TrustArc Terms of Use for Artificial Intelligence Features

These TrustArc Terms of Use for Artificial Intelligence Features (“AI Terms”) are incorporated into and form part of your Agreement with TrustArc (the “Agreement”). Specifically, these AI Terms govern your use of artificial intelligence, machine learning, or similar technologies (“AI-Technologies”) made available within any AI-enabled features for the TrustArc Solutions (“AI-Enabled Features”).

1. PRIVACY AND DATA USE COMMITMENTS.

1.1. User Control and Transparency

(a) Use of any AI-Enabled Features is strictly optional. TrustArc will not process or transmit any of your Customer Data to AI-Technologies unless you use and interact with an AI-Enabled Feature. Prior to AI-Technologies Processing your Customer Data, you will be informed of such use through an appropriate notice.

(b) TrustArc’s authorization to Process remains solely as authorized under the Agreement and you retain full control over your Customer Data. TrustArc will not use your Customer Data for AI model training, model improvement, or any similar purpose beyond the scope of your authorized use of the AI-Enabled Features under the Agreement.

(c) As AI-Enabled Features are optional, you may discontinue use at any time and TrustArc will cease Processing your Customer Data under any unutilized or disabled AI-Enabled Features promptly upon your request.

(d) TrustArc is committed to maintaining transparency about the third-party providers that support its AI-Enabled Features (listed in Table 1 below) and the manner in which Customer Data is processed and protected, in accordance with the terms of our Data Processing Agreement. For the avoidance of doubt, the AI-Technologies utilized through the AI-Enabled Features (i.e., via API calls) are explicitly opted out of large language model (or “LLM”) training. These AI-services are used solely to generate responses for authenticated users within the TrustArc Solutions environment.

1.2. Purpose Limitation and Restrictions

(a) Data submitted via AI-Enabled Features shall be used only for the purposes authorized in the Agreement, including the provision and operation of the Solutions, and shall not be used for any unrelated purpose.

(b) Due to the novel nature of AI-Technologies, while TrustArc takes measures designed to ensure that information is accurate, TrustArc is not responsible for the quality, accuracy, effectiveness, safety, or security of AI-generated output. You must therefore carefully review all AI-generated output before using it (e.g., by consulting an internal or external subject-matter-expert), and we further recommend that you do not input any sensitive or proprietary into the AI-Enabled Features. Additionally, when you utilize the AI-Enabled Features and either input information or utilize the output, you remain responsible for compliance with applicable law.

1.3. Security, Confidentiality, and Accountability

(a) TrustArc maintains comprehensive administrative, technical, and operational measures, as described in TrustArc’s Technical and Organizational Measures (“TOMs”), designed to ensure that it maintains suitable privacy and security controls for all aspects of the Solutions and shall, consistent with the Agreement or Data Processing Agreement, as applicable, promptly notify you of any Security Incident involving AI-related data processing.

2. USE OF AI-ENABLED FEATURES AND DISCLAIMERS.

2.1. Warranty

AI-Enabled Features are provided with the same warranties and exclusions as the Solutions, including but not limited to those specified or excluded (if any) warranties of accuracy, reliability, completeness, or fitness for a particular purpose. You acknowledge that AI-outputs may contain errors or inaccuracies and that you are responsible for reviewing and validating such outputs and not rely upon them for decision-making without human oversight.

2.2. Usage Limits, Suspension, and Changes

(a) TrustArc may enforce reasonable usage limits on AI-Enabled Features (e.g., daily query caps) to ensure stable performance and fair access.

(b) TrustArc may update or modify these AI Terms, or underlying AI provider relationships from time to time. In the event that these AI Terms are modified in a manner that materially and adversely impacts your rights, TrustArc shall provide advance notice of no less than thirty (30) days and an opportunity to object prior to the effective date of such modifications.

3. MISCELLANEOUS.

These AI Terms supplement, and do not replace, the Agreement. In the event of any conflict between these AI Terms and the Agreement, these AI Terms will govern with respect to your use of AI-Enabled Features.

If any provision of these AI Terms is unenforceable, such provision will be severed, and the remaining provisions will remain in full force and effect.

These AI Terms are governed by and construed in accordance with the laws specified in your Agreement.

Notices under these AI Terms may be provided via email or posted on TrustArc’s website, consistent with the notice provisions of your Agreement.

Table 1: AI-Enabled Features

TrustArc Service	AI-Enabled Feature(s)	AI Technologies	Third-Party Provider
NymityAI	AI-Assisted Research Chatbot	Azure AI Platform	Microsoft Corp., and its affiliates
PrivacyCentral	AI Assistant (Nymity AI / Arc) Attestor – Similar control/question lookup Review Page – AI Evidence Reviewer/AI Analyze	Azure AI Platform OpenAI API OpenAI API	Microsoft Corp., and its affiliates OpenAI, L.L.C. and its affiliates OpenAI, L.L.C. and its affiliates
Data Inventory Hub	Bulk AI Record Creation Similarity Search Record auto-fill	OpenAI API OpenAI API OpenAI API	OpenAI, L.L.C. and its affiliates OpenAI, L.L.C. and its affiliates OpenAI, L.L.C. and its affiliates
Trust Center	AI Translations	OpenAI API Gemini API	OpenAI, L.L.C. and its affiliates Google Cloud Platform
Arc	Ask Arc	Anthropic (US) Bedrock (EU)	Anthropic PBC Amazon Inc

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Last Updated: November, 2025