Privacy Policies

Adjutant Co is committed to protecting the privacy of individuals whose personal data we collect (“you” or “your”). Adjutant Co may collect personal data from individuals who register to use Adjutant Co’s services, applications, and programs (“Services”), visitors to our website, individuals who request information, prospective customers, and event attendees. This Privacy Policy describes how Adjutant Co and its subsidiaries and affiliated companies (“Adjutant Co” or “we”) collect, use, and disclose personal data, and the choices Adjutant Co offers regarding its collection and use of personal data.

This Privacy Policy does not apply to the information we collect about employees or job applicants, nor to information collected by third parties, like third-party websites, social media platforms or accounts, third-party service providers, or other third-party services or applications that integrate with our Services. This Privacy Statement also does not apply to any information that is not personally identifiable, like aggregated or anonymous information.

We may update this Privacy Statement from time to time and provide notice to you as described below in the section titled “Notice of Changes.” Our Services are not directed at children under the age of 18, and we do not knowingly collect personal data from individuals under the age of 18. If you are under the age of 18, you may not use the Services or provide your information to us.

Personal Data We Collect

Adjutant Co collects personal data directly from you, for instance when you inquire about one of Adjutant Co’s Services, or from your interactions with our website, products or Services. Adjutant Co may also collect personal data from

other sources and we may combine this data with data we already have about you. This personal data may include the following:

Contact details.

When you inquire about our Services, register for an event, or enter an AI chat, we may collect your contact details, such as your name, company, address, phone number and email address. If your company uses the Services and we provision you an account, we may collect your name, email address, and associated IP address as part of your company’s use of the Services.

Billing data.

When you purchase Services, we may collect billing and payment information. For automated transactions, such as credit card payments, we will use a third-party payment processor to process the payment. We do not collect your credit card number, expiration date, or pin number. The transaction details we retain are those details that allow us to verify that you paid for the Services or transaction, including price, currency, date of payment, payment method, name, and account name. We will combine that information with your account information.

Support data.

You may provide data or content for customer support. When you engage with our support team, in addition to your account information, we may ask you to provide additional information about your issue, which may include information about your technology, software, internet connection, or screenshots.

Device and usage data.

When you use our website or our Services, we may also automatically collect data about your device and about your usage of and activity on our website and Services. For example, we collect your device’s operating system type, IP address, device identifiers, browser type, device type, domain name, access times, and the duration of visit, and other information.

Data from our SMS service. When you use our SMS Services, we may collect your contact details, the geographic location of the device, the geographic locations you provide to our Services, and geographic areas derived from your IP address.

Cookies and Other Technologies.

When you navigate our website, we may use cookies, web beacons, pixels, or other technologies to collect data

about your device and activity on our website and in our Services to provide functionality, personalize your experience, and recognize you across services or devices.

Third-party applications.

The Services allow you to create connections or integrations between the Services and third-party applications you use. For example, a user may connect the Services to a third-party application to access a list of contacts stored in that application. We collect data that is transferred between the third-party applications that may allow us to identify your account within the third-party applications (like name, email address, phone number, tokens, or other identifying information), the log data, content, and device information. The information or content we receive from your organization is subject to your organization’s privacy policies. When you integrate our Services with a third-party application, the information we receive depends on the settings, permissions, and privacy policy controlled by that third-party application.

Partners.

Adjutant Co may engage in joint marketing activities or event sponsorships with our third-party partners and we may collect personal data about you from these activities. We also allow partners to provide referrals to Adjutant Co of individuals who may be interested in learning more about Adjutant Co’s Services. We rely on our partners to obtain your permission before sharing your personal data with us.

How We Use Your Personal Data

Adjutant Co uses your data to provide you with and improve upon the Services that you or your company requests and to communicate with you, as follows:

Providing and Improving Adjutant Co’s Services.

Adjutant Co uses the data you provide, or data that we collect when you use our Services, to operate our Services, provide you with the Services that you or your company has requested, and continually improve our Services, internal systems, website, and processes. We may use your data to authenticate your ability to access and use the Services. We also use your data to detect and prevent fraud, protect the security of our website and Services, and enhance the safety of our Services.

Further, we may also use data provided by you or collected by third-party service providers or partners on our behalf to troubleshoot or provide customer support. We may also use your data to plan and host events, including online webinars.

Communicating with you.

Adjutant Co’s website allows you to fill out forms for more details about our Services, and to engage with us via our AI chat functionality. We use this information to provide you with the material you requested and to follow up with you about your interest in the Services. We may also use personal data to understand you and your preferences so that we may enhance your experience and send you information about Adjutant Co.

Adjutant Co may also receive personal data from other sources, including third parties from whom we have purchased data, and combine this with the data we already have about you. This helps us update, expand and analyze our records, identify new customers, and create more tailored advertising to provide products and services that may interest you.

Advertising.

We may use data collected via cookies and other technologies to manage our advertising on other sites or to provide you with offers or advertisements, including for third-party services, based upon your browsing activities and interests. If you follow or like Adjutant Co on third-party social media sites, we can see your public profile and may direct advertising to you.

Legal obligations.

Where required by law, or where we think it is necessary to protect our legal rights and legitimate interests or the legal rights and interests of others, we use information about you in connection with legal claims, compliance and regulatory functions. If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfill your request, we will keep basic data to identify you and prevent further unwanted processing. As used above, “legitimate interests” means our interests in conducting our business and managing and delivering the best Services to you. We will not use your personal data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

With your consent. We use personal data about you where you have given us consent to do so for a specific purpose not listed above. For example, with your permission, we may publish testimonials or featured customer stories on

our website to promote the Services, including names and profile photos of representatives of our customers alongside the testimonial.

How We Share Personal Data

Service Providers.

Adjutant Co may share your data with our contracted service providers and vendors so that these service providers and vendors can perform services on our behalf. For example, we may use third parties to assist us with maintaining and delivering the Services (including server hosting and billing), providing customer service, detecting and preventing fraud, analyzing and improving the Services (including website analytics and data science), integrating our Services with third-party applications, and providing marketing and advertising services. These service providers are authorized to use your data only as necessary to provide the requested services to us. We may also share personal data with third-party social networking websites for our marketing and advertising on those websites. Unless described in this Privacy Policy, Adjutant Co does not share, sell, rent, or trade any data with third parties for their promotional purposes.

Billing.

Adjutant Co uses third-party service providers to manage credit card processing. This service provider is not permitted to store, retain, or use billing information except for the sole purpose of credit card processing on our behalf.

Affiliates and Subsidiaries. We may share your data with our subsidiaries and affiliates (those entities under common control) to provide the Services you request, such as customer support, marketing, technical operations, and account management purposes. Further, we may share your information with your teammates, account administrators, billing, or technical account users.

Compelled Disclosure.

Adjutant Co reserves the right to share your data if required by law or to comply with a judicial proceeding, court order, or valid legal process. We may also disclose your data to protect the rights and property of Adjutant Co, our agents, employees, partners, and customers, including to prevent or stop an attack on our systems or network or to prevent spam or attempts to defraud our users. Finally, we may also need to disclose your data in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding

involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company.

With Your Consent. We may share Personal Data about you with third parties when you give us consent to do so. For example, with your permission, we may publish and display testimonials or featured customer stories on our website, including names and profile photos of representatives of our customers alongside the testimonial.

How to Manage Your Personal Data

Communication Preferences. If you have received promotional communications from Adjutant Co via email and would like to opt out of future communications, you can click on the “unsubscribe” link located at the bottom of the email message. If you have engaged with the Adjutant Co SMS Intake Service and would like to opt out of future communications, you can respond by texting the message “STOP”.

If you receive communications from Adjutant Co customers via text message through our Services and would like to opt-out of future communications, you can respond by sending the message “STOP”. Any personal data you provided to Adjutant Co’s customers is the responsibility of that customer and subject to their privacy policy. Adjutant Co is not responsible for its customer’s privacy policies as the Services provider.

Data Security

Adjutant Co takes reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in the processing and the nature of the personal data. We use industry-accepted electronic and physical standards of security to reduce the risk of improper access to or manipulation of personal data during transmission and storage. However, no application, Internet, or email transmission is ever fully secure or error-free, and we do not guarantee the security of any personal data. You are also responsible for ensuring that your account and the passwords we provide you are protected.

California Privacy Rights

Beginning on January 1, 2005, California Civil Code Section 1798.83 permits customers of Adjutant Co who are California residents to request certain information regarding Adjutant Co’s disclosure of personal information to third parties for such third parties' direct marketing purposes. To make this request, contact us using the information in the “Contact Us” section below.

Notice of Changes

The Services, our website, and our business may change from time to time. As a result, we may make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time. If we make changes to this Privacy Policy, we will post the changes on this page and will indicate at the top of this page and the date these terms were last revised. If we make material changes, we will notify you through the Services user interface, as a pop up on our website, in an email notification, or through other reasonable means. Your continued use of the Services or our website after the date any such notice constitutes your acceptance of the modifications.

If you have any questions about this Privacy Policy, please email us at davidalexander@adjutantco.com.