1. Introduction

This Privacy Policy explains what data the Action Model browser extension and related services collect, why that data is collected, and the terms on which you provide it.

The Action Model browser extension exists for a single purpose: to allow you to contribute anonymised browser interaction data for the training of artificial intelligence models, and to be rewarded for doing so.

Installing and using the extension is entirely voluntary. It is a deliberate choice made by you, for the purpose of earning rewards. You may stop at any time, and you may uninstall the extension at any time.

By installing or using the extension, you confirm that you have read, understood and accepted this Privacy Policy.

2. Who We Are

The Services are operated by ActionModel Ltd, a company registered in the British Virgin Islands (Company Number 2195097) (“Action Model”, “we”, “us”, “our”). ActionModel Ltd is the entity responsible for the data described in this Policy.

Action Model is building a community-owned Large Action Model (LAM), an artificial intelligence trained on real patterns of human interaction with websites, so that it can perform useful tasks on behalf of its users.

Contact: privacy@actionmodel.com

3. The Nature of Your Participation

This section describes the basis of the relationship between you and Action Model, and it is important that you read it.

You are contributing data in exchange for reward. When you use the extension, you are choosing to supply browser interaction data to Action Model. In return, Action Model credits you with Points, and, following any future token generation event, may allocate $LAM tokens on the basis of those Points. This is a voluntary exchange: you provide contributions, and we provide reward.

The exchange is the reason the data is collected. Data is not gathered incidentally, passively, or for any purpose unrelated to your participation. It is gathered because you have chosen to contribute it and to be rewarded for it, and it is used to train the models described in this Policy.

Your contributions become part of the training corpus. Once a contribution has been made and credited, it is incorporated into datasets and into models derived from those datasets. You grant Action Model a worldwide, perpetual, irrevocable, transferable, sub-licensable and royalty-free right to retain, process, reproduce, adapt and otherwise use your contributions, and any models, datasets, derivatives or outputs created from them, for any purpose connected with the development, improvement, operation, licensing or commercialisation of artificial intelligence models and related products and services.

Contributions cannot be recalled. Because contributions are anonymised, aggregated and incorporated into training data and trained models, individual contributions cannot afterwards be isolated, separated, extracted, reversed or removed from that data or from any model already trained. Reward has been given in exchange for the contribution, and the contribution is not returnable. You should treat every contribution as final at the moment it is made. If you do not wish to make further contributions, you may pause or stop training, or uninstall the extension, at any time.

Nothing obliges you to participate. If at any point you are not comfortable with the terms of this Policy, the correct course is to stop using the extension.

4. What the Extension Collects

During an active training session, the extension collects a structured record of how a page is interacted with. This consists of:

• Interface element data: the technical identifiers of the elements you interact with, such as element type, tag, class, identifier and position within the page structure

• Interaction events: clicks, selections, scrolling, keyboard events, and the sequence and timing of those events

• Navigation data: the addresses of pages visited during a session and the route taken through a site

• Page structure: the arrangement of the page and the state of its interface at the point of interaction

• Technical context: extension version, browser type and version, and operating system type

The purpose of this data is to allow a model to learn the shape of a task, that is, which elements a person interacts with, in what order, to achieve an outcome.

What the Extension Is Designed Not to Collect

The extension is designed to identify and exclude fields and content likely to be sensitive. In particular, it is designed not to collect:

• Values entered into password or credential fields

• Values entered into payment card, banking or financial fields

• Values entered into fields identified as carrying personal identifiers

• The content of private messages or personal correspondence

• Cookies from the websites you visit, other than those needed to keep you signed in to Action Model

Where such fields are detected, the extension records that a field of that type exists and was interacted with, and does not record what was entered into it.

5. Local Filtering and Anonymisation

Action Model has designed the extension so that filtering happens on your own device, before anything is transmitted to us.

The extension applies automated classification techniques locally to identify content that appears to be sensitive or personally identifying, and to remove, mask or replace that content before any data leaves your computer. These techniques are applied in both Background mode and ActionFi (Custom) mode.

The intention behind this design is that what reaches Action Model is a structural and behavioural record of interaction, not a record of personal information.

Important: these techniques are automated and operate on a best-efforts basis. Automated classification is not, and cannot be, perfect. Action Model does not warrant, represent or guarantee that every item of sensitive or personal content will be identified and removed in every case, and you should not use the extension on the basis that such a guarantee has been given. You remain responsible for the pages on which you choose to train, and you should not conduct training on any page displaying information you would not wish to contribute. See Section 10.

No re-identification. Action Model does not seek to identify any individual from contributed training data, does not attempt to reconstruct removed content, and does not attempt to link training contributions back to any individual person. Our objective is to hold the data in a form that is as anonymised as we can reasonably make it.

6. Training Modes, Control and the Block List

You control when and where the extension operates.

ActionFi (Custom) mode operates on a per-session basis. Training runs only for the session you have started, and only for as long as you allow it to run.

Background mode operates while you have chosen to enable it. It can be paused or switched off at any time from the extension or from your dashboard, and no collection occurs while it is off.

The block list applies to Background mode. Action Model maintains a default block list of categories where training does not take place, including online banking and financial services, healthcare, webmail and messaging, and similar categories. You may add any website you wish to that list, at any time, and you may add as many as you wish. The block list is managed at https://train.actionmodel.com/websites.

You may review and manage your training activity at https://train.actionmodel.com/training-history.

The default block list is provided as a convenience and as a sensible starting point. It is not represented as exhaustive, and it remains your responsibility to add any further sites you do not wish to train on.

7. Rewards, Scoring and Integrity

Points are credited for contributions in accordance with the reward rules in force from time to time.

Scoring is automated. The assessment of contributions, including their volume, quality, validity and eligibility for reward, is performed automatically by our systems. Action Model does not operate a manual review or appeal process in respect of scoring outcomes, and scoring determinations are final.

Integrity and clawback. Action Model may withhold, reduce, suspend, reverse or cancel Points and any associated entitlement where it determines that contributions are or may be fraudulent, artificial, automated, duplicated or otherwise not genuine, including where they originate from bots, scripts, emulators, automated tooling, duplicate or multiple accounts, or coordinated activity intended to inflate rewards. Action Model may suspend or close accounts on the same basis.

No guarantee of value. Points have no monetary value, are not redeemable for cash, and carry no entitlement to any particular allocation, quantity, timing or value of $LAM tokens. Any future token generation event, and the terms of any allocation, are matters entirely within Action Model’s discretion and may not occur at all.

8. How the Data Is Used

Contributed data, and data derived from it, may be used to:

• Train, evaluate, refine and improve the Large Action Model and any successor, derivative, related or future models

• Develop, operate, license and commercialise artificial intelligence models, products, features and services, whether existing now or created in future

• Build and maintain datasets, benchmarks and internal research resources

• Operate the reward, referral and account systems

• Diagnose faults, test systems, prevent abuse and improve reliability and performance

• Understand usage patterns and improve the products

Account and usage data may also be used to operate, secure and support your account, to communicate with you, and to comply with applicable legal and regulatory obligations.

9. Account and Platform Data

Separately from training contributions, we hold data necessary to operate your account. This includes your email address or third-party sign-in identifier, authentication and session identifiers, IP address and connection data, device and browser information, your training and reward history, your referral relationships, and any correspondence you send us.

Referrals. If you were referred to Action Model by another user, that user is able to see that you have joined and the reward contribution attributable to you. Referrers cannot see your contributed data, your browsing activity, your training sessions, or the contents of your account.

Access controls. Access to systems and data is restricted to authorised personnel. Authorised personnel may inspect samples of collected data for the purposes of verifying that filtering, anonymisation, collection and reward systems are functioning correctly, and for maintaining the integrity and security of the platform.

10. Your Responsibilities and Warranties

By using the extension, you represent, warrant and undertake that:

• You are aged 18 or over and have the legal capacity to accept this Policy

• You are entitled to contribute the data generated by your use of the extension, and to grant the rights set out in Section 3

• You will not conduct training on any page or service where you do not have the right to do so, including where doing so would breach the terms of that website or service

• You will not conduct training on any page displaying the personal information, confidential information or private communications of any other person, or any information belonging to an employer or third party which you are not authorised to disclose

• You will not conduct training on any page displaying information you are not willing to contribute

• You will not use bots, scripts, automation, emulation or any other artificial means to generate or inflate contributions or rewards

• You will use the extension in compliance with all laws applicable to you

Indemnity. You agree to indemnify, defend and hold harmless Action Model, its affiliates, officers, directors, employees, contractors and agents against all claims, demands, proceedings, losses, damages, liabilities, fines, penalties, costs and expenses (including reasonable legal fees) arising out of or connected with your breach of this Policy, your breach of any of the warranties above, your use of the extension, or the content of any page on which you have chosen to conduct training.

11. Requests From Third Parties

If you believe that data relating to you has been contributed by another user without authority, contact privacy@actionmodel.com. Where the data can be identified and located, we will take reasonable steps to remove it. Because contributed data is anonymised and aggregated, identification and location will not always be possible, and removal cannot be guaranteed in respect of data already incorporated into datasets or into trained models.

12. Service Providers and Global Processing

Action Model uses third-party providers to operate the Services, including providers of cloud infrastructure and storage, authentication, data processing, analytics and monitoring, artificial intelligence and machine learning services, communications and payment or distribution infrastructure. The providers we use may change from time to time. These providers process data on our behalf or in accordance with their own terms.

Global processing. Action Model operates internationally. Data may be stored, processed, transferred and accessed in any country in which we or our service providers operate. This includes countries outside the European Economic Area and the United Kingdom, and countries whose data protection frameworks differ from those of your own country.

By using the Services, you acknowledge and agree that your data may be processed outside the European Economic Area, the United Kingdom, and your country of residence, and you consent to such processing, storage, transfer and access.

13. Retention

Contributed training data is retained by Action Model on a permanent basis. It has been contributed in exchange for reward, is held in anonymised form, is incorporated into datasets and trained models, and is not separable from them. It is not deleted on account closure.

Account data is retained for as long as your account remains open. If you close your account, your account data will be deleted, save for records we are required or entitled to retain for legal, regulatory, tax, accounting, security, fraud prevention or dispute purposes.

You may close your account at any time via your dashboard or by contacting privacy@actionmodel.com.

14. Security

Action Model takes the security of its systems seriously. Data is transmitted using encryption in transit (HTTPS/TLS), is stored using established cloud infrastructure providers, and access is restricted to authorised personnel. We periodically review our systems and security practices.

No system, product, network or method of transmission is completely secure. Action Model does not warrant or guarantee that the Services, or any data held within them, will be free from unauthorised access, loss, misuse, interception or alteration, and you use the Services on that basis.

15. Cookies

We use cookies and equivalent technologies to keep you signed in, to maintain your session, and to understand and improve how the Services are used. We do not use cookies for cross-site tracking, retargeted advertising or behavioural advertising.

16. Age Restriction

The Services are intended for users aged 18 and over. They are not directed at, and must not be used by, anyone under 18. We do not knowingly collect data from anyone under 18. If you believe a person under 18 has used the Services, contact privacy@actionmodel.com and we will take reasonable steps to close the account and delete the associated account data.

17. Requests About Your Account Data

You may contact privacy@actionmodel.com to request a copy of the account data we hold about you, to correct inaccurate account data, or to close your account and have your account data deleted.

These requests relate to account data. As explained in Sections 3, 5 and 13, contributed training data is held in anonymised form, has been supplied in exchange for reward, and cannot be identified as relating to any particular individual, isolated from datasets, or extracted from trained models. Requests in respect of contributed training data therefore cannot be fulfilled.

18. Disclaimers and Limitation of Liability

The Services are provided “as is” and “as available”, without warranty or representation of any kind, whether express, implied or statutory, including any implied warranty of merchantability, satisfactory quality, fitness for a particular purpose, accuracy, or non-infringement, all of which are excluded to the fullest extent permitted by law.

Without limiting the foregoing, Action Model gives no warranty, representation or guarantee that:

• Automated filtering and anonymisation will identify and remove all sensitive or personal content in all circumstances

• The Services, the extension, the block list or any reward system will operate without interruption, delay or error

• Any Points, tokens, allocation or reward will be issued, will hold any value, or will be transferable

To the fullest extent permitted by law, Action Model shall not be liable for any indirect, incidental, special, consequential, exemplary or punitive damages, or for any loss of profit, revenue, data, goodwill, opportunity or anticipated saving, however arising, whether in contract, tort (including negligence), breach of statutory duty or otherwise, and whether or not Action Model was advised of the possibility of such loss.

To the fullest extent permitted by law, Action Model’s total aggregate liability arising out of or in connection with the Services and this Policy shall not exceed one hundred United States dollars (US$100).

Nothing in this Policy excludes or limits any liability which cannot lawfully be excluded or limited.

19. Changes to This Policy

Action Model may update this Policy from time to time. The current version will always be available on our website and through the extension, and the effective date at the top of this Policy will be updated accordingly.

Your continued use of the Services following any update constitutes acceptance of the updated Policy. If you do not accept an update, you should stop using the Services and uninstall the extension.

20. Governing Law

This Policy, and any dispute or claim arising out of or in connection with it or its subject matter, is governed by the laws of the British Virgin Islands, and the courts of the British Virgin Islands shall have exclusive jurisdiction, without regard to conflict of law principles.

21. Chrome Web Store Compliance

The extension complies with the Chrome Web Store User Data Policy, including the Limited Use requirements:

• Data minimisation: only the permissions necessary for the extension’s function are used (storage, cookies, tabs, activeTab, scripting)

• Dynamic permissions: broader host permissions such as `<all_urls>` are requested at runtime, with your explicit approval via Chrome’s native permission prompt

• Purpose limitation: data is used for the training of artificial intelligence models and the operation of the platform, and is not used for advertising, advertising profiling, or creditworthiness or lending purposes

• User initiation: collection is initiated and controlled by the user

The extension is currently available for Google Chrome.

22. Google API Data Usage

If you sign in with Google, or connect a Google account to enable a particular feature, Action Model may request access to certain Google APIs. Depending on the features you enable, these may include basic account information (name, email address, profile image), and, where a feature requires it, access to Google services such as Calendar, Drive, Gmail, Docs and Sheets, or Contacts.

This access is feature-dependent and entirely optional. You are prompted to grant a permission only where it is required for a specific feature, you choose which permissions to grant, and you are not required to grant any of them to use the core functionality of Action Model.

How we use it. Google API data is used solely to provide the user-facing feature you have enabled, such as authenticating your account or allowing a workflow to act on your Google services at your direction. It is not used for advertising, is not sold, and is not used to train models outside the core functionality of the product.

How we store it. OAuth tokens and credentials are stored securely and encrypted locally on your device, using industry-standard encryption practices. Tokens are never stored in plain text. Google OAuth tokens are not transmitted to Action Model servers, and we do not store or process Google API data in our cloud infrastructure. Access to your Google account therefore remains device-bound and under your control.

Revoking access. You may revoke Action Model’s access at any time by visiting https://myaccount.google.com/permissions, selecting Action Model, and clicking “Remove Access”. Once revoked, stored tokens become invalid and the application will no longer have access to your Google data. You may reconnect at any time.

Retention. Google OAuth tokens are retained only for as long as necessary to maintain an active session, and are deleted when you log out, disconnect your Google account, or uninstall the application or extension. We do not retain historical Google API data beyond what is required for active functionality.

Compliance. Action Model’s use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

23. Contact

Email: privacy@actionmodel.com Dashboard: https://train.actionmodel.com

ActionModel Ltd, British Virgin Islands (Company Number 2195097)