PXIQ Privacy Policy
Effective Date: [INSERT DATE]
Last Updated: [INSERT DATE]
Always Culture LLC
1. Introduction
Always Culture LLC (“Company,” “we,” “us,” or “our”) operates the PXIQ platform (the “Service”). This Privacy Policy describes how we collect, use, disclose, retain, and protect your personal information when you access or use the Service. This Privacy Policy applies to all users of the Service, including individual account holders and authorized users of organizational accounts.
By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our data practices as described in this Privacy Policy, please do not use the Service. This Privacy Policy is incorporated into and subject to our Terms of Service.
2. Information We Collect
2.1 Information You Provide Directly
Account Registration Information:
- Name and professional title
- Email address
- Professional credentials and qualifications
- Healthcare facility affiliation
- Billing information (processed and stored by Stripe, Inc.; we do not store full payment card details)
User-Generated Content:
- Notes, action plans, and observations created within the platform
- Co-Pilot chat messages and queries
- Training progress and assessment responses
- Data dispute submissions and opt-out requests
2.2 Information Collected Automatically
When you use the Service, we automatically collect certain information, including:
- Device information (browser type, operating system, device identifiers)
- Log data (IP address, access times, pages viewed, referring URLs)
- Usage data (features used, session duration, interaction patterns)
- Performance data (page load times, error logs)
2.3 Cookies and Tracking Technologies
We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your use of the Service.
Types of cookies we use:
- Essential Cookies: Required for the Service to function (e.g., authentication, session management). These cannot be disabled.
- Analytics Cookies: Help us understand how users interact with the Service (e.g., Google Analytics). These collect aggregated, anonymized data about usage patterns.
- Functional Cookies: Remember your preferences and settings to enhance your experience.
You can manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Service.
2.4 Information We Do NOT Collect
- Protected Health Information (PHI) as defined under HIPAA
- Patient-level or individual patient data
- Social Security numbers or government identification numbers
- Financial data beyond publicly available sources used in our analytics
3. How We Use Your Information
- Service Delivery: To provide, maintain, and improve the Service, including processing your analytics requests, delivering training content, and operating AI-powered features.
- Account Management: To create and manage your account, authenticate your identity, and communicate with you about your account.
- Billing: To process subscription payments and manage billing records through our payment processor.
- AI Processing: To transmit your inputs to third-party AI providers for the purpose of generating Co-Pilot responses and other AI-powered features.
- Analytics and Improvement: To analyze usage patterns, diagnose technical issues, and improve the Service’s features and performance.
- Communication: To send you service-related notices, updates, security alerts, and administrative messages.
- Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
- Security: To detect, prevent, and address fraud, abuse, security issues, and technical problems.
4. Third-Party Service Providers
4.1 Payment Processing
We use Stripe, Inc. to process subscription payments. Stripe collects and processes your payment information in accordance with its own privacy policy. We do not store full credit card numbers on our servers.
4.2 AI Processing
We use Anthropic, PBC to power the AI features of the Service, including the Co-Pilot chat functionality. User inputs submitted through AI features are transmitted to Anthropic for processing. Anthropic’s handling of this data is governed by its own terms of service and privacy policies. We strongly advise users not to submit confidential or sensitive information through AI features.
4.3 Data Enrichment
We use Google Places API to enrich publicly available facility data displayed within the Service. This does not involve the sharing of your personal account information with Google.
4.4 Analytics
We use analytics tools to understand how users interact with the Service. These tools may collect information such as your IP address, browser type, pages visited, and time spent on the Service. Data collected by analytics providers is typically aggregated and anonymized.
5. Data Retention
- Account Data (name, email, credentials, facility affiliation): Retained for the duration of your active account. Upon account termination or cancellation, account data will be deleted within ninety (90) days, except as required by law or for legitimate business purposes.
- Co-Pilot Chat Data: Retained for ninety (90) days from the date of creation, after which it is automatically deleted. Users may request earlier deletion at any time.
- Usage and Analytics Data: Retained in aggregated, de-identified form for up to twenty-four (24) months for the purpose of improving the Service.
- Billing Records: Retained as required by applicable tax and financial regulations (typically seven (7) years).
- User-Generated Content (notes, action plans): Retained for the duration of your active account and deleted within ninety (90) days of account termination, unless earlier deletion is requested.
6. AI Processing Disclosure
The Service incorporates artificial intelligence features powered by third-party providers.
- What is processed: Text inputs you submit through the Co-Pilot chat and other AI-powered features.
- Who processes it: Anthropic, PBC (our current AI provider). We may change or add AI providers in the future and will update this Privacy Policy accordingly.
- Purpose: To generate responses, insights, and recommendations based on your queries.
- Retention by AI provider: Subject to Anthropic’s own data retention and privacy policies.
WARNING: Do NOT submit confidential business information, trade secrets, protected health information, personally identifiable information of third parties, or any other sensitive information through AI features. The Company is not responsible for the confidentiality of information submitted through AI-powered features.
7. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Right of Access: You may request a copy of the personal information we hold about you.
- Right to Correction: You may request that we correct inaccurate or incomplete personal information.
- Right to Deletion: You may request that we delete your personal information, subject to certain legal exceptions.
- Right to Data Portability: You may request a copy of your data in a structured, commonly used, machine-readable format.
- Right to Opt Out: You may opt out of certain types of data processing, as described in this Privacy Policy.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.
To exercise any of these rights, please contact us at support@alwaysculture.com. We will respond to your request within thirty (30) days.
8. Data Security
We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, alteration, or destruction. These measures include:
- Encryption of data in transit (TLS/SSL) and at rest
- Role-based access controls and authentication requirements
- Regular security assessments and monitoring
- Employee access limited to those with a legitimate business need
No method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.
9. Data Breach Notification
In the event of a data breach that compromises your personal information, we will:
- Assess: Promptly investigate the nature and scope of the breach.
- Notify Affected Users: Notify affected individuals without unreasonable delay, and in any event within the timeframes required by applicable law (generally within sixty (60) days of discovery for most U.S. state laws, or seventy-two (72) hours for users subject to GDPR where applicable).
- Notify Authorities: Notify relevant regulatory authorities as required by applicable law.
- Provide Details: Breach notifications will include, to the extent known: the nature of the breach, the types of information affected, the steps we are taking to address the breach, and recommendations for affected users to protect themselves.
- Remediate: Take reasonable steps to mitigate the effects of the breach and prevent future occurrences.
10. No Sale of Personal Data
We do NOT sell your personal information. We do NOT share your personal information for cross-context behavioral advertising. We do NOT use or disclose sensitive personal information for purposes other than those permitted under applicable privacy laws.
11. State-Specific Privacy Rights
11.1 California Residents (CCPA/CPRA)
If you are a California resident, you have the following additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:
- Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collecting it, and the categories of third parties with whom we share it.
- Right to Delete: You may request that we delete your personal information, subject to certain exceptions.
- Right to Correct: You may request that we correct inaccurate personal information.
- Right to Opt Out of Sale or Sharing: We do not sell personal information or share it for cross-context behavioral advertising.
- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
To submit a CCPA request, contact us at support@alwaysculture.com. We will respond to verified requests within forty-five (45) days.
11.2 Virginia Residents (VCDPA)
If you are a Virginia resident, you have the right to access, correct, delete, and obtain a portable copy of your personal data, and to opt out of targeted advertising, sale of personal data, or profiling. To exercise your rights, contact us at support@alwaysculture.com. You may appeal any denial by contacting us with the subject line “VCDPA Appeal.”
11.3 Colorado Residents (CPA)
If you are a Colorado resident, you have the right to access, correct, delete, and obtain a portable copy of your personal data, and to opt out of targeted advertising, sale of personal data, or profiling. To exercise your rights, contact us at support@alwaysculture.com. You may appeal any denial by contacting us with the subject line “CPA Appeal.”
11.4 Other State Privacy Laws
Residents of other states with applicable consumer privacy laws (including but not limited to Connecticut, Utah, Oregon, Texas, Montana, and other states that may enact similar legislation) may have similar rights. We are committed to complying with all applicable state privacy laws. Please contact us at support@alwaysculture.com to exercise any rights you may have under your state’s privacy laws.
12. Children’s Privacy
The Service is designed for use by business professionals and is not intended for individuals under the age of eighteen (18). We do not knowingly collect personal information from anyone under the age of 18. If we become aware that we have collected personal information from a person under 18, we will take steps to delete that information promptly.
13. International Data Transfers
The Service is operated from the United States. If you are accessing the Service from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using the Service, you consent to the transfer of your information to the United States.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes, we will: (a) post the updated Privacy Policy on our website with a revised “Effective Date”; and (b) send an email notification to the address associated with your account at least thirty (30) days prior to the effective date of the material changes. Your continued use of the Service after the effective date constitutes your acceptance of the updated Privacy Policy.
15. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at:
Always Culture LLC
Email: support@alwaysculture.com
Product: PXIQ
For privacy-related requests, please include “Privacy Request” in the subject line of your email to ensure prompt routing.