Introduction

TextExpander, Inc., and its subsidiaries and affiliates (“us”, “we”, or “our”) is committed to the responsible development and use of artificial intelligence (“AI”) technologies. This AI Policy (“Policy”) describes how we incorporate AI into our Services, the safeguards we maintain to protect your data, the third-party AI providers we work with, and your rights and choices with respect to AI features.

This Policy supplements our Privacy Policy and Terms of Service. Capitalized terms not defined here have the meanings given in those documents. If there is any conflict between this Policy and our Privacy Policy, this Policy governs with respect to AI-related data processing.

How TextExpander Uses AI in the Services

We incorporate AI technologies into the Services to enhance your productivity, improve the quality of Snippet recommendations, and deliver intelligent features. All current AI features are processed entirely on TextExpander’s own infrastructure. Your Content is vectorized and stored within our own systems; it is not transmitted to any third-party AI provider. Our current AI-powered capabilities include:

• Snippet Recommendations. AI models analyze your current page context to recommend relevant Snippets, predict completions, and surface content you are likely to need.
• Safety and Abuse Detection. Automated systems monitor the Services for violations of our Terms of Service, including security threats and misuse.

We may introduce additional AI features over time. When we do, we will update this Policy and, where required by applicable law, provide advance notice to Customers.

AI in Product Development

In addition to AI features within the Services, TextExpander uses AI-assisted tools internally as part of our software development and engineering processes. This may include AI coding assistants, automated testing tools, and other AI-powered development software used by our engineering team to build, maintain, and improve the Services.

Our internal development use of AI tools is governed by our internal security and acceptable use policies. These tools operate on code and internal system data only — your Customer Data and Personal Data are not used as inputs to our internal development AI tools.

How We Use Your Data in Connection with AI

Customer Data and AI Model Training

TextExpander does not use your Content — including the text of your Snippets, expansion inputs and outputs, or any other data you store within the Services — to train, fine-tune, or otherwise improve any foundational AI or large language model (“LLM”), whether operated by TextExpander or by a third party. This prohibition applies to all Customers and Users by default and requires no opt-out.

Inputs and Outputs

When you use AI features, the text or other content you submit (“Inputs”) and the AI-generated responses you receive (“Outputs”) are treated as your Customer Data under our Privacy Policy. TextExpander does not claim ownership of your Inputs or Outputs. All intellectual property rights in Outputs generated from your Inputs are assigned to you, subject to any restrictions in our Terms of Service.

Please be aware that Outputs are generated through probabilistic machine learning processes. Outputs may be inaccurate, incomplete, or unreliable. You are responsible for reviewing and verifying any Output before relying on it. TextExpander does not warrant that Outputs are accurate, complete, current, or fit for any particular purpose.

Aggregate and De-Identified Data

We may use aggregated, de-identified, or anonymized data — which cannot reasonably be used to identify you — to improve our Services, develop new features, measure product quality, and conduct research. Such data is not considered Customer Data and is not subject to the no-training commitment above.

Retention of AI Inputs and Outputs

Because all AI processing occurs on TextExpander’s own infrastructure, your Inputs and Outputs are not transmitted to or retained by any third-party AI provider. We do not retain Inputs or Outputs in a form associated with your account for longer than is necessary to deliver the requested AI feature. Vector representations of your Content used to power Snippet recommendations are stored in our own database and are deleted when you delete the underlying Content or close your account.

AI Infrastructure and Data Processing

No Third-Party AI Processing

As of the effective date of this Policy, TextExpander does not share your Content with any third-party AI provider, large language model service, or external AI subprocessor in connection with the delivery of AI features. All AI inference, vectorization, and similarity search used to power Snippet Recommendations and related features is performed on infrastructure owned and operated by TextExpander.

Your Snippets and related Content are converted into vector representations (“embeddings”) using models hosted on our own systems. These embeddings are stored in our own database alongside your other Customer Data and are subject to the same security controls, access restrictions, and retention policies described in our Privacy Policy.

Future Third-Party AI Integrations

We may in the future integrate third-party AI providers to deliver new or enhanced features consistent with our internal governance of AI technologies. If we do so, we will update this Policy and our Subprocessor Page in advance and, where required by applicable law, provide notice to Customers before any such integration takes effect. Any third-party AI providers we engage will be required to:

• Process Customer Data only as instructed by TextExpander and only to deliver the requested Services;
• Refrain from using Customer Data to train, fine-tune, or improve any AI model;
• Maintain technical and organizational security measures consistent with industry standards;
• Delete or return Customer Data upon termination of our agreement; and
• Comply with applicable data protection laws, including GDPR and CCPA.

Customer and User Controls

Individual Users may, at any time:

• Opt out of AI-powered Snippet recommendations in their account settings;
• Choose not to use other AI features within the Services; and
• Request deletion of any AI-generated content associated with their account by contacting us at privacy@TextExpander.com.

Acceptable Use of AI Features

You agree not to use AI features within the Services to:

• Generate content that is unlawful, defamatory, discriminatory, harassing, or otherwise harmful;
• Deceive or mislead any person, including by representing AI-generated content as human-authored without appropriate disclosure;
• Violate the intellectual property, privacy, or other rights of any third party;
• Circumvent safety measures, filters, or content policies built into the AI features;
• Develop or train a competing AI model or service using Outputs generated by the Services;
• Process sensitive personal information (including health, financial, or government-issued identifier data) through AI features unless expressly authorized by your agreement with TextExpander; or
• Engage in any activity that violates our Terms of Service or applicable law.

Violations of this section may result in suspension or termination of access to AI features or the Services. We reserve the right to update these restrictions as the technology and regulatory landscape evolves.

Compliance and Regulatory Alignment

TextExpander is committed to aligning our AI practices with applicable legal requirements and recognized frameworks, including:

• EU AI Act. We monitor our AI features for potential classification under the EU AI Act risk tiers and maintain documentation of our AI systems and their data sources as required. AI features embedded in our Services are designed to operate transparently, with users informed when content is AI-generated.
• GDPR and UK GDPR. Where AI features may involve the processing of personal data of EEA or UK residents, we rely on appropriate lawful bases, honor data subject rights, and maintain records of processing activities. Because all current AI processing occurs on our own infrastructure within the United States, international transfers of personal data for AI purposes are governed by the transfer mechanisms described in our Privacy Policy.
• CCPA / CPRA. We do not sell or share Customer Data with any third party for cross-contextual behavioral advertising, including in connection with AI features. California residents may exercise their rights under the CCPA with respect to AI-related processing by contacting us at privacy@TextExpander.com.
• SOC 2 Type II. Our AI features are within the scope of our SOC 2 Type II audit program. Security controls applicable to AI data processing are subject to independent third-party attestation.

Security of AI Data Processing

We apply technical and organizational safeguards to data processed through AI features, including:

• Encryption of data in transit (TLS 1.2 or higher) and at rest;
• Access controls limiting AI data processing to authorized personnel and automated systems with a documented need;
• Regular security assessments of AI tooling and infrastructure used in the Services;
• Logging and audit trails for AI feature usage within Organization accounts; and
• Incident response procedures that include AI-related data incidents within the scope of our breach notification obligations.

Despite these measures, no AI system is completely free of risk. We encourage Customers to avoid submitting highly sensitive or regulated data through AI features unless they have established appropriate controls with us in advance.

Transparency and Human Oversight

We believe AI should enhance human judgment, not replace it. TextExpander’s AI features are designed as assistive tools. No AI feature in the Services makes binding decisions about Users without human review. When AI generates content, suggestions, or recommendations, the User retains full control over whether to accept, modify, or discard the Output.

We are committed to:

• Providing Users with accessible controls to adjust or disable AI features;
• Publishing and maintaining this Policy so that Customers understand how AI is used; and
• Engaging with Customers whose enterprise requirements call for additional contractual AI commitments.

Changes to This Policy

This AI Policy is effective as of the date reflected above. We may update this Policy from time to time as our AI features evolve or as laws and industry standards change. We will post any changes on this page. For material changes, we will provide notice through the Services or by email. Your continued use of the Services after any changes become effective constitutes acceptance of the updated Policy.

Contacting TextExpander

If you have questions, concerns, or requests related to this AI Policy or our AI practices, please contact us at:

Email: privacy@TextExpander.com

TextExpander, Inc.

548 Market St # 37453

San Francisco, CA 94104

Version History

• First version, adopted March 30, 2026