Privacy Policy

1.Definitions

“Services” means Ares websites, software, applications, AI coding assistant features, developer tools, documentation, customer support, and related services.

“Personal information” includes similar terms under applicable privacy laws, including “personal data” and “personally identifiable information.” In general, personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.

“Inputs” means any code, prompts, files, repositories, documents, conversations, chat history, instructions, data, or other content you submit, upload, connect, or otherwise provide to the Services.

“Suggestions,” “Outputs,” or “AI Outputs” means any code, text, explanations, recommendations, commands, configurations, documentation, or other material generated by the Services in response to your Inputs.

“Content” means, collectively, your Inputs and the resulting Suggestions or Outputs.

2.No children under 18

Our Services are not directed to children under 18. We do not knowingly collect personal information from children under 18.

If you are under 18, you may not access or use the Services.

If we learn that we have collected personal information from a child under 18, we will take reasonable steps to delete that information, subject to applicable law.

3.Collection and use of information

We collect information you provide directly and information collected automatically when you use the Services.

• Account information, such as name, email address, authentication identifiers, company name, invite information, billing-related information, and account preferences.
• Inputs, including code, prompts, files, documents, repository references, conversations, chat history, instructions, and other content you submit to the Services.
• Suggestions and Outputs generated by AI features in response to your Inputs.
• Usage data, telemetry, product interactions, session metadata, feature usage, device information, browser details, feedback, support communications, and information you choose to provide.
• Log Data and Cookies, as described in the sections titled “Log data” and “Cookies and other tracking technologies.”
• Payment-related information processed by third-party payment processors. We do not store full payment card numbers on our own systems unless expressly stated at the time of collection.

4.How we use information

We use information to provide, operate, improve, personalize, secure, troubleshoot, and support the Services; communicate with you; authenticate users; manage accounts and organizations; process payments; detect and prevent abuse; enforce our terms; comply with legal obligations; and defend our rights.

We use Inputs to generate Suggestions and Outputs, maintain conversation history where enabled, provide support, debug issues, detect abuse, monitor safety, and protect the integrity and security of the Services.

We may use aggregated, anonymized, or de-identified telemetry and usage information that does not include your actual source code or prompts to improve reliability, security, performance, and user experience.

5.AI training policy

We do not use your Inputs or Suggestions to train or improve our AI models, or permit third parties to do so, unless one of the following applies: the Content is flagged for security review or abuse; you explicitly report the Content as feedback; or you have given us explicit consent through an account setting, written agreement, in-product control, or other clear consent mechanism.

If you provide feedback, suggestions, bug reports, abuse reports, evaluations, or feature requests, we may use that information to improve the Services, including reliability, safety, security, product quality, and user experience.

We do not sell your Inputs or Suggestions.

6.AI content processing and model providers

Processing your Inputs is necessary to generate Suggestions and provide AI coding assistant functionality.

We may share Inputs with trusted third-party AI model providers solely to generate responses on our behalf, operate AI features, provide safety controls, prevent abuse, and maintain the Services.

AI model providers and other service providers are required to process data only as instructed by us and in accordance with this Privacy Policy, applicable law, and contractual obligations that restrict them from using your data for their own purposes or training unless you have given explicit consent or another permitted exception applies.

Because AI features may process source code, prompts, files, and technical data, you should avoid submitting passwords, private keys, access tokens, production secrets, regulated health information, payment card data, classified information, or other sensitive information unless your use is authorized and appropriate safeguards are in place.

7.Legal bases for processing

Where applicable law requires a legal basis for processing personal information, including the EU General Data Protection Regulation, the UK Data Protection Act 2018, the California Consumer Privacy Act, the California Privacy Rights Act, the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Utah Consumer Privacy Act, the Canadian Personal Information Protection and Electronic Documents Act, and similar laws, we generally process personal information based on one or more of the following legal bases.

• Performance of a contract with you, including providing the Services, generating AI Suggestions, managing accounts, processing transactions, and providing support.
• Compliance with legal obligations applicable to Ares.
• Our legitimate business interests, including securing the Services, preventing abuse, improving reliability, enforcing our terms, communicating with users, maintaining business records, and defending legal rights.
• Your consent, where required or where we request it for a specific processing activity.

8.Purposes of use and processing

• Providing the Services and related support.
• Generating AI Suggestions and Outputs in response to your Inputs.
• Protecting the integrity, safety, availability, and security of the Services.
• Analyzing, maintaining, troubleshooting, and improving the Services and our business.
• Personalizing the Services and remembering preferences.
• Authenticating users and managing accounts, organizations, subscriptions, and billing.
• Communicating with you about service updates, security notices, support requests, and administrative messages.
• Detecting, investigating, and preventing fraud, abuse, security incidents, policy violations, and unauthorized access.
• Defending our legal rights and enforcing our agreements.
• Auditing, reporting, corporate governance, accounting, and compliance.
• Complying with legal obligations and responding to lawful requests.

9.Investigations and legal disclosures

ARES may investigate and disclose information from or about you, as permitted by applicable law, if we have a good faith belief that such investigation or disclosure is reasonably necessary to comply with legal process, law enforcement instructions, court orders, subpoenas, statutes, judicial proceedings, or other lawful requests.

We may also investigate and disclose information where helpful to prevent, investigate, or identify possible wrongdoing in connection with the Services; protect the rights, reputation, property, safety, or security of Ares, users, third parties, or the public; detect abuse; enforce our agreements; or respond to security incidents.

10.Vendors and service providers

We engage third-party vendors, agents, service providers, contractors, and affiliated entities to operate and support the Services, including cloud hosting, infrastructure, authentication, payment processing, analytics, customer support, security, communications, data storage, and AI model providers.

These providers may access or process personal information, Inputs, and Suggestions only as necessary to deliver the Services and under contractual obligations that prohibit them from using your data for their own marketing, training, or unrelated purposes.

We do not sell your personal information.

We may disclose automatically collected, aggregated, anonymized, or de-identified information that does not reasonably identify you to help us understand usage patterns, improve the Services, measure performance, and communicate about our business.

11.Business transfers

If ARES is acquired by or merged with another entity, if substantially all of our assets are transferred to another company, or as part of a bankruptcy, financing, reorganization, or similar proceeding, we may transfer information we have collected about you to the relevant third party, subject to applicable law.

12.Log data

Whenever you use the Services, ARES may automatically collect Log Data, including your IP address, browser type and version, device information, pages visited, features used, timestamps, referring URLs, session metadata, usage statistics, and diagnostic information.

For AI interactions, we may temporarily retain certain exchanges, metadata, or related records for safety monitoring, abuse prevention, security, troubleshooting, and system improvement. Some temporary safety-related records may not appear in your visible conversation history.

13.Cookies and other tracking technologies

ARES and third parties we interact with may use cookies, web beacons, local storage, local shared objects, and similar technologies in connection with your use of the Services and third-party websites.

Cookies are small data files that may have unique identifiers and may reside on your computer, mobile device, browser, emails we send, or the Services.

We may use cookies and similar technologies to keep you signed in, remember preferences such as theme selection, support essential application functionality, secure the Services, understand how users engage with the Services, improve performance, and support analytics.

Cookies may be persistent or stored only during an individual session. You can manage cookie settings through your browser or device settings, but disabling certain cookies may affect the availability or functionality of the Services.

14.Information security and accuracy

ARES uses reasonable administrative, technical, organizational, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, disclosure, and destruction.

We take reasonable steps to maintain the accuracy of personal information where necessary for the purposes for which it is processed.

No method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, and you are responsible for using appropriate safeguards when submitting code, credentials, secrets, regulated data, or sensitive information.

15.Retention period

ARES retains personal information for as long as necessary to fulfill the purposes for which it is processed, including providing the Services, maintaining security, complying with legal and regulatory obligations, handling disputes, maintaining business records, and establishing, exercising, or defending legal claims.

Conversation history, including Inputs and Suggestions, may be retained in your account so you can access past sessions. You may delete individual chats or your entire account at any time, subject to applicable law and product functionality.

Certain temporary, backup, diagnostic, legal, security-related, or safety-related data may be retained for a limited period even after deletion requests, as permitted by law.

If you cancel your account or request that we no longer use your personal information to provide the Services, we will process that request as required by applicable law. If you withdraw consent or object to certain processing, you may not be able to use some or all of the Services.

16.Links to other sites

The Services may contain links to sites, applications, tools, or services that are not controlled by ARES.

We are not responsible for the privacy practices, security practices, content, or policies of third-party sites or services. We encourage you to review the privacy policies of each site or service you visit or use.

This Privacy Policy applies only to information collected by or on behalf of ARES through the Services.

17.Notice

By using the Services, you consent to receive electronic communications from ARES. You agree that electronic communications satisfy any legal requirement that communications be in writing under this Privacy Policy or applicable law.

We may provide notice to you by sending an email to the address associated with your account, posting notice through the Services, or using another legally permissible method.

Any notice to ARES under this Privacy Policy must be sent by email to privacy@arescode.com and by certified mail, return receipt requested, to Ares Product Development Services LLC, 945 McKinney St #640, Houston, TX 77002, ATTN: Legal.

18.Governing law and venue

This Privacy Policy is governed by the laws of the United States of America and the State of Texas, without regard to conflict-of-law principles.

Harris County, Texas is the exclusive forum for any mediation, arbitration, litigation, or dispute resolution relating to this Privacy Policy, unless applicable law requires another forum.

19.Your choices and privacy rights

Depending on where you live and subject to applicable law, you may have rights to access, correct, delete, restrict, object to, or receive a copy of certain personal information we maintain about you.

You may also have the right to withdraw consent where processing is based on consent, opt out of certain processing, or appeal a privacy request decision where required by law.

To exercise privacy rights or ask privacy-related questions, contact us at privacy@arescode.com.

We may need to verify your identity before fulfilling a request. Some rights are not absolute, and we may deny or limit requests where permitted by law, including where necessary to protect security, comply with legal obligations, complete transactions, maintain business records, prevent fraud or abuse, or defend legal claims.

20.California residents

This section applies to California consumers and describes how we collect, use, and disclose Personal Information in our role as a business under the California Consumer Privacy Act and California Privacy Rights Act.

For purposes of this section, “Personal Information” has the meaning given in the CCPA and CPRA. We may collect the following statutory categories of Personal Information.

• Identifiers, such as name, email address, account identifiers, IP address, and similar identifiers.
• Customer records information, such as account information, billing-related information, and contact information.
• Commercial information, such as subscription, transaction, product usage, and service history.
• Internet or other electronic network activity information, such as device information, browser information, pages visited, features used, timestamps, Log Data, and usage statistics.
• Geolocation data, such as approximate location inferred from IP address.
• Inferences drawn from usage activity, preferences, or interactions with the Services.
• Other personal information, including code, prompts, files, conversations, chat history, AI-generated Suggestions, support messages, feedback, and other information you provide or receive while using the Services.

21.California privacy rights

California residents have certain rights regarding Personal Information we collect or maintain. These rights are not absolute, and we may decline requests as permitted by law.

• Right to know and access: You may request that we disclose what Personal Information we collected, used, disclosed, or sold or shared, as applicable, during the relevant period.
• Right to deletion: You may request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
• Right to correction: You may request that we correct inaccurate Personal Information we maintain about you.
• Right to opt out of sale or sharing: We do not sell Personal Information. If our practices change in a way that constitutes “sharing” for cross-context behavioral advertising under California law, we will provide legally required choices.
• Right to limit use of sensitive Personal Information: We do not use sensitive Personal Information for purposes requiring a right to limit unless we provide the required notice and choice.
• Right to non-discrimination: We will not discriminate against you for exercising your privacy rights.

22.California requests and authorized agents

California residents may exercise their rights themselves or designate an authorized agent to exercise rights on their behalf.

To protect Personal Information, we will verify your identity using a method appropriate to the type of request. We may request written permission from you authorizing an agent to make the request and may verify the authorized agent’s identity.

Please contact us at privacy@arescode.com if you would like to access this policy in an alternative format, exercise your rights, learn more about your rights or our privacy practices, or designate an authorized agent.

23.European Union, United Kingdom, and similar jurisdictions

Subject to the conditions set out in applicable law, users in the European Union, European Economic Area, United Kingdom, and other jurisdictions with similar rights may have the following rights regarding our processing of personal information.

• Right of access: You may ask us to confirm whether we are processing your personal information and, where applicable, provide a copy of that information and related details.
• Right to correction or rectification: You may request correction of inaccurate or incomplete personal information.
• Right to erasure: You may ask us to delete personal information in certain circumstances, such as where we no longer need it or where you withdraw consent and no other legal basis applies.
• Right to restrict processing: You may ask us to restrict processing of personal information in certain circumstances, such as where you contest accuracy or object to our use or legal basis.
• Right to data portability: You may have the right to receive certain personal information in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to object: You may object to processing based on legitimate interests. We will stop such processing unless we have compelling legitimate grounds or need to process the information for legal claims.
• Right to object to marketing: You may ask us to stop processing personal information for direct marketing purposes.
• Right not to be subject to certain automated decision-making: You have rights relating to decisions based solely on automated processing that produce legal or similarly significant effects. ARES does not use AI Outputs to make legal or similarly significant decisions about users without appropriate human involvement.
• Right to withdraw consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
• Right to lodge a complaint: You may lodge a complaint with a supervisory authority if you believe our processing of personal information infringes applicable law.

24.International processing

ARES is based in the United States. If you access the Services from outside the United States, your information may be processed in the United States and other jurisdictions where we or our vendors operate.

These jurisdictions may have data protection laws that differ from those in your location. Where required, we use appropriate safeguards for international transfers of personal information.

25.Right to change this policy

We reserve the right to update or change this Privacy Policy at any time, with or without cause, subject to applicable law.

Changes will be effective when posted through the Services unless a later effective date is stated. The latest version will be posted with the most recent posted or effective date.

If we make a material change to this Privacy Policy, we will provide notice as required by law, which may include posting a notice through the Services or sending an email to the address associated with your account.

Your continued use of the Services after an updated Privacy Policy takes effect means you have read, understood, and agree to the updated Privacy Policy where permitted by law.

26.Enforceability

If any provision of this Privacy Policy is found to be unlawful, void, or unenforceable, that provision will be deemed severable from this Privacy Policy and will not affect the validity and enforceability of the remaining provisions.

27.Entire agreement

This Privacy Policy, together with the Terms of Service and any additional terms that expressly apply to specific Services, constitutes the entire agreement between you and ARES regarding the privacy practices described in this Privacy Policy and supersedes prior agreements or communications regarding those practices.

28.Contact details

• Privacy inquiries: privacy@arescode.com
• Legal notices: privacy@arescode.com
• Mailing address: Ares Product Development Services LLC, 945 McKinney St #640, Houston, TX 77002, Attention: Privacy