Proximo - Career Coaching Software for Counselors

1. Introduction

Proximo Inc. ("Proximo," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered career intelligence platform and related services (the "Services").

2. Information We Collect

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Account information (name and email address)
Profile information (resume, work history, skills, career goals)
Communication data (messages, feedback, support requests)
Assessment responses and career preference data
Payment information (processed securely by third-party providers)
Uploaded content and media
Metadata from uploaded content

We also automatically collect certain information when you use our Services, including device information, usage data, and cookies.

3. How We Use Your Information

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We use the information we collect to:

Provide, maintain, and improve our career coaching services
Personalize your experience and deliver tailored recommendations
Process transactions and send related information
Send you technical notices, updates, and support messages
Respond to your comments, questions, and requests
Analyze usage patterns to improve our platform
Protect against fraudulent or unauthorized activity
Facilitate account creation and authentication and otherwise manage user accounts
Send administrative information to you
Keep our Services safe and secure, including fraud monitoring and prevention
Save or protect an individual's vital interests or prevent harm
Process, review, and license uploaded content
Facilitate payments and payouts
Enforce agreements and prevent fraud
Maintain legal compliance
Train and improve our AI models

4. Information Sharing

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do so. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

We may share your information in the following circumstances:

With your consent: When you direct us to share information with third parties
With service providers: Who perform services on our behalf
With partner organizations: Such as workforce development agencies, with your permission
For legal purposes: When required by law or to protect our rights
In business transfers: In connection with mergers or acquisitions

The categories of third parties we may share personal information with are as follows:

AI Platforms
Cloud Computing Services
Data Storage Service Providers
Payment Processors
Performance Monitoring Tools
User Account Registration & Authentication Services
Website Hosting Service Providers
Communication & Collaboration Tools
Testing Tools

Third party service providers in connection with our Services, which utilize their own terms and conditions and privacy policies:

We also may need to share your personal information in the following situations:

Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company
Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. This includes encryption, secure servers, and regular security assessments. However, no method of transmission over the Internet is 100% secure.

6. Data Retention

We retain your personal information for as long as necessary to provide our Services and fulfill the purposes outlined in this policy. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

You may request deletion of your account and associated data at any time by contacting us at:

hello@myproximo.com

If you would at any time like to review or change the information in your account or terminate your account, you can do so by sending an email with the request to hello@myproximo.ai.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at hello@myproximo.com.

7. Your Rights and Choices

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at hello@myproximo.com.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

You have the right under the California Consumer Privacy Act of 2018 ("CCPA") and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods to you, if that difference is reasonably related to the value provided to our business by your personal information.

8. Cookies and Tracking

We use cookies and similar tracking technologies to collect information about your browsing activities. You can control cookies through your browser settings, though disabling them may affect functionality.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

9. Children's Privacy

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at hello@myproximo.com.

10. AI Model Training and Licensing of User Content

We may use information about you with data contributions opportunities, including user-submitted career information, resume content, skills assessments, job preferences, feedback data, and anonymized usage patterns. We may use approved user-submitted audio, video, and image content, which may contain personal information (such as your image or likeness), to create, train, fine-tune, test, and improve artificial intelligence models for commercial purposes. We may also send them as samples to AI companies or companies working with AI. We may also license such content to AI companies, AI labs, and research organizations for the purpose of creating, training, fine-tuning, testing, and improving AI models that may be sold, licensed, or otherwise used in commercial products and services. We do not permit the use of your content for unrelated purposes without your additional consent.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. We encourage you to review this policy periodically.

12. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Email: hello@myproximo.com