Privacy Policy

01What information do we collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• account credentials created through our authentication provider
• the information you enter to set up a coaching session, which may include your job title, your employer or prospective employer, your industry, your current compensation, the offer you have received, and the outcome you are targeting
• the text or transcribed speech you submit during a coaching session, and the outcome you log at the end of it

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• account login information
• financial information about your compensation, including current pay, offers received, target amounts, and negotiated amounts

We do not ask you for information about your race or ethnicity, health, sexual orientation, religious beliefs, or trade union membership, and we ask that you do not enter it. We do not use sensitive personal information to infer characteristics about you.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

Sign-In Provider Data. We may provide you with the option to register using an existing third-party account, such as a Google account. If you choose to register this way, we receive basic profile information from that provider, as described in the section called "How do we handle your social logins?" below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Location Data. We collect approximate location information, such as the country or region inferred from your IP address. We use it for security, fraud prevention, and understanding where our users are. We do not collect precise device location and do not use GPS.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

02How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "What are your privacy rights?" below.
• To generate coaching using artificial intelligence. We send the information you enter during a session to our AI service provider so it can produce coaching for you. See "Do we offer artificial intelligence-based products?" below.
• To post testimonials. We post testimonials on our Services that may contain personal information. We obtain consent before posting a testimonial that identifies you.
• To keep the Services secure and prevent fraud. We may process your information to monitor for abuse, prevent fraudulent transactions, enforce usage limits, and protect our Services and our users.
• To comply with our legal obligations. We may process your information to comply with applicable law, respond to lawful requests, and establish, exercise, or defend legal claims.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

03What legal bases do we rely on to process your information?

The Services are intended for users in the United States and Canada, and we do not target or market them to individuals in the European Economic Area or the United Kingdom. In the United States, we process your information to provide the Services you have asked for, to meet our contractual and legal obligations, to keep the Services secure, and with your consent where consent is required.

If you are located in Canada, the rest of this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

04When and with whom do we share your personal information?

We may need to share your personal information in the following situations:

• Service Providers. We share information with vendors who perform services for us under written contract and who may use it only to perform those services for us. They are: Clerk, for account creation and authentication; Stripe, for payment processing; Anthropic, for generating AI coaching; and Vercel, for hosting and delivering the Services. Each of these is bound by contract to use your information only on our instructions.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Legal requirements and safety. We may disclose your information where we are legally required to do so, including in response to a subpoena, court order, or lawful government request, or where disclosure is necessary to investigate suspected fraud or to protect the rights, property, or safety of our users or the public.

We do not sell your personal information, we do not share it for cross-context behavioral advertising, and we do not disclose it to advertising networks or data brokers.

We do not use the contents of your coaching sessions to train artificial intelligence models, and our agreements with our AI service provider prohibit that provider from using your inputs or outputs to train its models.

05Do we use cookies and other tracking technologies?

We use cookies and similar technologies (like web beacons and pixels) when you interact with our Services. They fall into three groups:

• Strictly necessary. These keep you signed in, maintain the security of your account, and make basic site functions work. The Services do not work without them.
• Analytics. These help us understand how the Services are used in aggregate so we can improve them, including which pages are visited and where people drop off.
• Advertising measurement. If you arrive from an advertisement, these tell us that the visit resulted in a sign-up so we can measure whether the advertising is working.

We do not use cookies to build advertising profiles about you, to serve you retargeted advertisements, or to track you across unrelated websites. To the extent advertising measurement is deemed a "sale" or "sharing" under applicable US state laws, you can opt out as described under "Do United States residents have specific privacy rights?"

Most browsers accept cookies by default. You can set your browser to refuse or delete cookies, though the Services may not work correctly without the strictly necessary ones.

Analytics providers

We may use Google Analytics to understand how the Services are used. We do not enable Google Analytics Advertising Features such as Remarketing or Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across websites, visit https://tools.google.com/dlpage/gaoptout. For more information on Google's privacy practices, see the Google Privacy & Terms page.

06Do we offer artificial intelligence-based products?

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including Anthropic. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "When and with whom do we share your personal information?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

• Generating suggested negotiation responses based on the situation you describe and what you tell us the other side has said
• Explaining the tactic behind a suggested response
• Building a negotiation plan from the offer and target you provide

How we process your data using AI

All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with our AI Service Providers. Those agreements prohibit the provider from using your inputs or outputs to train its models. Our AI Products produce suggestions for you to consider. They do not make decisions about you, and nothing they generate has legal or similarly significant effects on you.

07How do we handle your social logins?

Our Services offer you the ability to register and log in using a third-party account, such as a Google account. Where you choose to do this, we receive basic profile information from that provider, which typically includes your name, email address, and profile picture. We do not request or receive your contact list, friends list, or posts.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by that provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences.

08How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. In general, we keep your account information and coaching session content for as long as you maintain an account with us, and delete or anonymize it after your account is closed.

There is one exception. Records of payments and transactions are retained for as long as required by tax, accounting, and anti-fraud obligations, which is typically seven years, even after an account is closed. Those records are held by us and by our payment processor.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

09How do we keep your information safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10Do we collect information from minors?

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at support@programmanagementsolutions.com.

11What are your privacy rights?

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "How can you contact us about this notice?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "How can you contact us about this notice?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "How can you contact us about this notice?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at support@programmanagementsolutions.com.

12Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

13Do United States residents have specific privacy rights?

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months, with illustrative examples of each category. For a full description of what we collect, see "What information do we collect?"

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Categories A, B, F, G, H, I, K, and L — As long as the user has an account with us
• Category D — For as long as required by tax, accounting, and anti-fraud obligations, typically seven years

Sources of personal information

Learn more about the sources of personal information we collect in "What information do we collect?"

How we use and share personal information

Learn more about how we use your personal information in the section "How do we process your information?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section "When and with whom do we share your personal information?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

In the preceding twelve (12) months we have disclosed the categories of personal information marked YES above to our service providers for the business purposes described in this notice. We have not sold personal information, and we have not shared personal information for cross-context behavioral advertising. We do not sell or share the personal information of website visitors, users, or other consumers, and we have no knowledge of selling or sharing the personal information of consumers under sixteen years of age.

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to exercise your rights

To exercise these rights, you can contact us by emailing us at support@programmanagementsolutions.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at support@programmanagementsolutions.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "How can you contact us about this notice?"

14Do we make updates to this notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

15How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at support@programmanagementsolutions.com or contact us by post at:

16How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email support@programmanagementsolutions.com.