ORIGEN TECH LLC
COMPREHENSIVE DATA POLICY

Effective Date: February 17, 2026
Last Updated: February 17, 2026
Version: 1.17

1. DEFINITIONS AND SCOPE
2. CORPORATE STRUCTURE AND DATA OWNERSHIP
3. DATA SOVEREIGNTY ARCHITECTURE
4. AIMEE PLATFORM DATA PRACTICES
5. R.A.I.N. INFRASTRUCTURE DATA PRACTICES
6. DATA COLLECTION AND USAGE
7. DATA RETENTION AND DELETION
8. DATA SECURITY MEASURES
9. THIRD-PARTY RELATIONSHIPS
10. INTERNATIONAL COMPLIANCE
11. USER AND CLIENT RIGHTS
12. BREACH NOTIFICATION PROCEDURES
13. INTELLECTUAL PROPERTY PROTECTIONS
14. LIABILITY LIMITATIONS
15. POLICY MODIFICATIONS
16. CONTACT INFORMATION
17. SEVERABILITY AND GOVERNING LAW

1. DEFINITIONS AND SCOPE

1.1 CORPORATE ENTITIES

"Origen Tech" or "Company" refers to Origen Tech LLC, a Nevada limited liability company, and all wholly-owned subsidiaries and operating entities.

"AIMEE" refers to the Artificial Intelligence Messaging Engagement Engine platform operated by Origen Tech.

"R.A.I.N." refers to Remote Access Intelligence Network, the sovereign AI infrastructure division of Origen Tech.

"Owner" refers to the sole member and beneficial owner of Origen Tech LLC.

1.2 DATA CLASSIFICATIONS

"Customer Data" means any data provided to or collected by AIMEE from end users (venue customers, content subscribers, etc.) in the course of platform operations.

"Client Data" means any data, models, algorithms, or infrastructure owned by or operated on behalf of R.A.I.N. clients.

"Platform Data" means operational data generated by AIMEE or R.A.I.N. systems, including logs, analytics, and performance metrics.

"Proprietary Data" means any data, algorithms, models, or intellectual property developed by Origen Tech or its systems.

"Sovereign Data" means Client Data that is physically isolated and controlled exclusively by the client under R.A.I.N. infrastructure agreements.

1.3 PARTIES

"Venue Partners" means businesses using AIMEE for customer engagement (restaurants, hotels, nightlife establishments, etc.).

"Creators" means individuals using AIMEE for audience engagement (OnlyFans creators, influencers, etc.).

"R.A.I.N. Clients" means entities utilizing sovereign AI infrastructure services (betting syndicates, family offices, hedge funds, etc.).

"End Users" means individuals who interact with AIMEE-powered messaging services.

2. CORPORATE STRUCTURE AND DATA OWNERSHIP

2.1 ABSOLUTE OWNERSHIP

All data infrastructure, systems, algorithms, and intellectual property developed by or through Origen Tech are the sole and exclusive property of the Owner. This includes:

All AIMEE platform code, models, and systems
All R.A.I.N. infrastructure designs and implementations
All customer databases and derived intelligence
All proprietary algorithms and AI models
All business processes and operational frameworks

2.2 ENTITY SEPARATION

Where Origen Tech operates through separate legal entities (Embassy LLCs, international subsidiaries, etc.):

All intellectual property licenses flow from Origen Tech to subsidiary entities
All data generated by subsidiary operations belongs to Origen Tech
Local partners may receive operational equity but never IP ownership
Data flows are unidirectional: subsidiaries to Origen Tech, never reverse
Dissolution of any subsidiary entity returns all data to Origen Tech

2.3 IRREVOCABLE ASSIGNMENTS

Any employee, contractor, partner, or affiliate executing work for Origen Tech irrevocably assigns all IP, data, and work product to the Owner. No exceptions.

3. DATA SOVEREIGNTY ARCHITECTURE

3.1 R.A.I.N. SOVEREIGNTY PRINCIPLES

R.A.I.N. infrastructure operates on absolute data sovereignty:

CLIENT HARDWARE OWNERSHIP

Clients purchase or lease dedicated physical hardware
Hardware is owned by client, housed by R.A.I.N.
Zero shared compute resources between clients

PHYSICAL ISOLATION

Each client's infrastructure is physically separated
Isolated power, cooling, and network infrastructure
No cross-contamination of data between clients
Visual verification available via surveillance systems

ZERO CLOUD DEPENDENCIES

No data leaves client's physical hardware
No cloud APIs, no third-party model access
All processing occurs on client-owned infrastructure
No internet connectivity required for AI operations

3.2 DATA FLOW RESTRICTIONS

Under R.A.I.N. agreements:

Client data NEVER flows to Origen Tech systems
Origen Tech has NO access to Client Sovereign Data
Models trained on client data remain on client hardware
Surveillance of client areas is client-viewable only
Physical access to client infrastructure requires client authorization

3.3 ORIGEN TECH'S ROLE

For R.A.I.N. clients, Origen Tech provides:

Physical facility and security infrastructure
Power, cooling, and network backbone
System administration and maintenance services
Hardware procurement and installation
Compliance monitoring and reporting

Origen Tech does NOT provide:

Access to Client Sovereign Data
Analytics derived from client operations
Cross-client intelligence or pattern recognition
Third-party access to client systems

4. AIMEE PLATFORM DATA PRACTICES

4.1 DATA WE COLLECT

AIMEE collects and processes:

CUSTOMER COMMUNICATIONS

Text messages sent via iMessage or LINE
Customer responses to AI-generated messages
Message timestamps and delivery status
Read receipts and engagement metrics

CUSTOMER PROFILE DATA

Names, nicknames, and aliases
Phone numbers or LINE IDs
Location information (if provided)
Birthdays and special dates
Preferences and stated interests
Purchase history and spending patterns
Visit frequency and recency
Relationship status and personal details (if shared)

BEHAVIORAL DATA

Response times and engagement patterns
Conversation sentiment and tone
Topic preferences and aversions
Time-of-day interaction patterns
Message length and complexity preferences

VENUE PARTNER DATA

Business hours and operations
Service menus and pricing
Staff names and roles
Brand voice and communication style
Customer segmentation rules
Promotional campaigns and offers

4.2 HOW WE USE DATA

Customer Data is used to:

Generate contextually appropriate AI responses
Personalize messaging based on customer history
Automate follow-up sequences and retention campaigns
Segment customers for targeted outreach
Analyze engagement effectiveness
Improve AI model performance
Generate reporting and analytics for Venue Partners

4.3 DATA OWNERSHIP - AIMEE CONTEXT

CRITICAL DISTINCTION:

VENUE PARTNERS own their customer relationships
CREATORS own their subscriber relationships
ORIGEN TECH owns the platform, systems, and derived intelligence
ORIGEN TECH owns all AI models trained on platform data
ORIGEN TECH owns all aggregated and anonymized insights

Venue Partners and Creators are granted:

Access to their customer data via AIMEE dashboard
Export capabilities for their customer lists
Right to delete their account and associated customer data

Venue Partners and Creators are NOT granted:

Ownership of AIMEE AI models
Ownership of platform infrastructure
Rights to derived intelligence used across platform
Source code or algorithmic IP

4.4 CROSS-CLIENT INTELLIGENCE

Origen Tech reserves the right to:

Train AI models on aggregated data across all Venue Partners
Use anonymized patterns to improve platform performance
Develop industry benchmarks and insights
Create proprietary algorithms from platform-wide data

Individual customer data is never shared between Venue Partners, but system-wide learning benefits all platform users.

5. R.A.I.N. INFRASTRUCTURE DATA PRACTICES

5.1 CLIENT DATA ISOLATION

Each client operates on dedicated hardware
Network isolation prevents cross-client data flow
Physical barriers separate client infrastructure zones
Access controls restrict Origen Tech personnel from client areas
Encryption keys are client-managed, not Origen Tech-managed

5.2 SURVEILLANCE AND MONITORING

Physical security surveillance at R.A.I.N. facility:

Perimeter cameras monitor property boundaries
Common areas (entry, parking) are surveilled
Client-specific areas have client-viewable cameras
Clients can access their surveillance feeds remotely
Origen Tech personnel movements in client areas are logged
All surveillance data is stored locally, not in cloud

5.3 OPERATIONAL DATA

Origen Tech collects minimal operational data:

Power consumption per client zone
Cooling system performance
Network bandwidth utilization
Physical access logs (who entered where, when)
System uptime and maintenance events

This operational data is used solely for facility management and is not analyzed for intelligence purposes.

5.4 ABSOLUTE NON-DISCLOSURE

Origen Tech personnel are bound by:

Strict NDAs prohibiting disclosure of client operations
Zero-knowledge protocols for system administration
No retention of temporary access credentials
Immediate access revocation upon service termination
Criminal and civil penalties for unauthorized access

6. DATA COLLECTION AND USAGE

6.1 LEGAL BASIS FOR COLLECTION

AIMEE Platform: Contractual necessity (to provide messaging services), Legitimate business interest (platform improvement), Consent (for optional data like birthdays, preferences)

R.A.I.N. Infrastructure: Contractual necessity (to provide infrastructure services), Legal obligation (facility security and compliance)

6.2 AUTOMATED DECISION-MAKING

AIMEE uses AI to generate responses, determine timing, segment customers, and prioritize interactions. End Users have the right to request human review, opt out of automated messaging, and request deletion of their data.

6.3 DATA MINIMIZATION

We collect only data necessary for service provision. No collection of sensitive data unless specifically required by service.

6.4 PURPOSE LIMITATION

Data is used only for purposes disclosed at collection. No sale of data to third parties. No use for purposes unrelated to disclosed services.

7. DATA RETENTION AND DELETION

7.1 RETENTION PERIODS - AIMEE

Customer conversation data: Active customers retained indefinitely, inactive customers retained for 24 months after last interaction, deleted accounts purged within 30 days.

Venue Partner data: Active accounts retained indefinitely, terminated accounts retained for 90 days then purged, legal hold retained as required by law.

7.2 RETENTION PERIODS - R.A.I.N.

Client operational data: Retained for duration of contract, purged within 30 days of termination. Surveillance data: 90-day rolling retention, client-specific areas available to client.

7.3 DELETION PROCEDURES

Upon deletion request: Data marked for deletion within 48 hours, purged from production within 30 days, purged from backups within 90 days. Anonymized aggregated data may be retained for analytics.

7.4 RIGHT TO DELETION

Users can request deletion by contacting Venue Partner, emailing privacy@origentech.com, or using in-platform deletion tools. Deletion requests processed within 30 days.

8. DATA SECURITY MEASURES

8.1 INFRASTRUCTURE SECURITY

R.A.I.N. Facility (67859 Valle Vista Rd, Twentynine Palms, CA):

PHYSICAL SECURITY

Perimeter fencing around 128-acre property
24/7 AI-powered surveillance (Frigate NVR)
Access control systems with biometric verification
Security personnel and autonomous monitoring systems

ENVIRONMENTAL CONTROLS

Redundant power systems (solar + battery + generator)
Climate-controlled server environments
Fire suppression systems
Seismic and disaster resistance measures

NETWORK SECURITY

VLAN segmentation by client and function
Zero internet exposure for client infrastructure
Encrypted network traffic
Intrusion detection and prevention systems
Regular security audits

8.2 DIGITAL SECURITY

Encryption: Data encrypted in transit (TLS 1.3+) and at rest (AES-256). Client-managed encryption keys for R.A.I.N. clients.

Access Controls: Role-based access control, multi-factor authentication, principle of least privilege, regular access reviews.

Monitoring and Logging: Real-time intrusion detection, comprehensive audit logs, anomaly detection, regular security assessments, annual penetration testing.

8.3 PERSONNEL SECURITY

All employees and contractors undergo background checks
Signed confidentiality and IP assignment agreements
Security awareness training (quarterly)
Immediate access revocation upon termination
Zero-knowledge protocols for R.A.I.N. client access

8.4 INCIDENT RESPONSE

Documented procedures for breach detection, containment, forensic investigation, notification, remediation, and post-incident review.

9. THIRD-PARTY RELATIONSHIPS

Service providers must sign DPAs, implement equivalent security, use data only for specified purposes, and delete data upon contract termination. Origen Tech never sells customer data. Subprocessor list maintained at www.origentech.com/subprocessors.

10. INTERNATIONAL COMPLIANCE

Compliance with: CCPA, state privacy laws (Virginia, Colorado, Connecticut, Utah), GDPR, Japan APPI, Thailand PDPA, Singapore PDPA, Australia Privacy Act. Data Protection Officer: dpo@origentech.com

11. USER AND CLIENT RIGHTS

End users have rights to access, rectification, erasure, portability, objection, restriction, and human review. Venue Partners can export data, delete accounts, access analytics. R.A.I.N. clients have absolute control over Sovereign Data, physical access to infrastructure, audit rights, portability, and veto power over Origen Tech personnel access.

12. BREACH NOTIFICATION PROCEDURES

Breach response within 24 hours (contain and assess), 72 hours (investigate and notify authorities), 30 days (notify affected individuals). Notifications include breach nature, data types affected, consequences, measures taken, and recommended actions.

13. INTELLECTUAL PROPERTY PROTECTIONS

Origen Tech owns all AIMEE platform IP, R.A.I.N. infrastructure designs, and derived intelligence. R.A.I.N. clients retain ownership of their proprietary algorithms and models trained on Sovereign Data. Platform-generated IP: Venue Partners own customer lists, Origen Tech owns AI models and analytics. All work product assigns to Origen Tech irrevocably.

14. LIABILITY LIMITATIONS

Services provided 'AS IS' without warranties. Liability limited to direct damages only, capped at amount paid in preceding 12 months. Not liable for lost profits, data loss (except gross negligence), third-party actions, force majeure, or acts of God. Clients indemnify Origen Tech for their misuse of services.

15. POLICY MODIFICATIONS

Origen Tech may modify policy at any time. Changes effective 30 days after notification (60 days for material changes). Continued use constitutes acceptance. Users who disagree may terminate and request data deletion. All versions archived and available upon request.

16. CONTACT INFORMATION

PRIVACY INQUIRIES: privacy@origentech.com

DATA PROTECTION OFFICER: dpo@origentech.com

SECURITY INCIDENTS: security@origentech.com

GENERAL SUPPORT: support@origentech.com

MAILING ADDRESS: Origen Tech LLC

[Corporate Address]

R.A.I.N. FACILITY: 67859 Valle Vista Rd

Twentynine Palms, CA 92277

BUSINESS HOURS: 24/7/365 for critical security matters

9am-6pm PT for general inquiries

17. SEVERABILITY AND GOVERNING LAW

Governed by laws of Nevada (corporate), California (facility), federal laws, and applicable jurisdictions. Disputes resolved through negotiation, then binding arbitration (JAMS rules) in Las Vegas, Nevada. Exceptions for injunctive relief, IP disputes, and criminal matters.

ACKNOWLEDGMENT AND ACCEPTANCE

By using Origen Tech services (AIMEE or R.A.I.N.), you acknowledge that you have read, understood, and agree to be bound by this Comprehensive Data Policy.

For Venue Partners, Creators, and R.A.I.N. Clients: Your continued use of services constitutes binding acceptance.

For End Users: Your interactions with AIMEE-powered messaging constitute acceptance of data practices described herein.

This policy is effective as of February 17, 2026.

ORIGEN TECH LLC
By: _______________________________
Title: Managing Member
Date: February 17, 2026

APPENDICES

APPENDIX A: DATA PROCESSING ADDENDUM (DPA)