Privacy Policy

Welcome to Atoms. We at MetaGPT LLC (together with our affiliates, "MetaGPT", “Atoms”, "we", or "us") respect your privacy and are strongly committed to keeping secure any information we obtain from you or about you. This Privacy Policy describes our practices with respect to Personal Data that we collect from or about you when you use our website, applications, and services (collectively, "Services").

Consent to this Privacy Policy

By accessing the platform or furnishing information to us, you acknowledge that you have thoroughly reviewed and agreed to this Policy. If any aspect of this Policy is not acceptable to you, we kindly ask that you cease using our Services. Your ongoing engagement with our platform indicates your consent to this Policy, subject to any exceptions outlined by applicable local laws.

1. Information Atoms Collects

We collect and store information you voluntarily provide while using our Services, along with data gathered via automated means during your use of features or receipt of services.

1.1 Information Atoms Receives from You

1. Account Data: Includes, without limitation, your username and email address;
2. Payment Information: Covers, but isn't limited to, your credit card information and billing address;
3. Communication Data: We store all content that you post, send, receive, or share via the Atoms services. This includes data you input within the product, along with any files and links you upload;
4. Interaction Data: Information provided during your interactions with us on platforms (e.g., GitHub, Twitter, WeChat) and our website. This includes, but is not restricted to, feedback, surveys, contests, and other related activities;
5. Other Data: Any data not otherwise specified above will be processed and utilized in compliance with this Privacy Policy or the instructions provided at the point of collection.

1.2 Automated Data Collection

While using our Services, we may automatically collect certain data:

1.2.1 Log and Usage Data

When you access our Services, we record the following information:

1. The features you use;
2. The links you click;
3. The type, size, and file name of the attachments you upload;
4. Your interaction behaviors and click patterns regarding the product services.

1.2.2 Device and Connection Data

We collect device-related information when you access our Services, including but not limited to:

1. Device type (e.g., computer, mobile device, or tablet);
2. Connection attributes and configurations;
3. Operating system version;
4. Browser version;
5. Unique device identifier;
6. IP address;
7. Crash records;
8. Other relevant data: during service installation, access, update or use.

1.2.3 Geolocation Data

Based on your device settings, we may collect geolocation data when you access our Site and use our Services. For example, we may use your IP address to estimate your approximate location.

1.2.4 Cookies Information

When you visit Atoms, we may send one or more cookies - a small text file containing a string of alphanumeric characters - to your computer that uniquely identifies your browser. Atoms uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser help file directions. A session cookie is temporary and disappears after you close your browser.

You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of Atoms may not function properly if the ability to accept cookies is disabled.

1.3 Information Obtained from Other Sources

1.3.1 External Data Resources

We may acquire information about you from other users, partners, third-party providers, social media platforms, and public databases. This information may be integrated with what we already possess. Such integration enables us to update records, identify new customers, develop more targeted advertising, and recommend services likely to be of interest to you. You have the right to refuse when asked to provide personal information. However, not providing information necessary for certain services may result in your inability to use the Services or some of their features. Notwithstanding the foregoing, any advertising-related use described in this Section expressly excludes Google Workspace API Data, which is subject to the restrictions set out in Sections 1.3.3 and 1.3.4.

1.3.2 Third-Party Websites

We bear no liability for the data policies, procedures, or content of third parties. We recommend that you review the privacy terms of every website you access.

1.3.3 Google Workspace API Data and Advertising

For purposes of this Privacy Policy, “Google Workspace API Data” means information obtained through Google Workspace APIs, including data from Google Calendar, Google Drive, and Google Sheets, as well as information derived from such data. Notwithstanding any advertising-related uses described elsewhere in this Privacy Policy, Google Workspace API Data is excluded from all advertising-related uses. We do not sell, use, transfer, or otherwise make Google Workspace API Data available for targeted, personalized, interest-based, retargeted, or any other advertising purpose.

1.3.4 Google Workspace API Data and Limited Use

Atoms accesses, uses, stores, and shares Google Workspace API Data only to provide or improve the specific user-facing integration features requested and authorized by the user. For purposes of this Section, “improve” refers solely to improving the functionality, reliability, security, or user experience of those integration features and does not include developing, training, fine-tuning, or improving any artificial intelligence or machine-learning model. Atoms’ use and transfer of information received from Google Workspace APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Atoms does not use Google Workspace API Data, or transfer such data to any third party for the purpose of developing, training, fine-tuning, or improving any artificial intelligence or machine-learning model, including any generalized, non-personalized, personalized, or user-specific model. This restriction applies to raw data and information derived from such data, including aggregated or anonymized information. Google Workspace API Data may be transmitted to or processed by cloud infrastructure providers, technical service providers, or model service providers only to the extent necessary to provide the user-requested features. Processing such data through a pre-existing model solely to generate an output requested by the user constitutes inference and does not constitute model training. Such processing does not authorize any provider to use the data for its own advertising, model training, or other independent or secondary purposes. Where an AI-enabled feature uses a self-hosted or offline model, Google Workspace API Data is processed within an isolated environment controlled by Atoms. Such data is not transmitted through an API to, or made accessible to, the relevant external model provider. Atoms personnel will not access or read Google Workspace API Data except where the user has affirmatively authorized access to specific data for support or troubleshooting, where access is necessary for security, abuse prevention, or compliance with applicable law, or where the data has been aggregated or de-identified and is used for internal operations in accordance with applicable requirements. We retain Google Workspace API Data only for as long as reasonably necessary to provide the relevant user-requested features or comply with applicable law. Any transfer in connection with a merger, acquisition, reorganization, or sale of assets will be subject to any prior user consent required by the Google API Services User Data Policy or applicable law. No general description of data use, sharing, advertising, service improvement, or third-party processing elsewhere in this Privacy Policy or our Terms of Service expands the permitted uses of Google Workspace API Data described in Sections 1.3.3 and 1.3.4.

2. The Way Atoms Uses Information

We process your personal information only when we have a valid legal basis to do so, primarily for the following purposes:

Performance of a Contract: To provide, maintain, operate, and improve our systems, websites, and services .

Legitimate Interests: To secure our services, prevent fraud and abuse, and analyze product usage to improve features and performance.

Consent: Where required by law, to send you product updates or marketing communications based on your explicit consent. You may opt out at any time.

Legal Obligation: To comply with applicable laws, regulations, court orders, or governmental requests.

Your specific data will be used for the following associated purposes:

1. To optimize the user experience, offer personalized recommendations in line with user preferences, conduct marketing activities, and obtain user feedback;
2. To monitor and analyze user interactions with our products to identify usage patterns;
3. To respond to your inquiries and provide technical support;
4. To safeguard the legal rights, interests, and property of us, affiliated entities, you, or other third parties;
5. To investigate and prevent other illegal activities.

Furthermore, we may use the information as described at the time of collection or for other specific purposes upon obtaining your consent.

3. Disclosure of Personal Data

Under certain circumstances, we might disclose your personal information to third parties:

3.1 Vendors and Service Providers

To assist us in meeting business operations needs and to perform certain services and functions, we may disclose Personal Data to vendors and service providers, including providers of hosting services, customer service vendors, cloud services, content delivery services, support and safety monitoring services, email communication software, web analytics services, payment and transaction processors, and other information technology providers. Pursuant to our instructions, these parties will access, process, or store Personal Data only in the course of performing their duties to us.

3.2 Business Transfers

If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a "Transaction"), your Personal Data may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

3.3 Legal Mandates

We may share your Personal Data, including information about your interaction with our Services, with government authorities, industry peers, or other third parties in compliance with the law:

1. If required to do so to comply with a legal obligation, or in the good faith belief that such action is necessary to comply with a legal obligation;
2. To protect and defend our rights or property;
3. If we determine, in our sole discretion, that there is a violation of our terms, policies, or the law;
4. To detect or prevent fraud or other illegal activity;
5. To protect the safety, security, and integrity of our products, employees, users, or the public.

3.4 Affiliates

We may disclose Personal Data to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Atoms. Our affiliates may use this Personal Data in a manner consistent with this Privacy Policy.

4. Storage and Protection of Collected Information

4.1 Data Storage and Transfer

4.1.1 Special Note to International Users

Atoms is hosted in the United States and is intended for and directed to users in the United States. If you are a user accessing Atoms from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from United States laws, please be advised that through your continued use of Atoms, which is governed by U.S. Law, this Privacy Policy, and Atoms' Terms of Service, you are transferring your personal information to the United States and such transfers will be safeguarded by appropriate measures.

4.2 Our Commitment to Data Security

Atoms prioritizes the security of your data. We implement commercially reasonable technical, administrative, and organizational measures designed to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you provide to the Services. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.

4.2 Retention

We will determine the length of time for retaining your Personal Data based on the purpose of processing such data and the requirements of applicable laws. For example, we'll retain your Personal Data for only as long as we need in order to provide our Services to you. In addition, we'll retain for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations.

If you opt to deactivate your account or discontinue using our Services, we will delete or anonymize such data upon fulfillment of the aforementioned requirements. However, if the data cannot be deleted due to certain circumstances (e.g., the information has already been backed up), we will store your personal information by employing appropriate security measures and ensure its isolation from future processing until it can be safely deleted.

5. Your Rights

Depending on where you live, you may have certain statutory rights in relation to your Personal Data. For example, you may have the right to:

1. Access your Personal Data and information relating to how it is processed;
2. Delete your Personal Data from our records;
3. Update or correct your Personal Data;
4. Transfer your Personal Data to a third party (right to data portability);
5. Restrict how we process your Personal Data;
6. Withdraw your consent—where we rely on consent as the legal basis for processing at any time;
7. Object to how we process your Personal Data;
8. Lodge a complaint with your local data protection authority.

You can exercise some of these rights through your Atoms account. If you are unable to exercise your rights through your account, please submit your request through [email protected].

6. Children

Our Services are not directed to, or intended for, children under 13. We do not knowingly collect Personal Data from children under 13. If such information is collected inadvertently, we will promptly delete it. If you have reason to believe that a child under 13 has provided Personal Data to Atoms through the Services, please email us at [email protected]. We will investigate any notification and, if appropriate, delete the Personal Data from our systems. Users under 18 must have permission from their parents or guardians to use our Services.

7. Changes to the Privacy Policy

This Privacy Policy may be revised periodically, and this will be reflected by the “effective date” below. If such changes have a substantial impact on the manner in which we collect, utilize, or disclose your personal information and affect your rights under this policy, we will provide a more prominent means of notification. Unless otherwise mandated by applicable local laws, your continued use of Atoms constitutes your agreement to this Privacy Policy and any future revisions.

8. How to Contact us

If you have any questions about this Privacy Policy or Atoms, please contact us at [email protected].

MetaGPT LLC is a U.S. incorporated company with its principal place of business at Ste R 8 The Green Dover, Delaware, USA (document number 7606285).

Effective Date: 07/09/2026