Privacy Policy

1. Introduction

This Privacy Policy explains how JC Consult LLC ("ValueOS", "we", "our", or "us"), located at 447 Broadway, 2nd Floor, 1647, New York, NY 10013, collects, uses, discloses, and safeguards your information when you use our web application and services (collectively, the "Service").

By using ValueOS, you agree to the collection and use of information in accordance with this policy. We may update this Privacy Policy from time to time. If we make changes, we will notify you by revising the "Last updated" date above. We encourage you to review this policy periodically.

2. Information We Collect

Information You Provide

We collect information you provide directly when you create an account, use our coaching features, or communicate with us. This includes:

• Name and email address (required for account creation)
• Profile picture (optional, via Google OAuth or manual upload)
• Personal stories and narratives you share during value discovery
• Your values, principles, and commitments
• Integrity report scores and reflections
• Chat conversations with our AI coach

ValueOS is designed around honest self-reflection. We do not seek sensitive information (such as health data, political opinions, or religious beliefs), but if you choose to share such information in your coaching conversations, you consent to our processing it as described in this policy.

Automatically Collected Information

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

• Device and browser information (such as browser type, operating system, and device identifiers)
• IP address and general location
• Usage information (such as pages viewed, features used, access times, and interactions with the Service)

3. How We Use Your Information

We use the information we collect to:

• Provide and maintain the ValueOS service
• Personalize your coaching experience with our AI
• Track your progress and generate integrity reports
• Send you important updates about the service
• Improve our product and develop new features
• Respond to your inquiries and support requests
• Detect and prevent misuse or security incidents
• Comply with our legal obligations

4. Legal Basis for Processing

We process your personal information on the following legal grounds:

• Contract performance: Processing necessary to provide the Service you signed up for, including AI coaching, value tracking, and integrity reports.
• Consent: For optional processing, such as receiving non-essential communications or sharing sensitive personal information in coaching conversations. You may withdraw consent at any time.
• Legitimate interest: Processing necessary for improving the Service, ensuring security, and communicating important updates, provided these interests do not override your fundamental rights.
• Legal obligation: Processing necessary to comply with applicable laws and regulations.

5. AI and Data Processing

Your data is not used to train AI models.

ValueOS uses artificial intelligence to provide personalized coaching. To do this, we share relevant context with our AI providers when you use the service:

• Anthropic (Claude) processes your coaching conversations, including your values, principles, commitments, and the stories you share. This is what allows your AI thinking partner to give you personalized, context-aware support.
• Google (Gemini) generates text embeddings for semantic search. It receives anonymized text fragments only, not your full conversations or personal data.

Both providers process your data solely to deliver the service. They do not use it to train their general models. They may temporarily retain data for safety monitoring in accordance with their own policies, but not for training or other purposes.

Please use discretion when sharing information with the AI coach. Given the nature of AI processing, it is not possible for us to selectively recall specific information once it has been submitted for processing.

6. Data Storage and Security

Your data is stored within the European Union.

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data at rest and in transit, strict access controls, and regular security reviews.

7. International Data Transfers

JC Consult LLC is based in the United States and your primary data is stored in the European Union. Some of our service providers (including AI providers) are also based in the United States. This means your information may be transferred to and processed in countries outside the EU.

Where we transfer personal information outside the EU, we rely on appropriate safeguards, including contractual data processing agreements with our providers, to ensure your data receives an adequate level of protection.

8. Data Sharing

We do not sell, rent, or trade your personal information. We do not use your data for advertising.

We share data only with the service providers necessary to operate ValueOS:

• AI providers that process your coaching conversations and generate text embeddings
• Cloud infrastructure providers for database hosting and authentication
• Email delivery services for transactional emails only

We may also share data when:

• Legal requirements: When required by law or to protect our rights
• Business transfers: In connection with a merger, acquisition, or sale of assets

9. Data Retention

We retain your personal data for as long as your account is active or as needed to provide the Service. If you request account deletion, we will remove your personal data within 30 days.

Conversation data already sent to AI providers for processing cannot be recalled after processing is complete, but it is not retained by those providers for training or other purposes.

10. Your Rights and Choices

You have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion of your data
• Export your data in a portable format
• Object to or restrict certain processing
• Withdraw consent at any time

Account Information

You may update your account information at any time through your account settings. If you wish to delete your account, you can do so through the account settings or by contacting us at [email protected].

Communications

You may opt out of non-essential communications at any time by using the unsubscribe link in our emails or adjusting your notification preferences in the application. We may still send you important service-related messages.

Questions or Complaints

To exercise any of these rights, please contact us at [email protected]. If you are in the EU and have a concern about how we process your data, you also have the right to lodge a complaint with your local data protection authority.

11. Cookies

ValueOS uses essential cookies for authentication and session management. We do not use tracking cookies or third-party advertising cookies.

12. Children's Privacy

ValueOS is not intended for users under 18 years of age. We do not knowingly collect personal information from children.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Last updated" date. Your continued use of the Service after changes constitutes acceptance of the updated policy.