Privacy Policy

Effective Date: May 13, 2024

1. Introduction and Scope

Predictable Prompts ("Predictable Prompts," "we," "us," or "our") is dedicated to upholding the privacy and security of your Personal Information. This Privacy Policy ("Policy") articulates with transparency how Predictable Prompts collects, uses, processes, discloses, retains, and safeguards Personal Information when you visit our official website, https://predictableprompts.com/ (the "Website"), and when you engage with or utilize our specialized prompt engineering consultation, strategy development, and implementation services (collectively, the "Services").

Within the context of this Policy, "Personal Information" shall mean any information relating to an identified or identifiable natural person ("Data Subject"), as such term is defined under prevailing and applicable data protection legislation (including, but not limited to, the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK General Data Protection Regulation ("UK GDPR"), the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA")). This encompasses, without limitation, identifiers such as your name, email address, telephone number, professional affiliations (e.g., company name, job title), Internet Protocol (IP) address, online identifiers, and any other data that, alone or in combination with other information, can be used to identify you.

This Policy is applicable to all individuals whose Personal Information Predictable Prompts processes in connection with the operation of the Website and the provision of Services. This includes, but is not limited to, casual Website visitors, individuals making inquiries, prospective clients, and authorized representatives of current corporate clients ("you," "your," or "User").

Your access to the Website or engagement with our Services signifies your acknowledgment that you have read, understood, and consented to the data practices described in this Privacy Policy. If you do not concur with any part of this Policy, you are advised to refrain from using our Website or Services.

Predictable Prompts reserves the right to amend or update this Policy at its discretion and at any time. Material changes will be communicated by posting the revised Policy on this page and conspicuously updating the "Effective Date" at the top. We strongly encourage you to periodically review this Policy to stay informed about our data protection practices and any modifications thereto.

2. Personal Information We Collect

Predictable Prompts collects Personal Information through various interactions and from multiple sources, as delineated herein:

2.1. Information Voluntarily Provided by You

We collect Personal Information that you knowingly and voluntarily provide to us when you engage with Predictable Prompts, including, inter alia, when you:

• Complete Online Forms: When you submit information through contact forms, service inquiry forms, booking request forms, or any other data entry fields on our Website, Predictable Prompts may collect:
  • Identifiers: Full legal name, business email address, direct telephone number (and extension, if applicable), mobile telephone number (optional).
  • Professional Information: Company name, your job title or role, industry, company size, and website URL.
  • Inquiry/Project Details: Preferred dates and times for consultations, specific questions or challenges you are facing, project objectives, existing AI tools or platforms in use, budget considerations (optional), and any other narrative details you provide regarding your requirements.
• Direct Communications: When you communicate with Predictable Prompts via email (e.g., to contact@predictableprompts.com), telephone, video conferencing, or other communication channels, we may collect your contact details, the content and metadata of your communications (including date, time, and participants), and any attachments or information you share.
• Service Engagement and Client Onboarding: If you or your organization engage Predictable Prompts for Services, we will collect Personal Information necessary for the establishment of a client relationship, contract execution, service delivery, and billing. This may include more detailed business contact information, information required for due diligence (if applicable), payment and invoicing details (which may be processed by our third-party payment processors), and specific project-related data as governed by a mutually executed Client Agreement or Statement of Work (SOW).

2.2. Information Collected Automatically (Technical and Usage Data)

When you navigate or interact with our Website, Predictable Prompts and its third-party service providers may automatically collect certain technical and usage data about your device and browsing activities using technologies such as cookies, web beacons, pixels, server logs, and similar tracking mechanisms. This information may encompass:

• Log Data: Internet Protocol (IP) address, browser type and version (e.g., Chrome, Firefox, Safari), operating system and platform (e.g., Windows, macOS, iOS, Android), referring and exit URLs, pages visited on our Website, links clicked, time spent on pages, session duration, frequency of visits, date and time stamps of access, and other interaction and diagnostic data.
• Device Information: Type of device used to access the Website (e.g., desktop, laptop, tablet, mobile phone), device manufacturer and model, screen resolution, operating system version, unique device identifiers (e.g., MAC address, IDFA, Android Advertising ID, subject to your device settings and permissions), and mobile network information if accessing via a mobile device.
• Location Information: We may infer your general geographic location (e.g., city, country) from your IP address. More precise location information will only be collected with your explicit consent, if applicable for specific services.

Further details regarding our use of cookies and similar technologies, and your choices in relation thereto, are provided in Section 5 (Cookies and Tracking Technologies) of this Policy.

2.3. Information from Third-Party Sources

In limited circumstances, and in compliance with applicable law, Predictable Prompts may receive Personal Information about you from third-party sources. These sources may include publicly available databases, professional networking platforms (if utilized for business intelligence and in compliance with their terms), third-party lead generation services, or business partners, consistent with applicable law and your permissions with such third parties. This information may be combined with information we collect directly from you.

3. Legal Bases for Processing Personal Information

Predictable Prompts processes your Personal Information lawfully, fairly, and transparently, relying on one or more of the following legal bases as mandated by applicable data protection laws (e.g., GDPR Art. 6(1)):

• Consent (Art. 6(1)(a) GDPR): Where you have provided your unambiguous, freely given, specific, and informed consent for Predictable Prompts to process your Personal Information for one or more specified purposes (e.g., subscribing to non-transactional marketing newsletters or consenting to non-essential cookies). You possess the unequivocal right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.
• Performance of a Contract (Art. 6(1)(b) GDPR): Where the processing of your Personal Information is necessary for the performance of a contract to which you (or your organization) are a party, or to take steps at your request prior to entering into such a contract (e.g., processing your service inquiries, negotiating a Client Agreement, delivering contracted Services, and managing client accounts).
• Legitimate Interests (Art. 6(1)(f) GDPR): Where the processing is necessary for the purposes of the legitimate interests pursued by Predictable Prompts or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Information. Predictable Prompts' legitimate interests include, inter alia:
  • Operating, maintaining, securing, and improving our Website, IT infrastructure, and Services.
  • Responding effectively to your inquiries and providing high-quality customer support and communication.
  • Understanding user needs and enhancing user experience on our Website.
  • Conducting business analytics, market research, and strategic planning to improve our service offerings.
  • Direct marketing of our Services to existing or prospective business clients (B2B marketing), where a pre-existing relationship or a clear indication of interest exists, subject to compliance with applicable e-privacy regulations and offering clear opt-out mechanisms.
  • Preventing fraud and protecting our legal rights and interests.
  • Internal administrative purposes, including record-keeping and corporate governance.

  Where we rely on legitimate interests, we conduct a balancing test to ensure that our interests do not unduly impinge upon your rights and freedoms.

• Compliance with a Legal Obligation (Art. 6(1)(c) GDPR): Where the processing of your Personal Information is necessary for Predictable Prompts to comply with a legal obligation to which we are subject (e.g., for tax reporting, financial accounting, responding to lawful requests from courts or regulatory authorities, or fulfilling other statutory duties).

4. Purposes for Which We Use Your Personal Information

Predictable Prompts utilizes the Personal Information we collect for the following specific, explicit, and legitimate purposes, consistent with the legal bases articulated in Section 3:

• Service Provision, Delivery, and Management: To provide, operate, maintain, support, and improve our Website and the full spectrum of our Services; to process and fulfill your requests for Services and consultations; to manage client relationships, projects, and accounts effectively; and to discharge all contractual obligations set forth in Client Agreements.
• Communication, Engagement, and Support: To respond promptly and comprehensively to your inquiries, comments, feedback, and questions submitted via our Website, email (to contact@predictableprompts.com), or other channels; to provide dedicated customer service and technical support; and to send you essential administrative or transactional communications, such as service-related announcements, updates regarding our Services, modifications to our terms, conditions, and policies, or critical security alerts.
• Personalization and User Experience Enhancement: To personalize and enhance your experience on our Website and with our Services, for instance, by remembering your preferences (e.g., language settings, if applicable), tailoring content to your expressed interests, or streamlining your interactions (subject to your consent for non-essential personalization technologies).
• Analytics, Research, Development, and Improvement: To conduct in-depth analysis of trends, usage patterns, and user interactions with our Website and Services; to gather demographic information and insights; to better understand user needs, pain points, and preferences; to continuously improve our existing service offerings and develop innovative new products, features, and services; and for internal research, development, and quality assurance purposes.
• Marketing, Advertising, and Promotional Activities: Subject to your explicit consent where required by applicable law (e.g., for B2C electronic marketing or for B2B marketing where no prior relationship exists) and your ongoing marketing preferences, to send you targeted marketing communications, newsletters, industry insights, case studies, and promotional materials concerning Predictable Prompts' Services, new features, upcoming events, or other information that we believe may be of genuine interest and value to you. All marketing communications will provide clear and easily accessible mechanisms for you to opt-out or unsubscribe from future mailings (see Section 9).
• Security, Fraud Prevention, Risk Management, and Legal Compliance: To vigilantly monitor, protect, and maintain the security, integrity, and availability of our Website, IT systems, networks, and data assets; to prevent, detect, investigate, and remediate fraudulent activities, security breaches, unauthorized access, and other potentially prohibited or illegal activities; to enforce our Terms of Service and other policies; to comply with all applicable local, national, and international laws, regulations, legal processes (e.g., subpoenas, court orders), and binding governmental requests; and to protect the legal rights, privacy, safety, or property of Predictable Prompts, our clients, our employees, and the public.
• Business Operations, Administration, and Governance: For essential internal business operations, including but not limited to, data analysis for strategic decision-making, financial auditing and reporting, corporate governance, compliance monitoring, internal record-keeping, resource allocation, and strategic business planning and development.

5. Cookies, Tracking Technologies, and Your Choices

Predictable Prompts, along with its authorized third-party service providers, utilizes cookies (small text files placed on your device) and similar tracking technologies, such as web beacons, pixels, embedded scripts, and server logs, to automatically collect and store certain information when you interact with our Website. These technologies are instrumental in enabling essential Website functionality, enhancing your browsing experience, analyzing Website traffic and performance, and, where applicable and consented to, supporting our marketing and advertising efforts.

Categories of Cookies We May Employ:

• Strictly Necessary Cookies (Essential Cookies): These cookies are indispensable for the proper operation of our Website and enable core functionalities such as page navigation, access to secure areas (if applicable), and form submissions. The Website cannot function properly without these cookies. These cookies do not store any personally identifiable information.
• Analytical/Performance Cookies (Statistics Cookies): These cookies enable us to collect information about how visitors use and interact with our Website. This includes counting visits, identifying traffic sources, determining which pages are most and least popular, understanding how visitors navigate through the site, and detecting if users encounter technical issues. All information these cookies collect is aggregated and therefore anonymous (unless you have consented to non-anonymized analytics). This data is crucial for us to measure and improve the performance, usability, and effectiveness of our Website (e.g., Google Analytics cookies).
• Functionality Cookies (Preference Cookies): These cookies allow our Website to remember choices you make and provide enhanced, more personalized features. For example, they may be used to remember your username (if you have an account), language preference, or the region you are in. The information these cookies collect may be anonymized, and they are not used to track your browsing activity on other websites.
• Targeting/Advertising Cookies (Marketing Cookies): [This section must be included and customized IF such cookies are actively used. If Predictable Prompts does NOT use these, this section should explicitly state that or be omitted, and consent mechanisms adjusted accordingly.] These cookies may be set through our Website by Predictable Prompts or by our third-party advertising partners. They are used to build a profile of your interests based on your browsing activity and to display advertisements on other sites that are more relevant to you. They do not directly store personal information but are based on uniquely identifying your browser and internet-connected device. If you do not allow these cookies, you will experience less targeted advertising. The use of these cookies will be subject to your explicit prior consent where required by law.

Your Choices, Consent, and Control Regarding Cookies:

You have several options to control or limit how Predictable Prompts and our partners use cookies and similar technologies:

• Browser Settings: Most modern web browsers provide controls that allow you to view, manage, delete, and block cookies. You can typically configure your browser settings to refuse all cookies or to alert you when a cookie is being sent, allowing you to decide whether to accept it. Please consult your browser's help menu or support documentation for detailed instructions. Please be aware that if you choose to disable or refuse cookies, particularly Strictly Necessary Cookies, some parts of our Website may become inaccessible or may not function as intended.
• Cookie Consent Management Platform (CMP): In jurisdictions where explicit consent for non-essential cookies is mandated by law (e.g., under GDPR, ePrivacy Directive), Predictable Prompts will implement a Cookie Consent Management Platform or banner. This tool will provide you with granular information about the categories of cookies used and allow you to provide or withdraw your consent for each category of non-essential cookies. Your preferences will be respected and can be modified at any time through the CMP.
• Third-Party Opt-Out Tools:
  • Google Analytics: To prevent your data from being used by Google Analytics, you can install the Google Analytics opt-out browser add-on, available at: https://tools.google.com/dlpage/gaoptout.
  • Advertising Industry Opt-Outs: [Include if using advertising cookies] For more information about interest-based advertising and to opt-out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance (DAA), please visit http://optout.aboutads.info/. European users may opt-out of interest-based advertising through the European Interactive Digital Advertising Alliance (EDAA) at http://www.youronlinechoices.eu/.

Please note that opting out of interest-based advertising does not mean you will no longer see advertisements online, but rather that the ads you see may be less relevant to your interests.

6. Disclosure and Sharing of Personal Information

Predictable Prompts is committed to maintaining the confidentiality of your Personal Information. We do not sell, rent, or lease your Personal Information to third parties for their direct marketing purposes. We may share or disclose your Personal Information only in the following limited circumstances and with the specified categories of recipients, always in accordanceance with applicable law and for the legitimate purposes outlined in this Policy:

• Authorized Third-Party Service Providers and Sub-processors: We engage carefully selected third-party vendors, consultants, contractors, and other service providers (acting as data processors or sub-processors on our behalf) to perform a variety of functions and provide essential services necessary for our business operations. These may include, but are not limited to:
  • Cloud infrastructure, hosting, and data storage providers.
  • Website analytics and performance monitoring services (e.g., Google Analytics).
  • Form submission and data capture tools (e.g., Formspree).
  • Customer Relationship Management (CRM) platform providers.
  • Marketing automation and email service providers (for communications you consent to).
  • Payment processing partners (for client billing, ensuring PCI DSS compliance where applicable).
  • IT support, security, and managed service providers.
  • Professional advisory services (legal, accounting, audit, insurance).
  Predictable Prompts provides these service providers with access to Personal Information only to the extent strictly necessary for them to perform their contracted services on our behalf. We maintain contractual agreements with these third parties that obligate them to protect the confidentiality and security of your Personal Information, to process it only in accordance with our documented instructions, and to comply with all applicable data protection laws.
• Business Transfers, Mergers, or Acquisitions: In the event that Predictable Prompts undergoes a significant corporate transaction, such as a merger, acquisition by another company, sale of all or a substantial portion of its assets, financing, reorganization, bankruptcy, or receivership, your Personal Information may be disclosed, shared, or transferred as part of the transaction or during the due diligence process. In such cases, Predictable Prompts will ensure that the recipient entity is bound by appropriate confidentiality obligations and, where feasible and legally required, will notify you of such a transfer.
• Compliance with Legal Obligations and Protection of Rights: Predictable Prompts may disclose your Personal Information if we have a good faith belief that such disclosure is reasonably necessary to:
  • Comply with applicable laws, regulations, subpoenas, court orders, binding governmental requests, or other valid legal processes.
  • Establish, exercise, or defend our legal rights, claims, or property.
  • Prevent, detect, investigate, or otherwise address illegal activities, suspected fraud, security incidents, or technical issues.
  • Protect the rights, property, or personal safety of Predictable Prompts, our clients, our employees, other users, or the public, as required or permitted by law.
  • Enforce our Terms of Service, Client Agreements, or other applicable policies and agreements.
• With Your Explicit and Informed Consent: We may share or disclose your Personal Information with other third parties for any other specific purpose not covered by this Policy, but only with your explicit, prior, and informed consent. You will be provided with clear information about the intended sharing before you provide such consent.
• Aggregated, Anonymized, or De-identified Information: Predictable Prompts may share aggregated, anonymized, or de-identified information, which cannot reasonably be used to identify you or any individual Data Subject, with third parties for various purposes, including statistical analysis, research, industry reporting, and to improve our services. Such information is not considered Personal Information.

7. Data Storage, Security, and Integrity

Predictable Prompts accords the utmost importance to the security of your Personal Information and implements a robust, multi-layered security strategy designed to protect it from unauthorized or unlawful access, use, disclosure, alteration, loss, or destruction. Our commitment to data security encompasses the following key principles and measures:

7.1. Security Measures Implemented

We employ a comprehensive suite of administrative, technical, and physical security safeguards that are continuously reviewed and updated to address evolving threats and are proportionate to the sensitivity of the Personal Information we process and the risks associated with its processing. These measures include, but are not limited to:

• Technical Safeguards:
  • Encryption Protocols: Consistent utilization of strong, industry-standard encryption protocols (e.g., Transport Layer Security (TLS) / Secure Sockets Layer (SSL)) for all Personal Information transmitted over public networks, such as between your browser and our Website. Encryption of Personal Information at rest (e.g., within databases, storage systems, and backups) using robust encryption algorithms and key management practices, where appropriate and technically feasible.
  • Access Control Mechanisms: Implementation and enforcement of strict logical access control mechanisms, including unique user IDs, strong password policies, role-based access controls (RBAC), and the principle of least privilege, ensuring that access to Personal Information is granted only to authorized personnel based on their specific job responsibilities and a legitimate need-to-know. Multi-factor authentication (MFA) is mandated for administrative access to critical systems and sensitive data repositories.
  • Network Security Architecture: Deployment and maintenance of resilient network security architecture, including firewalls, intrusion detection and prevention systems (IDS/IPS), web application firewalls (WAFs), and other network segmentation and security technologies to protect our systems and data from external and internal threats. Regular vulnerability assessments, security scanning, and penetration testing (where appropriate and based on risk) are conducted to proactively identify and remediate potential security weaknesses.
  • Secure Software Development Lifecycle (SSDLC): Adherence to secure software development practices for any custom applications or software developed by or for Predictable Prompts, including secure coding standards, code reviews, static and dynamic application security testing (SAST/DAST), and vulnerability management throughout the development lifecycle.
  • Endpoint Security and Device Management: Utilization of advanced endpoint detection and response (EDR) solutions, comprehensive anti-malware software, and robust device management policies (including encryption and remote wipe capabilities) to protect company-owned and managed devices that access or process Personal Information.
  • Data Loss Prevention (DLP): Implementation of DLP measures, where appropriate, to monitor and control the movement of sensitive data and prevent unauthorized exfiltration.
• Administrative and Organizational Safeguards:
  • Data Protection Policies and Governance: Establishment, maintenance, and enforcement of comprehensive internal data protection policies, standards, and procedures that govern the collection, use, storage, and disposal of Personal Information.
  • Employee Training and Awareness Programs: Provision of regular, mandatory data privacy and security training and awareness programs for all employees, contractors, and relevant personnel who have access to Personal Information, to ensure they understand their responsibilities and best practices for data protection.
  • Third-Party Vendor Risk Management (TPRM): Implementation of a rigorous due diligence and risk assessment process for selecting and managing third-party service providers and sub-processors who handle Personal Information on our behalf. This includes contractual requirements for robust security measures, data protection compliance, audit rights, and breach notification.
  • Incident Response and Management Plan: Maintenance and regular testing of a comprehensive incident response and management plan to effectively prepare for, detect, respond to, contain, mitigate, and recover from any potential data security incidents or breaches. This plan includes procedures for timely notification to affected individuals and relevant regulatory authorities, as required by applicable law.
  • Data Minimization and Purpose Limitation Principles: Strict adherence to the principles of data minimization (collecting only Personal Information that is adequate, relevant, and limited to what is necessary for the specified purposes) and purpose limitation (processing Personal Information only for the specified, explicit, and legitimate purposes for which it was collected).
  • Confidentiality Agreements: Requiring employees, contractors, and relevant third parties with access to Personal Information to sign confidentiality and non-disclosure agreements.
• Physical Security Safeguards:
  • Secure Data Center Facilities: Where Personal Information is stored in physical data centers (primarily through our reputable cloud service providers), we rely on providers who maintain state-of-the-art physical security measures for their facilities. These typically include multi-layered access controls (e.g., biometric scanners, card readers), 24/7 surveillance and monitoring, environmental controls (fire suppression, climate control), and robust disaster recovery capabilities. Predictable Prompts selects cloud providers who demonstrate compliance with internationally recognized security standards and certifications (e.g., ISO 27001, SOC 2 Type II, FedRAMP).
  • Secure Office Environments: Implementation of appropriate physical security measures for any Predictable Prompts office premises where Personal Information might be accessed or processed, such as access controls, secure areas for sensitive work, and policies for secure document handling and disposal (e.g., shredding).

7.2. Data Storage Location and Cloud Security

Personal Information collected and processed by Predictable Prompts is primarily stored on secure servers provided by leading, reputable cloud service providers. These providers are selected based on their robust security infrastructure, compliance certifications, and commitment to data protection. Our primary data storage locations are within [Specify primary storage jurisdiction(s) with more detail, e.g., "the United States, utilizing Amazon Web Services (AWS) regions such as US-East and US-West," or "the European Economic Area, utilizing Google Cloud Platform (GCP) regions in Frankfurt and Dublin"]. Specific data residency commitments, if any, for client data will be governed by the applicable Client Agreement. We configure and manage our cloud environments in accordance with security best practices, including appropriate access controls, encryption, and monitoring. For further details on international data transfers, please refer to Section 10 of this Policy.

7.3. Your Role in Data Security

While Predictable Prompts implements extensive measures to safeguard your Personal Information, the security of your information also depends on your own practices. We encourage you to take appropriate precautions to protect your Personal Information, such as using strong, unique passwords for any accounts you may have that interact with our Services (if applicable), keeping your login credentials confidential, being vigilant against phishing attempts, and ensuring the security of your own devices and internet connections.

7.4. Disclaimer on Absolute Security

Despite our steadfast commitment and the implementation of comprehensive, industry-standard security measures, it is important to acknowledge that no method of data transmission over the Internet or method of electronic storage can be guaranteed to be absolutely 100% secure. Therefore, while Predictable Prompts strives to use commercially acceptable and robust means to protect your Personal Information, we cannot ensure or warrant the absolute security or invulnerability of any Personal Information you transmit to us or that is stored on our systems. Any transmission of Personal Information is undertaken at your own risk. In the unfortunate event of a data breach that is determined to pose a high risk to your rights and freedoms, Predictable Prompts will take all appropriate and legally required steps to notify you and relevant regulatory authorities in accordance with our incident response plan and applicable legal obligations.

8. Data Retention and Deletion Practices

Predictable Prompts will retain your Personal Information only for the period reasonably necessary to fulfill the specific, legitimate purposes for which it was collected, as detailed in this Privacy Policy, and thereafter as required or permitted by applicable laws, regulations, contractual obligations, or for the establishment, exercise, or defense of legal claims. Our data retention practices are designed to ensure that Personal Information is not kept longer than necessary, adhering to principles of data minimization and storage limitation.

The criteria used by Predictable Prompts to determine appropriate data retention periods include, but are not limited to:

• The nature and duration of your active relationship with Predictable Prompts: For instance, if you are an active client, Personal Information directly related to your account, service delivery, and contractual relationship will be retained for the duration of our engagement and for a defined period thereafter as necessary for final reporting, dispute resolution, audit purposes, or ongoing support as mutually agreed.
• The specific purposes for which the Personal Information was collected and processed: We retain Personal Information only as long as it remains relevant and necessary for these initial purposes.
• Compliance with legal, regulatory, and statutory obligations: Certain laws and regulations may mandate specific minimum or maximum retention periods for particular categories of data (e.g., financial transaction records for tax and audit compliance, employment-related records, data relevant to ongoing or anticipated litigation or regulatory investigations). Predictable Prompts adheres to these legally mandated retention schedules. For example, financial records are typically retained for [Specify Period, e.g., "seven (7) to ten (10) years"] in accordance with applicable financial and tax laws.
• The necessity of retaining Personal Information for the establishment, exercise, or defense of legal claims: We may retain Personal Information for periods corresponding to applicable statutes of limitations or as reasonably necessary to support or defend against potential or actual legal claims, investigations, or disputes.
• The terms of any explicit consent you have provided for specific processing activities: Where processing is based on your consent, we will generally retain the relevant Personal Information for the period specified at the time of consent collection, or until such time as you withdraw your consent, subject to any overriding legal obligations or legitimate interests that may require longer retention.
• Operational and business continuity requirements: Personal Information may be retained in backup archives or disaster recovery systems for a limited period in accordance with our established backup and data recovery policies and schedules. Such data, while retained, will be isolated from further active processing and will be securely deleted in line with our backup rotation and destruction procedures.
• Industry best practices and professional guidelines: We consider relevant industry standards and professional guidelines when determining appropriate retention periods.

Illustrative Examples of Retention Periods (Subject to specific legal and contractual context):

• Website Visitor Data (e.g., server logs, IP addresses, aggregated analytics data): Retained in an identifiable or linkable form for a period generally not exceeding [Specify Period, e.g., "12 to 24 months"] for purposes of security monitoring, traffic analysis, and website performance optimization, after which such data may be aggregated, anonymized, or securely deleted. Cookie-related data retention is governed by cookie expiration dates and user consent preferences.
• Contact Form Submissions and General Inquiries (Non-Client): Personal Information submitted through website contact forms or general email inquiries (e.g., to contact@predictableprompts.com) that do not result in a client relationship may be retained for [Specify Period, e.g., "a period of up to three (3) years"] following our last substantive communication regarding the inquiry. This allows for appropriate follow-up, historical context for future interactions, and analysis of inquiry trends, unless a longer period is mandated by law or you request earlier deletion and such deletion is permissible and technically feasible.
• Prospective Client Data (Pre-Contractual Engagement): Information pertaining to prospective clients with whom Predictable Prompts is actively engaged in discussions or negotiations regarding potential Services may be retained for the duration of such engagement process. If no contractual relationship is established, this data may be retained for a reasonable period thereafter (e.g., [Specify Period, e.g., "up to two (2) years"]) for purposes of business development analysis, record-keeping, and potential future re-engagement, subject always to your marketing preferences and right to object.
• Client Personal Information (Pursuant to Client Agreements): Personal Information directly related to active clients and the provision of Services will be retained for the duration of the applicable Client Agreement and for a subsequent period as defined by the terms of that agreement, relevant legal and regulatory record-keeping requirements (e.g., financial, tax, corporate governance), and applicable statutes of limitations. Typically, this retention period extends for [Specify Period, e.g., "seven (7) to ten (10) years"] after the formal termination or conclusion of the client relationship.

Upon the expiration of the applicable retention period, or when Personal Information is determined to be no longer necessary for the legitimate purposes for which it was collected and processed, Predictable Prompts will take commercially reasonable and technically feasible steps to securely and permanently delete or irreversibly anonymize your Personal Information in accordance with our internal data disposal protocols and all applicable legal requirements. If, in certain limited and exceptional circumstances, complete deletion is not immediately possible (e.g., due to technical constraints related to immutable backup archives that are scheduled for eventual overwriting), we will ensure that the Personal Information is securely stored, effectively isolated from any further active processing or use, and protected by appropriate security measures until such time as secure deletion can be achieved.

9. Your Privacy Rights and Choices

Predictable Prompts acknowledges and respects your rights concerning your Personal Information. Subject to your jurisdiction of residence and the specific provisions of applicable data protection laws (including, but not limited to, the GDPR for individuals located in the European Economic Area (EEA) and the United Kingdom (UK), the CCPA/CPRA for residents of California, and other analogous legislation), you may be entitled to exercise certain rights regarding the Personal Information that Predictable Prompts processes about you. These rights are not absolute and may be subject to certain exceptions, limitations, or conditions as prescribed by law. Your principal rights may include:

• The Right to Access (or Right to Know): You have the right to request confirmation from Predictable Prompts as to whether or not Personal Information concerning you is being processed, and, where that is the case, to request access to that Personal Information. This may include the right to obtain a copy of the specific pieces of Personal Information we hold about you, as well as information regarding the categories of Personal Information collected, the sources from which it was collected, the purposes for which it is processed, the categories of third parties with whom it has been shared or disclosed, the criteria used to determine data retention periods, and information about your other rights.
• The Right to Rectification (Correction): You have the right to request that Predictable Prompts correct, without undue delay, any inaccurate or incomplete Personal Information we hold about you. This may involve providing supplementary information to complete the data.
• The Right to Erasure (Deletion or "Right to be Forgotten"): You have the right to request the deletion or removal of your Personal Information under certain circumstances, such as when the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed, when you withdraw your consent (if consent was the sole legal basis for processing), when you successfully object to processing and there are no overriding legitimate grounds for continued processing, or when the Personal Information has been unlawfully processed. This right is not absolute and may be subject to legal or legitimate overriding interests for continued retention.
• The Right to Restrict Processing: You have the right to request that Predictable Prompts restrict the processing of your Personal Information under certain conditions, for example, if you contest the accuracy of the Personal Information (for a period enabling us to verify its accuracy), if the processing is deemed unlawful but you oppose the erasure of the Personal Information and request restriction of its use instead, if Predictable Prompts no longer needs the Personal Information for the purposes of processing but you require it for the establishment, exercise, or defense of legal claims, or if you have objected to processing pending the verification of whether our legitimate grounds override your own.
• The Right to Data Portability: Where the processing of your Personal Information is based on your consent or on the performance of a contract to which you are a party, and the processing is carried out by automated means, you have the right to receive the Personal Information that you have provided to Predictable Prompts in a structured, commonly used, and machine-readable format. You also have the right to transmit that data to another data controller without hindrance from Predictable Prompts, where technically feasible.
• The Right to Object to Processing: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Information which is based on Predictable Prompts' legitimate interests (or those of a third party) as the legal basis for processing. Upon such an objection, Predictable Prompts shall no longer process your Personal Information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims. You also have an absolute and unconditional right to object at any time to the processing of your Personal Information for direct marketing purposes (including profiling to the extent that it is related to such direct marketing).
• The Right to Withdraw Consent: Where Predictable Prompts relies on your explicit consent as the legal basis for processing your Personal Information (e.g., for certain marketing activities or non-essential cookies), you have the right to withdraw that consent at any time, easily and freely. The withdrawal of consent will not affect the lawfulness of any processing conducted by Predictable Prompts based on your consent prior to its withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on other lawful processing grounds.
• Rights Related to Automated Individual Decision-Making, Including Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such decision is (a) necessary for entering into, or performance of, a contract between you and Predictable Prompts; (b) authorized by Union or Member State law to which Predictable Prompts is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (c) based on your explicit consent. Predictable Prompts does not currently engage in automated decision-making processes that produce legal or similarly significant effects on individuals in this manner. Should this practice change, this Policy will be updated, and appropriate safeguards implemented.
• Specific Rights for California Residents (under CCPA/CPRA): In addition to the rights outlined above, residents of California may be entitled to further specific rights, including:
  • The right to opt-out of the "sale" or "sharing" (for purposes of cross-context behavioral advertising) of their Personal Information. Predictable Prompts currently does not "sell" Personal Information in the traditional sense of exchanging it for monetary or other valuable consideration. [Predictable Prompts must clearly state its position on "sharing" for cross-context behavioral advertising and provide a compliant "Do Not Sell or Share My Personal Information" mechanism if applicable.]
  • The right to limit the use and disclosure of their Sensitive Personal Information to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services, or for other permitted business purposes under the CCPA/CPRA.
• The Right to Non-Discrimination: Predictable Prompts will not discriminate against you in any way (e.g., by denying goods or services, charging different prices or rates, or providing a different level or quality of goods or services) for exercising any of your applicable privacy rights under data protection laws.
• The Right to Lodge a Complaint with a Supervisory Authority: You have the right to lodge a complaint with a competent data protection supervisory authority in your Member State of habitual residence, place of work, or place of the alleged infringement if you believe that Predictable Prompts' processing of your Personal Information infringes applicable data protection laws. A list of EU/EEA supervisory authorities can be found at [Provide link to EDPB website or relevant resource].

Procedure for Exercising Your Rights: To exercise any of these rights, or if you have any questions, concerns, or require clarification regarding your privacy rights or Predictable Prompts' data processing practices, please contact Predictable Prompts by sending an email to contact@predictableprompts.com. Please clearly state the nature of your request in the subject line and body of your email (e.g., "Data Subject Access Request," "Request for Deletion of Personal Information").

Predictable Prompts will respond to your verifiable request in accordance with, and within the timeframes stipulated by, applicable data protection laws (typically within one month of receipt, extendable by a further two months where necessary, taking into account the complexity and number of requests). To protect your privacy and security, and to ensure that Personal Information is not disclosed to any unauthorized person, we may need to request specific information from you to help us verify your identity and confirm your right to access your Personal Information (or to exercise any of your other rights). This verification process may involve asking you to provide information that matches the Personal Information we already hold about you. We may also contact you to ask for further clarification or information in relation to your request to expedite our response. If we are unable to verify your identity sufficiently, we may be unable to process your request. There may be circumstances where we are legally permitted or required to decline your request, in whole or in part; if so, we will inform you of the reasons for such a decision, subject to any legal restrictions.

Managing Your Marketing Preferences (Opt-Out): You can opt-out of receiving promotional or marketing communications from Predictable Prompts at any time by: (a) clicking the "unsubscribe," "opt-out," or "manage preferences" link typically found at the bottom of any marketing email you receive from us; or (b) by sending an email to contact@predictableprompts.com with "Unsubscribe from Marketing" in the subject line and specifying your request in the body of the email. Please note that even if you opt-out of receiving marketing communications, Predictable Prompts may still need to send you essential non-promotional, transactional, or service-related communications regarding your account, our services, updates to our terms or policies, or our ongoing business relations (e.g., service announcements, administrative notices, responses to your direct inquiries or service requests).

10. International Data Transfers

Predictable Prompts is a global service provider, and as such, your Personal Information may be transferred to, stored in, and processed in countries other than your country of habitual residence or the country from which you initially provided the information or accessed our Website or Services. These countries may include, but are not limited to, the United States of America, where Predictable Prompts' primary operations or those of its key service providers may be based, as well as other jurisdictions where our data centers, cloud service providers, or sub-processors are located. It is important to note that the data protection laws and regulations in these recipient countries may differ from, and in some cases, may provide a lower level of data protection than, those in your own jurisdiction (particularly if you are located within the European Economic Area (EEA), the United Kingdom (UK), Switzerland, or other regions with comprehensive data protection regimes).

Where Predictable Prompts transfers Personal Information internationally, particularly when transferring Personal Information originating from jurisdictions such as the EEA, UK, or Switzerland to countries outside of these regions that have not been formally recognized by the relevant authorities (e.g., the European Commission, the UK Information Commissioner's Office) as providing an "adequate" level of data protection, we are unequivocally committed to implementing and maintaining robust and appropriate safeguards to ensure that such transfers comply with all applicable data protection laws and that your Personal Information remains protected to a standard essentially equivalent to that required within your jurisdiction. These safeguards are designed to provide legal certainty and protection for your data and may include, but are not limited to, one or more of the following mechanisms:

• Adequacy Decisions: Relying on formal adequacy decisions adopted by the European Commission (pursuant to Article 45 of the GDPR) or equivalent adequacy regulations issued by the UK Secretary of State or the Swiss Federal Data Protection and Information Commissioner (FDPIC), which recognize that certain non-EEA/UK/Swiss countries ensure an adequate level of data protection.
• Standard Contractual Clauses (SCCs): Entering into legally binding Standard Contractual Clauses (also known as Model Clauses) as approved by the European Commission (or the UK Information Commissioner's Office Addendum for UK transfers, or the revised Swiss SCCs for Swiss transfers) with the data recipient (data importer) located in a third country. These SCCs impose specific contractual obligations on the data importer to implement technical and organizational measures to protect the Personal Information to a standard comparable to that required within the EEA/UK/Switzerland. Predictable Prompts will also conduct Transfer Impact Assessments (TIAs) where necessary in conjunction with the SCCs to evaluate the level of protection in the recipient country and implement supplementary measures if required to ensure an essentially equivalent level of protection.
• Binding Corporate Rules (BCRs): For intra-group transfers of Personal Information within the Predictable Prompts corporate family (if Predictable Prompts establishes such a structure in the future and obtains regulatory approval), we may seek to implement and rely on Binding Corporate Rules that provide a legally binding and enforceable framework for international data transfers, ensuring consistent data protection standards across the group.
• Other Legally Permissible Transfer Mechanisms or Derogations: In specific and limited circumstances, relying on other data transfer mechanisms or derogations as permitted under applicable data protection laws (e.g., GDPR Article 49). This may include transfers made with your explicit, informed consent to the proposed transfer after having been fully informed of the possible risks of such transfers due to the absence of an adequacy decision and appropriate safeguards; transfers necessary for the performance of a contract between you and Predictable Prompts or for the implementation of pre-contractual measures taken at your request; transfers necessary for the conclusion or performance of a contract concluded in your interest between Predictable Prompts and another natural or legal person; transfers necessary for important reasons of public interest; or transfers necessary for the establishment, exercise, or defense of legal claims.

By using our Website or engaging our Services and thereby providing Predictable Prompts with your Personal Information, you acknowledge and understand that your Personal Information may be transferred to, stored, and processed in countries outside of your country of residence, including potentially the United States. You further acknowledge that Predictable Prompts will implement the appropriate safeguards as described herein to protect your Personal Information during such international transfers.

If you have any questions or require further information regarding the specific safeguards applied by Predictable Prompts to the international transfer of your Personal Information, please do not hesitate to contact us at contact@predictableprompts.com.

11. Third-Party Websites, Links, and External Services

Our Website may, from time to time, contain hyperlinks or references to external websites, online platforms, applications, content, products, or services that are owned, operated, or provided by third parties and are not under the direct control or ownership of Predictable Prompts ("Third-Party Services"). Additionally, certain functionalities or content on our Website may be integrated with, or allow you to access or interact with, such Third-Party Services (e.g., social media sharing buttons, embedded videos from third-party platforms, links to partner websites or industry resources).

This Privacy Policy applies solely and exclusively to the collection, use, processing, and protection of Personal Information by Predictable Prompts through our own Website and Services. It does not extend to, nor does it govern, the privacy practices, data collection methods, or security measures of any such Third-Party Services. Predictable Prompts is not responsible or liable for the content, privacy policies, terms of service, or practices of any Third-Party Services, including how they may collect, use, share, or secure your Personal Information.

If you choose to follow a link to any of these Third-Party Services or decide to utilize any functionalities that connect you to such services, you do so entirely at your own risk. We strongly advise and encourage you to exercise due diligence and caution by carefully reviewing the privacy policies, data protection statements, and terms of service of any Third-Party Service you visit or interact with before providing them with any of your Personal Information or engaging in any transactions. Predictable Prompts disclaims any and all responsibility or liability for your interactions with, or any Personal Information you may provide to, such Third-Party Services.

12. Children's Privacy and Online Protection

The Website and Services offered by Predictable Prompts are not designed for, intended for, or directed at individuals who are considered children under applicable data protection and online privacy laws. In most jurisdictions, this typically refers to individuals under the age of sixteen (16) years, or such other age as may be stipulated by specific local or national legislation (for example, under the Children's Online Privacy Protection Act ("COPPA") in the United States, the relevant age is under thirteen (13) years for the collection of personal information online without verifiable parental consent).

Predictable Prompts does not knowingly or intentionally solicit, collect, use, or disclose Personal Information from or about children under the applicable minimum age without first obtaining verifiable parental consent, where such consent is legally required. If Predictable Prompts becomes aware, through reliable means, that we have inadvertently collected or received Personal Information from a child under the applicable minimum age without the requisite verifiable parental consent, we will take commercially reasonable and legally mandated steps to promptly delete such information from our systems, records, and databases. We may retain limited information as necessary to ensure that the child is not contacted again.

If you are a parent, legal guardian, or an individual with knowledge that a child under the applicable minimum age has provided Predictable Prompts with their Personal Information without proper parental consent, please contact us immediately by sending an email to contact@predictableprompts.com. Please provide sufficient detail to allow us to investigate and address the matter appropriately. We are committed to complying with all applicable laws and regulations concerning children's privacy and online protection.

13. Contact Information; Data Protection Inquiries

Should you have any questions, comments, concerns, or complaints regarding this Privacy Policy, Predictable Prompts' data protection and privacy practices, or if you wish to exercise any of your statutory privacy rights as detailed in Section 9 of this Policy, please do not hesitate to contact Predictable Prompts. Our designated point of contact for data protection matters is:

Predictable Prompts
Attn: Data Privacy Officer / Legal Department
Email: contact@predictableprompts.com

Please ensure that your communication clearly outlines the nature of your inquiry, request, or concern to facilitate a timely and effective response. Predictable Prompts is committed to addressing your privacy-related inquiries and resolving any complaints in a fair, transparent, and efficient manner, in accordance with applicable data protection laws.

While we encourage you to contact us in the first instance, if you believe that Predictable Prompts has not adequately addressed your complaint or concern, and you are located in a jurisdiction that has an established data protection supervisory authority (e.g., an EU/EEA Member State, the UK, or California), you may have the right to lodge a formal complaint with that authority. We would, however, appreciate the opportunity to address your concerns directly before you approach a supervisory authority and will make all reasonable efforts to resolve the matter with you.