This Privacy Policy describes how Everett Advisors LLC (the “Company,” “we,” “our,” or “us”) collects, uses, retains, discloses, and otherwise processes information through JetpackProducts.com and any related websites, applications, and products (collectively, the “Services”). It is incorporated into our Terms & Conditions, which also govern your use of the Services.

Broad Authorization — By using the Services, you authorize the Company to collect and use information as described in this Privacy Policy, including for product improvement and for use with artificial intelligence and machine learning, as set out below.

Not Legal Advice — This Privacy Policy is a statement of our practices, not legal advice. Where mandatory consumer-protection or data-protection laws apply, we will comply with them; some provisions are framed broadly to preserve the Company’s rights to the fullest extent permitted by applicable law.

2.1 Information You Provide — We collect information you provide directly, such as:

• Account and contact information (name, email address, phone number, username, password).
• Profile and preference information you choose to provide.
• Payment and billing information (processed through our payment providers; we may retain billing name and transaction records).
• Communications and support requests you send us.

2.2 User Content — We collect any content, prompts, queries, instructions, files, documents, images, audio, video, feedback, and other material you submit, upload, transmit, or generate through the Services (“User Content”).

2.3 Activity Data — We collect information about your interactions with the Services, including usage patterns, inputs and outputs, prompts and responses, clicks, navigation, search and filter activity, transactions, and other telemetry about how you use the Services.

2.4 Technical and Device Data — We collect technical data such as IP address, browser and device type, operating system, identifiers, referral URLs, pages viewed, timing, and similar information, including through cookies and similar technologies.

2.5 Information From Others — We may receive information from third parties (such as analytics providers, partners, and authentication services) and combine it with information we collect.

3.1 Purposes — We use the information we collect for any lawful purpose, including to:

• Provide, operate, maintain, secure, support, and troubleshoot the Services.
• Improve, enhance, refine, develop, and personalize the Services and our products, features, and offerings.
• Develop new products, services, features, models, and datasets.
• Use with AI and machine learning, including to develop, train, fine-tune, evaluate, validate, prompt, operate, and improve AI models and to generate outputs.
• Conduct research, analytics, benchmarking, and quality assurance.
• Process transactions, manage accounts, and communicate with you.
• Detect, prevent, and address fraud, abuse, security, and legal or policy violations.
• Comply with legal obligations and protect our rights, users, and the public.

3.2 Aggregated and De-identified Data — We may aggregate or de-identify information and use it for any purpose, including analytics, research, and AI, without restriction, provided it is not re-identified.

3.3 Broad Use — To the fullest extent permitted by applicable law, you authorize the broad uses described in this Section 3, including the use of User Content and Activity Data with AI.

4.1 AI Use Authorized — We may use information we collect — including User Content and Activity Data — with AI and machine learning. This includes developing, training, fine-tuning, evaluating, validating, prompting, operating, and improving AI models and datasets, and generating outputs, whether for our products, our internal purposes, or in connection with partners or customers.

4.2 Combination and Retention — We may combine your information with other data and may retain and use it for AI purposes during and after your use of the Services, including after account closure, to the fullest extent permitted by applicable law.

4.3 Sensitive Information — Do not submit sensitive personal, health, financial, or confidential business information that you do not want used as described in this Policy. If you do submit it, you authorize its use as described here.

4.4 Outputs — AI outputs may be inaccurate or biased. You are responsible for evaluating any output before relying on it.

5.1 Bases — Where the GDPR, UK GDPR, or similar laws apply, we rely on one or more of: your consent; the performance of a contract with you; our compliance with legal obligations; and our legitimate interests (and those of third parties) in operating, improving, securing, and developing the Services, including AI development, balanced against your rights.

5.2 Legitimate Interests — Our legitimate interests include providing and improving the Services, product and AI development, security, fraud prevention, and analytics. We will limit processing where your interests override our legitimate interests, except where required or permitted by law.

6.1 Sharing — We may share information with:

• Service providers and processors that support our operations (hosting, analytics, payments, email, AI infrastructure, customer support), under appropriate obligations.
• Our affiliates and group companies.
• Partners and customers in connection with products, integrations, or services you use, including AI-related services.
• Authorities, courts, or third parties where required by law, court order, or to protect our rights, users, or the public.
• A successor in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business.

6.2 Not a Sale — To the extent any sharing or use of information for AI or other purposes could be characterized as a “sale” or “sharing” under applicable law, we generally do not sell your personal information for monetary consideration, and where an opt-out applies you may exercise it as described in Section 9. Our broad license to use information under our Terms and this Policy is not a sale.

7.1 Use — We and our providers use cookies, web beacons, SDKs, and similar technologies to operate, secure, and analyze the Services, remember preferences, and enable features.

7.2 Cookie Disclosure — The table below describes the categories of cookies and similar technologies we may use.

7.3 No Targeted Advertising — We do not use cookies to track you across third-party websites for targeted advertising.

7.4 Choices — You can control or delete cookies through your browser or device settings. Disabling essential cookies may affect functionality. Where required by law, we will obtain consent before setting non-essential cookies, and you may withdraw that consent at any time.

7.5 Do Not Track — Because there is no standardized interpretation of “Do Not Track” signals, we do not currently respond to them in a specific way, but we limit use as described in this Policy.

8.1 Retention — We retain information for as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements, and thereafter as needed or permitted, including for AI and research purposes.

8.2 De-identified and Aggregated — De-identified or aggregated information may be retained and used indefinitely.

8.3 Discretion — Retention periods are determined in our discretion based on legal, operational, and business needs, subject to applicable law.

9.1 Rights — Depending on your jurisdiction, you may have rights to access, correct, delete, port, restrict, or object to processing of your personal information, to withdraw consent, and to opt out of certain “sales” or “sharing” or targeted advertising. To exercise any right, contact us as described in Section 14.

9.2 Limits — We may need to verify your identity, and we may retain or refuse to act on requests where permitted or required by law (for example, to comply with law, protect security, complete transactions, resolve disputes, or enforce our rights). Exercising certain rights may limit or terminate your ability to use some features or the Services.

9.3 Authorized AI Use Not Subject to Withdrawal — To the fullest extent permitted by applicable law, the licenses and authorizations you grant under our Terms (including the use of User Content and Activity Data to improve products and for AI) are irrevocable and not subject to withdrawal, deletion, or opt-out except to the extent required by mandatory law.

10.1 Your California Rights — If you are a California resident, you have the right to: know the categories and specific pieces of personal information we collect and how we use them; delete your personal information; correct inaccurate personal information; opt out of the “sale” or “sharing” of your personal information; limit the use of sensitive personal information; and not receive discriminatory treatment for exercising these rights.

10.2 Do Not Sell or Share My Personal Information — We do not sell your personal information for monetary consideration. To the extent any use of your information (including for AI) could be considered a “sale” or “sharing” under California law, you have the right to opt out. Use the opt-out path below, or contact us through our contact page with the subject line “CCPA Opt-Out — Do Not Sell or Share.”

10.3 How to Submit a Request — You or your authorized agent may submit a rights request through the link above or by contacting us (see Section 14). We will verify your identity before acting and will respond within the time required by California law.

10.4 Authorized Agents — You may exercise rights through an authorized agent; we may require proof that the agent has your authorization.

10.5 Effect of an Opt-Out — Exercising an opt-out may limit or end certain AI-powered features and the broad authorizations in our Terms, and some features may become unavailable as a result. We will not discriminate against you for exercising your rights.

10.6 Children — The Services are not directed to children under 13 (or the equivalent minimum age in your jurisdiction), and we do not knowingly sell or share the personal information of children. If you believe a child has provided us information, contact us to request deletion.

11.1 Transfers — Your information may be processed and stored in the United States and other countries where we or our providers operate. By using the Services, you consent to these transfers.

11.2 Safeguards — Where required, we will use appropriate safeguards for cross-border transfers, such as standard contractual clauses or other lawful transfer mechanisms.

12.1 Reasonable Measures — We use reasonable administrative, technical, and physical safeguards to protect information. However, no system or transmission is fully secure, and we cannot guarantee the security of information.

12.2 Breach Notification — Where legally required, we will notify affected individuals and authorities of a personal data breach.

Third Parties — The Services may contain links to or integrations with third-party sites and services that have their own privacy practices. We are not responsible for their practices. Our products may also direct you to external destinations; their handling of your information is governed by their own policies.

Changes — We may update this Privacy Policy at any time. We will indicate the updated date below. Your continued use of the Services after a change constitutes acceptance of the updated Policy.

For privacy questions or to exercise any rights, please contact:

Everett Advisors LLC — EverettAdvisors.com