ModuleSix Privacy Policy

Version 1.0 | Effective November 2, 2026

This version describes our information practices from the effective date above, subject to prior commitments, applicable law and the notice and consent requirements in section 11.

1 Who we are

1.1 Scope. ModuleSix, LLC ("ModuleSix," "we," "us") provides the ModuleSix business dashboard. This policy describes information collected when you visit modulesix.com, book an introductory call or, when enabled, apply for the test group through that website, or use the dashboard app. The app is identified as staging.modulesix.com during private testing and app.modulesix.com for the later app service. This notice describes privacy practices; the Terms of Service separately govern the service and contractual protection of business data. It does not expand the data-use permissions or reduce confidentiality, security, export or deletion protections in the Terms.

1.2 Contact. Contact ModuleSix, LLC at admin@modulesix.com with privacy questions or requests. Include enough information for us to locate the relevant records, but do not send passwords or sensitive identity documents unless securely requested for necessary verification. Our business service is offered in the United States only for now. That eligibility limit does not determine where website visitors are located or which privacy laws apply.

1.3 Personal and business information. Personal information is information identifying, relating to or reasonably linkable to an individual. Business figures may also be personal information, including for a sole proprietor or where they identify staff, customers or contacts. We protect business data under our Terms, including the confidentiality provisions; this policy explains privacy practices and does not replace those protections.

1.4 Responsibility for processing. ModuleSix determines the purposes of website inquiries, account administration and service-security processing. For personal information a business customer supplies for its dashboard, we also process information to provide the service on that customer’s instructions. The business customer must have authority and any required lawful basis to submit others’ information. Depending on the data flow and applicable law, ModuleSix may act as a controller or business for its own purposes and as a processor or service provider for customer-directed processing. Requests involving a customer’s information are handled as described in section 9.2.

2 On the website

2.1 Website inventory. The following table describes information supplied directly by visitors and information collected automatically through the website and its service providers. Planned collection is identified separately.

2.2 Cookies and similar technologies. Wix and app authentication services use cookies or similar storage for site operation, security and sign-in. Website visit statistics may involve additional analytics cookies or identifiers. Essential technologies support requested functions; analytics and other optional tracking serve separate purposes. Session technologies ordinarily expire at the end of a session. Persistent technologies remain until their configured expiration or deletion through browser or available website controls. We limit their use to the stated purposes and provide additional cookie information and choices through the website where required by law.

2.3 Controls. Browser settings let you block or delete cookies, which can affect site or sign-in functions. You may also use any cookie-preference controls displayed on the website to change optional tracking choices. Withdrawing consent affects future processing and does not by itself erase existing records. Where applicable law requires prior consent for optional technologies, we will not activate them without that consent; where an opt-out is required, we will provide and honor it.

2.4 Tracking disclosures. We do not otherwise change website behavior in response to a browser’s legacy Do Not Track signal. Global Privacy Control is a separate opt-out preference signal; we treat a valid signal as an opt-out of sale, sharing or targeted advertising to the extent applicable law requires, without requiring a new account. We do not currently sell personal information or share it for cross-context behavioral advertising, and we do not deploy third-party advertising trackers. Wix and the service providers identified in this policy may process technical and analytics information through the website for the stated service purposes, but we do not authorize its use for cross-site advertising. Essential security and sign-in processing may continue when necessary to provide the requested service.

3 In the app

3.1 Data inventory. The table covers information supplied by account representatives, generated during use and processed automatically by hosting, authentication and other providers. Planned signals are identified separately. Relevant records may exist in the app database and in provider, authentication, hosting and diagnostic systems.

3.2 Data to avoid. Do not enter health information, payment-card or bank-account numbers, government identification numbers, passwords, or other sensitive personal information in interviews, plans or support messages. ModuleSix does not need that information for the described pilot. Do not provide information you lack permission to share. If we become aware of unnecessary sensitive information in a submission, we will restrict its use and take reasonable steps to remove it securely, subject to applicable legal preservation requirements. Please contact admin@modulesix.com if you believe you submitted information that should be removed.

3.3 Company access. Each business has one company login during the pilot. Under Terms section 3.3, the designated account holder and staff or coaches authorized by the business and approved in writing by ModuleSix may use that login within the approval’s scope. Data in the account may be visible to those users; a shared login does not provide individual-user privacy within the company account. The company must revoke access when authority ends, including changing shared credentials where necessary. Separate staff and area accounts are future features.

4 How we use information

4.1 Service purposes. We use the information described above to provide the requested website and app functions; schedule calls and consider pilot applications; create and administer accounts; conduct interviews, calculate KPIs and display plans; communicate about the account, pilot and terms; manage service costs and prevent misuse; investigate errors and security issues; and meet legal obligations. Usage signals may support service improvement only as described in the inventory in section 3. We limit access and processing to what is reasonably necessary for these purposes. We also keep limited records of applicable terms and permissions: the customer business, accepting representative and account email, acceptance timestamp and time zone, version and issue date, and a copy of the Terms accepted. We also keep the Privacy Policy delivery and preference records described in section 11 so we can identify which notice was provided to each owner and which separate permissions apply.

4.2 De-identified aggregated use. Consistent with Terms section 6.3, we may use genuinely de-identified, aggregated information to improve ModuleSix and develop cross-company reference figures. We remove direct identifiers, combine information across businesses, and suppress or generalize small cohorts or distinctive figures where needed to prevent reasonable identification, including through combination with other reasonably available information. We maintain qualifying data in de-identified form and do not attempt to re-identify it. Working data is limited to personnel and service providers who need it and are bound by confidentiality, purpose limits and prohibitions on re-identification; only qualifying aggregated results may be disclosed more broadly. Qualifying aggregates created before source-data deletion may be retained afterward while these safeguards continue to apply. This does not permit identifying disclosures, sale, advertising use, model training contrary to section 5.2 or delayed deletion of source data.

4.3 No sale or advertising use. We do not sell personal information or customer business data or use it for advertising, and we do not share it for cross-context behavioral advertising.

4.4 AI and decisions. ModuleSix’s code calculates scores; the AI assistant asks questions and drafts explanations and options. Customer remains responsible for validating inputs, scores, explanations and recommendations before acting. The described pilot is not intended to make decisions about individuals that produce legal or similarly significant effects.

4.5 Purpose limits. New training, benchmarking, connector or other materially expanded uses require review and any necessary notice or separate consent before the new use. A general policy update or continued pilot use does not by itself supply a separate opt-in required by the Terms or law.

5 Service providers and other disclosures

5.1 Provider inventory. The table identifies the providers used for the website and app. Providers may use subprocessors. We limit disclosures to the information needed for the stated functions and use appropriate confidentiality, purpose, security and retention restrictions. Any provider use for independent account administration, security or legal compliance must be consistent with applicable law and the data-use commitments in our Terms. Diagnostic logging is handled through our existing hosting and database providers; a separate external error-monitoring provider is not part of the pilot described by this policy.

5.2 AI processing limits. Consistent with Terms section 6.5, ModuleSix sends only information reasonably needed for requested AI functions and does not use, or authorize providers to use, customer data or identifiable inputs or outputs to train or fine-tune general-purpose or shared AI models or for unrelated product development without the customer’s separate express opt-in. We do not submit customer content to optional provider feedback or data-sharing programs without that authorization. Any consent concerning personal information must also satisfy applicable law; a company’s approval alone may not be sufficient. The provider inventory and retention disclosures identify the AI provider, transmitted data categories and material processing exceptions.

We use Anthropic’s commercial API for interview and action-plan requests. Under its published standard commercial policy, API inputs and outputs are ordinarily deleted from Anthropic’s systems within 30 calendar days after receipt or generation. Longer retention may apply to selected storage features, legally required records, or safety and abuse-prevention processing. For content flagged as a usage-policy violation, Anthropic’s published policy describes retention of inputs and outputs for up to two years and associated trust-and-safety classification scores for up to seven years. Certain models may require limited retention and safety review. We do not submit customer content to optional provider feedback programs or authorize model training without the separate permission described above. We do not represent that a zero-retention arrangement exists. These published provider periods do not override a shorter binding contractual or legal requirement; ModuleSix remains responsible for meeting its obligations under the Terms.

5.3 Other recipients. Information may be disclosed to authorized company representatives as explained in section 3.3 and to personnel and professional advisers who need it for the stated purposes and are subject to appropriate confidentiality duties. Legally required disclosure will be limited to what is required; notice will be provided where legally permitted and required by the Terms.

5.4 Business transfers and provider changes. Before a new provider receives app data, we will update the provider inventory and complete the appropriate privacy and security review. We will provide any notice and opportunity to object required by law or an applicable agreement; material changes are also addressed in section 11. If the relevant business is transferred, any successor must assume the applicable Terms obligations, including confidentiality, security, deletion and data-use limits. Any transfer of personal information must meet applicable law and required notice or consent obligations. This clause does not authorize unrelated uses or override the Terms.

6 Where data is stored

6.1 Locations. The primary Supabase database and Vercel app hosting use United States regions. Service providers and their subprocessors may process, store or access other records, including backups, logs, AI requests, website data, email and calendar entries, in the United States and other countries where they operate. The business service’s US eligibility limit is not a guarantee that all processing stays in the United States. We apply the confidentiality, security, purpose and access restrictions described in this policy and the Terms and use any additional transfer safeguards required by applicable law.

6.2 Testing and production. We keep real pilot business data in the designated production data environment and use synthetic or appropriately de-identified data for testing. Real data must not be copied into development, preview, testing or error-reporting systems without appropriate authorization and safeguards. A staging domain name alone does not establish database isolation.

7 How we protect information

7.1 Reasonable safeguards. ModuleSix maintains reasonable administrative, technical and organizational safeguards appropriate to the information and risks, including access controls and secure handling in transit and storage. Access by personnel and providers is limited to those who need it for the stated purposes. No system is completely secure.

7.2 Specific controls. The pilot safeguards include company-level database access rules, environment separation, HTTPS and interview usage limits. These controls do not guarantee that unauthorized access is impossible.

7.3 Incidents. Consistent with Terms section 6.9, if ModuleSix becomes aware of confirmed unauthorized access to, acquisition of, disclosure, loss or alteration of customer data in its custody or its providers’ custody, it will notify the affected customer without undue delay and within any shorter period required by applicable law. It will reasonably investigate, contain and remediate the incident and provide available information and material updates. Investigation or confirmation will not delay notice required earlier by law. ModuleSix will make notices to individuals or regulators for which it is legally responsible and reasonably cooperate with customers on notices for which they are responsible. Customer notices use the designated account contact; privacy concerns may be sent to the contact in section 1.2.

8 Retention export and deletion

8.1 Retention limits. We retain information only as reasonably necessary for the stated purposes and applicable legal obligations. The schedule below describes our retention limits. App export and deletion commitments follow Terms sections 6.10 and 13. A shorter applicable legal or contractual deletion duty takes precedence over a general operational or published provider retention period. Customer content copied into logs or diagnostic records is not retained longer merely because it appears in those records.

8.2 Requests and export opportunity. A verified account administrator may request account export, closure or deletion through section 1.2. Closure alone uses the default export schedule; an express deletion request uses the shorter route in section 8.3 unless the customer elects export first. During any termination notice period and for 60 calendar days after access ends, the administrator may request the company’s figures, interview responses and saved scores and plans actually held. Structured records will be supplied in CSV or JSON and narrative content in PDF, plain text or another commonly readable format through secure electronic delivery within 14 calendar days after receipt of a verified request. Verification must be prompt. Exports may be prepared manually and do not require continued interactive access. A legal or security restriction may limit delivery, but does not permit indefinite retention.

8.3 Deletion scope and timing. Unless a customer expressly elects export first, customer data covered by the Terms will be deleted from active systems within 7 business days after receipt of an express deletion request, subject to prompt authority verification and the lawful retention exceptions below. An immediate-deletion request overrides the longer default export and retrieval periods. For ordinary closure with no export request, active-system deletion occurs within 7 business days after the 60-calendar-day export-request window ends. For a timely export request, the data is retained until delivery and for 90 calendar days afterward, then deleted from active systems within 7 business days. Residual backups of the corresponding ModuleSix records expire or are overwritten within 14 business days after active-system deletion; restored backups have deletion requests reapplied. Applicable statutory deadlines still control. We will communicate applicable deletion instructions to providers and remain responsible for our contractual obligations. Published provider-specific periods, including Anthropic’s standard API retention and legal or limited safety exceptions, are described separately in sections 5.2 and 8.4; they do not amend the Terms or extend a shorter binding deadline. Account deletion does not by itself immediately erase every log, email, calendar entry, website form or independently retained provider record.

8.4 Exceptions. Information required by law or reasonably necessary for security or legal claims may be retained only for that purpose and necessary duration, with restricted access and continuing protection. We will explain material retention exceptions to the requester where lawful and appropriate, including provider-specific legal or limited safety-processing exceptions. Once an exception ends, we will apply the deletion schedule. Qualifying de-identified aggregates may be retained only under the safeguards in section 4.2 and applicable law. Business days are Monday through Friday, excluding United States federal holidays; periods measured after an event begin the following day.

9 Your choices and privacy requests

9.1 General request process. Email admin@modulesix.com to ask about information held about you, request access or a copy, request correction, or request deletion. Account holders may also update fields the app permits them to edit. Company administrators may request company exports under section 8 and the Terms. Individual privacy requests and company exports are distinct. We will not disclose another person’s information or the entire company account merely because an individual submits a request, and we will protect other individuals’ rights and the business’s confidential information.

9.2 Verification and routing. We may seek information reasonably needed to verify identity and, for company actions, authority. Verification will be proportionate; we will not require unnecessary sensitive documents. Where law permits an authorized agent, we may require proof of authorization and any legally permitted identity confirmation. We will not impose identity verification on opt-outs where law prohibits it. If a request involves information processed on a business customer’s instructions, we will coordinate with or direct the requester to that customer as appropriate while meeting our own applicable duties. Requesters do not need to create a new account merely to submit a privacy request.

9.3 Response periods and legal rights. We will respond to privacy requests within 30 calendar days after receipt, or any shorter applicable deadline, unless applicable law permits an extension and we provide the required notice and explanation. We will provide any legally required acknowledgment sooner. Depending on applicable law and our role, you may have rights to access, correct, delete or obtain portable copies of personal information; opt out of sale, sharing, targeted advertising or certain profiling; limit certain sensitive-data uses; and receive nondiscriminatory treatment for exercising protected rights. These rights are subject to applicable scope, verification requirements and exceptions. If we deny a request, you may appeal or request reconsideration at admin@modulesix.com. We will respond to an appeal within 45 calendar days, or any shorter applicable period, subject to a lawful extension with the required notice. Where required, we will also explain how to complain to the relevant state attorney general or privacy regulator. These response periods do not extend a shorter deadline for opt-out requests.

9.4 Cookies and communications. Cookie controls are described in section 2. You may opt out of non-essential promotional email using the available unsubscribe method or the privacy contact; account, security and requested-service communications may continue. Providing a phone number for a booking does not by itself constitute consent to marketing calls or texts.

9.5 Applicable law. Your rights and our duties depend on applicable law, the information and processing involved, and any relevant thresholds or exemptions. US-only business eligibility does not eliminate duties relating to website visitors, individual contacts, breaches or marketing. We will reassess required disclosures and choices as features, customer locations, revenue, data volumes and provider arrangements change.

10 Children

ModuleSix is intended for business users aged 18 or older and is not directed to children. We do not knowingly collect personal information from children for this service. If you believe a child has provided information, contact the privacy address so ModuleSix can investigate and delete it as appropriate under applicable law.

11 Changes to this policy

11.1 Version and effective date. This is ModuleSix Privacy Policy Version 1.0, effective November 2, 2026. Each later published version will have a distinct version number and effective date. ModuleSix will retain an unchanged copy of each version and record its first publication date and time, including the time zone. A copy of the applicable or an earlier version may be requested at admin@modulesix.com.

11.2 Changes and notice. For material changes, we will notify app account holders by email or in the app at least 14 calendar days before the change takes effect and post a prominent website notice for website-related changes. The notice will identify the revised version, its effective date and the material changes. Where an urgent legal or security requirement requires shorter notice, the change will be limited to what is necessary and explained promptly. A revised notice does not retroactively authorize processing inconsistent with prior commitments or reduce protections under the Terms.

11.3 Owner and account notice records. At onboarding and when an updated policy is provided, we will keep a record linking the customer business and account to the owner or designated administrator, contact email, policy version and effective date, the date and time it was provided with its time zone, and the delivery method. We will record any acknowledgment separately from the fact of delivery and retain the relevant notice text and evidence of the communication. We will make the current version and effective date provided to an account available through the account or email confirmation. An owner may also request that information at admin@modulesix.com. Delivery records identify the notice provided; they do not establish that it was read or that consent was given.

11.4 Separate permissions and historical commitments. Where consent or another affirmative permission is required, we will obtain it before the relevant processing and record the person’s choice, specific purpose, version of the consent wording, date and time, method and any later withdrawal. Providing or acknowledging a privacy notice does not by itself supply that permission or acceptance of amended Terms. Historical notices and permission records will be retained under section 8 so that earlier commitments and processing choices remain traceable.

12 Future features and geographic expansion

12.1 Review before activation. Non-US service, separate staff and area accounts, external AI assistants, integrations and app device-type usage signals are future scope rather than active features described by this policy. Before enabling them, we will map new data flows, update notices and applicable agreements, and implement necessary security, retention, consent and rights measures. Existing legal duties continue to apply even where a feature is planned or a visitor is outside the intended market.

12.2 Planned capabilities. Geographic expansion, including Europe and South America, requires review of the applicable privacy and transfer requirements before launch. Separate staff and area accounts require an individual-user inventory and permissions review. External AI assistants and other integrations require review of the data fields accessed, recipients, processing purposes, consent, security and retention. App phone/desktop usage signals remain deferred until the necessary privacy controls are established. Spending alerts are outside the current scope described by this policy.

12.3 Updated disclosures. We will update the applicable disclosures before activating a feature that materially changes the information collected, its purposes, recipients, retention or available choices. Any separately required consent will be obtained before the new processing begins.

See also: Terms of Service