Privacy policy
Effective Date: October 13, 2025
Last Revised: October 13, 2025
This Privacy Policy ("Policy") governs the manner in which JFernandez, LLC, doing business as 60 Watts of Clarity (hereafter "Company," "we," "us," or "our"), a Texas limited liability company, collects, uses, discloses, and protects information acquired through its websites, applications, custom AI builds, SaaS platforms, workshops, and any tools, software, or services provided directly or indirectly via the Launch Lemonade platform, including but not limited to AI agent builds, integrations through the Spanel console, and services enhanced by prompt injection protection mechanisms such as Lakera. This Policy complies with applicable privacy laws in jurisdictions where the Company operates or where its clients reside, including but not limited to the Texas Data Privacy and Security Act (TDPSA) and the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).
By accessing, interacting with, or utilizing any of the Company's services or related digital properties, the user ("you" or "your") consents to the practices described herein. You also acknowledge your continued ownership of your Input Data and agree that your engagement with the Company is subject to the terms herein. This Policy represents our commitment to transparency, ethical AI development, and the protection of user privacy in accordance with both legal requirements and the professional standards derived from social work ethics and educational best practices.
1. OUR PRIVACY PHILOSOPHY
60 Watts of Clarity was founded on the principle that artificial intelligence should enhance human connection rather than diminish it, and that ethical considerations must precede technological advancement. This Privacy Policy reflects not only our legal obligations under applicable state and federal law but also our explicit commitments to professional transparency, AI safety, and human dignity standards derived from social work ethics and higher education faculty norms. We believe that your data is your property, and this core principle permeates every aspect of our data handling practices, technical architecture, and business operations.
Unlike many technology companies that view user data as a commodity to be monetized through advertising, analytics partnerships, or data brokerage, we view your data as an extension of your professional practice, creative endeavors, or educational pursuits. We do not participate in surveillance capitalism. We do not extract value from your information beyond the narrow purpose of delivering the specific services you have requested. Our business model is built on providing valuable AI tools and education, not on harvesting and monetizing your personal information or creative outputs.
2. DEFINITIONS
For purposes of this Privacy Policy, the following terms shall hold the indicated meanings. "Input Data" refers to any data, content, files, prompts, documents, instructions, or other information provided, uploaded, stored, or otherwise input by the user into our systems or through our services, including but not limited to text prompts, uploaded documents, voice recordings, images, or any other form of content submitted for processing by AI agents. "Output Data" refers to content, results, recommendations, analyses, creative works, or any other materials generated by AI agents trained using Input Data as provided by the user, including but not limited to text responses, generated documents, strategic recommendations, educational materials, or clinical documentation.
"Personal Information" shall denote any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including but not limited to identifiers such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. "Sensitive Personal Information" includes, but is not limited to, data revealing racial or ethnic origin, religious or philosophical beliefs, health conditions, mental health status, precise geolocation, biometric identifiers processed for unique identification purposes, genetic data, or any category designated as sensitive under applicable data privacy laws including CCPA, CPRA, or other state privacy statutes.
"AI Agents" refer to individualized artificial intelligence assistants, chatbots, conversational interfaces, or automated reasoning systems created, trained, and deployed using user-provided Input Data. These AI Agents are distinct from foundational large language models ("LLMs") operated by third-party vendors such as OpenAI, Anthropic, Google, or Meta. While our AI Agents may utilize third-party LLMs as underlying computational infrastructure, the training and customization performed using your Input Data is isolated to your specific agent and does not contribute to the improvement or training of the foundational models themselves.
"Processing" shall mean any operation or set of operations performed on Personal Information or Input Data, whether or not by automated means, including but not limited to collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
3. SCOPE OF COVERAGE
This Policy applies comprehensively to all websites operated by the Company, including but not limited to www.60wattsofclarity.com, faculty.60wattsofclarity.com, socialwork.60wattsofclarity.com, and business.60wattsofclarity.com; to any custom-built AI agents provided to third-party clients through individual contracts or enterprise agreements; to SaaS solutions provided through the Launch Lemonade platform infrastructure; to educational services including workshops, training sessions, webinars, and consulting engagements; and to any documentation, communications, newsletters, or marketing materials in tangible or digital form relating to such services.
This Policy applies regardless of the method by which you access our services, including through desktop computers, mobile devices, tablets, or any other internet-enabled device. It applies whether you are a paying customer, trial user, workshop participant, newsletter subscriber, or visitor to our websites. The Policy governs all data collection and processing activities conducted by the Company, its employees, contractors, and authorized subprocessors acting on our behalf.
4. DATA OWNERSHIP AND USER RIGHTS
The Company affirms unequivocally and without reservation that users retain full and exclusive ownership of all Input Data. The provision of Input Data to any system or platform operated by the Company shall in no way constitute a transfer of title, assignment of rights, licensing of proprietary interest, or creation of any ownership claim by the Company. This principle applies regardless of the volume, complexity, commercial value, or nature of the Input Data, and extends to all forms of content including but not limited to proprietary business strategies, clinical case notes, educational curricula, creative works, research data, or personal reflections.
Likewise, users retain all legal and equitable interests in any Output Data derived from their respective Input Data. The Company undertakes no claim of intellectual property arising from such Output Data, nor any entitlement to financial, commercial, or reputational gains realized through user innovation, creativity, or professional practice using Company tools. Whether the Output Data consists of business plans, therapeutic interventions, educational lesson plans, research findings, creative writing, or any other form of intellectual production, you maintain complete ownership and control.
Any monetary wealth, commercial success, professional advancement, or derivative benefits achieved by a user through use of the Company's platforms is deemed categorically the property of the user. The Company shall not be entitled to any share, royalty, commission, equity interest, revenue participation, or implied benefit from your success. Our role is solely that of tool provider and infrastructure facilitator, analogous to a software vendor providing word processing tools or spreadsheet applications. Just as a word processor manufacturer does not claim ownership of the novel you write using their software, we do not claim ownership of the innovations, strategies, or creative works you develop using our AI tools.
This data ownership principle is not merely aspirational but is embedded into our technical architecture through data sandboxing, access controls, and contractual arrangements with subprocessors. We have designed our systems to ensure that your data remains isolated, that cross-user data contamination cannot occur, and that your Input Data benefits only your specific AI agent rather than improving our platform generally or benefiting other users.
5. CATEGORIES OF DATA COLLECTED
The Company collects only such Personal Information as is strictly necessary to maintain user accounts, provide services, comply with applicable laws, or fulfill legitimate business purposes consistent with user expectations. We adhere to the principle of data minimization, collecting the least amount of information necessary to accomplish these purposes.
We collect Account Information when you register for our services, including your name, email address, organizational affiliation (for enterprise or educational clients), professional credentials (where relevant to service customization), and payment information. Payment information is processed through secure third-party payment processors such as Stripe and is not stored directly on Company servers. We collect only the minimum payment information necessary to process transactions and maintain billing records for tax and accounting purposes.
We collect Input Data that you voluntarily provide when using our AI agents, including prompts, questions, documents uploaded for analysis, voice recordings submitted for transcription or analysis, and any other content you submit for processing. This Input Data may include information about your professional practice, business strategies, educational methods, clinical cases (appropriately de-identified), research projects, or personal productivity workflows. We recognize that this Input Data may contain sensitive professional information, and we treat it with the highest level of confidentiality and security.
We collect Usage Data through automated means when you interact with our services, including technical information such as IP addresses, browser types, device identifiers, operating systems, referring URLs, pages viewed, features accessed, time spent on various pages, clickstream data, and session duration. This Usage Data is collected through standard web technologies including cookies, web beacons, and similar tracking mechanisms. We use this information to understand how users interact with our services, identify technical issues, optimize performance, and improve user experience.
We collect Educational Analytics when you participate in our workshops, training sessions, or educational programs, including interaction with instructional materials, completion rates, assessment results (where applicable), and engagement metrics. This information helps us improve our educational offerings and tailor content to user needs. We collect Communications Data when you contact us through email, support tickets, feedback forms, or other communication channels, including the content of your messages, your contact information, and any attachments you provide.
We do not knowingly collect data from individuals under the age of thirteen (13) years. Our services are designed for adult professionals in fields such as social work, education, healthcare, and business, and are not directed toward children. If we discover that we have inadvertently collected information from a child under 13, we will delete that information promptly upon verification.
6. HOW WE USE YOUR DATA
We use Personal Information to create and maintain user accounts, authenticate users, provide customer support, process payments, send service-related communications, and fulfill our contractual obligations to deliver the services you have purchased or subscribed to. We use this information to personalize your experience, remember your preferences, and provide continuity across sessions and devices.
We use Input Data solely and exclusively to train, improve, and enhance the performance of the specific AI Agent that you have contracted or accessed. This is the critical distinction that sets 60 Watts of Clarity apart from many AI service providers. We do not use your Input Data to train foundational large language models (LLMs) such as GPT, Claude, Gemini, or any other general-purpose AI system. We do not aggregate your data with data from other users to improve our platform generally. We do not use your data to create training datasets for machine learning research. Your Input Data is sandboxed within your specific agent instance and is used only to improve that agent's ability to serve you.
The technical implementation of this principle involves several mechanisms. First, we employ data isolation techniques that ensure your Input Data is stored separately from other users' data and is accessible only to the specific AI agent instance assigned to you. Second, we use retrieval-augmented generation (RAG) and similar techniques that allow your agent to reference your data contextually without incorporating it into the underlying model weights. Third, we maintain strict access controls that prevent our engineers, data scientists, or other personnel from accessing your Input Data except as necessary for technical support, security incident response, or compliance with legal obligations, and only with appropriate authorization and audit trails.
We use Usage Data to monitor system performance, identify and resolve technical issues, detect and prevent security threats, analyze user behavior patterns to improve service design, optimize our infrastructure, and conduct internal research and development. This Usage Data is typically aggregated and anonymized for analytical purposes, meaning it cannot be traced back to individual users. We use Educational Analytics to assess the effectiveness of our training programs, identify areas where participants struggle or excel, customize educational content to learner needs, and continuously improve our workshop curricula and delivery methods.
We use Communications Data to respond to your inquiries, provide technical support, address complaints or concerns, gather feedback about our services, and maintain records of our interactions for quality assurance and legal compliance purposes. We may also use contact information to send you important service announcements, security alerts, policy updates, or other transactional communications necessary for the proper functioning of our services.
7. WHAT WE DO NOT DO WITH YOUR DATA
The Company does not, under any circumstances, sell, lease, rent, barter, exchange, or otherwise transfer Personal Information or Input Data to third parties for commercial gain. We are not in the business of data brokerage, advertising technology, or surveillance capitalism. We do not participate in data marketplaces. We do not provide your information to advertisers, marketing firms, analytics companies (beyond the limited service providers described in Section 8), or any other third parties seeking to use your data for their own purposes.
We do not use Input Data to train foundation-level LLMs, including but not limited to those managed by Anthropic, OpenAI, Google, Meta, Cohere, or any other third-party vendor. When we utilize third-party LLM APIs as computational infrastructure for our AI agents, we do so under contractual terms that prohibit the API provider from using your data for model training purposes. We have specifically selected API providers and service tiers that offer these protections, even when more economical options without such protections are available.
We do not use Output Data derived from one user's Input Data to power, improve, or reinforce another user's agent or experience. Each user's AI agent operates independently, and the improvements made to your agent based on your usage patterns and feedback do not benefit other users' agents. This ensures that your competitive advantages, proprietary methodologies, or unique insights remain exclusively yours.
We do not engage in cross-context behavioral advertising or tracking. We do not build profiles of your interests, behaviors, or characteristics for advertising purposes. We do not participate in advertising networks or allow third-party advertisers to track your activity across our services. Our business model is based on providing valuable services for which you pay directly, not on monetizing your attention or personal information through advertising.
We do not make automated decisions with legal or similarly significant effects based solely on automated processing of your Personal Information without human intervention. While our AI agents may provide recommendations, suggestions, or analyses, we do not use these outputs to make decisions about your eligibility for services, pricing, terms of service, or other matters that could significantly affect your rights or interests without meaningful human review.
8. DATA SHARING AND THIRD-PARTY SUBPROCESSORS
While we do not sell your data, we do share certain information with carefully selected third-party service providers (subprocessors) who assist us in delivering our services. These subprocessors are contractually obligated to use your information only for the specific purposes we authorize and to implement appropriate security measures to protect your data.
We use Launch Lemonade as our primary platform infrastructure provider. Launch Lemonade hosts our SaaS applications, manages user authentication systems, stores certain user account information, and provides the underlying technical infrastructure that powers our AI agent delivery platform. Data you provide through our services may be processed through Launch Lemonade's infrastructure. We maintain a Data Processing Agreement (DPA) with Launch Lemonade that specifies their obligations regarding data security, confidentiality, and permissible uses of data. Users are encouraged to review Launch Lemonade's privacy policy to understand their data handling practices, though our DPA with them requires compliance with standards at least as protective as those set forth in this Policy.
We use Lakera to provide advanced prompt injection protection and security monitoring for AI interactions. Lakera's technology analyzes prompts and responses in real-time to detect malicious inputs, jailbreak attempts, prompt injection attacks, and other security threats. Lakera's services are restricted to detection and mitigation only and do not retain or exploit your data for secondary purposes such as model training or service improvement. The security analysis is performed ephemerally, and your content is not stored by Lakera beyond the time necessary to complete the security assessment.
We use third-party Large Language Model (LLM) API providers such as OpenAI, Anthropic, Google, or others as computational infrastructure for our AI agents. When you interact with an AI agent, your prompts may be sent to these API providers for processing, and the generated responses are returned to our systems for delivery to you. We have specifically selected API service tiers and contractual arrangements that prohibit these providers from using your data to train their foundational models. For example, we use OpenAI's API under terms that exclude customer data from model training, and we employ similar protective arrangements with other LLM providers.
We use Stripe or similar payment processors to handle credit card transactions, subscription billing, and payment processing. These payment processors receive only the information necessary to process payments and are subject to Payment Card Industry Data Security Standard (PCI DSS) compliance requirements. We do not store complete credit card numbers on our servers; instead, we maintain tokenized references that allow us to process recurring payments without exposing sensitive payment information.
We use email service providers such as Google Workspace, SendGrid, or similar platforms to deliver transactional emails, service notifications, and (with your consent) marketing communications. These providers have access to your email address and the content of messages we send to you, but are contractually prohibited from using this information for their own purposes.
We use cloud hosting providers such as Amazon Web Services (AWS), Google Cloud Platform (GCP), or Microsoft Azure to host our applications, store data, and provide computational resources. These providers offer infrastructure-level services and do not have access to the content of your data in a meaningful sense, as data is encrypted at rest and in transit. We select hosting providers based on their security certifications, compliance with industry standards, and contractual commitments to data protection.
In the event of a business transaction such as a merger, acquisition, reorganization, asset sale, or bankruptcy proceeding, your information may be transferred to a successor entity. In such circumstances, we will provide notice before your Personal Information is transferred and becomes subject to a different privacy policy, and you will have the opportunity to delete your data before such transfer if you do not wish to continue under the new ownership.
We may disclose your information if required to do so by law, regulation, legal process, or governmental request, including but not limited to compliance with court orders, subpoenas, warrants, or regulatory investigations. We may also disclose information when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. Where legally permissible, we will notify you of such legal demands and give you an opportunity to challenge the disclosure.
9. SECURITY MEASURES
All user interactions with our platform are protected by industry-standard encryption protocols during transit and at rest. We employ Transport Layer Security (TLS) 1.2 or higher for all data transmitted between your device and our servers, ensuring that information cannot be intercepted or read by unauthorized parties during transmission. Data stored on our servers is encrypted using AES-256 encryption or equivalent standards, protecting it from unauthorized access even in the unlikely event of a physical security breach.
AI prompts and platform interactions are monitored using advanced prompt injection security provided by Lakera. This security layer analyzes every interaction in real-time to detect attempts to override system instructions, extract confidential information, manipulate agent behavior, or exploit vulnerabilities in the AI system. When a potential security threat is detected, the system may block the request, sanitize the input, or alert our security team for manual review. This protection operates transparently and does not interfere with legitimate use of the services.
The Company employs strict access controls, requiring secured credentials and multi-layered authentication on internal infrastructural tools such as the Spanel administrative console. Access to user data is restricted on a need-to-know basis, with role-based access controls ensuring that employees and contractors can access only the information necessary to perform their specific job functions. We maintain detailed audit logs of all access to sensitive systems, allowing us to detect and investigate any unauthorized access attempts.
We have implemented processes for detection of anomalous access patterns and real-time breach escalation. Our security monitoring systems analyze access logs, system behavior, and network traffic to identify potential security incidents. In the event that a security breach is detected, our incident response team follows established protocols to contain the breach, assess the scope of compromise, notify affected users as required by law, and implement remediation measures to prevent recurrence.
We conduct regular security assessments, including vulnerability scanning, penetration testing, and code reviews, to identify and address potential security weaknesses before they can be exploited. We maintain a responsible disclosure program that allows security researchers to report vulnerabilities to us confidentially, and we commit to addressing reported vulnerabilities in a timely manner.
Our employees and contractors with access to user data are required to undergo security training, sign confidentiality agreements, and comply with our data handling policies. We conduct background checks on personnel with access to sensitive systems and data, and we terminate access immediately when employment or contractual relationships end.
Despite our implementation of robust security measures, no system is completely secure, and we cannot guarantee absolute security of your information. In the event of a data breach that compromises your Personal Information, we will notify you in accordance with applicable law, typically within 72 hours of discovering the breach, and will provide information about the nature of the breach, the types of information affected, the steps we are taking to address the breach, and recommendations for protecting yourself from potential harm.
10. USER RIGHTS UNDER CCPA AND OTHER PRIVACY LAWS
Because one or more users may reside in California or other jurisdictions providing enhanced privacy rights, we extend the following rights to all users regardless of location, ensuring that everyone benefits from the highest level of privacy protection.
You have the right to request access to the categories and specific pieces of Personal Information we have collected, used, or disclosed about you. This right includes the ability to obtain a copy of your Personal Information in a portable format that allows you to transmit it to another service provider. To exercise this right, you may submit a request through our privacy portal or by emailing [email protected]. We will verify your identity before providing access to your information and will respond to verified requests within forty-five (45) days, with the possibility of a forty-five (45) day extension where necessary to complete a thorough response.
You have the right to request deletion of your Personal Information, subject to certain exceptions provided by law. These exceptions include situations where we need to retain information to complete a transaction, detect security incidents, comply with legal obligations, or exercise free speech rights. When you request deletion, we will delete your information from our active systems and instruct our subprocessors to do the same, though some information may persist in backup systems for a limited time before being permanently purged. For AI agents, deletion of Input Data may affect agent performance, and we will inform you of these consequences before completing the deletion.
You have the right to request correction of inaccurate Personal Information maintained on your behalf. If you believe that information we hold about you is incorrect or incomplete, you may submit a correction request, and we will make reasonable efforts to correct the information, taking into account the nature of the information and the purposes for which it is processed.
You have the right to direct us not to sell or share your Personal Information. While this right is somewhat symbolic in the context of our Company, as we do not sell or share Personal Information for cross-context behavioral advertising or other purposes that would trigger CCPA's definition of "sale" or "sharing," we nevertheless provide a mechanism for you to exercise this right. You may invoke this right via the link labeled "Do Not Sell or Share My Personal Information" at the footer of our public websites, and we will record your preference and ensure that no such sales or sharing occur.
You have the right to limit the use and disclosure of Sensitive Personal Information. If we collect Sensitive Personal Information as defined by CCPA (such as precise geolocation, health information, or biometric data), you have the right to direct us to use such information only for purposes necessary to provide the services you requested and not for other purposes such as inferring characteristics about you. Given the nature of our services, we typically do not collect Sensitive Personal Information beyond what is necessary for service delivery, but this right is available should such information be collected.
You have the right to not be discriminated against for exercising any privacy rights granted by this Policy or under applicable law. We will not deny you services, charge you different prices or rates, provide you with a different level or quality of services, or suggest that you will receive a different price or level of service as a result of exercising your privacy rights. Your decision to exercise these rights will not affect your relationship with the Company or the quality of services you receive.
You may exercise any of these rights by contacting us at [email protected] or through the official privacy portal located at the domain's dedicated contact section. We may require verification of your identity before processing your request to ensure that we are providing information to the correct individual and not inadvertently disclosing your information to an unauthorized party. Verification may involve confirming your email address, account credentials, or other identifying information.
We honor all verified California rights requests within forty-five (45) days of receipt unless legally extended or delayed with notice to the requester. If we require additional time to complete your request, we will notify you of the extension and the reason for the delay. We do not charge a fee for processing privacy requests unless the requests are manifestly unfounded, excessive, or repetitive, in which case we may charge a reasonable fee or refuse to process the request.
11. SPECIFIC OBLIGATIONS REGARDING AI AGENTS
Users deploying AI agents through our platform acknowledge that these agents may access limited internal APIs, manage cloud functions, or interact with third-party systems embedded in enterprise-grade builds. The scope of these interactions is defined in your service agreement or agent configuration documentation, and we maintain technical controls to ensure that agents cannot access systems or data beyond their authorized scope.
All data processed by these agents is subject to this Privacy Policy and to any additional data processing agreements executed for enterprise clients. Where an AI Agent makes decisions with legal or economic significance—such as providing clinical recommendations, generating legal documents, making financial projections, or producing content for publication—the Company strongly recommends that a manual human override be maintained as best practice. We do not approve of autonomous actions affecting vulnerable populations, making high-stakes decisions, or producing outputs with significant real-world consequences without human intervention and user assent.
Any automated processing logic that determines recommendations, outputs, or task paths is fully disclosed to enterprise customers upon request. We maintain documentation of the AI models used, the training methodologies employed, the types of data processed, and the decision-making logic implemented. This transparency allows you to understand how your AI agent operates and to make informed decisions about its appropriate use in your professional context.
We implement bias testing and fairness assessments for AI agents deployed in sensitive contexts such as healthcare, education, social services, or employment. While we cannot guarantee that AI outputs will be free from bias, we take proactive steps to identify and mitigate potential biases, and we encourage users to report concerns about AI output quality, fairness, or bias to our support team for investigation and remediation.
12. DATA RETENTION AND DELETION
We retain Personal Information for as long as necessary to provide our services, fulfill the purposes outlined in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention periods vary depending on the type of information and the purposes for which it is processed.
Account Information is retained for the duration of your active account and for a reasonable period thereafter to allow for account reactivation, address billing disputes, or comply with legal requirements. Typically, we retain account information for up to two (2) years after account closure, after which it is deleted or anonymized. Payment and billing information is retained for seven (7) years to comply with tax laws and accounting regulations.
Input Data used to train your AI agent is retained for as long as you maintain an active subscription or service agreement, as this data is necessary for your agent to function effectively. Upon account termination or deletion request, we will delete or anonymize your Input Data within thirty (30) to sixty (60) days, except where retention is required by law or necessary to resolve disputes. We will inform you if deletion of Input Data will affect your AI agent's performance and provide options for data export before deletion.
Usage Data and analytics information is typically retained in aggregated, anonymized form indefinitely for business intelligence and service improvement purposes. Personally identifiable usage data is retained for up to two (2) years and then either deleted or anonymized. Communications Data, such as support tickets and email correspondence, is retained for up to three (3) years to maintain service continuity and address recurring issues.
You may request deletion of your data at any time by contacting [email protected] or through our privacy portal. We will process deletion requests in accordance with applicable law and will confirm completion of the deletion within the timeframes specified in Section 10. In some cases, we may retain certain information in anonymized or aggregated form that cannot be used to identify you personally.
13. COOKIES AND TRACKING TECHNOLOGIES
We use cookies, web beacons, and similar tracking technologies to collect Usage Data, remember user preferences, authenticate users, and provide a personalized experience. Cookies are small text files stored on your device that allow us to recognize you when you return to our services and to maintain session state across page loads.
We use both session cookies, which expire when you close your browser, and persistent cookies, which remain on your device for a specified period or until you delete them. Essential cookies are necessary for the basic functioning of our services and cannot be disabled without affecting your ability to use the platform. These include cookies for authentication, security, and session management.
We use functional cookies to remember your preferences, such as language settings, display options, and customization choices, enhancing your user experience by eliminating the need to reconfigure settings each time you visit. We use analytical cookies to understand how users interact with our services, which features are most popular, where users encounter difficulties, and how we can improve the overall experience. These cookies collect information in aggregate form and do not identify individual users.
We do not use advertising cookies or allow third-party advertising networks to track your activity across our services. We do not participate in cross-site tracking or behavioral advertising. Most web browsers allow you to control cookies through browser settings, including blocking cookies entirely, deleting existing cookies, or receiving notifications when cookies are set. Please note that disabling essential cookies may prevent you from using certain features of our services.
14. INTERNATIONAL USERS – DATA SOVEREIGNTY AND JURISDICTION
The Company's servers and primary data platforms are hosted within the United States, primarily in data centers located in regions with strong data protection laws and robust physical security. Users located outside of the United States who provide data acknowledge that their information will be transferred to, processed, and stored in the United States, and that such information will be subject to United States law, including laws that may require disclosure to government authorities under certain circumstances.
By using our services, users outside the United States consent to the transfer of their data to the United States and the application of United States data protection practices as described in this Policy. We implement appropriate safeguards to protect your information during international transfers, including encryption, contractual protections with subprocessors, and compliance with applicable international data transfer frameworks.
For users in the European Economic Area (EEA), United Kingdom, or Switzerland, we acknowledge that data transfers from these jurisdictions to the United States may be subject to additional legal requirements. While we primarily serve users in the United States, if we do collect personal data from EEA, UK, or Swiss residents, we will implement appropriate transfer mechanisms such as Standard Contractual Clauses or rely on adequacy decisions where available.
Users in jurisdictions with data localization requirements or restrictions on international data transfers should carefully consider whether our services are appropriate for their use case and should consult with legal counsel if uncertain about compliance with local laws.
15. CHANGES TO THIS POLICY
We reserve the right to update this Privacy Policy at our discretion to reflect changes in our practices, technologies, legal requirements, or business operations. Any material changes shall be posted to the Company's websites with revised effective dates prominently displayed at the top of the Policy. In the event of significant changes to data usage practices, user rights, or security measures, users shall be notified via email to the address associated with their account or through in-app messaging when they next access the services.
Continued use of our services after the posting of changes constitutes acceptance of the amended terms. If you do not agree to the revised Privacy Policy, your sole remedy is to discontinue use of the services and, if desired, request deletion of your account and associated data. We encourage you to review this Policy periodically to stay informed about how we are protecting your information.
We will maintain prior versions of this Policy in an archive accessible through our website, allowing you to review the terms that were in effect at any given time. The "Last Revised" date at the top of this document indicates when the most recent changes were made.
17. CONTACT AND DATA PROTECTION OFFICER
To assert data subject rights, raise privacy concerns, obtain clarifications regarding this Privacy Policy, report a suspected data breach, or communicate with our Data Protection Officer, please use the following contact information:
Contact Name: Chief Data Privacy Officer
Email: [email protected]
Mailing Address: 60 Watts of Clarity (JFernandez, LLC)
[Insert Office Address in Texas]
We are committed to responding to privacy inquiries promptly and thoroughly. For general privacy questions, you can expect a response within five (5) business days. For formal data subject rights requests under CCPA or similar laws, we will acknowledge receipt within ten (10) business days and provide a substantive response within forty-five (45) days as required by law.
If you are not satisfied with our response to a privacy concern, you have the right to file a complaint with the appropriate regulatory authority in your jurisdiction. For California residents, complaints may be filed with the California Attorney General's office. For residents of other states with privacy laws, complaints may be filed with the relevant state attorney general or consumer protection agency.
18. GOVERNING LAW AND DISPUTE RESOLUTION
This Policy shall be governed by and construed in accordance with the laws of the State of Texas without regard to conflict of laws principles, subject to any rights and protections granted under the laws of California or other applicable jurisdictions where users reside. In the event of any dispute arising from or relating to this Policy or our privacy practices, the parties agree to first attempt to resolve the dispute through good-faith negotiation.
If negotiation does not resolve the dispute within thirty (30) days, the parties may pursue resolution through mediation, arbitration, or litigation as appropriate. Any legal action arising from this Policy shall be brought in state or federal courts located in Harris County, Texas, unless such venue would deprive you of substantive rights under applicable consumer protection or privacy laws, in which case you may bring action in your jurisdiction of residence.
Nothing in this Policy limits your right to file a complaint with a data protection authority or to pursue claims under applicable privacy laws in your jurisdiction. We are committed to working cooperatively with privacy regulators and to addressing privacy concerns through dialogue and remediation rather than litigation wherever possible.
19. SEVERABILITY
If any provision of this Privacy Policy is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving the original intent, or if such modification is not possible, such provision shall be severed from this Policy. The invalidity or unenforceability of any provision shall not affect the validity or enforceability of any other provision, and the remaining provisions shall continue in full force and effect.
20. ENTIRE PRIVACY AGREEMENT
This Privacy Policy, together with our Terms and Conditions and any additional data processing agreements executed for enterprise clients, constitutes the entire agreement between you and the Company regarding the collection, use, and protection of your Personal Information and supersedes all prior or contemporaneous understandings regarding such subject matter. In the event of any conflict between this Privacy Policy and the Terms and Conditions regarding privacy matters, this Privacy Policy shall control.
— End of Policy —
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