Privacy Policy

Effective 2026-07-14

Innermost Privacy Policy

Effective Date: July 14, 2026

Introduction
1. This Privacy Policy (this "Privacy Policy") describes what Personal Information Innermost, a brand of Touchdown AI, Inc. ("Innermost" "we," "our" and its correlatives) may collect, how Innermost collects such Personal Information, how Innermost uses such Personal Information in connection with Innermost’s software-as-a-service solutions hosted by Innermost (the "Service"), and the choices available to you related to your Personal Information. This Privacy Policy also provides additional information required under applicable U.S. federal law and the comprehensive consumer privacy laws that have been enacted by various U.S. states, about our collection, use, and disclosure of the Personal Information of residents of those states, along with other required information such as the rights that may be available to such residents. This Privacy Policy is applicable to individuals located in the United States. Because our customers and users may be located throughout the United States, this Privacy Policy is designed to describe our practices generally and to identify, on a jurisdiction-neutral basis, the categories of rights that may become available to you depending on where you reside; Innermost will update this Privacy Policy as necessary to reflect the specific states in which we become subject to a state comprehensive privacy law as our business and customer base grow.
2. This Privacy Policy applies to any users of the Service, who are referred to herein as "you," "your" or "user," and it is part of and incorporated into the applicable Innermost Master Services Agreement ("MSA") for the Service. Any terms capitalized herein but not defined shall have the meanings assigned to such terms in the applicable MSA or associated Order. By using the Service, or otherwise affirming acceptance of an agreement into which this Privacy Policy is incorporated by reference, you acknowledge and agree to accept the practices described in this Privacy Policy regarding the collection, use, disclosure, and transfer of your Personal Information. If you do not agree to the terms of this Privacy Policy, please do not use the Service. Your use of the Service is governed by the applicable MSA and Order for the services provided to you by Innermost.
3. Please note that some privacy rights and obligations may differ depending on the state or jurisdiction in which you reside, in which case Innermost will comply with the legal requirements applicable to that jurisdiction. If you reside in a U.S. state that has enacted a comprehensive consumer privacy law, our "Your U.S. State Privacy Rights" notice in Section 16 below may apply to you and describes the rights that may be available to you. Innermost reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share Personal Information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. Innermost will note the effective date of the latest version of this Privacy Policy at the beginning of this Privacy Policy.
The Personal Information We Collect
1. When you access and use the Service, we may collect the following types of information:
  1. "Personal Information" is information that identifies an individual or relates to an identifiable individual or household. The types of Personal Information collected, and the uses thereof, depend on the purposes for which we collect the Personal Information.
  2. "Usage Data" is information that we automatically collect about your use of the Service and includes the sort of information that Web browsers and servers typically make available, through Web server logs, Web beacons, cookies, and other similar tracking technologies, about the devices you use to access our Service, as well as information on how you interact with our Service. Usage Data may include the IP address of a device or internet service used to connect your device to the Internet and may provide information about your location; computer and connection information such as your browser type and version; operating system and platform; confirmation when you open e-mail that we send you; purchase history; and the URLs which lead you to and around the Service, including the date and time of access. Usage Data may overlap with location information. Usage Data generally does not directly identify an individual, but may constitute Personal Information in some instances.
How We Collect Your Personal Information
1. Innermost uses information collected from users of the Service to personalize and improve your visit and experience, to provide services to you under the MSA, to provide the Service to you, and for other purposes set out below. When you use the Service, Innermost may collect Personal Information in the ways described below.
2. Information You Provide to Innermost: Innermost collects Personal Information when you use and interact with the Service, such as when you:
  1. Utilize the Service;
  2. Communicate with Innermost about our services, whether by e-mail, online chat window, or telephone;
  3. Complete and submit forms to us on our websites or through the Service (e.g., to register for an account, to authenticate yourself to verify your authorized use of the Service, or to subscribe to our newsletters); or
  4. Visit our Service or interact with us on social media and provide us Personal Information.
3. Information that Innermost Collects Automatically: When you use the Service, Innermost may automatically collect Usage Data subject to the settings of the device that you use to access the Service. With your consent, we may also collect information from your device to facilitate your use of certain features of the Service. Innermost may use this data to analyze trends and statistics to improve your online experience or our customer service. We do not deploy non-essential third-party cookies or similar tracking technologies on our Service but may collect Usage Data for purposes such as ensuring the security and integrity of our Service.
Use of Information Collected by Innermost
1. Innermost uses the Personal Information collected to provide services to our customers, to improve user experience with the Service, and to communicate with you about requested information. Innermost may use Personal Information to help target specific offers to customers and others and to develop and improve its services.
2. Additionally, Innermost may disclose your Personal Information as discussed below in Section 6, and use your Personal Information to:
  1. Respond to customer service requests, customer questions and concerns, and administer customer accounts. We may use your information to verify your identity, register you, administer your account, or provide you the information, products, and services that you request.
  2. Provide the Service and any associated services to you.
  3. Communicate with users about our products, services, and related issues. We may use your information to try to identify if you may be interested in any of our services. If we think something may interest you, we may send you information and promotional materials. You may unsubscribe from receiving marketing e-mails from us by using the unsubscribe link included in marketing e-mails.
  4. Administer fees and provide users with invoices or resolve billing issues. We may use your information to verify your identity in order to process your payments.
  5. Ensure the security and integrity of our Service.
  6. Conduct internal analytics for the purposes of development and improvement of the Service.
  7. Verify and maintain the quality of our Service, improve the Service, or develop new services.
  8. If we are exploring or go through a business transition or financial transaction, such as a merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, securities offering, or sale of all or a portion of our assets, we may use your information in connection with exploring or concluding such transaction.
  9. Comply with law. We may disclose your information to comply with any applicable laws and/or regulations, such as to comply with valid legal processes such as a search warrant, subpoena, or order from a court or tribunal of competent jurisdiction.
Data Collection Technologies
1. We may use cookies, Web beacons, log files, and other technologies (collectively, "Data Collection Technologies") to help us provide, customize, and improve the Service. The Data Collection Technologies we use on our Service include:
  1. Web Beacons: A Web Beacon is a Web page element (such as a clear gif, pixel tag, or single-pixel gif) that may be embedded into our Service or e-mail communications, and which may employ cookie technology to enable Innermost to record clickstream data.
  2. Cookies: Cookies are small text files placed on your device to store data that can be recalled by a Web server in the domain that placed the cookie. Cookies enable Innermost to collect clickstream data, including traffic on the Service. You may set your browser to reject certain cookies or to notify you when you are sent a cookie. Rejecting cookies may limit functionality of the Service. Third parties also provide software that allows you to visit the Service without providing certain types of this information. Our Service may use the following types of cookies:
  3. Essential/Strictly Necessary Cookies: These cookies are necessary for the Service to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Service will not then work.
    
    Analytics/Performance Cookies: These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our Service. They help us know which pages are the most and least popular and see how visitors move around the Service.
    
    Analytics Services: We may use third-party Web analytics services and other technologies on our Service to collect and analyze usage information through cookies and similar tools; engage in activities such as auditing, research, or reporting; and provide certain features to you.
2. Notice Concerning Do Not Track: Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. We do not currently use technology that specifically recognizes DNT signals from your Web browser.
Disclosing Your Information
1. We may disclose your Personal Information for the following reasons:
  1. At Your Request: Innermost may disclose Personal Information to third parties at your request, direction, or authorization. For example, if you direct Innermost to disclose your Personal Information to a third-party entity, we will share your information with that third party.
  2. Internal Sharing: Innermost may disclose Personal Information to its affiliates (including parents, entities under common ownership, and subsidiaries) and other related companies.
  3. With Our Service Providers: Innermost may disclose Personal Information to service providers for the purposes of operating our business, delivering, improving, and customizing our products or services, sending marketing and communications related to our business, payment processing, and for other legitimate purposes permitted by applicable law.
  4. Compliance with Law: To the extent permitted by law, Innermost will disclose Personal Information to government authorities or third parties pursuant to a legal request, subpoena, or other legal process. Innermost may also use or disclose your Personal Information as permitted by law to perform charge verifications, apply or enforce the MSA, or protect Innermost's rights, interests, or property, as well as those of Innermost's affiliates, customers, or Service users.
  5. Business Transaction: If Innermost sells all or part of its business, or makes a sale or transfer of assets, or is otherwise involved in a merger or business transfer, Innermost may transfer your Personal Information to a third party as part of that transaction.
Security of Personal Information
1. Innermost has reasonable and appropriate safeguards in place to help protect the Personal Information Innermost collects from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Although Innermost attempts to protect the Personal Information in our possession, no security system is perfect, and Innermost cannot promise that your Personal Information will remain absolutely secure in all circumstances.
Retention of Personal Information
1. Innermost will retain your Personal Information as needed to fulfill the purposes for which it was collected. Innermost will retain and use your Personal Information as necessary to comply with Innermost's business requirements and legal obligations, resolve disputes, protect our assets, and enforce our agreements. Additional information about our data retention practices for residents of U.S. states with comprehensive consumer privacy laws is available in our "Your U.S. State Privacy Rights" notice in Section 16 below.
Aggregated De-Identified Information
1. Innermost may collect and use aggregated and/or de-identified information related to your Personal Information. This information is used in a collective manner and does not identify you individually in any way.
Links to Third-Party Websites
1. Our Service may contain links to third-party websites. Innermost is not responsible or liable for the privacy practices or content found on these websites. You should check the privacy notice and policies of each website you visit. Links to third-party websites are provided solely for your convenience, and any use of or submission of data to such websites shall be at your sole risk.
Children's Privacy
1. Our Service is not directed toward individuals under the age of 18. We do not promote our Service to individuals under 18, and we do not knowingly collect any Personal Information through our Service from individuals under 18. To the extent applicable, we comply with the requirements of the Children's Online Privacy Protection Act ("COPPA") with respect to any information we may inadvertently collect from children under the age of 13.
United States Only
1. The Service is intended for use only in the United States of America. If you use the Service or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America, and (ii) by using the Service or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.
Compliance with Federal Law
1. In addition to any applicable state law obligations described in Section 16 below, Innermost's collection, use, and disclosure of Personal Information is subject to applicable U.S. federal law, including, as applicable, the Federal Trade Commission Act's prohibition on unfair or deceptive acts or practices, the Controlling the Assault of Non-Solicited Pornography and Marketing Act ("CAN-SPAM Act") governing commercial e-mail communications, and the Children's Online Privacy Protection Act ("COPPA") described in Section 11 above. If Innermost's Service is used in a manner that implicates other federal privacy or data security regimes (such as the Gramm-Leach-Bliley Act or the Health Insurance Portability and Accountability Act), Innermost will comply with the requirements applicable to the categories of information and activities involved.
Changes to This Privacy Policy
1. Innermost may change this Privacy Policy at any time. Unless we say otherwise, changes will be effective upon the last updated date at the top of this Privacy Policy. Please check this Privacy Policy regularly to ensure that you are aware of any changes. We may try to notify you of material changes to this Privacy Policy, which, if we do so, may be by means such as posting a notice directly on the Service, sending an e-mail notification (if you have provided your e-mail address to us), or by other reasonable methods. In any event, if you use the Service after changes to this Privacy Policy, you have accepted the changes. If you do not agree with the changes, please stop using the Service.
Contact Information
1. If you have any questions or concerns related to this Privacy Policy, or if you need to report a privacy or security incident, please contact support@innermost.com

Pursuant to applicable law, Innermost may be required to send you notice of known or suspected security breaches that impact your Personal Information. In the event that Innermost must provide notice of a security breach to you, Innermost will send security breach notices to the contact information contained in your account information, unless Innermost is required by law to notify you using another method. Otherwise, if Innermost needs, or is required, to contact you concerning any event that involves information about you, we may do so by e-mail, telephone, or mail.

Your U.S. State Privacy Rights
1. This section supplements the information contained in this Privacy Policy and applies to visitors to our Service, users, and other individuals who reside in a U.S. state that has enacted a comprehensive consumer privacy law (each, a "State Privacy Law," and each such resident, a "State Consumer"). As of the effective date of this Privacy Policy, states that have enacted such laws include California (the California Consumer Privacy Act, as amended by the California Privacy Rights Act, collectively, "CCPA/CPRA"), Texas (the Texas Data Privacy and Security Act, "TDPSA"), Virginia, Colorado, Connecticut, Utah, and a growing number of other states, and these laws grant State Consumers rights that are substantially similar to one another, as described below. Innermost will update this section periodically to reflect the specific states in which Innermost becomes subject to a State Privacy Law, and, in each case, will comply with the specific requirements of the applicable State Privacy Law, including any state-specific variations described below.
2. Personal Information/Personal Data We Collect and Process. Depending on how you have interacted with us, we may collect and process the categories of Personal Information (sometimes referred to as "personal data" under certain State Privacy Laws) described in this Privacy Policy, which may include identifiers, commercial information, internet or network activity information, geolocation information, professional or employment-related information, sensory information, and inferences drawn from such information. We collect this information directly from you and through the Data Collection Technologies described in this Privacy Policy. We process this information for the business and commercial purposes described in this Privacy Policy. Innermost has not sold consumers’ Personal Information in the twelve (12) months preceding the effective date of this Privacy Policy.
3. Your Rights. Subject to certain exceptions and, in some cases, subject to a minimum volume of processing activity or other applicability thresholds under the relevant State Privacy Law, State Consumers generally have the right to: (i) confirm whether we are processing their Personal Information and to access that information; (ii) correct inaccuracies in their Personal Information, taking into account the nature of the information and the purposes of processing; (iii) request deletion of Personal Information that they provided to us or that we obtained about them; (iv) obtain a copy of their Personal Information, where available, in a portable and readily usable format; (v) opt out of the processing of their Personal Information for purposes of targeted advertising, the sale of Personal Information, or certain profiling; (vi) appeal our decision if we decline to act on a request; and (vii) not receive discriminatory treatment for exercising these rights. Not every right described above is available under every State Privacy Law, and the availability of a particular right to you will depend on the law of the state in which you reside.
4. Sensitive Data and Universal Opt-Out Signals. We will not process sensitive Personal Information (which may include precise geolocation data or the Personal Information of a known child, among other categories, depending on the applicable State Privacy Law) without first obtaining your consent, where required by applicable law. Where required by applicable law, our Service will recognize an opt-out preference signal, such as Global Privacy Control, sent by your browser as a valid request to opt out of the sale of your Personal Information and targeted advertising.
5. Exercising Your Rights. To exercise the rights described above, please submit a request to us by emailing us at support@innermost.com. To verify your identity when you submit a request and confirm your state residency, Innermost will match the identifying information you provide to the Personal Information we have about you. If necessary, we may ask you to provide additional information for verification regarding your request. You will not be required to create an account with us in order to submit a request.
6. Appeals. If we decline to take action on your request, you may appeal our decision by contacting us using the methods described above within a reasonable time after receiving our decision. Depending on the State Privacy Law applicable to you, if we deny your appeal, you may have the right to submit a complaint to your state's Attorney General or other applicable state regulator.
7. State-Specific Variations. While the rights described above are broadly consistent across states, certain details — including, without limitation, whether a universal opt-out signal must be honored, whether we are afforded an opportunity to cure a violation before enforcement, and any additional state-specific disclosures (such as the California “Shine the Light” law, which permits California residents to request information regarding our disclosure, if any, of their personal information to third parties for the third parties’ own direct marketing purposes) — vary by state, and Innermost will comply with the specific requirements applicable in each state as they come to apply to us. No state currently provides consumers a private right of action to sue us directly for violation of its State Privacy Law; these laws are enforced exclusively by the applicable state attorney general or other state regulator.

End of policy