Init Intelligence, Inc.

Privacy Policy

Last updated: October 9, 2026

Init, Inc. (“Init,” “we,” “us,” or “our”) respects the privacy of individuals whose personal information we collect, use, disclose, or otherwise process. This privacy policy (“Privacy Policy”) explains our privacy practices in connection with our websites, products, services, applications, communications, and other interactions that link to this Privacy Policy (collectively, the “Services”). As used in this Privacy Policy, “personal information” means any information relating to an identified or identifiable individual and includes any information that constitutes “personally identifiable information,” “personal data,” or “personal information” under applicable privacy or data protection laws or regulations. This Privacy Policy describes the categories and sources of personal information we collect; how and why we use and disclose it; how we protect and retain it; how we address information processed through artificial intelligence systems; the privacy rights and choices that may be available; and how to contact us. Init, Inc. is the controller responsible for the personal information described in this Privacy Policy, except where we process personal information on behalf of our customers as described below. This Privacy Policy does not replace or modify any contractual privacy or security obligations between Init and its customers. Where Init processes personal information solely on behalf of a customer, including where Init acts as a processor or service provider, the customer’s agreement with Init and applicable law govern that processing. Individuals whose information is processed by Init solely on behalf of a customer should direct privacy requests to that customer.

1. Personal Information We Collect

The personal information we collect depends on how an individual interacts with Init and the Services. Where applicable, we indicate whether and why you must provide us with your personal information, as well as the consequences of failing to do so. If you do not provide personal information when requested, you may not be able to benefit from our Services if that information is necessary to provide you with them or if we are legally required to collect it.

A. Identity and Contact Information

This may include:

B. Account and Authentication Information

This may include:

C. Customer and Business Information

This may include:

D. Technical Device and Usage Information

This may include:

We do not intend for users to provide passwords used for unrelated third-party services to Init unless expressly required by an authorized integration.

E. Cookies and Similar Technologies

We may use cookies, pixels, local storage, software development kits, analytics technologies, and similar tools in connection with our website and Services. These technologies may be used to operate and secure the Services, remember preferences, authenticate users, understand use, diagnose technical problems, measure performance, and improve functionality. Where applicable law requires consent for non-essential cookies or similar technologies, we will obtain consent or provide appropriate choices before using those technologies. Additional information may be provided through a separate Cookie Notice or consent-management interface.

F. Communications

We may collect information contained in communications with us, including support tickets, email correspondence, meeting communications, survey responses, feedback, and requests submitted through forms or other channels.

G. Sensitive Personal Information

Depending on the Services provided to a customer, Init may process information considered sensitive or subject to heightened legal protection. Init does not use sensitive personal information for purposes unrelated to providing and supporting the Services other than as instructed by the relevant customer or as required by law.

H. Information Processed Through AI Systems

Depending on the Services and features used, personal information or customer-provided information may be processed through artificial intelligence or machine-learning systems. Our practices concerning AI are further described in Section 9.

2. Sources of Personal Information

We may obtain personal information:

When Init receives personal information from a customer for processing on the customer’s behalf, the customer is responsible for ensuring that it has appropriate authority to provide the information to Init.

3. How We Use Personal Information

Depending on the circumstances and our relationship with the individual or customer, we may process personal information to:

Where Init processes information solely on behalf of a customer, Init processes the information for the purposes specified in its agreement with that customer and applicable customer instructions.

4. Legal Bases for Processing Personal Data

Where the European Economic Area (“EEA”), United Kingdom, or another jurisdiction requiring a legal basis for processing applies, Init relies on one or more appropriate legal bases depending on the processing activity.

Performance of a Contract

We may process personal data when necessary to enter into or perform a contract with you, including to provide requested Services.

Legitimate Interests

We may process personal data where necessary for our or a third party’s legitimate interests, provided those interests are not overridden by applicable privacy rights. Legitimate interests may include operating and improving the Services, securing systems, preventing fraud and misuse, managing customer and business relationships, supporting users, conducting appropriate business analytics, and protecting Init’s legal rights.

Consent

We may rely on consent where required or appropriate. Where processing is based on consent, an individual may withdraw that consent as permitted by applicable law. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

Compliance With Legal Obligations

We may process personal data where necessary to comply with applicable law, regulation, court order, legal process, or regulatory obligation.

5. Special Categories of Personal Data

In providing the Services, Init may process special categories of personal data on behalf of customers, including health-related information or other sensitive personal information contained in customer systems, support requests, or workflows. Such processing is limited to what is necessary to perform customer-authorized activities and is carried out in accordance with the customer's documented instructions and applicable data protection requirements. Where Init acts as a data processor, the customer is responsible for identifying the applicable lawful basis under Article 6 of the GDPR and the specific condition under Article 9(2) that permits the processing of special category data, such as explicit consent under Article 9(2)(a) or processing necessary for obligations under employment law under Article 9(2)(b), where applicable. Init processes such information only in accordance with applicable contractual and legal requirements and implements appropriate technical and organizational safeguards to protect it.

6. How We Disclose Personal Information

A. Service Providers and Subprocessors

We may use third parties to support infrastructure and cloud hosting, security, communications, customer support, analytics, authentication, payment processing, professional services, software and technology services, and other functions necessary to operate our business and provide the Services. These include cloud hosting providers located in the United States, the third-party AI providers described in Section 9, and the analytics and session-recording provider described in Section 16. We require service providers to handle personal information in accordance with applicable contractual and legal requirements.

B. Customer Directed Disclosures

Where Init processes information for a customer, we may disclose or make information available as directed or authorized by that customer.

C. Business Partners and Integrations

When a customer or user elects to connect the Services to a third-party service or integration, information may be exchanged with that third party as necessary to provide the requested integration or functionality. The third party’s own privacy practices may apply to its independent processing.

D. Legal and Regulatory Requirements

We may disclose information where we reasonably believe disclosure is necessary to comply with applicable law or legal process; respond to lawful government or regulator requests; enforce agreements; protect the rights, safety, or property of Init, our customers, users, or others; or investigate or respond to fraud, security incidents, or unlawful activity.

E. Corporate Transactions

Personal information may be disclosed as part of or in preparation for a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, subject to appropriate confidentiality and legal protections.

F. With Consent or Direction

We may disclose personal information where the individual or authorized customer has consented to or directed the disclosure.

7. Data Retention

We retain personal information for no longer than reasonably necessary for the purposes for which it was collected or otherwise processed, subject to contractual requirements, customer instructions, legal and regulatory requirements, security requirements, dispute resolution, legal claims, and applicable retention schedules. Retention periods may vary based on the nature of the information and the context in which it is processed. Where Init processes information on behalf of a customer, retention and deletion may also be governed by the customer agreement. At the end of an applicable retention period, information will be deleted, anonymized, or otherwise handled in accordance with Init’s applicable procedures and legal obligations.

8. Information Security

Init employs administrative, technical, and physical safeguards (including encryption, access controls, and secure server hosting) designed to safeguard the data we maintain. However, because no electronic transmission or storage of data can be entirely secure, we can make no guarantees as to the security or privacy of your data.

9. Artificial Intelligence and Automated Processing

Init recognizes that the use of artificial intelligence and machine-learning technologies can create distinct privacy, security, transparency, and governance considerations. This section describes Init’s practices concerning AI where applicable to the Services.

A. Use of AI

Init may use AI-enabled systems or functionality for purposes such as:

The specific AI functionality used may vary by product or service.

B. Data Processed by AI Systems

Depending on the AI functionality and customer configuration, AI systems may process content that users submit to Init's AI features, tickets and support records, knowledge-base content, and information from systems a customer connects to the Services, such as user, account, access, and device information. AI systems do not receive the passwords or other access credentials for a customer's connected systems. Init applies applicable contractual, privacy, security, and governance requirements to such processing.

C. Third Party AI Providers

Init may use third-party AI providers in connection with certain Services or internal business processes. Where third-party AI providers process personal information or customer information on Init’s behalf, Init evaluates and manages those providers in accordance with applicable vendor-management, privacy, security, and contractual requirements.

D. Use of Customer Data for AI Training

Certain information may be used to train, fine-tune, evaluate, or improve AI functionality as described at the time of collection or use and subject to applicable customer agreements, privacy requirements, and available choices.

E. Automated Decision Making

Init does not use automated processing to make decisions that produce legal or similarly significant effects concerning individuals without meaningful human involvement. Where applicable law requires disclosures, rights, or safeguards concerning automated decision-making or profiling, Init will provide the required information and mechanisms.

G. Human Oversight and AI Concerns

Where appropriate to the nature and potential impact of an AI system, Init uses governance and oversight processes designed to address AI-related risks. Individuals may contact Init using the information below with questions or concerns regarding applicable AI processing.

10. International Data Transfers

Init may process personal information in countries other than the country in which the information was originally collected. If you are located in the EEA or UK, this means your personal information will be transferred to and processed in countries outside the EEA and UK, including the United States, that may not provide the same level of data protection as your home country. Where personal data subject to the GDPR, UK GDPR, or similar transfer restrictions is transferred internationally, Init uses an appropriate lawful transfer mechanism where required. Such mechanisms may include an applicable adequacy decision, Standard Contractual Clauses, the UK International Data Transfer Addendum or other approved UK mechanism, binding contractual protections, or another legally recognized transfer mechanism. Where required, additional safeguards are implemented based on the circumstances of the transfer. Individuals may contact us to request additional information about applicable transfer safeguards.

11. Privacy Rights

Depending on an individual’s location and the circumstances of processing, applicable law may provide rights concerning personal information. These may include the right to:

These rights are subject to exceptions and limitations under applicable law.

Exercising Your Rights

Email: [email protected] We may take reasonable steps to verify a request before acting on it. We will not discriminate against an individual for exercising privacy rights protected by applicable law.

Customer Controlled Information

If Init processes personal information solely on behalf of a customer, Init may refer the request to the relevant customer or instruct the requester to contact that customer directly. Init assists customers with privacy requests as required by applicable contracts and law.

Authorized Agents

Where permitted by law, an authorized agent may submit a request on an individual’s behalf. We may require evidence of the agent’s authority and may independently verify the individual’s identity as permitted by law.

12. Additional Rights for Individuals in the EEA and United Kingdom

For processing subject to the GDPR or UK GDPR, individuals may have rights to access their personal data; correct inaccurate data; erase data under applicable circumstances; restrict or object to processing; obtain data portability; withdraw consent where consent is the basis for processing; and lodge a complaint with a competent supervisory authority. Where Init relies on legitimate interests, you have the right to object to processing. If you object, we will stop that processing unless we have compelling legitimate grounds that override your interests. Information regarding the applicable interests may be requested through the contact information below.

13. Changes in Processing Purpose

If Init intends to process personal information for a materially different purpose from the purpose for which it was collected, we will provide additional information or notice where required by applicable law before undertaking the new processing.

14. Children’s Privacy

The Services are not directed to children under the age of 18. Init does not knowingly collect personal information from children in circumstances prohibited by applicable law. If Init learns that personal information from a child has been collected in violation of applicable law, we will take appropriate steps to address the information.

15. Marketing Communications

Where permitted by law, Init may send marketing or promotional communications. Depending on where you are located, applicable law may require your prior consent before we send you marketing emails. Individuals may unsubscribe from marketing email by following the unsubscribe instructions included in the communication or by contacting us. Unsubscribing does not prevent Init from sending transactional, security, contractual, or other non-marketing communications where appropriate.

16. Do Not Track and Preference Signals

Some web browsers and devices let you send a "Do Not Track" ("DNT") signal, a Global Privacy Control ("GPC") signal, or another preference signal to the websites you visit.

Our public website. Our public website at init.inc does not use cookies, analytics, advertising, or similar tracking technologies. Because our website does not track visitors, there is no tracking for a preference signal to turn off.

The Services. When you use the Services after signing in, we use analytics and session-recording technologies, provided by a service provider, to operate, support, troubleshoot, secure, and improve the Services. The Services do not currently change their operation in response to DNT, GPC, or similar signals.

Your choices. You can block or delete cookies and similar technologies through your browser settings, although some features of the Services may not function properly as a result. You may also contact us at [email protected] with questions about these technologies.

17. Links and Third Party Services

The Services may contain links to or integrations with third-party websites, applications, or services. This Privacy Policy does not govern third parties’ independent privacy practices. We encourage individuals to review the privacy notices of third parties with which they interact.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, processing practices, applicable law, technology, regulatory requirements, or privacy, security, and AI governance programs. When we make changes, we will update the Last Updated date above.

20. Contact Us

Init, Inc.
Attn: Privacy Officer
523 Bryant St, San Francisco, CA 94107
Email: [email protected]

Data Protection Officer

Intiser Parash
[email protected]

EU or UK Representative

Conor McCabe
[email protected]
The Exchange, George's Dock, International Financial Services Centre (IFSC), Dublin 1, D01 W213, Ireland