Privacy Policy

1. Introduction

ThoughtPartnr LLC ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you access or use the ThoughtPartnr platform, the A.I. Thought Widget, and all related services (collectively, the "Service").

This Privacy Policy is incorporated by reference into our Terms and Conditions. By using the Service, you consent to the data practices described in this policy. If you do not agree with this Privacy Policy, please do not use the Service.

2. Information We Collect

2.1 Information You Provide

We collect information that you voluntarily provide when you use the Service, including:

• (a) Account information such as your name, email address, and business information;
• (b) Prompts, questions, inputs, and other content you submit through the Service or the A.I. Thought Widget;
• (c) Communications you send to us, including support requests and feedback; and
• (d) Payment information when you subscribe to a paid plan (processed by our third-party payment processor; we do not store full payment card numbers).

2.2 Information Collected Automatically

When you use the Service, we may automatically collect certain information, including:

• (a) Device information such as device type, operating system, and browser type;
• (b) Log data including IP address, access times, pages viewed, and referring URLs;
• (c) Usage data such as features used, interactions with the Service, and session duration; and
• (d) General location data inferred from your IP address (we do not collect precise geolocation).

2.3 A.I. Thought Widget on Third-Party Sites

When you interact with the A.I. Thought Widget embedded on a third-party Host Site, we collect the inputs you submit through the Widget and associated usage data. Any cookies, analytics tools (such as Google Analytics), advertising pixels, or other tracking technologies on the Host Site are operated by the Host Site operator, not by ThoughtPartnr. The Host Site's own privacy policy governs those technologies. We encourage you to review the Host Site's privacy policy separately.

3. How We Use Your Information

We use the information we collect for the following purposes:

• (a) To operate, maintain, and provide the features and functionality of the Service;
• (b) To deliver AI-generated insights, recommendations, and educational content;
• (c) To process transactions and manage your subscription;
• (d) To communicate with you, including sending service-related notices, updates, and promotional communications (with your consent where required);
• (e) To provide recommendations for and facilitate connections with Resource Partners;
• (f) To monitor, analyze, and improve the Service and user experience;
• (g) To detect, prevent, and address fraud, abuse, and security issues;
• (h) To comply with legal obligations and enforce our Terms and Conditions; and
• (i) To respond to your inquiries and provide customer support.

4. Anonymized and Aggregated Data

We may collect, create, use, and share anonymized and aggregated data derived from your use of the Service. This data is de-identified and cannot be used to identify you or your business. We use anonymized data for purposes including:

• (a) Improving and training AI models and system performance;
• (b) Conducting industry benchmarks and research;
• (c) Analyzing trends and usage patterns; and
• (d) Developing new features and services.

Your identifiable data is never used to publicly disclose confidential business information. All anonymized data processing is conducted in accordance with applicable data protection laws.

5. How We Share Your Information

We do not sell your personal data to third parties.

We may share your information in the following limited circumstances:

5.1 Service Providers

We share information with trusted third-party service providers who assist us in operating the Service, including cloud hosting providers, payment processors, analytics services, and AI API providers. These providers access your data only as needed to perform services on our behalf and are contractually obligated to protect your information.

5.2 Third-Party AI Providers

The Service utilizes third-party AI application programming interfaces (APIs) and models to deliver certain features. Your inputs may be transmitted to these providers for processing. We select our AI partners with care and require them to maintain appropriate security measures. We encourage you not to submit highly sensitive personal information (such as Social Security numbers, financial account numbers, or protected health information) through the Service.

5.3 Resource Partners

If you choose to connect with a Resource Partner (such as a lender, consultant, or vendor) through the Service, we may share relevant information to facilitate that connection. Resource Partners are independent third parties with their own terms of service and privacy policies. Your engagement with any Resource Partner is voluntary and governed by their own agreements.

5.4 Legal Requirements

We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, the safety of others, investigate fraud, or respond to a government request.

5.5 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

6. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards to protect your information, including encryption, access controls, and secure hosting infrastructure. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

If you become aware of any unauthorized access to your account or data, please contact us immediately at Tpadmin@ThoughtPartnr.com.

7. Data Retention

We retain your personal information for as long as necessary to:

• (a) Provide the Service and fulfill the purposes described in this Privacy Policy;
• (b) Maintain and improve AI systems and Service performance;
• (c) Comply with legal, accounting, or reporting obligations;
• (d) Resolve disputes and enforce our agreements; and
• (e) Protect our legitimate business interests.

When personal information is no longer needed for these purposes, we will securely delete or anonymize it. Anonymized data may be retained indefinitely.

8. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information. We honor the following rights for all users, subject to applicable law:

8.1 Right to Access

You have the right to request a copy of the personal information we hold about you.

8.2 Right to Correction

You have the right to request that we correct inaccurate or incomplete personal information.

8.3 Right to Deletion

You have the right to request deletion of your personal information, subject to certain exceptions (such as data we are legally required to retain). You may request account deletion at any time.

8.4 Right to Opt Out

You may opt out of promotional communications at any time by following the unsubscribe instructions in our emails or by contacting us at Tpadmin@ThoughtPartnr.com. Please note that you may still receive transactional or service-related communications.

8.5 Exercising Your Rights

To exercise any of these rights, please contact us at Tpadmin@ThoughtPartnr.com. We will respond to your request within the timeframe required by applicable law, and in any event within thirty (30) days.

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:

• (a) The right to know what personal information we collect, use, disclose, and sell (we do not sell personal information);
• (b) The right to delete personal information we have collected from you, subject to certain exceptions;
• (c) The right to correct inaccurate personal information;
• (d) The right to opt out of the sale or sharing of personal information (we do not sell or share personal information for cross-context behavioral advertising); and
• (e) The right to non-discrimination for exercising your privacy rights.

To submit a request, contact us at Tpadmin@ThoughtPartnr.com. We will verify your identity before processing your request.

10. European and UK Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, the General Data Protection Regulation (GDPR) or UK GDPR provides you with additional rights, including:

• (a) Right of access to your personal data;
• (b) Right to rectification of inaccurate data;
• (c) Right to erasure ("right to be forgotten");
• (d) Right to restrict processing;
• (e) Right to data portability;
• (f) Right to object to processing; and
• (g) Right to withdraw consent at any time where processing is based on consent.

10.1 Legal Bases for Processing

We process your personal data on the following legal bases:

• (a) Contract: Processing necessary to perform our contract with you (providing the Service);
• (b) Legitimate interests: Processing necessary for our legitimate business interests, such as improving the Service, fraud prevention, and analytics, where those interests are not overridden by your rights;
• (c) Consent: Where you have provided consent for specific processing activities; and
• (d) Legal obligation: Processing necessary to comply with applicable laws.

10.2 International Data Transfers

Your data may be transferred to and processed in the United States and other countries where our service providers operate. When we transfer personal data outside the EEA or UK, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission or the UK Information Commissioner's Office.

10.3 Supervisory Authority

If you are located in the EEA or UK, you have the right to lodge a complaint with your local data protection supervisory authority if you believe our processing of your personal data violates applicable law.

11. Children's Privacy

The Service is not intended for individuals under the age of eighteen (18). We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe a child has provided us with personal information, please contact us at tpadmin@ThoughtPartnr.com.

12. Third-Party Links

The Service may contain links to third-party websites, services, or resources that are not owned or controlled by ThoughtPartnr. We are not responsible for the privacy practices of third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the Service or via email at least thirty (30) days before they take effect. The Effective Date at the top of this document will be updated accordingly. Your continued use of the Service after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: