Privacy Policy

Effective Date: May 20, 2026 Last Updated: May 20, 2026

Claxton AI Corporation, a Delaware corporation (the "Company," "Claxton," "we," "us," or "our"), is committed to maintaining robust privacy protections for its users. This Privacy Policy ("Privacy Policy") explains how we collect, use, share, and safeguard information when you access our website, mobile application, and related services.

For purposes of this Privacy Policy, "Site" refers to Claxton's website located at claxton.ai, our iOS mobile application (the "App"), and any other websites, applications, or online services we provide under the Claxton name (collectively, the "Services").

"Service" refers to the AI-powered land deal screening, analysis, and decision-support capabilities Claxton makes available through the Site, including parcel and market analysis, comparable market analysis (CMA), pro forma and scenario analysis, and related tools used by residential land developers, homebuilders, and build-to-rent developers.

The terms "we," "us," and "our" refer to the Company.

"You" refers to you, as a user of our Site or our Service.

By accessing or using our Services, you acknowledge that you have read this Privacy Policy and our Terms of Service (available at claxton.ai/terms). In most cases, your access to Claxton is provisioned by your employer or another organization that has entered into a separate written agreement with us (a "Customer Organization"). Where that is the case, the Customer Organization is the controller of the deal-related and business data you submit to the Services, and our processing of that data is governed by our agreement with the Customer Organization.

I. Information We Collect

We collect both "Personal Information" (information that identifies you or is reasonably linkable to you) and "Non-Personal Information" (information that does not identify you, such as aggregated or de-identified usage data, device and browser characteristics, referring URLs, language and locale, and event counts). Personal Information we collect includes: your name, work email address, employer or organization, role or title, authentication credentials, and (if you choose to provide it) your phone number. When you use our Services, we also process the deal-related inputs you submit on behalf of your Customer Organization, which may include parcel addresses, property characteristics, market data, underwriting assumptions, deal notes, and uploaded documents.

1. Information collected via Technology

To begin using the Service, you provide an email address and authenticate through credentials issued by us or by your Customer Organization (which may use single sign-on). During your use of the Service, we automatically collect limited technical information such as: device type and operating system (including iOS version when you use the App), browser type and version, IP address, time zone, referring URL, the date and time of access, and usage events such as feature interactions and error reports. We collect this information using server logs, cookies, mobile SDKs, and similar technologies. Cookies are small text files placed on your device that allow us to recognize you across sessions, keep you signed in, and remember your preferences. The Company may use cookies, mobile identifiers, and similar technologies to collect the following information:

Authentication state and session identifiers; user preferences and saved views; language and locale; product analytics events such as page views, feature usage, and error or crash reports; and, on the iOS App, device-level identifiers used to deliver push notifications you have opted in to receive.

The Company may use both persistent and session cookies. Persistent cookies remain on your device after you close your session and until they expire or you delete them; session cookies expire when you close your browser. For example, we store a persistent cookie to keep you signed in to your account across browser sessions and to remember your interface preferences. We do not use cookies, mobile identifiers, or similar technologies for cross-context behavioral advertising.

2. Information you provide us by registering for an account

Claxton accounts are typically provisioned to you by your Customer Organization. To activate and use the Service you will register with your work email address and authenticate using credentials issued by us or through your organization's identity provider. By registering, you authorize us to collect, store, and use the account information described above in accordance with this Privacy Policy and our agreement with your Customer Organization.

3. Children's Privacy

The Services are intended exclusively for business use by adult professionals working in residential land development. The Services are not directed to, and we do not knowingly collect Personal Information from, anyone under the age of 18. If you believe we have collected information from a person under 18, please contact us at privacy@claxton.ai and we will promptly delete that information.

Personal Information

We do not sell, trade, rent, or share your Personal Information for cross-context behavioral advertising or for any other monetary or valuable consideration. We share Personal Information only with: (a) your Customer Organization (including its administrators), (b) service providers and subprocessors performing services on our behalf under written contracts that restrict their use of the information to the services they provide to us, and (c) other parties as described elsewhere in this Privacy Policy. We do not use the deal-related or business data submitted to the Services to train general-purpose artificial intelligence or large language models offered to other customers.

Categories of subprocessors. We use a limited number of third-party service providers to operate the Services, including: cloud infrastructure and hosting providers, identity and authentication providers, payments processors, parcel and public-records data providers, demographic data providers, product analytics and error reporting providers, email and notification providers, and customer support providers. A current list of our material subprocessors is available on request to privacy@claxton.ai.

We use Personal Information to: (i) provide and operate the Services, (ii) authenticate users and maintain account security, (iii) respond to questions and provide technical support, (iv) communicate with you about your account, your Customer Organization, and material changes to the Services, (v) improve and develop the Services, (vi) detect, investigate, and prevent fraud, abuse, and security incidents, and (vii) comply with our legal obligations and enforce our agreements.

We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms of Service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.

Non-Personal Information

We use Non-Personal Information to help us operate, secure, and improve the Services, to understand usage patterns, and to produce aggregated or de-identified statistics. We do not sell Non-Personal Information and we do not share Non-Personal Information with advertisers for cross-context behavioral advertising.

In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.

III. How We Protect Information

We maintain administrative, technical, and physical safeguards designed to protect your information from unauthorized access, disclosure, alteration, and destruction. These include encryption of data in transit using industry-standard TLS, encryption of data at rest using AES-256, least-privilege access controls, multi-factor authentication for privileged access, audit logging, vendor security review for our subprocessors, and regular review of our security practices. We will notify affected users and Customer Organizations of any security incident affecting Personal Information without undue delay and in accordance with applicable law. No method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security; by using the Services, you acknowledge these inherent risks.

IIIa. Data Retention and Account Deletion

Retention. We retain Personal Information and deal-related data for as long as your Customer Organization maintains an active account with Claxton, plus any additional period required to comply with our legal obligations, resolve disputes, and enforce our agreements. When a Customer Organization terminates its agreement with us, we will delete or de-identify Personal Information and deal-related data associated with that organization within the timeframe specified in our agreement with that organization (and in any event no later than ninety (90) days after termination), except where a longer retention period is required by law.

Account deletion. Because Claxton accounts are provisioned and controlled by Customer Organizations, individual users do not have a self-service mechanism to delete their account or the deal-related data associated with their account. To request deletion of your account or Personal Information, please contact us at privacy@claxton.ai. We will verify your request, coordinate with the administrator of your Customer Organization where appropriate, and complete the deletion within thirty (30) days of verification, subject to the retention exceptions above. This managed-account deletion process is intended to satisfy applicable app-store account-deletion requirements (including Apple App Store Guideline 5.1.1(v) for accounts that are part of an enterprise or organizational account).

IV. Your Rights Regarding the Use of Your Personal Information

You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions in each promotional email. You can also indicate that you do not wish to receive marketing communications from us in your Account Settings. Please note that, notwithstanding the marketing preferences you indicate, we may continue to send you administrative communications relating to your account or the Services, including periodic updates to this Privacy Policy.

IVa. U.S. State Privacy Rights

This Section IVa describes additional rights that may apply to residents of certain U.S. states, including California (under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA")), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and Texas (TDPSA), among others. Where applicable law gives you greater rights than this Section, applicable law controls.

Categories of Personal Information we collect. In the past 12 months we have collected the following categories of Personal Information, as enumerated by the CCPA: identifiers (name, work email, account identifiers, IP address); customer records information (employer, role); commercial information (account and billing information held by your Customer Organization); internet or other electronic network activity information (browser and device data, usage logs); geolocation data (approximate, derived from IP); professional or employment-related information; and inferences drawn from the above. We do not collect sensitive Personal Information for the purpose of inferring characteristics about you.

Sources, purposes, and recipients. We collect Personal Information directly from you, from your Customer Organization, and automatically as you use the Services. We use Personal Information for the business purposes described in Section II of this Policy. We disclose Personal Information only to the categories of recipients described in Section II.

Your rights. Subject to applicable law and identity verification, you have the right to: (i) know the categories and specific pieces of Personal Information we have collected about you; (ii) request correction of inaccurate Personal Information; (iii) request deletion of your Personal Information; (iv) opt out of the sale or sharing of your Personal Information for cross-context behavioral advertising (we do not engage in either, but you may submit a request); (v) limit the use of sensitive Personal Information; (vi) port your Personal Information; and (vii) not receive discriminatory treatment for exercising any of these rights.

How to exercise your rights. To exercise any of these rights, contact us at privacy@claxton.ai. We will verify your identity using reasonable methods before processing your request. Where your account is provisioned by a Customer Organization, we may coordinate with that organization to process your request. You may also designate an authorized agent to make a request on your behalf in accordance with applicable law. We do not sell Personal Information and we do not share Personal Information for cross-context behavioral advertising, so no separate "Do Not Sell or Share My Personal Information" mechanism is currently necessary; this disclosure is provided pursuant to CCPA/CPRA regardless. California residents may also request information regarding our disclosure of Personal Information to third parties for direct marketing purposes under California Civil Code Section 1798.83 (the "Shine the Light" law); we do not disclose Personal Information for such purposes.

V. Links to Other Websites

As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Service. Therefore, this Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

Va. Apple App Store and iOS Disclosures

App Tracking Transparency. Claxton does not engage in "tracking" as defined by Apple's App Tracking Transparency framework. We do not link data collected from the App with data collected by third-party apps or websites for advertising or advertising-measurement purposes, and we do not share App data with data brokers.

Privacy Nutrition Label categories. The categories of data we collect through the App, as expressed in Apple's App Privacy framework, include: Contact Info (name, work email); Identifiers (user ID, device identifiers); Usage Data (product interactions, error reports); and Diagnostics (crash data). Each category is collected for the purposes described in Section II of this Policy and is linked to your identity in order to provide and secure the Service.

Push notifications. With your consent, we may send push notifications to your device. You may disable push notifications at any time in the iOS Settings app under Notifications, or within the App.

iOS controls. You can review and limit Claxton's access to device-level data (such as Notifications, Cellular Data, and Background App Refresh) at any time in the iOS Settings app.

VI. Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. We will notify you of material changes by sending a notice to the email address associated with your account, by placing a prominent notice on the Site or within the App, or by other reasonable means. Material changes will take effect 30 days after notification; non-material changes or clarifications will take effect upon posting. We encourage you to review this Privacy Policy periodically. Your continued use of the Services after the effective date of an updated Privacy Policy constitutes your acceptance of the updated terms.

VII. Contact Us

If you have any questions or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Claxton AI Corporation Attn: Privacy Email: privacy@claxton.ai Mailing address: 285 W Wieuca Rd NE STE 63830 Atlanta, GA 30342