JEFFREY MICHAEL CAPITAL, LLC | PRIVACY POLICY

Effective Date: January 1, 2026
Last Updated: April 1, 2026

Jeffrey Michael Capital, LLC and its affiliated brands and platforms, including Praxis, respect your privacy and are committed to handling personal information responsibly. This Privacy Policy explains how we collect, use, disclose, protect, and otherwise process personal information through our websites, digital properties, consulting services, digital services, AI integration services, and the Praxis platform.

This Privacy Policy applies to (a) jeffreymichaelcapital.com and related JMC websites, (b) praxis.jeffreymichaelcapital.com and related Praxis pages and services, and (c) communications, forms, demos, consultations, account interactions, and business engagements connected to JMC or Praxis.

This Privacy Policy describes our general privacy and data-handling practices. If you enter into a separate written agreement with Jeffrey Michael Capital, LLC relating to Praxis, consulting services, implementation services, digital services, AI integration services, or another specific engagement, that agreement will control to the extent of any conflict with this Privacy Policy for the applicable subject matter.

1. Who We Are

Jeffrey Michael Capital, LLC is an Indiana limited liability company with headquarters in Michigan, USA.

Jeffrey Michael Capital, LLC provides strategic advisory, fractional leadership, expansion strategy, capital readiness, web and digital marketing, AI integration, and related business services in the United States. Praxis is a custom decision-intelligence and AI-enabled platform within the JMC ecosystem and may be used in connection with consulting, advisory, digital, and AI-related service engagements.

We provide our standard websites, services, and Praxis offerings only for individuals and businesses physically located in the United States and for U.S.-based business activity. Jeffrey Michael Capital, LLC does not market, contract for, or knowingly provide its standard services outside the United States.

If an entity is headquartered outside the United States but seeks services solely for its U.S.-based operations, personnel, or business activity, Jeffrey Michael Capital, LLC may, in its sole discretion, require separate written approval and additional contractual terms before providing any service or permitting any use beyond the standard U.S.-only framework.

For questions about this Privacy Policy or our privacy practices, contact:

Jeffrey Michael Capital, LLC
legal@jeffreymichaelcapital.com
313-356-6665

2. Roles and Data Context

Our privacy role may differ depending on how you interact with us.

When you interact with our public websites or contact us directly

We act as the business responsible for determining how personal information is collected, used, disclosed, and otherwise processed in connection with website visits, contact forms, consultation requests, scheduling tools, newsletter sign-ups, recruiting interactions, and general inquiries.

When you use Praxis or provide materials in connection with a client engagement

We may process information on behalf of a customer or client under a separate written agreement. In those situations, the customer or client generally determines what information is submitted, whether submission is lawful, and whether a lawful basis exists for the processing. To the extent required by applicable law and contract, our role may be that of a service provider, processor, contractor, or similar provider acting on behalf of that customer or client.

3. Information We Collect

We may collect the following categories of information.

Information you provide directly

(a) Name, email address, phone number, company name, and job title.
(b) Account, billing, or payment-related information where applicable.
(c) Communications you send to us.
(d) Information submitted through forms, consultations, scheduling tools, demos, or service requests.
(e) Recruitment and career-related submissions.
(f) Business information, records, or documents you voluntarily provide.

Praxis account and platform information

If you use Praxis, we may collect:

(a) Account registration and login information.
(b) User profile and account settings.
(c) Platform activity and usage information.
(d) Support and service communications.
(e) Inputs, prompts, files, records, business materials, and documents submitted through Praxis.
(f) Outputs, reports, summaries, recommendations, workflows, or generated content associated with Praxis use.

Customer Content

“Customer Content” means business materials, files, records, internal documents, datasets, prompts, communications, or other content submitted to us or through Praxis by or on behalf of a customer or client. Depending on what is submitted, Customer Content may contain personal information, confidential business information, trade secrets, or other sensitive materials.

Information collected automatically

When you visit our websites or interact with certain digital services, we and our service providers may automatically collect:

(a) IP address.
(b) Browser type.
(c) Device identifiers and device information.
(d) Operating system.
(e) Referring URLs.
(f) Website usage and navigation activity.
(g) Approximate location derived from IP address.
(h) Cookie, analytics, and similar tracking information.

Information from third parties

We may receive information from:

(a) Analytics providers.
(b) Advertising and social media platforms.
(c) Scheduling, CRM, and communications providers.
(d) Recruitment platforms.
(e) Service providers and contractors.
(f) Business partners.
(g) Publicly available or lawfully obtained commercial sources.

4. Restricted Data and Submission Rules

Unless we expressly agree otherwise in writing and implement appropriate controls, you must not submit through public website forms, general email channels, or Praxis any of the following:

(a) Payment card information subject to PCI or similar payment-security standards.
(b) Protected health information or medical records.
(c) Social Security numbers or similar government-issued identifiers beyond ordinary and expressly approved business necessity.
(d) Biometric data.
(e) Children's data.
(f) Precise geolocation data.
(g) Export-controlled information.
(h) Highly regulated personal information or regulated datasets.
(i) Any information that you do not have the legal right to disclose or instruct us to process.

Do not send confidential deal materials, regulated data, highly sensitive personal information, or legally restricted business materials through public forms or general intake channels unless we have specifically instructed you to do so through an approved secure process and, where appropriate, under a signed agreement.

You are solely responsible for ensuring that you have all necessary rights, permissions, notices, consents, and lawful bases required to provide personal information, business records, or other materials to us. We are not responsible for independently verifying that every submission you provide was collected, disclosed, or transferred lawfully before it is submitted to us.

Unless expressly agreed otherwise in writing, we may rely on your representations regarding your authority, permissions, notices, consents, and lawful basis to provide information to us and instruct us to process it.

We may reject, remove, quarantine, decline to process, or require secure re-submission of information or materials that violate these submission rules, are provided through channels not approved for that type of information, or create legal, security, confidentiality, operational, or compliance risk in our judgment.

5. How We Use Information

We may use personal information and related business information for the following purposes:

(a) To operate, maintain, secure, and improve our websites, services, and platform.
(b) To respond to inquiries, schedule consultations, and communicate with you.
(c) To provide strategic advisory, fractional leadership, digital services, AI integration, Praxis-related services, and customer support.
(d) To create, administer, maintain, and secure accounts.
(e) To evaluate requests for demos, pilots, partnerships, or service engagements.
(f) To review submitted business information internally in order to assess scope, configure services, support consulting analysis, and determine how best to deploy requested services.
(g) To deliver analytics, reporting, outputs, recommendations, workflows, and service functionality.
(h) To improve user experience, website performance, service delivery, and platform reliability.
(i) To conduct internal business operations, quality assurance, recordkeeping, audit support, and business administration.
(j) To send marketing, newsletter, event, or promotional communications where permitted by law.
(k) To protect our rights, users, systems, data, and business operations.
(l) To detect, prevent, investigate, and address fraud, abuse, unauthorized access, security incidents, or unlawful conduct.
(m) To comply with legal obligations, lawful requests, contractual commitments, and industry requirements.
(n) To monitor, review, retain, and maintain email, telephone, support, and other business communications for quality assurance, service administration, security, compliance, recordkeeping, training, and legal purposes, subject to applicable law.

We may also use de-identified, anonymized, or aggregated information for internal analysis, service improvement, benchmarking, security, and business operations where permitted by law and where such information does not identify a specific individual.

6. AI, Praxis, and Customer Content

Praxis may use AI-enabled tools, models, workflows, and decision-support processes to help customers analyze business conditions, evaluate variables, improve workflows, and support decision-making.

Customer Content submitted through Praxis or in connection with services may be processed internally by Jeffrey Michael Capital, LLC and its authorized employees, contractors, advisors, service providers, and approved subprocessors, each subject to appropriate confidentiality, contractual, or professional obligations, solely as reasonably necessary to:
(a) provide requested platform, consulting, integration, or advisory functionality;
(b) understand business needs and define service scope;
(c) support customer-authorized configuration, implementation, integration, and service delivery;
(d) generate outputs, analyses, summaries, recommendations, or workflows;
(e) maintain, host, administer, secure, troubleshoot, monitor, support, review, and improve the reliability of the customer environment;
(f) conduct internal administration, quality assurance, audit support, recordkeeping, abuse prevention, and service operations; and (g) comply with law, enforce agreements, and protect rights, systems, users, and business operations.

Customer Content and related business information are used only for internal business purposes by Jeffrey Michael Capital, LLC and its authorized employees, contractors, advisors, service providers, and approved subprocessors, each subject to appropriate confidentiality, contractual, or professional obligations, and are not published, sold, or made publicly available by us except:
(a) at the customer's direction,
(b) as necessary to provide requested services, or
(c) as required by law.

Unless expressly agreed in writing, we do not use Customer Content submitted through Praxis to train public or general-purpose AI models.

Praxis outputs, recommendations, and generated materials may depend on the quality, completeness, timeliness, and accuracy of the information submitted. Customers remain solely responsible for reviewing outputs, validating assumptions, and exercising independent judgment before relying on or acting upon any output, recommendation, summary, or model result.

7. How We Disclose Information

We may disclose personal information and related business information:

(a) To service providers, vendors, contractors, and subprocessors that support our business operations.
(b) To hosting, cloud, communications, CRM, analytics, security, scheduling, support, payment, and infrastructure providers.
(c) To professional advisors such as lawyers, accountants, insurers, auditors, and consultants.
(d) To affiliates, business units, or personnel within the JMC ecosystem as reasonably necessary to provide services.
(e) In connection with a merger, financing, acquisition, restructuring, sale, diligence process, or other business transfer.
(f) To comply with applicable law, regulation, court order, subpoena, legal process, or lawful governmental request.
(g) To enforce agreements, investigate misconduct, protect rights, prevent fraud, or address security incidents.
(h) With your consent, at your direction, or as otherwise authorized by you.

We do not publish Customer Content or make it publicly available except (a) at the customer's direction, (b) as necessary to provide requested services, or (c) as required by law.

We do not sell personal information for monetary consideration.

We do not use or disclose sensitive personal information for purposes that would require a separate right to limit under applicable law except as permitted by law, authorized by contract, or reasonably necessary to provide requested services.

8. Cookies and Tracking Technologies

We and our service providers may use cookies, pixels, tags, scripts, analytics tools, session technologies, and similar mechanisms to:

(a) Operate and secure the websites and services.
(b) Understand user behavior and measure site performance.
(c) Improve content, navigation, and user experience.
(d) Support campaign measurement, analytics, and marketing activities where used.

You may be able to control cookies through browser settings, consent tools, or device preferences. Blocking or disabling certain technologies may affect website performance, functionality, or user experience.

Public website analytics, campaign measurement, cookies, and similar tracking technologies may differ from the logging, security, account, support, and platform-administration records associated with Praxis or other authenticated service environments. Additional service-specific terms or disclosures may apply where appropriate.

9. Marketing Communications

We may send you newsletters, event invitations, marketing messages, promotional content, or service updates where permitted by law and consistent with your communications preferences. You may opt out at any time by using the unsubscribe link in an email or by contacting us at legal@jeffreymichaelcapital.com.

Opting out of marketing communications does not prevent us from sending transactional, operational, account-related, legal, or service-related communications.

10. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

(a) Provide requested services.
(b) Maintain accounts and business records.
(c) Meet contractual obligations.
(d) Comply with legal, tax, accounting, regulatory, and recordkeeping requirements.
(e) Resolve disputes.
(f) Enforce agreements.
(g) Protect our rights, systems, and business operations.

Retention periods may vary depending on (a) the nature of the information, (b) the type of relationship, (c) the sensitivity of the material, (d) backup and disaster-recovery cycles, (e) legal obligations, and (f) applicable contract terms.

Where Praxis or other services are governed by separate written agreements, retention, deletion, and return of Customer Content may also be governed by those agreements, including any applicable DPA, order form, statement of work, or enterprise services agreement.

11. Security

We use administrative, technical, physical, and organizational safeguards designed to protect personal information appropriate to the nature of the information and our business operations. However, no website, platform, network, system, storage environment, or method of transmission is completely secure, and we cannot guarantee absolute security.

You are responsible for (a) using secure channels where instructed, (b) maintaining the confidentiality of your credentials, and (c) notifying us promptly if you believe your interaction with us, your account, or any submitted information is no longer secure.

12. Your Privacy Rights

Depending on your U.S. state of residence, you may have legal rights regarding your personal information. These rights may include the right to:

(a) Confirm whether we process certain personal information.
(b) Access certain personal information.
(c) Request deletion of certain personal information.
(d) Request correction of inaccurate personal information.
(e) Obtain a copy of certain personal information in portable format.
(f) Opt out of certain targeted advertising, profiling, or sale/share activities where applicable.
(g) Appeal certain request decisions where required by law.

These rights are subject to applicable exceptions, limitations, and verification requirements.

To exercise applicable rights, contact us at legal@jeffreymichaelcapital.com. We may request additional information reasonably necessary to verify your identity and authority before responding. If we deny a request and an appeal right applies, we will explain how to submit an appeal.

If your request relates to Customer Content processed by us on behalf of a Praxis customer or other business client, we may direct you to the relevant customer because that customer may be the party legally responsible for responding to your request.

13. Global Privacy Control and U.S. State Signals

Where required by applicable U.S. law, we will honor legally recognized browser-based opt-out preference signals, such as Global Privacy Control, for the browser and device that send the signal, to the extent the signal can reasonably be linked to the relevant processing activity.

14. U.S.-Only Services and Access

Our websites, services, and Praxis are intended only for individuals and businesses physically located in the United States and for U.S.-based commercial activity. We do not market, contract for, or knowingly provide our standard services outside the United States.

If an entity is headquartered outside the United States but seeks services solely for its U.S.-based operations, personnel, or business activity, we may require separate written approval and additional contractual terms before permitting access to or use of services beyond the standard U.S.-only framework.

If you access our websites from outside the United States, you do so on your own initiative and at your own risk. We make no representation that our websites, services, or platform are appropriate, lawful, or available for use outside the United States. Unless expressly agreed otherwise in writing, Michigan law and the applicable U.S.-based agreement framework will govern the relationship.

15. Third-Party Links and Services

Our websites and services may contain links to third-party websites, integrations, platforms, or tools. We are not responsible for the privacy practices, security, availability, or content of third-party services. Your interactions with those third parties are governed by their own terms, privacy policies, and practices.

16. Children's Privacy

Our websites, services, and Praxis are not directed to children, and we do not knowingly collect personal information directly from children. If we learn that personal information from a child has been collected without proper authorization, we may delete it and take other appropriate action.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date above. Material changes may also be communicated through the website, the Praxis platform, email, or other appropriate means where required or appropriate.

18. Contact Us

If you have questions about this Privacy Policy or our privacy practices, contact:

Jeffrey Michael Capital, LLC
legal@jeffreymichaelcapital.com
313-356-6665

19. Enterprise, Public Sector, and Regulated Use

If your organization requires a data processing agreement, security review, custom retention or deletion terms, separate confidentiality terms, written authorization for restricted data categories, foreign-law accommodations, or other contractual privacy, security, or compliance commitments, contact us before submitting information through Praxis or any public intake channel.

Additional review, written approval, and separate contractual safeguards may be required before certain uses, data categories, environments, users, or engagements are permitted. Jeffrey Michael Capital, LLC reserves the right to decline, delay, condition, or limit any requested use that would require obligations, controls, or compliance commitments beyond its standard approved framework unless separately agreed in writing.