Updated: June 6, 2024

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

Sunlit Software Inc. dba Mancer AI (“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”) that use our platform located at including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Platform”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Platform, about the types of information that Company may gather about or collect from you in connection with your use of the Platform. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Platform, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Platform you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Platform.

Our Platform is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Platform from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Platform, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Platform and your agreements with us. Any persons accessing our Platform from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure different from those of the jurisdictions mentioned above may only use the Platform in a manner lawful in their jurisdiction. If your use of our Platform would be unlawful in your jurisdiction, please do not use the Platform.

We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union.



It would be helpful to start by explaining some key terms used in this policy:

Terms Definitions
Company, We, us, our Sunlit Software Inc. dba Mancer AI
Privacy Officer Privacy Officer –
Personal information / Personally Identifying Information Any information relating to an identified or identifiable individual.
Special category personal information Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.
Sensitive Personal Information Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status.
Biometric Information An individual's physiological, biological, or behavioral characteristics, including information pertaining to an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

2. Personal Information We Collect About You

We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) Email address, Internet Protocol addresses used to connect to the service.
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account None (all payment processing is third-party)
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) Records of Company-specific account creation, purchases, and service usage (excluding usage contents)
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) Minimal analytics constrained to the domain.

If you do not provide personal information required to provide our services to you, it may delay or prevent us from providing our services to you.

3. How Your Personal Information is Collected

We collect personal information from the following categories of sources:

4. How and Why We Use Your Personal Information

Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for Our reasons
To provide and maintain our Services For the performance of our contract with you, such as processing a user’s prompts to provide a response or to take steps at your request before entering into a contract.
To detect and prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our systems and Services For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you. Where necessary to comply with a legal obligation. Where we are not under a specific legal obligation, where necessary for our legitimate interests and those of third parties, including protecting our Services from abuse, fraud, or security risks, such as processing data from security partners to protect against fraud, abuse and security threats to our services.
Conducting checks to identify our customers and verify their identity.
Screening for financial and other sanctions or embargoes.
Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator.
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information.
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to [our financial performance, customer base, product range or other efficiency measures] For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
Updating and enhancing customer records For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services [and those of selected third parties] to:
  • Existing and former customers
  • Third parties who have previously expressed an interest in our services
  • Third parties with whom we have had no previous dealings
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations

5. EEA Data Subjects: Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone, or mail) about our products or services including exclusive offers, promotions or new products or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving promotional communications at any time by:

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With

We may routinely share personal information with:

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7. Personal Information We Sold or Shared

In the preceding 12 months, we have sold or shared the following categories of personal information:

8. Categories of Personal Information We Disclosed for a Business Purpose

In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

9. How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

The retention periods are different depending on different criteria, such as the type of information and the purposes for which we use the information.

If you violate the Terms of Use or other conditions or policies, we may remove your profile immediately, but may keep other information about you to process the violation.

If you have questions about our data retention policies, please contact us as noted below.

10. California Privacy Rights under California Civil Code Section 1798.83

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclose to third parties for marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer using contact information on our Platform.

11. EEA Data Subjects: Your Rights Under the EU GDPR

Right to Be Informed The right to know or be notified about the collection and use of your personal information.
Right to Access The right to be provided with a copy of your personal information (the right of access)
Right to Rectification The right to require us to correct any mistakes in your personal information
Right to be Forgotten The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object

The right to object:
  • At any time to your personal information being processed for direct marketing (including profiling)
  • In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests
Right Not to be Subject to Automated Individual Decision-Making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.

12. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, you can email us at

If you choose to contact us directly by email, you will need to provide us with:

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

13. EEA Data Subjects: Where Your Personal Information is Held

Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”

14. Keeping Your Personal Information Secure

We take security of your Personally-Identifying Information seriously and use reasonable electronic, administrative, and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures.

We are dedicated to protecting all information on our Platform as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your credentials confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit Get Safe Online is supported by HM Government and leading businesses.

15. EEA Data Subjects: How to File a GDPR Complaint

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

16. Changes to This Privacy Notice

Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy.

Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to its Privacy Policy. Company will always post new versions of the Privacy Policy on the Platform. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

17. Children

The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. Any person who provides personal information through the Platform represents to us that he or she is 13 years of age or older. If we learn that personal information has been collected from a user under 13 years of age on or through the Platform, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Platform or has otherwise transferred personal information to the Platform, please contact Company using our contact information on the Platform to have that child’s account terminated and information deleted. Users under 18 must have permission from their part or guardian to use our Services.

18. Do Not Track Policy

Our Platform does not respond to “Do Not Track” signals or mechanisms.

19. How to Contact Us

Please contact us by email if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details

20. Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).