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PRIVACY POLICY (LLAMITAI / Lendix)

Last updated: October 16, 2026

This Privacy Policy applies to (i) the Lendix mobile application (the "App") published on Google Play and the Apple App Store by LlamitAI LLC (the "Company", "LlamitAI LLC", "we", "us"), and (ii) the website https://llamitai.com/ (the "Site"), as well as related services provided under the LlamitAI brand (collectively, the "Service").

Lendix is a mobile application offered by LlamitAI LLC for credit advisors (the "Advisors"), who use it to manage and support credit applications on behalf of their clients, the prospective borrowers (the "Applicants"). By accessing or using the App, Site, or Service, you (the "User") acknowledge and accept this Privacy Policy.

1. DEFINITIONS

  • Competent Authority: Public authority empowered by law to request information or intervene in personal data processing.
  • Consent: Freely given, specific, informed, and unambiguous indication of the User's wishes by which they agree to the processing of personal data.
  • Cookies: Small files stored on a User's device used for analytics, personalization, and security.
  • Customer: A company or institution (for example, a financial institution or advisory firm) that contracts the Service.
  • Advisor: A credit advisor who uses the App, either independently or on behalf of a Customer.
  • Applicant: An individual whose information is entered or submitted by an Advisor, or by the Applicant themselves, in connection with a credit application or credit advisory process.
  • Financial & Credit Information: Information about an Applicant's income, employment, debts, assets, credit history or score, and credit application status.
  • Customer Content: Documents, scans, photos, files, text, images, metadata, and any other content captured or submitted to the Service by or on behalf of a Customer or User.
  • Personal Data: Any information relating to an identified or identifiable natural person (e.g., full name, ID, email, phone number).
  • Sensitive Data: Personal data that impacts the User's private sphere or is sensitive by nature, which may include identifiers found in documents, identity verification outcomes (if used), and authentication credentials.
  • Technical Data: Device, browser, IP address, OS details, logs, and other telemetry necessary for security and service operation.
  • Camera & Image Data: Photos or scans you provide through the device camera or gallery when a feature of the App requests them, together with related metadata.
  • Geolocation: Information that determines a User's physical location in real time (via GPS or similar technologies).
  • Service Provider: Any person or entity processing data on behalf of the Company (e.g., hosting, infrastructure, analytics, support).
  • Processing: Any operation performed on personal data (collection, storage, use, disclosure, deletion, etc.).

2. GENERAL

By accessing and using the App, Site and/or Service, you confirm your agreement with this Policy and, where required by law, your consent to the processing of your Personal Data by LlamitAI LLC.

Use of the Service may be limited to Users with the legal capacity to contract, or Users authorized by a Customer (e.g., employees or contractors). We may perform identity, access, or security checks and, upon detecting inconsistencies, impersonation, or suspected fraud, may suspend or restrict access as reasonably necessary to protect the Service, Customers, and Users.

Controller / Processor note: When we process Customer Content, we typically do so on behalf of the Customer under the applicable service agreement. In those cases, the Customer may act as the "controller" (or equivalent) and the Company may act as a "processor/service provider" (or equivalent), depending on applicable law and contract terms.

3. PERSONAL DATA WE COLLECT

We may collect Personal Data through:

  • In-app screens (registration, login, settings)
  • Information and files you submit through the App (including photos or documents, if a feature requests them)
  • Forms on the Site (demo requests, contact forms, newsletters)
  • Customer communications (email, messages, meetings, support tickets)
  • Information about Applicants entered or uploaded by Advisors in the course of a credit application
  • Audio recordings of client interviews and the signed consent that precedes them
  • Eligibility checks run by the Advisor against internal lists, sanctions and PEP lists, and credit bureaus
  • Automatic capture via cookies, SDKs, logs, and similar technologies
  • Authorized third parties and public sources (e.g., business contact data)

Depending on your interaction with us, data may include:

A. Identification & Contact Data

Name, email, phone number, job title, company, and related business contact details.

B. Account & Authentication Data

Username, password (stored in hashed form where applicable), SSO identifiers, access tokens, and security/audit log events.

C. Technical & Usage Data

IP address, device identifiers, browser/OS, app version, crash logs, and activity logs (e.g., login timestamps).

D. Applicant & Financial Information (Customer Content)

Advisors may enter or upload information about Applicants, such as identification data, contact details, employment and income information, debts, and Financial & Credit Information. This information is sensitive by nature. The Advisor is responsible for having the legal basis and, where required, the Applicant's consent to provide that information to the Service.

E. Submitted Documents & Files (Customer Content)

If a feature of the App asks you to upload or capture documents or photos (for example, to verify identity or support a request), those files and any outputs derived from them may include Personal Data and may contain sensitive or regulated information (e.g., identification numbers, financial data, or signatures). The App will only access your camera or files after you grant the corresponding permission, and not for background recording.

The categories of Personal Data in Customer Content depend on what the User or Customer chooses to submit.

F. Interview Recordings & Signed Consent

Before recording an interview, the App shows the Applicant a consent statement that is read aloud and signed on screen (or, where the Applicant cannot sign, signed on their behalf with a witness). If the Applicant accepts, the App records the audio of the conversation, which is used to prepare the credit application. If the Applicant declines, the interview is not recorded. The audio is processed by a third-party service provider and deleted within the period stated in the consent shown in the App. Recordings are made on the Advisor's device and may be stored there until the device has a connection and can send them.

G. Eligibility & Credit Bureau Data

With the Applicant's authorization, the Advisor may check the Applicant's national ID number (CI) against internal lists, sanctions and watch lists (such as UIF and UN lists), lists of politically exposed persons (PEP), and credit bureau records (such as INFOCRED). We store the result of each check, including its date and validity, the source of each result, and the record of the Applicant's authorization.

H. Device Security & Biometrics

The App can be unlocked with a PIN or, if you enable it, your device's fingerprint or face recognition. Biometric data is handled by your device's operating system; Lendix does not receive or store your fingerprint or face data. We do not store your PIN in readable form.

I. Location Data (If Enabled)

Real-time or approximate location data only when you enable it or when required for a specific feature (for example, to support security or fraud-prevention checks). You can disable location access at any time in your device settings.

The App works without a connection for many tasks: data you enter is stored on your device and sent when a connection is available. Please keep your device protected with a screen lock. Lendix is intended for professional use by adults. We do not intentionally collect Personal Data from children.

4. HOW WE USE PERSONAL DATA

We process Personal Data for operational, technical, contractual, and legal purposes related to our services, including:

  • Service operation: providing, maintaining, and securing the App, Site, and Service
  • Interview processing: transcribing recorded interviews and suggesting answers for the Advisor to review and confirm or correct
  • Eligibility and compliance checks: running the checks the Advisor requests, with the Applicant's authorization, and keeping a record of them
  • Credit application support: helping Advisors organize, prepare, track, and submit credit applications
  • Service delivery: processing the information and files you submit to provide the features of the App
  • Account management: creating and administering accounts, roles, and permissions
  • Contract performance: delivering the Service (including processing of submitted information and outputs)
  • Support: responding to requests and troubleshooting
  • Communications: operational messages, security alerts, and service notices
  • Marketing (where permitted): feature updates, events, and offers (you may opt out where available)
  • Security & fraud prevention: monitoring suspicious activity and enforcing access controls
  • Analytics: understanding usage trends and improving performance
  • Compliance: meeting legal, regulatory, and contractual obligations

Where feasible, we may use aggregated and/or de-identified data to improve reliability and performance.

5. AUTOMATED PROCESSING AND AI

The Service may use automated tools, including AI-based methods, to analyze submitted information and generate outputs. Any outputs, suggestions, or assessments are intended to support the Advisor and do not constitute a credit decision. Credit approval or denial is made by the lender, not by Lendix, and Customers may configure human review steps depending on their workflow. The AI transcribes interviews and suggests answers by section; the Advisor reviews each suggestion and confirms or corrects it before anything is sent to a credit committee. We do not use Applicant data to train AI models for third parties. We do not make decisions that produce legal or similarly significant effects about you solely through automated processing unless explicitly required by the Customer's configured workflow and permitted by applicable law.

6. DATA SECURITY

We apply technical, administrative, and organizational measures designed to protect Personal Data against unauthorized access, loss, alteration, or disclosure, which may include:

  • Encryption in transit (e.g., TLS) and, where appropriate, encryption at rest
  • Role-based access controls and least-privilege permissions
  • Monitoring and logging of security events
  • Access reviews and environment segregation
  • Incident response and continuity measures

No method of transmission or storage is 100% secure. We are not responsible for breaches resulting from force majeure, external attacks, or third-party failures, provided we have acted with reasonable diligence consistent with industry practices.

7. DATA RETENTION

We retain Personal Data for as long as necessary to fulfill the purposes described in this Policy, including to provide the Service, comply with legal obligations, resolve disputes, and enforce agreements.

Interview audio is deleted within the period stated in the consent shown in the App, after it has been processed. Eligibility check results and the record of the Applicant's authorization are kept for as long as the Customer's agreement and applicable financial and anti-money-laundering rules require.

For Customer Content (including submitted documents and images), retention and deletion are generally governed by the applicable Customer agreement and Customer instructions, subject to legal requirements. You may delete documents you control from within the App where that functionality is available.

8. COOKIES AND SIMILAR TECHNOLOGIES

The Site and/or App may use cookies and similar technologies (including analytics SDKs) to:

  • operate essential features and security controls
  • remember preferences
  • analyze performance and usage
  • help prevent fraud and abuse

You can manage or delete cookies via your browser settings and, where available, in your device/app settings. Disabling cookies may affect certain functionality.

9. SHARING PERSONAL DATA

We may share Personal Data in the following situations:

  • With Service Providers: hosting, infrastructure, analytics, customer support, and security services, under appropriate safeguards
  • With data sources for eligibility checks: when an Advisor runs a check with the Applicant's authorization, the Applicant's CI is sent to the relevant list or credit bureau provider (such as INFOCRED) to obtain the result
  • With AI and transcription providers: interview audio is sent to a third-party provider to be transcribed and analyzed, under contractual confidentiality and security obligations
  • With lenders and financial institutions: when an Advisor submits an Applicant's credit application, we share the relevant information with the lender or institution designated by the Advisor or Customer, which then handles it under its own privacy policy
  • With Customers: if you use the Service as a Customer-authorized User, certain account/activity data may be visible to your organization's administrators consistent with the Customer's policies
  • With Affiliates: subject to protections consistent with this Policy
  • For legal reasons: to comply with law, legal process, or requests from Competent Authorities, or to protect rights, safety, and security
  • Business transfers: in connection with a merger, acquisition, financing, reorganization, or sale of assets (with appropriate confidentiality protections)
  • With your consent: when you instruct us to share data or authorize disclosure

We do not sell Personal Data.

10. YOUR PRIVACY RIGHTS

Depending on your jurisdiction and applicable law, you may have rights to:

  • Access your Personal Data
  • Correct/Rectify inaccurate or incomplete data
  • Delete Personal Data (subject to legal/contractual limitations)
  • Restrict or Object to certain processing
  • Opt out of certain marketing communications (where applicable)
  • Data portability where legally required and technically feasible

To exercise your rights, email contact@llamitai.com with the subject line "Privacy Request". We may request identity verification and will respond within the timeframe required by applicable law.

If you are an Applicant, your Personal Data was likely provided by your credit advisor. You may contact us at the email below, but we may need to coordinate your request with your Advisor, the Customer, or the lender involved.

If you are using the Service through a Customer (your employer/organization), some requests may need to be directed to or coordinated with that Customer, depending on their role and contractual setup.

11. WITHDRAWAL OR LIMITATION OF CONSENT

Where processing is based on consent, you may withdraw or limit your consent by contacting contact@llamitai.com or by disabling the relevant permission (e.g., camera, files, or location) in your device settings. Withdrawal may affect your ability to use certain features.

12. INTERNATIONAL TRANSFERS

Your Personal Data may be processed in countries other than your country of residence (for example, where we or our Service Providers operate). Where required, we implement appropriate safeguards to protect Personal Data consistent with this Policy and applicable law.

13. CONFIDENTIAL INFORMATION

All technical, financial, commercial, strategic, or other non-public information exchanged between the Company and the User/Customer is confidential. You agree not to disclose such information to third parties or use it for purposes other than those contemplated by your relationship with the Company, unless authorized or legally required.

14. CHANGES TO THIS POLICY

We may update this Policy from time to time. Any changes will be effective upon publication on the Site. Continued use of the App, Site, or Service after changes become effective constitutes acceptance of the updated Policy.

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