01Introduction

PrimalMogul AI is a private, membership-based business intelligence, leadership, capital readiness, and execution platform operated by Supreme Lion Group LLC (“Company,” “we,” “us,” or “our”).

This Privacy Policy explains how we collect, use, store, share, protect, and retain personal information when you visit primalmogul.com, create an account, join a paid membership (PrimalMogul Elite or PrimalMogul BoardRoom), use a free public tool such as the Business Power Audit, purchase Roadmap Pro, digital products, or merchandise, use AI tools, submit forms or assessments, join email or SMS communications, or otherwise use our website, member dashboard, store, and services.

This Policy should be read together with our Terms and Conditions, Cookie Policy, Affiliate Disclosure, and any separate notice presented at the point where information is collected, including the Notice at Collection in Schedule A and the Biometric Notice and Consent referenced in Section 9.

Capitalized terms not defined here have the meaning given in the Terms and Conditions.

02Who We Are and How to Reach Us

Requests may also be mailed to the address above. We respond to rights requests within the timeframes stated in Section 12.

03Scope and Territorial Application

The Platform is operated from the United States and intended for users located in the United States. We do not target, direct, or market the Platform to residents of the European Economic Area, the United Kingdom, or Switzerland, and we make no representation that our practices satisfy the laws of those jurisdictions. If you access the Platform from outside the United States, you do so on your own initiative, and your information will be processed in the United States.

04Age Requirement

The Platform is for adults. You must be at least eighteen (18) years of age to create an account or use any feature.

The Platform is not directed to children. We do not knowingly collect personal information from anyone under thirteen (13), and we do not knowingly collect personal information from anyone under eighteen (18) as a Member. If we learn we have collected information from a person under thirteen, we will delete it promptly.

We do not sell or share the personal information of consumers under sixteen (16) years of age, and we have no actual knowledge of doing so.

05Information We Collect

5.1 Information You Provide

Account and membership. Name, email address, username, password (stored in hashed form), membership tier, communication preferences, and account settings.

Purchase and billing. Billing name and address, shipping address where applicable, order number, purchase date, item purchased, payment status, refund and cancellation status, renewal consent records, and partial payment identifiers returned by the processor. We do not store full payment card numbers on our servers.

Communications. Support messages, contact form submissions, comments, testimonials, reviews, and survey responses.

Phone number. Only if you provide it and opt in to SMS.

AI tool content. Prompts, instructions, uploaded documents and images, business context, and any other material you enter into an AI Tool, together with the Outputs generated in response.

Company Memory and business data. Company information you choose to save to Company Memory, and revenue, cost, margin, and other business figures you enter into or connect to the Mogul Business OS or similar dashboards.

Assessment and diagnostic responses. Answers submitted to the Business Power Audit, the Mogul Business Diagnostic, the Mogul Funding Roadmap, Roadmap Pro, and any other questionnaire or assessment, including Free Public Tools used without an account.

Biometric identifiers, likeness, and voice. Only where you use an avatar or synthetic media feature and only under the separate consent described in Section 9.

5.2 Information Collected Automatically

IP address, browser type and version, device type, operating system, referring page, pages visited, time on page, click activity, approximate location derived from IP address, session and login information, cookie and pixel identifiers, error logs, security logs, membership access events, AI tool usage metadata such as request counts and timestamps, and general performance data.

5.3 Information From Third Parties

Transaction and dispute data from payment processors, email engagement data from our email provider, aggregate measurement data from analytics providers, campaign and conversion data from advertising platforms, and anti-spam and fraud signals from security services.

5.4 Information We Ask You Not to Submit

Do not enter any of the following into AI tools, Company Memory, forms, comments, or support messages: Social Security numbers; full financial account or payment card numbers; government identification numbers; passwords or private keys; protected health information or medical records; consumer report information; information subject to a third party’s attorney-client privilege; confidential third-party information you are not authorized to share; or the personal information of any other individual without that person’s permission.

You are responsible for what you choose to submit.

06Data Minimization

We collect only the categories of personal information described in this Policy, and only for the purposes stated in Section 7. We do not collect personal information for undisclosed purposes, and we do not use personal information for a materially different purpose without providing notice and, where required, obtaining consent.

07How We Use Information

We do not use personal information to make decisions that produce legal or similarly significant effects concerning you. Section 10 describes the limited profiling our diagnostics perform.

08Artificial Intelligence Data Processing

8.1 How AI Tools Process Your Information

When you use an AI Tool, your input is transmitted to a Third-Party AI Provider listed in Schedule E, processed to generate an Output, and returned to you. Inputs and Outputs may be stored in association with your account to support conversation history, features you have enabled, usage limit enforcement, security, and support.

8.2 Model Training

We do not sell your AI inputs or Outputs. We do not use your AI inputs or Outputs to train any model owned by the Company.

Where a Third-Party AI Provider offers a control restricting the use of submitted data for model training, we enable that control. Providers process data under their own agreements and published practices, which we do not control. Review those practices before submitting sensitive business information.

We may use aggregated, de-identified usage statistics that do not identify you and do not reveal the substance of your inputs to measure performance and improve the Platform.

8.3 Company Memory and Cross-Session Memory

The BoardRoom Membership includes Company Memory, which retains the company information you choose to save so that AI Tools and High Council seats can reference it across sessions. Where Company Memory or another memory feature is active, the associated context is stored in the vector storage service listed in Schedule E, retained for the period stated in Schedule B, and deleted when you remove it, disable the feature, delete the associated conversation, or close your account, subject to backup cycles.

8.4 Accuracy and Confidentiality Limitations

AI Outputs may be inaccurate, incomplete, outdated, or unsuitable for your situation, and are not professional advice of any kind. Do not treat an AI Tool conversation as a confidential or privileged consultation. Outputs are processed by third-party systems and stored in our infrastructure.

8.5 What We Will Not Do

We will not publish your AI inputs, Outputs, Company Memory, or business figures, or use them in marketing, without your permission, except where required by law or reasonably necessary for security, fraud prevention, or enforcement of our Terms.

8.6 Business Figures and the Mogul Business OS

Business figures you enter into or connect to the Mogul Business OS are used only to display your dashboards, warnings, and related AI analysis to you. We do not use them for advertising, we do not disclose them to advertising platforms, and we do not verify or audit them. The Mogul Business OS is a BoardRoom feature in development and processes data only when and as released.

09Biometric Identifiers, Voice, and Likeness

This Section applies only if you use a feature that accepts a facial image, video of your face, voice recording, or other personal likeness, including Mogul Studio and any avatar or synthetic media feature.

9.1 Separate Notice and Written Consent

Before any such feature processes a biometric identifier, we present a separate written notice and consent identifying the specific data collected, the purpose, the retention period, and the destruction schedule. Your written consent is required. This Privacy Policy alone does not constitute that consent.

9.2 Purpose

Biometric identifiers are used solely to generate the avatar, video, or synthetic media output you requested. We do not sell, lease, trade, or otherwise profit from biometric identifiers, and we do not use them for identification, verification, surveillance, or advertising.

9.3 Retention and Destruction

Our public written retention schedule and destruction guidelines appear in Schedule D and are incorporated into this Policy.

9.4 Disclosure

Biometric identifiers are disclosed only to the synthetic media provider listed in Schedule E, solely to produce the output you requested, and otherwise only where required by law or valid legal process. We do not disclose biometric identifiers for any other purpose without your separate written consent.

9.5 Your Rights

You may request destruction of your biometric identifiers at any time by writing to privacy@primalmogul.com. We will destroy them within the period stated in Schedule D and confirm in writing.

9.6 Third-Party Likenesses

You may only submit a likeness that is your own or one for which you hold a written release. See Terms and Conditions Section 20.

10Profiling and Automated Processing

10.1 What We Do

Our diagnostics and assessments, including Free Public Tools, analyze the answers you provide in order to classify a business stage, identify a stated bottleneck, and recommend tools, resources, learning paths, or membership tiers. This is profiling within the meaning of some state privacy laws.

10.2 What We Do Not Do

We do not use automated processing to make or support any decision regarding credit, lending, housing, employment, insurance, education, or access to essential services. We do not deny access to the Platform, alter pricing, or take adverse action against any individual based on automated profiling.

10.3 Human Involvement

Diagnostic and assessment results are educational recommendations. They are not determinations, they carry no legal effect, and you are free to disregard them entirely.

10.4 Opt Out

If you prefer that we not analyze your assessment responses to generate recommendations, write to privacy@primalmogul.com. Opting out may limit the usefulness of diagnostic features but will not affect your access to the Platform.

11How We Share Information, Sale, and Sharing

11.1 Categories of Recipients

See Schedule C for a mapping of information categories to the recipient categories we disclosed them to in the preceding twelve (12) months.

We disclose personal information to: service providers and processors that operate the Platform on our behalf; payment processors; Third-Party AI Providers; email, SMS, analytics, and security vendors; advertising platforms as described in Section 11.3; and professional advisers.

We may also disclose information where we reasonably believe it necessary to comply with law, respond to lawful process, enforce our Terms, prevent fraud, protect rights and safety, or defend against claims.

If the Company is involved in a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred as part of that transaction, subject to this Policy or a successor policy providing comparable protection.

11.2 Sale of Personal Information

We do not sell personal information for monetary consideration. We do not sell or rent customer lists, email addresses, phone numbers, account records, AI inputs, AI Outputs, Company Memory, business figures, assessment responses, or biometric identifiers to anyone.

11.3 Sharing for Cross-Context Behavioral Advertising

We use advertising and retargeting technologies, such as pixels and tags provided by advertising platforms listed in Schedule E, that transmit identifiers and internet activity to those platforms for cross-context behavioral advertising and campaign measurement. Under California and several other state laws, this may constitute “sharing” or “targeted advertising.” We never share AI inputs, Outputs, Company Memory, business figures, assessment responses, or biometric information for advertising. You may opt out at any time using the “Do Not Sell or Share My Personal Information” link in our site footer, through our cookie preference control, or by writing to privacy@primalmogul.com.

11.4 Opt-Out Preference Signals

We recognize and honor the Global Privacy Control signal and other recognized universal opt-out mechanisms as a valid request to stop selling or sharing personal information from the browser transmitting the signal. When we detect such a signal, our cookie preference control shows that your opt-out has been honored. Because such signals are browser-based, honoring them does not link the opt-out to your account unless you are logged in.

11.5 Equal Choices

Our privacy and cookie choices are designed so that opting out takes no more steps than opting in, no option is presented more prominently than its alternative, and closing a banner is not treated as consent.

12Your Privacy Rights

12.1 Rights Available

Depending on your state of residence, you may have the right to:

• know what personal information we collect, use, disclose, and retain;
• access a copy of your personal information;
• correct inaccurate personal information;
• delete personal information;
• obtain your information in a portable format;
• opt out of sale, sharing, or targeted advertising;
• opt out of profiling as described in Section 10;
• limit the use and disclosure of sensitive personal information; and
• not be discriminated against for exercising any of these rights.

12.2 How to Submit a Request

Email privacy@primalmogul.com or write to the address in Section 2. Include your name, the email address associated with your account, and the right you wish to exercise. Members may also submit deletion and access requests through the account area where available. Access requests may cover a specific date range or all personal information we hold about you, back to January 1, 2022.

12.3 Verification

We verify your identity before acting on a request, generally by confirming control of the email address on your account and matching information you provide against our records. For requests involving sensitive information or deletion, we may require additional verification. We do not use information collected for verification for any other purpose.

12.4 Timing

We acknowledge requests within ten (10) business days and respond substantively within forty-five (45) calendar days. Where reasonably necessary, we may extend once by an additional forty-five (45) days and will notify you of the extension and the reason within the original period. Requests to opt out of sale or sharing are processed as soon as feasibly possible and no later than fifteen (15) business days after receipt.

12.5 Authorized Agents

You may designate an authorized agent to submit a request on your behalf. We require written authorization signed by you, verification of your identity directly with us, and confirmation from you that the agent is authorized. An agent acting under a valid power of attorney may submit proof of that instrument instead.

12.6 Appeals

If we deny a request in whole or in part, you may appeal. Send an appeal to privacy@primalmogul.com with the subject line “PRIVACY APPEAL” within sixty (60) days of our response. We will review and respond in writing within forty-five (45) days, explaining the reasons for our decision. If we deny the appeal, we will provide a method to contact the attorney general of your state.

12.7 Limits

We may decline a request where an exception applies, including where retention is required for tax, accounting, legal, security, fraud prevention, or dispute purposes, where the information is necessary to complete a transaction, or where we cannot verify identity. We will explain any denial.

12.8 No Discrimination

We do not deny service, charge different prices, or provide a different level of quality because you exercised a privacy right. Some information is necessary to provide a Membership, and deleting it may end your ability to use the Platform.

12.9 Financial Incentives

We do not currently offer any financial incentive, price difference, or service difference in exchange for the retention, sale, or sharing of personal information. If we offer one in the future, we will publish a separate notice describing the material terms before you participate.

13California Privacy Notice

This Section applies to California residents.

13.1 Categories Collected in the Preceding Twelve Months

13.2 Sources, Purposes, and Recipients

Sources appear in Section 5. Purposes appear in Section 7. Recipient categories appear in Schedule C. Retention periods appear in Schedule B.

13.3 Sensitive Personal Information

We use sensitive personal information only to provide the services you requested, secure your account, and prevent fraud. We do not use or disclose sensitive personal information for purposes of inferring characteristics about you. Because our use falls within the permitted purposes, no separate right to limit applies. You may still request deletion under Section 12.

13.4 Sale and Sharing

We do not sell personal information. We share identifiers and internet activity for cross-context behavioral advertising as described in Section 11.3, and you may opt out as described in Sections 11.3 and 11.4.

13.5 Minors

See Section 4.

13.6 Shine the Light

California residents may request information about disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

14Other State Privacy Rights

Residents of states with comprehensive consumer privacy laws, including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and others, have rights substantially similar to those in Section 12, including the right to appeal a denial under Section 12.6.

Where a state law provides a right not listed in Section 12, we honor that right as required by the law of your state of residence. Submit all requests to privacy@primalmogul.com.

Illinois residents: see Section 9 and Schedule D regarding biometric identifiers. Nevada residents: you may submit a verified request that we not sell covered information. We do not sell covered information.

15Cookies and Tracking Technologies

We use cookies, pixels, and similar technologies for login sessions, membership access, checkout, security and fraud prevention, cookie preference management, analytics, and advertising.

You may manage non-essential cookies and advertising pixels through the cookie preference control on our site, through your browser settings, and through opt-out preference signals as described in Section 11.4. Disabling essential cookies will prevent login and checkout from functioning.

A categorized list of the cookies in use, including provider, purpose, and duration, appears in our Cookie Policy.

16Email and SMS Communications

Email. You may receive account, billing, renewal, security, membership, product delivery, educational, and promotional email, including The Mogul Intelligence Newsletter. Unsubscribe from promotional email using the link in any such message. Transactional, billing, renewal, security, and service messages continue while your account is active.

SMS. If you provide a mobile number and affirmatively opt in, you may receive recurring automated marketing and informational texts. Consent is not a condition of any purchase. Message frequency varies. Message and data rates may apply. Reply STOP to opt out and HELP for assistance. We retain records of consent and revocation as required by law. We do not share mobile numbers or SMS consent with third parties for their own marketing.

17Data Retention

We retain personal information only as long as necessary for the purposes described in this Policy, to comply with legal and tax obligations, to resolve disputes, to prevent fraud, and to enforce our agreements.

Specific retention periods by category appear in Schedule B, which is incorporated into this Policy.

When a retention period ends, we delete the information or de-identify it so that it can no longer reasonably be linked to you. Information in encrypted backups is deleted on the backup cycle stated in Schedule B.

18Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These include encryption of data in transit, access controls limiting internal access to those with a business need, use of reputable payment processors that handle card data outside our systems, authentication controls, and monitoring for suspicious activity.

No system is completely secure, and we do not warrant that the Platform is free of vulnerabilities. You are responsible for maintaining a strong, unique password, protecting your credentials, and logging out of shared devices.

Breach notification. If we determine that a security incident has compromised your personal information, we will notify you and any required regulator in accordance with applicable law, without unreasonable delay.

If you believe your account has been compromised, contact support@primalmogul.com immediately.

19Third-Party Links and Embedded Content

The Platform may link to or embed third-party websites, videos, social media content, tools, affiliate partners, and payment pages. Those third parties may collect information about you, set cookies, and track interactions under their own policies. We are not responsible for third-party privacy practices. Review their policies before using their services.

20Your Responsibility for Accuracy

You are responsible for the accuracy of information you provide. Inaccurate, incomplete, or outdated input into forms, AI tools, Company Memory, dashboards, or assessments will reduce the usefulness of Outputs and recommendations. You are responsible for reviewing all Outputs before relying on them.

21Changes to This Policy

We may update this Policy. For material changes, including any new category of information collected, any materially new purpose of use, or any change in our sale or sharing practices, we will provide at least thirty (30) days’ advance notice by email to your registered address, by notice within the Platform, or both, and will update the version number and effective date at the top of this page.

Material changes apply prospectively only. We will not apply a materially new processing purpose to personal information collected before the change without providing notice and, where required by law, obtaining your consent. Non-material changes take effect on posting. Prior versions are available on request.