1. Introduction and Scope

Adaptward, LLC (“Adaptward,” “we,” “us,” or “our”) is committed to protecting your privacy and handling your personal data with transparency and accountability. This Privacy Policy explains how we collect, use, disclose, and secure personal information when you engage with our website, communicate with us, or use our services—including our white-labeled AI assistant solutions provided to business clients (collectively, the “Services”).

This policy applies to:

• Visitors to our website at www.adaptward.com

• Business clients who contact us, request services, or access their portal

• Communications and data exchanges conducted through our service infrastructure

This Privacy Policy does not apply to the end users of our clients’ AI assistants. Adaptward does not directly collect or control data from such users. Any incidental exposure to such data is limited and necessary only to enable the Services on behalf of our clients.

We adhere to applicable data protection laws including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other privacy frameworks governing the jurisdictions in which we operate or from which we collect data.

2. Information We Collect

Adaptward collects both personal and non-personal information in various forms to fulfill business, legal, and operational purposes.

2.1 Personal Information Provided Voluntarily

When you interact with our website, request information, or sign up for services, we may collect:

• Full name, job title, and business name

• Business email address and phone number

• Company website and industry

• Billing contact details (collected via our payment processor)

• Messages submitted through our contact forms or intake processes

• Information provided during sales calls, onboarding, or demos

This information is collected directly from you and is necessary for us to communicate, provide service proposals, conduct account setup, and deliver ongoing services.

2.2 Information Collected Automatically

When you use our website or digital assets, we may automatically collect:

• Device Information: browser type, operating system, hardware model, IP address, screen resolution, language settings

• Usage Data: pages visited, time on site, links clicked, form activity

• Location Data: generalized geolocation based on IP address

• Technical Logs: error messages, diagnostic events, and timestamps

• Cookies and Tracking Technologies: include data collected via Google Analytics (see Section 12), which may include session duration, pages visited, referral source, and browser/device information.

This data helps us optimize our website performance, detect fraud, maintain security, and understand usage patterns for continuous improvement.

2.3 Information from Third-Party Integrations

We collect limited business information through platforms integrated into our operations, including:

• Scheduling data and meeting history via Calendly

• Payment and invoice metadata via Stripe

• Email engagement (opens, clicks) via MailerLite

• AI platform activity and message logs via Stammer.ai

• Interaction history and automation triggers via Zapier

We do not receive any sensitive personal data or authentication credentials from these platforms, and our access is restricted to necessary service-level integrations.

3. How We Collect Information

We collect data through the following means:

• Direct Submission: Via forms, email, intake surveys, scheduling tools, and onboarding questionnaires

• Automated Collection: Through tracking technologies, analytics scripts, and server logs

• Third-Party APIs and Tools: We access relevant business data through integrations with your permission

• Client Engagements: During service provisioning, AI assistant setup, and performance reviews

• Email Interactions: We collect delivery success, open rates, and link activity to gauge effectiveness

All data is collected with legitimate interest, contractual necessity, or with your explicit consent where required.

4. How We Use Your Information

We use your data strictly for purposes related to service delivery, client support, and business operations, including:

4.1 Service Delivery

• To respond to inquiries and provide information about our Services

• To create and manage business client accounts

• To customize and implement AI assistants tailored to each client

• To monitor system performance and provide technical support

• To schedule meetings and follow up on engagements

  
  

4.2 Communications

• To send onboarding and transactional messages

• To share feature updates, operational notices, and reminders

• To send occasional promotional or educational content with opt-out options

  
  

4.3 Service Improvement

• To analyze service usage and optimize platform functionality

• To detect and respond to issues, bugs, or errors

• To identify opportunities for service enhancements or automations

  
  

4.4 Legal and Security Purposes

• To comply with legal obligations, including data requests or audits

• To enforce our Terms of Service and safeguard intellectual property

• To prevent abuse, fraud, or illegal activity within our systems

We do not process sensitive personal data and we explicitly instruct our business clients to configure their AI assistants not to solicit or process such data from end users.

5. Disclosure of Information to Third Parties

We only share your data with third parties under limited, clearly defined circumstances:

5.1 Service Providers and Subprocessors

We contract with third-party vendors to deliver critical functionality such as infrastructure hosting, payment processing, email delivery, and automation. These vendors operate under strict contractual agreements and are listed in Appendix A.

We require subprocessors to maintain data protection measures that meet or exceed industry standards.

5.2 Legal Compliance

We may disclose personal information when legally required to do so, such as in response to a subpoena, court order, or applicable law enforcement process.

5.3 Business Transfers

In the event of a sale, merger, reorganization, or other corporate restructuring, your data may be part of the assets transferred or disclosed to involved parties. All such transfers will comply with applicable privacy laws and honor existing commitments.

5.3 Third-Party Data Processing and Privacy Accountability

Adaptward’s Services incorporate and depend upon a range of third-party platforms and service providers to deliver functionality, performance, and value to our business clients. These include both general-purpose service integrations (e.g., scheduling, payment, email delivery) and specialized infrastructure for artificial intelligence features. While Adaptward exercises diligent oversight and reasonable care in selecting these providers, it is important for clients and users to understand that some information and interactions may be subject to processing by third parties not controlled by Adaptward.

Adaptward requires all third-party service providers and subprocessors to demonstrate compliance with applicable privacy regulations, including but not limited to the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). However, each provider maintains its own data governance and privacy policies, and Adaptward does not have control over how these third parties collect, store, use, or secure your data once it passes into their systems. The use of such services is subject to their respective terms of service and privacy policies, which users and clients are encouraged to review.

In particular, we use Google Analytics 4 to better understand how visitors use our website. Google Analytics collects pseudonymous usage data, such as browser type, device details, geographic region (approximate), pages visited, and referral source. This information is processed by Google LLC on our behalf and helps us improve the performance and relevance of our website. We do not send personally identifiable information (PII) to Google through this tool, and IP addresses are anonymized where possible. For more information, see Google’s Privacy Policy and Google’s Partner Site Data Use Policy. You can opt out of Google Analytics by using the Google Analytics Opt-out Browser Add-on.

By using Adaptward’s Services, you expressly acknowledge and agree that:

• Certain data or content may be routed through or processed by external services and subprocessors;

• Those third parties may apply their own data processing practices;

• Adaptward disclaims liability for the actions, omissions, or policies of those third-party providers, except as required by law.

5.3.1 Use of AI Model Providers via Stammer.ai

Adaptward’s AI Assistant functionality is delivered through the Stammer.ai platform, a third-party solution that enables white-labeled deployment of AI-driven conversational agents. Stammer.ai, in turn, integrates with one or more third-party artificial intelligence model providers to generate and respond to end-user messages.

These providers include, but may not be limited to:

• OpenAI, L.L.C. (provider of the GPT family of models)

• Anthropic PBC (provider of Claude models)

• Additional large language model (LLM) services as required or integrated by Stammer.ai

These AI model providers act as subprocessors of business data to the extent necessary to fulfill the AI Assistant’s functionality. Data that is transmitted to these providers for processing may include user-submitted prompts, questions, or structured business content submitted as part of your assistant’s training. Adaptward does not control the infrastructure or retention policies of these providers, and any information routed through these models is handled in accordance with the third party’s own privacy policies and compliance frameworks.

Data transmitted to these providers during API calls is typically encrypted in transit using industry-standard protocols (e.g., HTTPS/TLS), and in most cases is not persistently stored or associated with personally identifiable information (PII) by the model provider. These AI model providers are designed to process text inputs statelessly and without linking content to end-user identities. However, because the nature of large language models involves processing and temporarily interpreting freeform input, Adaptward strongly advises against submitting any sensitive, confidential, or regulated information through the AI Assistant interface. Business clients are encouraged to configure their AI Assistants to recognize and avoid collecting such data. While best practices and privacy-focused design are employed throughout, no AI model provider can guarantee the prevention of all unintended disclosures, and clients and users should exercise discretion accordingly.

To protect your business and your users, please do not submit the following types of information via the AI Assistant:

• Government-issued identification numbers (e.g., SSN, passport, driver’s license)

• Financial account information (e.g., bank details, credit card numbers)

• Protected health information (PHI) under HIPAA

• Legal, criminal, or tax records

• Login credentials or passwords

• Sensitive business trade secrets or proprietary data not intended for sharing

• Information about children under the age of 13

• Any other data classified as sensitive or regulated under applicable privacy laws

While Adaptward does not intentionally retain AI conversations, and we advise against the submission of sensitive or regulated data (such as financial account numbers, protected health information, or government identifiers), some temporary exposure to such data may occur during processing. Clients are solely responsible for ensuring that their use of the AI Assistant complies with applicable laws and regulations regarding data privacy, consent, and disclosure.

Adaptward shall not be held liable for any breach, misuse, or unintended exposure that arises from the processing practices or infrastructure of Stammer.ai or the AI model providers it utilizes.

For more information, users and clients should refer to:

• OpenAI’s Privacy Policy

• Anthropic’s Privacy Policy

  
  

5.3.2 Other Third-Party Service Integrations

In addition to AI-specific infrastructure, Adaptward uses a number of third-party platforms to support various aspects of its business operations and the delivery of Services. These may include, but are not limited to:

• MailerLite (email communication and automation)

• Calendly (scheduling)

• Zapier (workflow automation and API-based data transfer)

• Stripe (payment processing)

• Google Workspace (business email and calendar)

• Framer (website hosting and content delivery)

• Plausible Analytics (privacy-friendly site analytics)

These third-party platforms may process personal or business data as part of their integration with Adaptward’s website, AI Assistant, or operational infrastructure. This may include names, email addresses, business contact information, booking data, payment information, or other non-sensitive personal information voluntarily submitted by you or your business during the use of our Services.

Adaptward has executed or relied upon appropriate data processing agreements with each subprocessor where legally required. We make good faith efforts to ensure that each third-party service provider we work with adheres to robust data protection practices. Nonetheless, each third party governs their own systems, data handling policies, and privacy terms.

By engaging with Adaptward’s Services, you understand and accept that:

• These third-party platforms may collect and process data independently of Adaptward;

• Any such data is governed by the respective platform’s privacy policies and terms of service;

• Adaptward is not liable for how these third parties handle or secure your data once it leaves our systems.

For a current list of our subprocessors and the functions they perform, please refer to Appendix A at the end of this Privacy Policy.

6. Subprocessors and Service Providers

Adaptward utilizes a number of third-party subprocessors that may access or process business client information in order to support service delivery.

All subprocessors are vetted for data security and are bound by data processing agreements that require confidentiality, security, and restricted use. See Appendix A for the full list and purpose of each provider.

7. Data Retention

We retain personal and business information only as long as it serves a clear and necessary business, legal, or technical purpose. Retention periods vary based on:

• The nature of the relationship (inquiry vs. active client)

• Legal and regulatory requirements

• Need for archival, billing, or contractual reference

• Ongoing obligations or troubleshooting requirements

When data is no longer needed, we securely delete, de-identify, or archive it using industry-standard methods.

Clients may request data deletion at any time by contacting privacy@adaptward.com.

8. Data Security

We employ administrative, technical, and organizational safeguards to protect data from loss, misuse, and unauthorized access.

Our security program includes:

• TLS encryption (HTTPS) for data in transit

• Firewalled cloud infrastructure with limited access

• Strong password policies and role-based user access

• Routine software updates and vulnerability patching

• Internal data access logs and administrative controls

• Vendor due diligence and audit capabilities

While no system is immune to breach, we maintain an incident response plan and will notify affected parties in accordance with legal obligations if a data breach occurs.

9. International Data Transfers

Our operations are based in the United States. If you are located outside the U.S., your data may be transferred to and processed in the U.S. or other jurisdictions where our subprocessors operate.

Where required, we implement safeguards for international transfers including:

• Standard Contractual Clauses (SCCs) approved by the European Commission

• Adequacy decisions under GDPR

• Vendor contract terms aligned with international data protection standards

You acknowledge that your data may be subject to access by U.S. government authorities under applicable laws.

10. Your Rights

We are committed to honoring the rights granted to individuals under applicable privacy laws.

10.1 Rights under GDPR (EU/EEA/UK Residents)

• Right to access your personal data

• Right to correct inaccurate or incomplete data

• Right to request deletion (right to be forgotten)

• Right to restrict or object to processing

• Right to data portability

• Right to lodge a complaint with a supervisory authority

  
  

10.2 Rights under CCPA (California Residents)

• Right to know the categories and specific data we collect

• Right to request deletion of your personal data

• Right to opt out of sale or sharing (we do not sell data)

• Right to equal service and non-discrimination for exercising your rights

To exercise your rights, email privacy@adaptward.com with the subject line “Privacy Request.” We will verify your identity and respond in accordance with applicable laws.

11. Marketing Communications and Opt-Out

We may send you promotional or informational emails if you have provided consent or engaged with our services. You may opt out at any time by:

• Clicking the unsubscribe link in our emails

• Emailing privacy@adaptward.com with “Unsubscribe” in the subject line

• Updating your preferences via any provided email preferences center

Note: Even if you opt out of marketing, you will continue to receive essential administrative and transactional emails related to your account or active services.

12. Cookies and Tracking Technologies

Adaptward uses cookies, tracking pixels, and related technologies to enhance user experience, track website performance, and support marketing campaigns.

Cookies may be placed by us or by authorized third-party providers (e.g., Google Analytics, MailerLite). These cookies allow us to:

• Analyze web traffic and session duration

• Understand referring sources

• Track conversions and form submissions

• Improve content and page relevance

• Monitor email open rates and interaction

You may manage cookie settings via your browser preferences. Disabling cookies may impact certain features of the site.

13. Children’s Privacy

Our Services are intended for use by business professionals aged 18 and older. We do not knowingly collect personal information from children or minors.

If we become aware that a minor has submitted personal information, we will delete it promptly. If you believe a child has provided us with data, contact privacy@adaptward.com.

14. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. Changes will be posted on this page with an updated “Effective Date.” If material changes are made, we will provide notice through the website or by email where appropriate.

We encourage you to review this Privacy Policy regularly to stay informed about how we protect your data.

15. Contact Us

If you have any questions about this Privacy Policy, your data, or our data practices, please contact:

Adaptward, LLC
Email: privacy@adaptward.com
Website: www.adaptward.com

Appendix A: Subprocessors & Third-Party Service Providers

Adaptward, LLC engages the following third-party service providers (“subprocessors”) in order to operate, deliver, and improve its Services. These providers may have access to limited personal or business data as required to perform their respective functions. Adaptward takes reasonable steps to ensure that each vendor adheres to applicable privacy and data protection standards, including GDPR and CCPA compliance, where applicable.