PB JAM Privacy Notice

Effective September 29, 2026 · Version 2 · Earlier versions

This Privacy Notice explains how PB JAM LLC ("PB JAM", "we", "us", "our") collects, uses, shares and protects your personal information when you use our services ("Services"), which include:

• our website at www.pbjam.in, and any website of ours that links to this notice;
• the PB JAM app, which you sign in to from our website, and its public demo;
• our soft-skill development experiences: 1-4 hour workshops (standard and bespoke), 4-week micro-credentials and lightning certifications, and multi-week programs including, but not limited to, Better You!, Beyond Placement, Resilience and Wellness, Free Your Calendar, Red Inbox No More and Character Based Leadership, offered directly and/or through our partners; and
• other ways you engage with us, including marketing and events.

We decide how your personal information is processed. If you have questions, email privacy@pbjam.in. If you do not agree with this notice, please do not use our Services.

Summary of key points

• What we process: the information you give us (such as your name, email and job title), what you create in our programs (such as reflections, discussion messages and feedback), and basic technical information. More
• Sensitive information: we do not ask for it. More
• Why: to run our programs and the app, communicate with you, keep the Services secure, and comply with law. More
• AI: if your program allows it, group and cohort conversations can be summarized by an AI provider, Anthropic, with names removed. More
• Sharing: with the people in your program as the Services and your choices allow, and with service providers who work for us under written contracts. We do not sell your personal information. More
• Your rights: depending on where you live, you can access, correct, delete or obtain a copy of your information. More

Contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on?
4. When and with whom do we share your information?
5. Do we use cookies and other tracking technologies?
6. Do we offer AI-based features?
7. How do we handle social logins?
8. How long do we keep your information?
9. How do we keep your information safe?
10. Do we collect information from minors?
11. What are your privacy rights?
12. Controls for Do-Not-Track features
13. Do United States residents have specific privacy rights?
14. Do other regions have specific privacy rights?
15. Do we make updates to this notice?
16. How can you contact us about this notice?
17. How can you review, update or delete your data?

1. What information do we collect?

Information you give us

We collect personal information that you provide when you register, take part in a program or activity on the Services, express interest in our Services, or contact us. Depending on how you use the Services, this may include:

• your name, email address, phone number, job title, username and password (passwords are stored by our authentication provider in a form we cannot read);
• profile details you choose to add, such as industry, function, role, experience band or location;
• what you create in our programs, such as written reflections, discussion messages, peer feedback, goals and steps, and documents you upload; and
• program records, such as attendance, completion and certificates.

Everything you write starts private. Who else can see it depends on your program's settings and on what you choose to share; the app's What I share page shows both.

Sensitive information. We do not ask for sensitive information (such as health, racial or ethnic origin, religious beliefs or sexual orientation). Please do not include it in what you write.

Payment data. If you make a purchase, your payment details are collected and stored by our payment processor, Stripe; we do not store your card number. See Stripe's privacy notice.

Information you provide must be true, complete and accurate, and you should tell us about any changes.

Information collected automatically

When you use the Services, our systems record technical information such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, approximate location derived from your IP address, and when and how you use the Services. The app also stores your time zone so deadlines are shown in your local time. We use this information to operate and secure the Services and for internal reporting. It does not, on its own, identify you by name.

2. How do we process your information?

We process your information to provide, improve and administer the Services, communicate with you, keep the Services secure, and comply with law. Specifically, we process it:

• to create and manage your account and let you sign in;
• to deliver our programs, including group formation, sessions, reflections, feedback, attendance and certificates;
• to enable communication between you and the other people in your program;
• to provide AI summaries of discussions where your program allows it (see section 6);
• to respond to your questions and provide support;
• to send administrative information, such as reminders and changes to our terms and policies;
• to fulfill and manage orders and payments;
• to request feedback about your experience;
• to protect the Services, including fraud monitoring and prevention;
• to understand usage trends so we can improve the Services; and
• to protect someone's vital interests, such as to prevent harm.

We process your information for other purposes only with your prior consent.

3. What legal bases do we rely on?

If you are in the EU or UK: we rely on performance of a contract (providing the Services you or your organization signed up for), legitimate interests (for example, securing and improving the Services, and program features such as AI summaries where your program has chosen them), consent (where we ask for it; you can withdraw it at any time, see section 11), legal obligations, and vital interests.

If you are in Canada: we process your information with your express or implied consent, which you can withdraw at any time, or where the law permits us to without consent (for example, for fraud prevention, or to comply with a subpoena, warrant or court order).

4. When and with whom do we share your information?

• People in your program. Other participants and your facilitators see what the Services show them and what you choose to share. Sponsors and program coordinators see only whether required work is done, never what you write.
• Service providers. We share personal information with service providers who process it on our behalf, under written contracts that limit their use of it:
  • Supabase - database, authentication and application hosting;
  • Hostinger - website and app file hosting, and delivery of account and program emails;
  • Anthropic PBC (United States) - AI summaries of group and cohort discussions, from pseudonymized text with names replaced by labels (see section 6); and
  • Stripe - payment processing, if you make a purchase.
• Business transfers. We may share or transfer information in connection with a merger, sale of company assets, financing or acquisition of all or part of our business.
• Legal requirements. We may disclose information where the law requires it.

We do not sell your personal information, and we do not share it for targeted advertising.

5. Do we use cookies and other tracking technologies?

We use only what the Services need to work: the app keeps you signed in and remembers settings in your browser. Our website loads fonts from Google Fonts, which receives your IP address when it does. We do not use advertising trackers or third-party analytics. Links to other services (for example, booking a call through Calendly) take you to sites with their own policies. Details are in our Cookie Policy.

6. Do we offer AI-based features?

AI summaries of discussions. PB JAM can show you a short summary of your group and cohort conversations, written by an AI. To make it, we send the text of those conversations to our AI provider, Anthropic PBC, in the United States. Before anything leaves our systems, we replace people's names with labels such as "Participant A" and "Facilitator". Names are removed, but what people write can still identify them. Direct messages are never included.

• A summary covers only conversations you can already read, and is shown only to you.
• We keep a summary for up to 14 days. It is deleted sooner when a message in the conversation is edited or deleted, when your program's setting changes, or when you delete your account.
• Each program agreement decides whether summaries are used. For educational institutions and credit-bearing programs, they are off unless the partner turns them on. If your program has them off, your messages are never sent, and others see only that a message was not included. The app's What I share page shows your program's setting.
• Anthropic processes this text only to produce the summary, under its commercial terms. It does not use the text to train its models, and it deletes it within 30 days, unless it must keep it longer to enforce its usage policy or to comply with the law.

Summaries help people catch up on a conversation. They are not used to make decisions about you.

7. How do we handle social logins?

If we offer sign-in with a third-party account and you choose to use it, we receive basic profile information from that provider, such as your name and email address, and use it only as this notice describes. The provider's own privacy notice governs what it does with your information.

8. How long do we keep your information?

We keep personal information only as long as needed for the purposes in this notice, and no longer than you have an account with us, unless the law requires or permits a longer period (for example, for tax or accounting). Some records last for shorter periods: AI summaries for up to 14 days (section 6). Program records that prove a certificate was earned may be kept so the certificate can still be verified. When we no longer need information, we delete or anonymize it; information in backups is isolated until it can be deleted.

9. How do we keep your information safe?

We use technical and organizational measures designed to protect your information, including access rules enforced in our database so that people see only what they are allowed to see. No transmission or storage is 100% secure, so we cannot guarantee that unauthorized parties will never defeat our safeguards. Please use the Services from a secure environment.

10. Do we collect information from minors?

We do not knowingly collect data from, or market to, anyone under 18 (or the equivalent age in your jurisdiction). If we learn that we have, we will deactivate the account and promptly delete the data. If you believe we have, contact dpo@pbjam.in.

11. What are your privacy rights?

Depending on where you live (for example, the EEA, UK, Switzerland, Canada and several US states), you may have the right to access and obtain a copy of your information, to correct or delete it, to restrict or object to its processing, to data portability, and not to be subject to decisions made solely by automated means that significantly affect you. To make a request, submit a data subject access request or email privacy@pbjam.in. We will respond as applicable law requires.

Withdrawing consent. Where we rely on your consent, you can withdraw it at any time by contacting us. This does not affect processing that took place before, or processing on other legal grounds.

Marketing emails. You can unsubscribe at any time using the link in our emails or by contacting us. We will still send service messages needed to run your account.

Your account. You can review and update your account in the app, or contact us. If you ask us to close your account, we will delete or deactivate it and your information, except what we must keep to prevent fraud, resolve problems, enforce our terms or comply with law.

Complaints. If you are in the UK, you can complain to us first; we will acknowledge within 30 days, investigate without undue delay and explain the outcome. You may also complain to the Information Commissioner's Office. In the EEA, you may complain to your national data protection authority; in Switzerland, to the Federal Data Protection and Information Commissioner.

12. Controls for Do-Not-Track features

There is no agreed standard for Do-Not-Track browser signals, so we do not respond to them. We do honor Global Privacy Control signals as a request not to sell or share your information, which we do not do in any case.

13. Do United States residents have specific privacy rights?

If you live in a US state with a comprehensive privacy law (including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia), you may have the right to know whether we process your personal data, to access, correct and delete it, to obtain a copy, to not be discriminated against for exercising your rights, and to opt out of targeted advertising, sale and profiling. Some states also let you obtain a list of the categories of third parties, or the specific third parties, to whom we have disclosed personal data.

What we collect. In the past 12 months we have collected: identifiers (such as name, email and account name); personal information under California's Customer Records statute (such as name, contact details and employment information); professional or employment-related information; and content you create in our programs. We have not collected biometric information, precise geolocation, or protected classification characteristics.

Disclosure. We disclose personal information to the service providers listed in section 4 for business purposes, under written contracts. We have not sold or shared personal information in the past 12 months, and we will not sell or share it.

How to exercise your rights. Submit a data subject access request or email privacy@pbjam.in. We will verify your identity before acting, and may ask an authorized agent for signed proof of authority. If we decline your request, you may appeal by emailing us; if your appeal is denied, you may complain to your state attorney general. California residents may also request, once a year, information about any disclosures for direct marketing (the "Shine the Light" law); we make none.

14. Do other regions have specific privacy rights?

Australia and New Zealand. We process your information under Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. You can ask to access or correct your information (see section 17). If you believe we have breached the privacy principles, you may complain to the Office of the Australian Information Commissioner or the Office of the New Zealand Privacy Commissioner.

South Africa. You can ask to access or correct your information (see section 17). If you are not satisfied with how we handle a complaint, you may contact the Information Regulator.

15. Do we make updates to this notice?

Yes. Each version has an effective date and a version number, and earlier versions stay available on our policy versions page. When a change matters, the app asks you to review and accept the new version, with a short note on what changed.

16. How can you contact us about this notice?

Email our Data Protection Officer at dpo@pbjam.in, call 844-521-2345, or write to: PB JAM LLC, Data Protection Officer, 14543 Chadwick St, Leawood, KS 66224, United States.

17. How can you review, update or delete your data?

Depending on where you live, you may have the right to access the personal information we hold about you, learn how we have processed it, correct it, delete it, or withdraw your consent. To make a request, submit a data subject access request or email privacy@pbjam.in.