This Privacy Policy describes how Datababy, Inc. (collectively “Datababy”, “we”, “us” or “our”) handles Personal Information when you use our website (“Site”) participate in our surveys, coaching sessions, or receive our emails and marketing communications (collectively with the Site, the “Services”).

FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM: PLEASE SEE THE “EEA, UK & SWISS PRIVACY RIGHTS” SECTION BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.

1. What is Personal Information?

In this Privacy Policy, “Personal Information” (sometimes referred to as “Personal Data”) means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, or as otherwise defined under applicable data protection laws. Personal Information does not include publicly available information or aggregated information that does not include personal identifiers.

2. Categories of Personal Information We Collect

We may collect the following categories of Personal Information from or about you, including when you use the Site or the Services:

Identifiers: such as your first name, last name, address, email address and telephone number (but only if you provide it to us).
Protected Classifications Under Applicable Law: such as your race, religion, sexual orientation, gender identity, gender expression, or age (but only if you provide it to us).
Commercial Information: such as survey results and other feedback you provide us; information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
Internet Data: such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city or town.
Geolocation Data: imprecise geolocation data such as your city, state, zip code, and country (based on IP Address).
Sensory Data: such as images, videos, and other content that you upload or submit to us through the Services, such as by participating on a panel, answering survey questions or uploading content, including pictures, video, captions and other text, audio, and metadata associated with those files.
Professional Data: such as your information about your employer, information from your resume or other information we may collect in operating the Service or when you apply for a job.
Educational Data: such as information about your schools attended, dates attended, degrees received and other information we may collect in operating the Service or when you apply for a job.
Inference Data: such as your preferences for receiving marketing communications, details about how you engage with our marketing communications and inferences we make from your Sensory Data.

3. Sources of Personal Information

We collect Personal Information from the following three sources:

Information you provide to us

We collect Personal Information from you when you communicate with us, participate in our surveys and focus groups or as otherwise identified in this Privacy Policy.

Information from third-party sources

We may collect Personal Information about you which we obtain from other sources, such as:

Third-party platforms: If you choose to connect the Services to a social media or other third-party platform, such as when you log in using a social media account, we will collect the information shared by the platform such as your username or handle, name, image, profile data, and other information. We will treat any information that you or the platform may provide to us in accordance with this Privacy Policy. When you visit or interact with our pages on one of those platforms, the platform provider's privacy policy will apply to your interactions and their collection, use, and processing of your Personal Information.
Business partners: such as clients and affiliates of such entities.
Public sources: such as publicly available social media profiles, directories, and other third-party sources.

Data collected automatically

We, our service providers, and our business partners may automatically log the following information about you, your computer or mobile device, and your activity over time on the Services and other online services:

Device data as described above under “Internet Data”
Usage data: pages or screens you viewed on our Site, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen or with our email communications, access times, and duration of access.
Cookies: text files stored on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently and remembering your preferences, enabling functionality, helping us understand user activity and patterns, facilitating online advertising and measuring the effectiveness of our ads.
Javascript libraries: snippets of code within web pages that execute when certain actions take place.
Web beacons: also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content within it was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.

4. How We Use Your Personal Information

We use your Personal Information for the following purposes or as otherwise described to you in this Privacy Policy or at the time of collection:

a. To Operate the Services

We use your Personal Information to:

provide, operate, maintain, and improve the Service;
conduct coaching sessions, analyze results, and communicate with you;
communicate with you regarding the Services, including by sending you Service announcements, technical notices, updates, security alerts, and support and administrative messages;
analyze and share your survey responses with our clients and brand partners;
process your Service transactions and process any related payments;
understand your opinions, needs and interests, and personalize your experience with the Service;
provide support for the Service and respond to your requests, questions and feedback;
provide for the monitoring and security of our Site; and
provide Services to our clients.

b. Research and development

We may use your Personal Information for research and development purposes, including to analyze and improve the Service and our business and develop other products and services. As part of these activities, we may create aggregated, de-identified or other anonymous data from the Personal Information we collect. We make Personal Information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service, but we will not reidentify any Personal Information once it has been deidentified.

c. Marketing

We may collect and use your Personal Information for marketing and advertising purposes. For instance, if you request information from us, use the Service or participate in our surveys, promotions or events, we may send you Datababy-related marketing communications as you request or as permitted by law. We will also provide you with the ability to opt-out of receipt of marketing materials, which you can exercise at any time. We use this Personal Information in several ways, including providing our services to our clients and brand partners, monitoring website activity, and enabling you to communicate with us and request information.

d. Compliance and protection

We may use your Personal Information to:

protect our, yours or others' rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements and internal policies;
enforce our Terms of Use, or our Master Service Agreements (or similar agreements), including those with our clients;
protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; or
comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

Other purposes with your consent

In some cases, we will ask for your consent to collect, use or share your Personal Information for other purposes. For example, we may ask for your consent to send you marketing emails where required by law or to post your testimonial or endorsement.

5. Parties With Whom We Share Your Personal Information

We may share your Personal Information with the following parties:

Our employees: We share your Personal Information with employees who need access to it for marketing, customer service, sales, customer success, research, product development, technology, and operations purposes. This includes scheduling and working with you on surveys, coaching sessions, and operating our business.
Our clients: We share your Personal Information with our clients. For example, when you participate in one of our surveys, we will disclose the information you provide to our clients. Please note that once we share your Personal Information with another company in the above circumstances, the information received by the other company is controlled by that company and becomes subject to the other company's privacy practices.
Service providers: We work with companies and individuals to help provide the Service on our behalf or help us operate the Service or our business (such as IT, customer support, hosting, website analytics, email delivery, marketing and advertising, research, and event management). These service providers are permitted to use your Personal Information only to help us operate the Service or our business as authorized under our contracts with them.
Professional advisors: We may disclose your Personal Information to professional advisors, such as lawyers, bankers, investment bankers, accountants, auditors, and insurers, where necessary in the course of the professional services they render to us.
Compliance and protection: We may disclose your Personal Information as we believe appropriate to government or law enforcement officials or private parties: (a) for the compliance and protection purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.
Business transfers: We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of all or substantially all of our assets, or in the event of bankruptcy. We may also share that Personal Information as part of due diligence with regard to any such proposed transaction.

6. Website Analytics

We use analytics services and targeted advertising cookies in addition to location features that are connected to your use of the Services. We use cookies, web beacons, pixel tags, and other technologies (collectively “Cookies”) on our Services to automatically collect information used to improve the Services and to advertise to you. A cookie is a small text file that our Services save onto your computer or device when you use the Site.

A cookie can either be a “session” cookie or a “persistent” cookie. Session cookies exist only for so long as you are visiting the Site and are typically deleted when you exit your web browser. Each time you visit a Website that has implemented a persistent cookie, the persistent cookie is renewed, and that cookie will remain active until its predetermined expiration date.

Website Analytics

We use third-party software tools on our Website to learn more about how visitors navigate the Site and view content. These third-party analytics providers provide us with analytical information collected through the Cookies that we use to improve the Site, to make sure it is easy to use, and to develop content that is both interesting and customized.

Google Analytics: We have enabled Google Analytics. We use this analytics information to evaluate the use of the Site, compile reports on Site activity, and for our use and for providing other services relating to activity on and use of the Site. To prevent Google from using data collected by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics opt-out browser add-on will not prevent us from using other analytics tools and will not prevent data from being sent to the Site itself or to Google. Opting out will not affect your use of the Site. For more information on how Google uses Personal Information, visit Google's Privacy Policy and Google's page on How Google uses data when you use their partners' websites or apps.

7. Your Privacy Choices

We provide you with the ability to make certain choices with regard to the Personal Information we collect from you as described below:

Access, delete or update your information: You may review, update, correct or delete the Personal Information in your registration profile by logging into your account or emailing us at privacy@datababy.io.
Opt-out of marketing communications: You may opt out of marketing-related emails by logging in and changing your account settings or by following the opt-out prompt in the email. You may continue to receive Service-related and other non-marketing emails.
Declining to provide your Personal Information: If you do not provide the information indicated as required or mandatory within the Service, or that is otherwise necessary to provide a requested service or feature within the Service, that portion or all of the Service may be unavailable to you and we may deactivate your account.
Third-party platforms or social media networks: If you choose to connect to the Service via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third party at the time you log in to the Service using the third-party's authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third party's platform or service. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.

8. Security

The security of your Personal Information is important to us. We take organizational, technical and physical measures consistent with applicable data protection laws designed to protect the Personal Information we collect, both during transmission and once we receive it. For instance, we protect Personal Information using physical protections, access controls, penetration testing, firewalls, multi-factor authentication, and end-point monitoring.

9. International Data Transfers

Datababy is headquartered in the United States and has service providers in other countries. We may transfer your Personal Information to the United States or to other locations outside of your home country for processing and storage. Privacy laws in the locations where we handle your Personal Information may differ and not be as protective as the privacy laws in your home country. When required by applicable data protection laws, we will use data transfer mechanisms such as Standard Contractual Clauses before transferring your Personal Information cross-border.

10. Data Retention

We will only keep Personal Information as long as we need that information for the purposes for which we collected it or as required by applicable law. If you have any questions about our data retention practices, please contact us at privacy@datababy.io.

11. Data Governance

Data Privacy is an obligation for all Datababy employees. Our privacy and security responsibilities are also cross-functional, aimed at protecting information concerning our participants, employees, and clients.

12. Third-Party Sites and Services

The Services may contain links to other websites and services operated by third parties, such as social media platforms, advertising services, and other websites and applications. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third-party websites, applications, or services, and are not responsible for their actions. Other websites and services follow different rules regarding their collection, use, and disclosure of your Personal Information. We encourage you to read their privacy policies to learn more.

13. Children

We will not knowingly collect information from users under the age of 18 without the consent of such individual's parent or legal guardian. If we learn that we have collected Personal Information from a user under the age of 18 without prior parental consent, we will take appropriate steps to delete that individual's Personal Information and restrict that individual from future access to the service, until such consent has been obtained. If a parent has any questions about our data privacy collection and use practices, or to request access to review or delete a child's information, please contact us at privacy@datababy.io.

14. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, we will notify you by posting the new Privacy Policy on our website and changing the effective date listed at the top of the Policy or otherwise communicating with you. If required by law, we will also notify you of changes in another way that we believe is reasonably likely to reach you, such as via email (if you have an account linked to a valid email address) or another manner through the Services.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes in the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any updated Privacy Policy indicates your acknowledgement of the update or modification(s).

15. EEA, UK & Swiss Privacy Rights

The purpose of this Section is to provide information and additional provisions that apply to Datababy's processing of Personal Data in accordance with the EU General Data Protection Regulation 2016/679, the UK General Data Protection Regulation and the Swiss Federal Data Protection Act (collectively “GDPR”). The terms in this section are only applicable to those persons located in the European Economic Area (“EEA”), Switzerland, and the United Kingdom (“UK”) (collectively, “EU Data Subjects”).

In the event of a conflict between this section and the remainder of the Privacy Policy, this section shall control for EU Data Subjects.

Lawful basis for Processing Personal Data of European Data Subjects

We process the personal data of European Data Subjects on the following lawful bases:

Legitimate Interests: Where the processing is necessary for the purposes of the legitimate interests pursued by Datababy or by a third party and not overridden by your fundamental rights and freedoms (e.g., product development and security purposes);
Performance of a Contract: Where the processing is necessary for the performance of a contract with you (e.g., to deliver the service you have requested);
Consent: Where you have given explicit consent to the processing of your Personal Information for one or more specific purposes (e.g., new and unexpected processing activities); and
Legal Obligation: Where processing is necessary for compliance with a legal obligation to which Datababy is subject (e.g., compliance with laws and regulations).

Purpose of Processing	Lawful Basis
Operate the Service	Legitimate Interest, Consent, Performance of a Contract
Research and Development	Legitimate Interest
Marketing	Legitimate Interest, Consent
Compliance and Protection	Legitimate Interest, Legal Obligations
Other Purposes	Consent, Legal Obligations

Privacy Rights of European Data Subjects

European Data Subjects have the following rights concerning their Personal Information under the General Data Protection Regulation, the UK GDPR or the Swiss FADP:

Withdrawal of Consent: If we are processing personal data on the basis of consent, you may have the right to withdraw consent to our processing at any time.
Access and Rectification: You may have the right to access, correct, and update your personal data.
Deletion/Erasure: You may have the “right to be forgotten” through the erasure or deletion of your personal data.
Portability: You may have the right to move, copy, and/or transfer certain personal data from our Services to another service.
Stop Processing: If processing is on the basis of legitimate interests, you may have the right to object to the processing of your personal data and to ask us to restrict the processing of your personal data, subject to certain limitations.
Submit a Complaint: You have the right to submit a complaint to a data protection authority about our collection and use of your personal data. Contact details for the EU/EEA are here:
- If you are located in the European Economic Area, https://edpb.europa.eu/about-edpb/about-edpb/members_en
- If you are located in Switzerland, https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
- If you are located in the United Kingdom, https://ico.org.uk/global/contact-us/contact-us-public/

Exercising Your Rights Under the European Data Protection Laws

You, or an authorized agent, may exercise your privacy rights by submitting a request to privacy@datababy.io.

We respond to and process requests promptly and within the time frames required by the European Data Protection Laws. Please note that all requests are subject to proper prior verification before processing. If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual's rights on their behalf.

Retention of European Data Subject Personal Data

Datababy retains personal data for a period commensurate with the purposes for which the personal data was collected or obtained. The criteria used to determine the retention of personal data includes any time necessary for legal and compliance purposes. Personal data may be retained in archival format (e.g., data backups) beyond its retention period.

Marketing

Datababy does not process personal data of European Data Subjects for the purpose of marketing without first obtaining your express, opt-in consent or having a legitimate interest for doing so. You have the right to object to the processing of personal data for marketing purposes at any time by contacting us at privacy@datababy.io.

Automated Decision Making

We do not make any automated decisions on your behalf or about you without first obtaining your express, opt-in consent. In the event we secure your consent to do so, you have the right to object to the processing of personal data via automated decision making at any time by contacting us at privacy@datababy.io.

16. Use of Artificial Intelligence

Datababy offers optional features that use artificial intelligence (“AI”) to generate customized content, recommendations, learning materials, interpretations, and simulations based on your Datababy profile data, including polarity and behavioral information.

AI Processing and Consent

Where required by law or by the nature of the feature, Datababy will obtain your explicit consent before using your data in AI-powered features. By enabling AI features, you consent to your Datababy profile data being processed by large language models solely for the purpose of generating personalized recommendations, insights, learning materials, and simulations.

Scope and Purpose of AI Use

AI-generated outputs are intended to support reflection, learning, practice, and development. These outputs are interpretive and probabilistic in nature and do not represent factual statements, guarantees, or decisions made by Datababy or any individual.

AI features may be available to you and, where applicable, to others based on your sharing settings within the Services.

No Model Training

Datababy does not use your Personal Information to train or improve general-purpose AI models. Your data is processed only to generate AI outputs requested through the Services and is not incorporated into model training datasets.

Temporary and Contextual Processing

Your data is referenced only as needed to generate AI-based outputs in context. AI processing is transient and limited to delivering the requested feature. Datababy does not create persistent AI replicas or autonomous profiles that operate independently of user-initiated interactions.

Control and Opt-Out

You may disable AI features or withdraw your consent at any time through your account settings. If you opt out, your data will no longer be processed for AI-generated recommendations, insights, or simulations, though your access to non-AI features of the Services may remain unaffected.

Disclaimer

1. General Advice Disclaimer

The insights and recommendations provided by Datababy are based on survey responses and behavioral models. They are intended for informational purposes only and are not a substitute for professional advice, including legal, medical, psychological, or business consulting services.

2. User Responsibility

Datababy supports organizations and individuals in making informed decisions, but all decisions and actions are the responsibility of the user or organization. We do not guarantee specific outcomes based on any recommendations provided through the platform.

3. No Medical or Mental Health Advice

Datababy is not a healthcare provider. Our content and analytics do not constitute or replace mental health treatment, diagnosis, or medical advice. If you are experiencing distress or mental health issues, please consult a licensed professional.

4. Coaching and Development Context

The feedback and suggestions provided are intended to support personal and team development. They are based on self and peer-generated data and should be considered as coaching-style guidance rather than prescriptive instructions.

5. Limitation of Liability

To the fullest extent permitted by law, Datababy disclaims any liability for decisions made or actions taken based on the content or suggestions provided through our platform.

Data Protection Inquiries

If you are a European Data Subject and you have questions about how we process your personal data, you may contact Datababy at privacy@datababy.io.

How to Contact Us

If you have any questions or concerns about our Privacy Policy or our privacy practices, please contact us at:

Datababy, Inc.

616 Mockingbird Drive

Murphy, TX 75094

Email: privacy@datababy.io