Privacy Policy

Last Updated: October 10, 2026

This Privacy Policy (this "Policy") describes how Growth.how LLC, a California limited liability company ("Growth.how," "we," "our," or "us"), collects, uses, discloses, and safeguards personal information in connection with your use of the AI leadership coaching tool (the "Tool") made available to you either through your employer's or organization's engagement with Growth.how, or on an evaluation basis using a unique access code issued directly by Growth.how. By accessing or using the Tool, you acknowledge that you have read and understood this Policy.

1. Categories of Personal Information Collected. In connection with your use of the Tool, we may collect the following categories of personal information:

(a) Conversation Data. The text of your interactions with the Tool, including questions, responses, and any personal information you voluntarily disclose during a session, such as your role, reporting relationships, professional challenges, or team dynamics.

(b) Usage and Technical Data. Session timestamps, access logs, feature engagement data, and other information generated by your use of the Tool.

(c) Access Codes. If you access the Tool using a unique access code issued to you or to your organization, we collect and retain that access code in association with your conversation and usage data.

(d) Contact Requests. If you submit a request through the contact form made available with the Tool, we collect the name, email address, organization (if provided), and message you submit.

We do not intentionally request or collect sensitive personal information such as Social Security numbers, financial account data, health or medical information, or government-issued identification numbers through the Tool. Users are advised not to submit such information during sessions. If you choose to share such information, it becomes part of your Conversation Data and is handled as described in this Policy.

2. Purposes for Which We Use Personal Information. Growth.how uses personal information for the following purposes:

(a) Delivery of Services. To operate the Tool, generate AI-assisted coaching responses, and provide the services either on an evaluation basis or as contracted for by your employer.

(b) Service Improvement and Quality Assurance. To analyze usage patterns, identify technical issues, and improve the quality and functionality of the Tool.

(c) Engagement Reporting. To generate aggregated reports for Client Organizations and prospective client organizations, including utilization data and thematic insights, that are not attributed to individual users, as described in Section 3.

(d) Legal Compliance and Enforcement. To comply with applicable legal obligations and to establish, exercise, or defend legal claims.

(e) Responding to Inquiries. To respond to requests submitted through the Tool's contact form.

(f) Safety. To address a serious or imminent threat to the safety of any person, as described in Section 3(f).

We do not use your personal information to train, fine-tune, or otherwise develop AI models. Conversation data may be reviewed by us to assess or evaluate team dynamics or to improve the Tool. Conversations are not continuously monitored or reviewed in real time, and you should not rely on Growth.how to identify or respond to an emergency. Conversation data is not shared with or reviewed by your employer organization, except as described in Section 3.

3. Disclosure of Personal Information. Growth.how does not sell, rent, or trade your personal information. We may disclose personal information to the following categories of recipients, and only to the extent necessary for the purposes described in this Policy:

(a) AI Infrastructure and Technology Providers. Third-party providers of the underlying AI and infrastructure technology used to operate the Tool.

(b) Client Organizations. Your employer may receive aggregated utilization data (for example, whether and how much the Tool was used) and aggregated thematic insights derived from users' conversations (for example, common themes across those conversations), in each case not attributed to individual users. Individual conversation data will not be shared with your employer without your prior written consent, except as required by law or as described in Section 3(f).

(c) Prospective Client Organizations (Demo Access). If you access the Tool using a Demo Access code issued to a prospective client organization, that organization may receive aggregated utilization data and aggregated thematic insights derived only from conversations conducted using its own access code, in each case not attributed to individual users. For example, whether and how much the Tool was used, or common themes across those conversations. A prospective client organization will not receive thematic insights derived from conversations of any other organization's users. Individual conversation data will not be shared with a prospective client organization without your prior written consent, except as required by law or as described in Section 3(f).

(d) Professional Advisors. Attorneys, accountants, and similar advisors, subject to professional obligations of confidentiality.

(e) Law Enforcement and Legal Process. As required by applicable law, court order, or governmental authority.

(f) Serious Safety Threats. To appropriate persons or authorities, where Growth.how reasonably believes disclosure is necessary to address a serious or imminent threat to the safety of any person. Conversations are not continuously monitored or reviewed in real time (see Section 2), and this Section 3(f) does not create any obligation on Growth.how to identify, monitor for, or respond to such threats.

4. Data Retention. We retain personal information only for as long as necessary to fulfill the purposes set forth in this Policy or as required by applicable law. Following the retention period, personal information is securely deleted or irreversibly anonymized. Notwithstanding the foregoing, we may retain conversation data longer, for engagement insights and for use in case studies.

5. Cookies and Tracking Technologies. The Tool may use cookies and similar tracking technologies (such as web beacons and session tokens) to operate and improve the user experience. Cookies are small data files placed on your device when you access the Tool. We use the following types of cookies:

(a) Strictly Necessary Cookies. Required for the Tool to function, including maintaining your session and authentication state. These cannot be disabled without impairing the Tool's functionality.

(b) Analytics Cookies. Used to collect aggregated information, not attributed to individual users, about how users interact with the Tool, such as session duration and feature usage, for purposes of quality improvement. We do not use this data to identify individual users.

You may configure your browser to refuse or delete cookies; however, doing so may affect the functionality of the Tool. Growth.how does not respond to browser "Do Not Track" signals, as no industry-standard protocol for such signals has been established. If our practices change, we will update this Policy accordingly.

6. Your Privacy Rights. Depending on your state of residence, you may have certain rights with respect to your personal information. The following rights apply to California residents under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA"), and similar rights may be available to residents of other states with applicable privacy laws:

(a) Right to Know. The right to request information about the categories and specific pieces of personal information we have collected about you, the purposes for which we use it, and the categories of third parties with whom we share it.

(b) Right to Delete. The right to request deletion of your personal information, subject to applicable legal exceptions.

(d) Right to Opt Out of Sale or Sharing. Growth.how does not sell or share personal information as those terms are defined under the CCPA or analogous state privacy laws.

(e) Right to Non-Discrimination. We will not discriminate against you for exercising any of your privacy rights.

To submit a privacy rights request, please contact us at legal@growth.how. We will respond within the timeframe required by applicable law. We may require reasonable verification of your identity before processing your request. Because we do not collect names, email addresses, or other personal identifiers in connection with your conversations with the Tool, we are generally unable to associate a data access, correction, or deletion request with a specific individual's conversation data. This remains true even if you have separately submitted a request through the Tool's contact form, as that information is stored separately from, and is not associated with, your conversation data. As a result, we may be unable to fulfill a request to delete your conversation data.

7. International Users. The Tool is operated from, and personal information collected through the Tool is stored and processed in, the United States. If you are accessing the Tool from outside the United States, you understand and agree that your personal information will be transferred to, stored, and processed in the United States, a jurisdiction whose data protection laws may differ from those of your country of residence. By using the Tool, you consent to this transfer, storage, and processing. Individuals outside the United States may have privacy rights under the laws of their own jurisdiction in addition to, or instead of, those described in this Policy. Growth.how will make reasonable efforts to honor a privacy rights request consistent with applicable local law; to submit such a request, contact us at legal@growth.how.

8. Security. Growth.how implements reasonable and appropriate technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. Such measures include access controls, encryption in transit, and contractual data security obligations imposed on third-party service providers. Notwithstanding the foregoing, no security measure is infallible, and Growth.how cannot guarantee the absolute security of any information transmitted to or stored by the Tool.

9. Children. The Tool is not directed at individuals under the age of sixteen (16). Growth.how does not knowingly collect personal information from individuals under the age of sixteen (16). If we become aware that we have inadvertently collected personal information from such an individual, we will take prompt steps to delete it.

10. Amendments to This Policy. Growth.how reserves the right to amend this Policy at any time. Material amendments will be communicated to affected Client Organizations and/or users through the Tool interface or by written notice. The "Effective Date" at the top of this Policy will be updated to reflect the date of any amendment. Continued use of the Tool following notice of an amendment constitutes acceptance of the revised Policy.

11. Language. This Policy may be made available in languages other than English. In the event of any conflict between the English version and any translated version, the English version governs.

12. Contact Information. All inquiries, requests, and complaints regarding this Policy or Growth.how's privacy practices should be directed to: Growth.how LLC, 440 N. Barranca Ave., #4769 Covina, CA 91723. Email: legal@growth.how.