Privacy Policy
JEFFREY MICHAEL CAPITAL, LLC - PRIVACY POLICY
Effective Date: January 1, 2026
Last Updated: February 12, 2026
This Privacy Policy explains how Jeffrey Michael Capital, LLC (“JMC,” “we,” “us,” “our”) collects, uses, discloses, and protects information when you visit or interact with our websites, including jeffreymichaelcapital.com and praxis.jeffreymichaelcapital.com (collectively, the “Sites”), and any related services, features, and tools we provide through the Sites (the “Services”).
JMC is an Indiana limited liability company with headquarters in Michigan, USA.
1) SCOPE; IMPORTANT NOTES ABOUT OUR SERVICES
JMC provides business advisory and operational services, including fractional executive leadership and managed operational support, capital advisory and investment readiness support, and Praxis, a decision-intelligence platform that can process business documents and data uploaded by users.
This Privacy Policy applies to information collected through the Sites and Services. It does not replace or override a separate written agreement you may have with JMC (such as a Master Services Agreement (MSA), Statement of Work (SOW), subscription agreement, NDA, Data Processing Addendum (DPA), or security addendum). If there is a conflict, the signed agreement controls for that relationship.
2) INFORMATION WE COLLECT
2.1 Information you provide to us
We collect information you choose to provide, including:
(a) Contact and business information. Name, email address, phone number, company/organization, job title (if provided), and the content of your message when you submit forms, request information, schedule a consultation, request a demo, or otherwise communicate with us.
(b) Account information (Praxis). If you create a Praxis account, we collect identifiers and account details such as name, email address, username, authentication credentials (stored in hashed form), account settings, and login/security events.
(c) Customer Content (Praxis uploads). Praxis allows users to upload or submit business materials to support decision-making, including financial statements, budgets, forecasts, sales data, pricing data, SOPs, operational documents, and workforce/employee-related data. Any such content you upload or submit through Praxis is “Customer Content.” Customer Content may contain personal information (for example, employee contact details or HR-related information) depending on what you upload.
(d) Marketing preferences. Subscription status, communication preferences, and opt-in/consent records.
(e) Recruiting/applicant information (if applicable). Resume/CV, employment history, and other information you provide when applying or recruiting.
2.2 Information collected automatically When you use the Sites, we (and our service providers) automatically collect:
(a) Device and network information. IP address, browser type, device identifiers, operating system, language, and approximate location derived from IP address.
(b) Usage information. Pages viewed, links clicked, time spent, referring/exit pages, and performance logs.
(c) Cookies and similar technologies. Cookies, pixels, tags, SDKs, and similar technologies used for site functionality, analytics, and advertising measurement.
2.3 Information from third parties
We may receive information from third parties, such as:
- Analytics providers (including Google Analytics)
- Advertising/measurement partners (including Meta Pixel and LinkedIn Insight Tag)
- CRM and marketing platforms (including HubSpot and Mailchimp)
- Identity providers (if single sign-on is enabled)
3) RESTRICTED DATA; DO NOT UPLOAD CERTAIN INFORMATION UNLESS EXPRESSLY AUTHORIZED
3.1 Restricted Data
Unless we have a signed written agreement that expressly permits it (and any required addenda are in place), you agree not to upload, submit, or provide the following categories of data through the Sites or Praxis (“Restricted Data”):
- Payment card data subject to PCI-DSS (full card numbers, CVV, magnetic stripe, etc.);
- Government-issued identifiers (e.g., Social Security numbers, driver's license numbers) beyond what is necessary for ordinary business communications;
- Protected health information (PHI) or medical information regulated by HIPAA or similar laws;
- Biometric identifiers or biometric information used for identification;
- Precise geolocation data of individuals;
- Information about children under 13 (or under 16 where applicable) or student education records regulated by laws such as FERPA; and
- Any other data that is subject to heightened regulatory obligations unless expressly agreed in writing.
3.2 Confidential deal materials and sensitive business information
If you are exploring capital advisory, investment readiness, or due diligence support, do not submit confidential deal materials via public web forms or general email addresses unless we have signed appropriate confidentiality protections (e.g., an NDA) and you are using a secure intake method approved by JMC.
4) HOW WE USE INFORMATION
We use information for the following purposes:
5) PRAXIS PROCESSING ROLE; AI OUTPUTS NOTICE
5.1 Processing roles (Controller / Processor)
When you upload Customer Content into Praxis, you (or your organization) control what data is uploaded and how it is used. In that context, JMC generally acts as a service provider/processor processing Customer Content to provide the Praxis service, subject to this Privacy Policy and any applicable agreement.
If you need a DPA for enterprise, public-sector, or regulated use cases, contact privacy@jeffreymichaelcapital.com.
5.2 AI outputs and decision support
Praxis may generate outputs based on your inputs. AI-generated outputs may be inaccurate, incomplete, or not appropriate for your specific situation. You are responsible for reviewing and validating outputs and for any decisions you make using the Service.
5.3 Model training position
Unless we have your explicit written agreement (e.g., an enterprise addendum), we do not use Customer Content to train public or general-purpose models. We may use de-identified, aggregated usage metrics to operate, secure, and improve the Services.
6) HOW WE DISCLOSE INFORMATION
6.1 Service providers
We share information with vendors that provide services on our behalf, such as website hosting, infrastructure, customer support tools, security monitoring, CRM/email platforms (HubSpot and Mailchimp), analytics (Google Analytics), and advertising measurement (Meta Pixel and LinkedIn Insight Tag). These providers are permitted to process information only to provide services to us and must protect it consistent with applicable law.
6.2 Advertising and measurement
We use cookies/pixels for advertising measurement and attribution and to understand the effectiveness of our marketing. Depending on your jurisdiction, this may be considered “sharing” for cross-context behavioral advertising.
6.3 Legal, safety, and rights
We may disclose information to comply with law or legal process, enforce agreements, investigate or prevent fraud/security issues, or protect rights, property, and safety.
6.4 Business transfers
Information may be transferred in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets.
7) COOKIES, ANALYTICS, AND YOUR CHOICES
7.1 Cookie and tracking technologies
We use cookies and similar technologies for authentication (Praxis), functionality, analytics (Google Analytics), and advertising measurement (Meta Pixel and LinkedIn Insight Tag).
7.2 Controls
You can control cookies through your browser settings. Disabling cookies may affect site functionality (including Praxis login and certain features).
7.3 Global Privacy Control (GPC)
If your browser sends a Global Privacy Control signal, we will treat it as an opt-out of “sharing” for cross-context behavioral advertising where required by law.
7.4 Marketing opt-out
You may opt out of promotional emails using the unsubscribe link. We may still send non-promotional messages such as security notices, account alerts, or administrative communications.
8) DATA RETENTION
We retain information only as long as reasonably necessary for the purposes described in this Policy, including:
- General inquiries: typically up to 24 months after last interaction.
- Marketing subscriptions: until you unsubscribe (and we may retain a suppression record to honor your opt-out).
- Praxis accounts: for the duration of your account and a reasonable period thereafter for backups, security, and compliance.
- Customer Content: retained according to your account settings and any applicable written agreement; limited backups may persist for a reasonable period.
- Security logs: typically 30–180 days unless needed longer for investigation or compliance.
9) SECURITY
We maintain reasonable administrative, technical, and physical safeguards designed to protect information. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
10) CHILDREN'S PRIVACY
The Sites are not directed to children under 13 (or under 16 where applicable), and we do not knowingly collect personal information from children.
11) U.S. STATE PRIVACY RIGHTS
Depending on your state of residence, you may have rights to request access, correction, or deletion of certain personal information, and to opt out of targeted advertising / “sharing” for cross-context behavioral advertising.
How to exercise rights: Email privacy@jeffreymichaelcapital.com with the subject line “Privacy Request.” We may verify your identity before responding. We will not discriminate against you for exercising privacy rights.
12) INTERNATIONAL VISITORS
If you use the Sites from outside the United States, your information may be transferred to and processed in the United States and other jurisdictions where we and our service providers operate. Where required, we use appropriate safeguards for international transfers.
13) CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. We will update the “Last Updated” date above and may provide additional notice if changes are material.
14) CONTACT US
For privacy questions or requests:
privacy@jeffreymichaelcapital.com