ACTI Privacy Notice

Actualized Intelligence, LLC (“ACTi”) and SJA TD Holdings LLC d/b/a Unblinded (“Unblinded”) are two separate but collaborating companies that provide technology-enabled coaching, education, and AI-powered solutions cooperatively. This Privacy Notice explains what personal information we collect, how we use it, how long we keep it, who can access it, and the choices and rights you have.

We have written this Notice to describe our actual data practices. Where our AI systems handle your information, this Notice tells you plainly what is retained, what is not, and who — if anyone — can see it. We do not make privacy promises our systems cannot keep.

Our Services include our websites (unblindedmastery.com and acti.ai), digital platforms, mobile apps, software, and AI-powered conversational agents (“ACTi Beings”) (together, the “Services”). Our Services are primarily designed for business-to-business (B2B) use, though individuals may interact with them directly or through an organization that uses our platform.

This Notice applies when you visit our websites, use our apps or digital tools, interact with us directly (by email, chat, or at events), or engage with a brand or organization that uses our Services.

Unblinded and ACTi are separate companies with shared leadership and technology, each managing its own operations and data.

• Independent use: When each company uses your information for its own business, it acts as a separate data controller.
• Shared programs:When we work together — for example, co-hosted events — we act as joint controllers and coordinate our privacy responsibilities.
• Service delivery: Sometimes ACTi processes data for Unblinded or its clients as a data processor, under a written data processing agreement.

Not all ACTi Beings handle your information the same way. Because your privacy expectations should match reality, we tell you which kind you are interacting with, and we build our systems to honor that distinction.

Private / Client-Facing Beings

These are Beings whose purpose is your private coaching, learning, growth, or use of the product — not sales or marketing.

Your conversations are not routinely reviewed by any human.

We configure our voice technology so that call recordings and logs are not retained beyond what is needed to deliver your session in real time.

We suppress storage of the underlying conversational content in our workflow-automation systems, so that no one can browse your prior private conversations through internal logs.

We retain only what is genuinely necessary to operate the product and preserve the Being's contextual memory of you, and only authorized personnel with a defined, role-based need may access that data.

Limited human access is possible only when necessary to provide or repair the service, investigate a security or abuse issue, comply with a legal obligation, enforce our agreements, or another specifically disclosed purpose. When that happens, it is purposeful, limited, and logged — never casual or convenience-driven.

Marketing, Sales, and Business-Development Beings

Where a Being is used for sales, marketing, business development, or campaign outreach, the interaction may be recorded and retained, and may be reviewed by a human. Wherever a Being records or retains an interaction:

• the interaction itself will clearly disclose that it is being recorded or retained; and
• this Notice and the applicable terms accurately describe that retention and possible human review.

Internal-Only and Beta Beings

Non-production, internal, or beta Beings may retain data where legitimately needed for testing, debugging, accessibility, support, or internal operations. Such retention is intentional and access is limited to individuals who require it.

When you interact with an ACTi Being, we will make clear that you are interacting with AI — not a human — at the time of that first interaction.

Information you provide:

• Contact details (name, email, phone number)
• Professional information (company, title, role)
• Messages, feedback, or content you share with us
• Event or registration details
• Conversational content.When you interact with an ACTi Being by text or voice, we process your inputs to generate real-time responses. For voice interactions, audio is processed by our voice technology provider to produce the Being's spoken response. Retention of that content is governed by the private-versus-marketing/sales distinction described above.
• Input content. Documents, prompts, contextual information, and other materials you or your organization submit for AI-assisted processing, including text prompts and queries; uploaded documents, files, or reference materials; contextual data provided to inform or customize responses; and structured inputs submitted through platform workflows or integrations. Input content is retained for the duration of the service relationship or as directed by the Customer, and is deleted or returned upon termination unless retention is required by law.

Information from brands and customers.If you engage with a company that uses our Services (our “Customer”), that company may share data with us — such as transcripts, recordings, or interaction details. In those cases we process the data only on that Customer's instructions and under contract.

Information we collect automatically: browser and device details; IP address and approximate location; usage data such as pages visited or features used; and cookies or similar technologies (see the Cookies section). We may also receive limited information from partners or publicly available sources where permitted by law.

We discourage you from submitting sensitive personal information — including health information (PHI) or unnecessary personal identifiers (PII) — through the Services, while recognizing you may nonetheless choose to provide it.

We use your information to:

• Provide and maintain our Services
• Support, troubleshoot, and respond to your requests
• Improve the performance, features, and usability of our Services
• Communicate updates, events, and opportunities
• Protect against fraud, misuse, and security threats
• Comply with legal obligations

Aggregated and de-identified data. We may use aggregated or de-identified information for statistical, performance, billing, product-improvement, and service-operation purposes, consistent with applicable law and this Notice.

We do not sell your personal information.

Customer responsibilities.If you use our Services as a business or brand, you are responsible for ensuring that you have the right to share data with us, that you manage your users' permissions responsibly, and that you inform your users when AI-enabled features are involved.

We do not use your conversational content, prompts, uploaded documents, or other input content to train or fine-tune AI models — ours or anyone else's.

Our third-party AI providers are contractually prohibited from using your inputs to train their general-purpose models, and where available we use zero-retention configurations with those providers. Any use of data to improve our own Services is limited to aggregated or de-identified information that no longer identifies you.

If we ever decide to use identifiable user content for model training in the future, we will not apply that change retroactively to previously collected data, and we will obtain your affirmative opt-in consent before doing so. See “Changes to This Notice.”

Depending on your location, we process personal data under one or more lawful bases:

• Contract: to provide the Services you have requested.
• Consent: where you have opted in (for example, to marketing or non-essential cookies).
• Legal obligation: to comply with applicable law.
• Legitimate interests: to secure our systems and improve our products, balanced against your rights.

You can withdraw consent at any time by contacting us.

We keep personal information only as long as needed for the purposes described in this Notice or as required by law.

Private-Being conversational content: not retained in voice/logging systems beyond real-time delivery; contextual-memory data is retained only as needed to operate the product and deleted when no longer needed.

Marketing/sales recordings: retained only for the disclosed purpose and period.

Input content: retained for the service relationship and deleted or returned on termination unless law requires otherwise.

Analytics data: de-identified or deleted within 13 months of collection.

We will not delete records subject to a legal preservation obligation, such as a litigation hold, until that obligation is resolved.

We operate on a least-privilege, zero-trust basis. No person has broad access to conversational or user data merely because they hold administrative privileges elsewhere in our technology stack. Access to systems holding user content is limited to a small number of authorized administrators, is role-based and purpose-specific, and is removed when no longer required. Personnel with elevated access are bound by confidentiality, privacy, and security obligations.

We use cookies and similar tools to make our Services work better, including Vercel Analytics for anonymized website performance and usage metrics. We do not use cross-site tracking cookies. Advertising or targeting cookies, if any, load only with your consent. You can manage cookie settings through our cookie banner or your browser, and we honor valid Global Privacy Control (GPC) signals where required by law.

We share information only as necessary to operate our Services or comply with law, including with:

• Service providers who help us operate the Services, each under contractual obligations prohibiting them from using your data for their own purposes, including training their general AI models. A current list of our sub-processors is available on request.
• Our corporate group (Unblinded and ACTi), under our intercompany data processing and transfer agreement.
• Legal and safety recipients, where required by law or to protect rights and safety.
• In a merger, acquisition, sale, or reorganization, with equivalent privacy protections maintained.
• As de-identified or aggregated data for analysis and product improvement.

We never sell or trade your personal information for marketing purposes.

Our ACTi Beings generate conversational responses using AI. Where an interaction could make or substantially influence a consequential decision — such as one affecting credit, employment, insurance, housing, education, or similar — a qualified human reviews the outcome before it is relied upon, and you may request information about the logic involved and human review. We provide these disclosures consistent with applicable law, including emerging state requirements.

Depending on where you live, you may have the right to access or receive a copy of your data; correct inaccurate information; request deletion or restriction; object to certain uses; withdraw consent; and request data portability.

To exercise these rights, contact us at the addresses below. We will respond within the time required by law. You may also contact your local data protection authority.

We do not sell or share your personal information as those terms are defined under the California Consumer Privacy Act (CCPA) and comparable state statutes. If this changes, we will provide a “Do Not Sell or Share My Personal Information” link on our websites and honor applicable opt-out rights.

We use administrative, technical, and physical safeguards — including encryption at rest and in transit, access controls, network segmentation, and continuous monitoring — to protect your information, following recognized frameworks such as ISO 27001 and the NIST Cybersecurity Framework. We maintain separate data environments for Unblinded and ACTi and for client-facing versus internal use, with limited cross-access. If a security incident occurs, we will act promptly and notify affected parties as required by law.

We may collect limited device data to improve mobile performance. Some features require device permissions — for example, voice interactions require microphone access, which your browser or device will prompt you to grant. You can use text-based features without a microphone and can revoke permissions at any time. If you receive SMS messages from us, you can opt out by following the instructions in the message or by contacting us.

Our online communities are public. Anything you post may be seen or shared by others; please avoid sharing personal or sensitive information there. We may moderate or remove posts that violate our terms or applicable law. Individuals under 18 should not post personal information publicly.

When data moves across borders, we use recognized safeguards such as Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum (IDTA), or other lawful mechanisms. Transfers between Unblinded and ACTi are covered by our intercompany data transfer agreement. If we participate in a formal framework such as the EU-U.S. Data Privacy Framework, we will post details on our websites.

Our Services are not directed to children. We do not knowingly collect personal information from individuals under 13 in the United States, under 16 in the EU/UK, or under the applicable minimum age elsewhere. If you believe a child has provided us data, please contact us so we can delete it promptly. California residents under 18 may request removal of their public posts as allowed by law.

We are committed to using AI responsibly:

• Transparency: We disclose when you are interacting with an AI system, at the time of interaction.
• No training on your content:We do not use your inputs to train AI models (see “Training and Model Improvement”).
• Human oversight: People remain accountable for consequential decisions.
• Data minimization: We use only the data our AI features need.
• Fairness: We work to test for bias and promote inclusive design.
• Vendor governance: Our AI providers are contractually prohibited from using your data to train their own general models.

We monitor and work to align with evolving standards, including the EU AI Act and the NIST AI Risk Management Framework.

We may update this Notice from time to time. We apply changes prospectively. We will not adopt materially more permissive data practices — such as beginning to use your data for AI model training, or sharing it with new categories of third parties for their own purposes — and apply them to previously collected data through a quiet or retroactive amendment. Material changes will be highlighted at the top of the relevant privacy page for at least thirty (30) days before taking effect, and where a change would expand how we use your identifiable data for model training, we will obtain your affirmative opt-in consent before that use.

Privacy inquiries — ACTi: info@acti.ai

Privacy inquiries — Unblinded: inquiry@unblindedmastery.com

General inquiries: info@acti.ai

If you are in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with your local supervisory authority. If you are in Australia, you may contact the Office of the Australian Information Commissioner (OAIC).