train any AI models.

• How our AI works: Steady uses third-party AI providers, including Anthropic and Google, to process your inputs and generate personalized responses in real time. Your prompts, goals, and career information are sent to these providers solely to generate your immediate response. Neither Steady nor these providers use your personal content to train, fine-tune, or improve any underlying AI model. We use a context management system that supplies each request with only the information needed to answer it.
• To analyze usage patterns: We analyze anonymized, aggregated Usage Data to understand which features and lessons are most effective, identify areas for improvement, and develop new tools and capabilities to support your learning journey. This analysis does not involve training AI models on your personal content.
• To conduct research on learning methodologies and the effectiveness of our platform, using anonymized and aggregated data only.

3.3. To Communicate With You

We use your contact information to communicate with you about your account and the Service.

• Service-Related Communications: To send you important administrative messages, such as updates to our Terms of Service or this Privacy Policy, security alerts, and account notifications.
• Platform Engagement: To provide you with progress updates, streak reminders, and motivational messages to support your learning journey.
• Support and Feedback: To respond to your questions, comments, and requests for customer support.

3.4. For Safety, Security, and Legal Compliance

We use information to protect our platform, our users, and to fulfill our legal obligations.

• To prevent fraud and abuse and to enforce our Terms of Service.
• To ensure the security of our platform and protect against unauthorized access to your account.
• To comply with applicable laws, regulations, legal processes, or governmental requests.

4. How We Share Your Information

We do not sell your personal information. We only share your information with third parties in the specific circumstances described below, which are necessary to operate our platform and provide the Service to you.

4.1. With Service Providers

We work with third-party vendors, consultants, and other service providers who perform services on our behalf. These companies need access to your information to carry out their work for us. They are contractually obligated to safeguard your information and are not permitted to use it for any other purpose. These providers include:

• Cloud Hosting Providers: To host our platform and store your data (Google Cloud Platform).
• Payment Processors: To securely process your subscription payments.
• Analytics Providers: To help us understand how our Service is being used.
• Communication Services: To send you emails and other communications.

4.2. With Third-Party AI Providers

Certain features of the Steady platform rely on integrations with third-party AI services to function — including Anthropic (Claude) and Google (Gemini). When you interact with your AI Mentor or other AI-powered features, your relevant inputs are sent to these providers solely to generate your response. We ensure we have appropriate data processing agreements with these providers, and your data is not used by us or by these providers to train their underlying models.

4.3. For Legal Reasons and to Protect Our Rights

We may disclose your information if we believe in good faith that it is necessary to:

• Comply with a legal obligation, such as a law, regulation, court order, or subpoena.
• Respond to valid requests by public authorities.
• Protect and defend the rights, property, or safety of Steady, our users, or the public.
• Prevent or investigate possible wrongdoing in connection with the Service.
• Enforce our Terms of Service.

4.4. In a Business Transfer

If Steady is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Service of any change in ownership or uses of your personal information.

5. Your Data Rights and Choices

We believe in giving you control over your personal information. Depending on your location, you may have certain rights regarding the personal information we hold about you.

5.1. Your Rights

You may have the right to:

• Access: Request a copy of the personal information we have collected about you.
• Correction (or Rectification): Request that we correct any inaccurate or incomplete personal information we have about you.
• Deletion (or Erasure): Request that we delete your personal information, subject to certain legal exceptions.
• Object to or Restrict Processing: Request that we stop or limit the processing of your personal information in certain circumstances.

5.2. How to Exercise Your Rights

You can exercise your rights in the following ways:

• Account Settings: You can review and update much of your personal information directly within your Account settings page.
• Contacting Us: For requests that cannot be fulfilled through your Account settings, such as account deletion, please contact us at the email address provided in the "Contact Us" section below. We will respond to your request within a reasonable timeframe and in accordance with applicable law. We may need to verify your identity before processing your request.

5.3. Communication Choices

You can opt out of receiving promotional or engagement-related emails from us by clicking the "unsubscribe" link provided in those emails. Please note that you will continue to receive essential transactional and service-related communications, such as updates to our Terms or security notifications, even if you opt out of promotional emails.

6. Data Security and Retention

6.1. Security

We take the security of your data very seriously. We use a combination of technical, administrative, and physical safeguards to protect your information from unauthorized access, use, disclosure, alteration, or destruction. These measures include data encryption, access controls, and secure software development practices.

However, please be aware that no security measures are perfect or impenetrable, and no method of data transmission over the Internet can be guaranteed to be 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

6.2. Retention

We will retain your personal information for as long as your Account is active or as needed to provide you with the Service. We may also retain your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer have a legitimate business need to process your personal information, we will either delete or anonymize it.

7. Children's Privacy

Our Service is intended for working professionals and is not directed at children. We do not knowingly collect personal information from anyone under the age of 16.

If we become aware that we have collected personal information from a child under 16 without appropriate consent, we will take steps to remove that information from our servers. If you believe a child has provided us with personal information, please contact us.

8. International Data Transfers

Steady's infrastructure is hosted on Google Cloud Platform, with primary data processing and storage located in Ireland (European Union). The information we collect is processed in accordance with applicable EU data protection standards.

If you are accessing the Service from outside the European Economic Area, please be aware that your information will be transferred to and stored in our EU-based infrastructure. Where we engage third-party AI service providers located outside the EU (see Section 4.2), we ensure appropriate safeguards, such as standard contractual clauses, are in place to protect your information in accordance with applicable data protection law.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. If we make material changes to this policy, we will notify you by posting the revised policy on this page and updating the "Effective Date" at the top. We may also provide you with notice through other means, such as by sending an email or through an in-app notification.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the Service after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised policy.