Pensive Privacy Policy

Last Updated: 12/06/24

Junto Tech, Inc. DBA Pensive ("Pensive" or "we") operates an AI-powered personal development and coaching platform. This Privacy Policy is designed to help you understand how we collect, use, and disclose your personal information and to help you understand and exercise your privacy rights.

SCOPE

This Privacy Policy applies to personal information processed by us, including on our websites and mobile applications, and in connection with other online or offline services we offer to our customers. To make this Privacy Policy easier to read, we collectively refer to our websites, mobile applications, and other offerings as “Services.”

PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you directly provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

User Account Creation. We may collect information, such as your name, email address, profile photo, and password, when you create a user account. We collect this information to provide account-related functionalities to users.
Personal Development Information. We may collect information about your goals, habits, emotions, and values, your progress data, and your responses to coaching prompts. We use this information to personalize your coaching experience and uncover insights that support your self-development journey. This may include tailoring advice, recommending exercises, and adjusting the AI's approach to best suit your individual needs and goals.
Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us. We use this information to communicate with our users about their accounts, their activities on our Services, and policy changes.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV, and/or cover letter to us, we will collect and use your information to evaluate your application or consider you for other positions.

Information Collected Automatically

We may collect personal information automatically when you use our Services through cookies, server logs, and other tools on our Services:

Your Use of Our Services. We use technology (e.g., a cookie or a pixel) to learn how you engage with our Services. This may include which links you click or what you type into our online forms. We may also track your IP address, the website that referred you to us, and data about your device. We collect this information to operate our Services. We also use it to understand how you interact with our Services, gather analytics, improve our Services, and learn your preferences. We may also use this information to help detect and prevent fraud.
Technology on Our Services for Targeted Advertising. We may let third parties place tracking technology on our websites (e.g., a cookie or a pixel). The third party might also collect data over time and across other websites. Among other things, they may use this data to serve ads tailored to your interests, which may include ads about us or our Services.
Mobile Devices. We collect information your device broadcasts when you use our Services.

C. Information Collected from Other Sources

We may collect personal information about you from other sources, including our affiliates, vendors, social media networking sites, publicly available sources, other companies (such as a those operating app stores or services that provide personal development or wellness content), or third-party applications.

HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including to provide our Services to you or third-party customers, for administrative purposes, and to market our products and Services. In addition to uses discussed elsewhere in this Privacy Policy, we may use your information to:

Identify you when you use our services;
Manage your information and accounts;
Provide access to certain areas, functionalities, and features of our Services;
Process your financial information and other payment methods for products or Services purchased.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
Improve, upgrade, or enhance our Services;
Develop new products and Services;
Protect your, our, and other customers’ and individuals’ safety;

Authenticate and verify individual identities, including requests to exercise your rights under this Privacy Policy;
Debug to identify and repair errors with our Services;
Conduct audits relating to interactions, transactions, and other compliance activities;
Enforce our agreements and policies; and
Comply with our legal obligations.

Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising, and interest-based or personalized advertising, including through cross-device tracking. We may use your information for retargeting and advertising purposes on platforms such as Facebook and Google.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

We also use your information for other purposes as requested by you or as permitted by applicable law, including in the following contexts.

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends or colleagues through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend or colleague to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

Training and Improving AI Models. We may use data to train and improve our AI coaching models.

HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. We do not sell your personal information.

Disclosures to Provide our Services

The categories of third parties with whom we may disclose your information are described below.

Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services. This may also include AI and machine learning service providers that help us improve our coaching algorithms.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
Affiliates. We may share your personal information with our company affiliates.
Other Users/Website Visitors. Our Services allow you to share your profile and/or user content with other users.
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).

Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);
Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
Request Deletion of your personal information;
Request Restriction of or Object to our processing of your personal information; and
Withdraw your Consent to our processing of your personal information (where applicable).

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected, including use of encryption and authentication technology. We also require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Pensive has collected about them and whether Pensive disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information Collected by Pensive	Category of Third Parties Information is Disclosed to for a Business Purpose
Identifiers. A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.	Service providers Other users (name, email address, alias) Third-party customers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, employment, and/or employment history.	Service providers Other users (name, employment) Third-party customers
Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Service providers Other users (information you choose to share in your profile) Third-party customers
Commercial information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Service providers Third-party customers
Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.	Service providers Third-party customers
Professional or employment-related information Current or past job history or performance evaluations.	Service providers
Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, and attitudes.	Service providers Third-party customers
Personal Development Information Information about goals, habits, emotions, values, responses to coaching prompts, and more.	Service providers Third-party customers

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

“Sales” of Personal Information under the CCPA

For purposes of the CCPA, Pensive does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Referral and Incentive Programs. As described above in How We Use Your Personal Information (“Share Content with Friends or Colleagues”), we may offer referral or incentive programs. We may offer incentives to you such as discounts or promotional credit in connection with these programs, wherein you provide personal information regarding your friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) These referral programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of the referred party’s data to us depends on whether the referred party ultimately becomes a user and uses our Services. Said value will be reflected in the incentive offered for each referral.

Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have acknowledged the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Junto Tech, Inc. DBA Pensive

344 Grove St #4067

Jersey City, NJ 07302

support@pensiveapp.com