Privacy Notice

This Privacy Notice (this “Notice”) is entered into by and between you (“user”, “you”, and “your”) and JDL Sales LLC, a Michigan limited liability company doing business as Dealflow AI (“Company”, “we”, “our”, and “us”).

This Notice describes how we collect, process, retain, and disclose personal data about you when providing services to you through our websites, platform, applications, features, products, and services (collectively, our “Services”) and our practices for using, maintaining, protecting, and disclosing that information.

This Notice does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries) that does not link to this Notice; or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Services.

We may provide additional or different privacy notices or policies that are specific to certain features, services, or activities.

Please read this Notice carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this Notice. This Notice may change from time to time pursuant to Section 12 herein. Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check this Notice periodically for updates.

Do not use the Services if you are under the age of 18. Our Services are not intended for, and we do not knowingly collect any personal data from, users under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

“Personal information” or “personal data” is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, payment information, or any other identifier that may be used to contact you online or offline.

The types and categories of personal data we collect or process include:

• Account and contact information, including name, email address, username, password, and other contact information you provide us;
• Payment information, including credit card or debit card information (processed and stored by Stripe, our third-party payment processor), payment status, and information about the payment methods and services you use in connection with the Services;
• Account history, including information about your subscription, account, transactions, billing cycle dates, purchases, order history, or discounts;
• Device information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, page views and navigation patterns, session duration, browser type and settings, and other device information;
• Information you elect to provide as part of your subscription to or use of our Services;
• Session performance data, including pressure score, skill signatures, wall profile data, mechanism vulnerability scores, session turn history, and coaching feedback during and after sessions;
• Usage data, including scenarios attempted and completion rates, streak data, and difficulty tier progression through the pressure ladder;
• Artificial intelligence (“AI”) interaction logs, including user text inputs during DealBot simulation sessions, scoring classification results generated by the AI engine, and coaching language generated by the AI for your sessions; and
• Audio recordings from phone calls, collected or stored in connection with the Services, if you have consented to such information collection to use such feature.

Some of the information identified above may be considered sensitive data under certain laws. If required under applicable law, we will collect and process sensitive personal data only with your consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information.

We also collect statistics or aggregated information and technical information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature. Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), products that you view or search for, page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

4.1 You Provide Information to Us

We collect information about you when you interact with our Services, such as when you create or update an account, subscribe to our Services, or create or upload content through the Services.

For example, through our call recording upload features, users are able to upload recorded sales for AI analysis. Our Services do not directly record phone calls — users provide their own recordings and confirm such recordings were captured legally. These recordings are then transcribed by a third-party service and analyzed by the Services. Additionally, for our pro tier subscribers, you can elect to have a Company sales manager see and assess your training data, call analyses, and coaching summaries. Users must explicitly opt in to this feature, and such consent can be revoked at any time.

Moreover, we allow users to sign in to our services using Google OAuth. When a user chooses to authenticate via Google, Google provides us with certain information from the user’s Google profile, such as the user’s name, email address, and basic profile information (including a profile photo, if available). We receive this information only after the user has affirmatively consented through Google’s authorization process.

4.2 Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies and other tracking technologies, including details of your interactions with our Services, such as traffic data, logs, and other communication data, and which resources and Services features that you access and use.

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The tracking technologies we use for this automatic data collection may include the following:

• Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you will be unable to access certain features of the Services.
• Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by contacting us at the information listed in Section 13. Please note that some Services features may be unavailable as a result.

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your device. These third parties may include:

• Advertisers, ad networks, and ad servers;
• Analytics companies;
• Your device manufacturer; and
• Your internet or mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

4.3 From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as, without limitation, public AI platforms; payment processors; and analytics, security, and anti-fraud services. Our third-party service providers include the following:

• Stripe, for payment processing;
• Anthropic, through Claude application programming interface (“API”) for an AI simulation engine;
• Vercel, such as Vercel hosting and Vercel Blob, for application hosting and storage of user-uploaded content;
• Neon (PostgreSQL), for database hosting;
• ElevenLabs, for voice synthesis;
• Google (Gemini), for AI-powered content generation;
• Google (OAuth), for identity authentication;
• AssemblyAI, for transcription of practice exercise voice input and for transcription with speaker identification of uploaded sales call recordings;
• Resend, for transactional email;
• Slack, for training event notifications via customer-configured webhook; and
• Salesforce/HubSpot, for customer relationship management integrations.

Our third-party payment processor, Stripe, does have cookies features set for its payment processes. These cookies are necessary to process your subscription purchase securely. Please visit Stripe’s terms of use or service and privacy policy for additional information on its privacy practices.

We use information that we collect about you or that you provide to us, including any personal data, to:

• Provide you with and operate the Services and any contents, features, information, products, or services that we make available through the Services;
• Fulfill and manage accounts and subscriptions;
• Process payments and other billing information;
• Fulfill any other purpose for which you provide it;
• Provide you with Services-related notifications and notices about your account and subscription, if applicable, including expiration and renewal notices;
• Improve our Services, including by analyzing your information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them, whereas our analysis may include the use of technology like machine learning and large language models, but we do not train AI models on your data, and we do not share your data with third parties for their model training;
• Develop new Services features and optimize the training experience;
• Generate performance analytics, such as your wall profile, pressure score trends, and other personalized performance insights;
• Promote our Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties’ services;
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; and
• Notify you when Services updates are available and about changes to any products or services we offer or provide though them.

We may also use your personal data in any other way we may describe when you provide the information and for any other purpose with your consent.

Please note, we use information obtained through Google OAuth solely for the purpose of creating and managing user accounts, authenticating users, and enabling access to our Services. We do not use Google user data for advertising, marketing unrelated to our Services, or any other secondary purposes not disclosed in this Notice. Our use of Google user data is limited to the purposes described here.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to, for example:

• Estimate our audience sizes and usage patterns;
• Store information about your preferences, allowing us to customize the Services according to your individual needs and interests;
• Speed up your searches; and
• Recognize you when you return to our Services.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect or you provide as described in this Notice:

• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties we use to support our organization;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by the Company is among the assets transferred;
• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information;
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply our Terms of Use, located at tmu.dfaimedia.com/terms, and other agreements, including for billing and collection purposes;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, our users, or others, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; and
• With your consent.

The categories of personal data we may disclose include:

• Account and contact information;
• Payment information;
• Account history;
• Device information;
• Information you elect to provide as part of your subscription to or use of our Services or as part of your Google OAuth profile;
• Session performance data;
• Usage data; and
• AI interaction logs.

Please see Section 4 of this Notice for a list of our third-party service providers. We share data only with the third-party service providers listed in Section 4, and only to the extent necessary to operate the Services.

Because the Services rely on AI, we want to be transparent about how your data interacts with AI systems:

• API Processing. User inputs during Services sessions are sent to Anthropic’s Claude API for processing. This processing enables simulation scoring, coaching feedback generation, and session analysis. Anthropic’s data retention and usage policies apply to this processing. Anthropic’s current policy states that API inputs are not used to train their models; however, please visit Anthropic’s terms of user or service and privacy policy for additional, up-to-date information on its privacy practices.
• Ephemeral Coaching. AI-generated coaching feedback is generated per-session. Coaching outputs are stored in your session history for your own review, but are not used for any purpose beyond your personal training experience.
• Deterministic-First Architecture. The majority of Services simulation responses are generated from pre-authored, deterministic content (logic trees and response banks). The AI API is used as a fallback for natural language processing, not as the primary content source.

This Section 8 describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

• Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. You can choose whether or not to allow the Services to collect information through other tracking technologies by disabling such technologies through the appropriate setting on your browser or device or contacting us at the information provided in Section 13. However, if you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a “Do Not Track” (“DNT”) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Services may not respond to all browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in this Notice.
• Promotions by the Company. If you do not wish us to use your information to promote our own products or services, you can opt out by contacting us at the information provided in Section 13 of this Notice.
• Other Uses. If you do not want us to use information that we collect for certain other purposes, you can contact us at the information provided in Section 13 of this Notice.

You may also be entitled to withdraw permission for certain third-party service providers to access your information. For example, users may revoke our access to their Google account information at any time by adjusting their permissions in their Google Account settings. Revoking access may limit or prevent continued use of certain features of our Services that depend on Google authentication.

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information’s nature and processing purpose.
• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.
• Opt Out of Using Personal Data for Targeted Advertising, Profiling, and Sales. You may request that we do not use your personal data for targeted advertising, profiling, and sales purposes.
• Restrictions on Processing. You may request that we limit how we process your data in certain circumstances, subject to certain exceptions under applicable law.

IMPORTANT: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, please contact us at the information provided in Section 13 of this Notice. To appeal a decision regarding a consumer rights request, we request you contact us at the information provided in Section 13 of this Notice, as well.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

Nevada provides its residents with a limited right to opt out of certain personal data sales. Residents who wish to exercise their sale opt out rights may submit a request to us at the information provided in Section 13. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

If you are a California resident, you may have additional rights under your state’s privacy laws not otherwise listed here. Please contact us at the information provided in Section 13 of this Notice for additional details, if applicable.

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email or other messages sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk. If a data breach affecting your personal information occurs, we will notify affected users and applicable authorities as required by law.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

We keep the categories of personal data described in this Notice for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data.

If you are a California resident, you may have additional rights under your state’s privacy laws not otherwise listed here. Please contact us at the information provided in Section 13 of this Notice for more information about the retention periods that apply to the personal data categories we collect.

We may update this Notice from time to time, and we will provide notice of any such changes to the Notice as required by law. The date the Notice was last updated is identified at the top of the page. We will notify you of changes to this Notice by updating the “last updated” date and posting the updated Notice on the Services. We may email or otherwise communicate reminders about this Notice, but you should check our Services periodically to see the current Notice and any changes we have made to it.

To exercise your rights or ask questions or comment about this Notice or our privacy practices, contact us at:

JDL Sales LLC d/b/a Dealflow AI
Attention: Jon Lambert, President & CEO
504 Avocet Drive
East Lansing, MI 48823
privacy@dfaimedia.com