Privacy Policy

ProAgentMe.com

A product of Telos Technologies LLC

Effective Date: April 22, 2026
Last Updated: April 22, 2026

Introduction

Welcome to ProAgentMe ("ProAgentMe," "Platform," "we," "us," or "our"), a product owned and operated by Telos Technologies LLC, a Virginia limited liability company ("Company"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Platform.

We are committed to protecting your privacy and handling your data with transparency and care. Please read this Privacy Policy carefully. By accessing or using ProAgentMe, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

Table of Contents

1. Definitions
2. Information We Collect
3. How We Use Your Information
4. Creator Content and Training Data Protection
5. Information Sharing and Disclosure
6. Data Retention
7. Data Security
8. Your Privacy Rights
9. International Data Transfers
10. Children's Privacy
11. Third-Party Services
12. Cookies and Tracking Technologies
13. Do Not Track Signals
14. California Privacy Rights (CCPA / CPRA)
15. European Privacy Rights (GDPR / UK GDPR)
16. Virginia Privacy Rights (VCDPA)
17. Other State Privacy Rights
18. HIPAA, GLBA, and Regulated-Data Positioning
19. Changes to This Privacy Policy
20. Contact Us

1. Definitions

For the purposes of this Privacy Policy:

• "Account" means a unique account created for you to access our Platform.
• "Agent" means an AI-powered digital assistant created by a Creator on the Platform.
• "Client" means any user who subscribes to or interacts with Agents.
• "Creator" means any user who creates, trains, and publishes Agents.
• "Creator Content" or "Training Materials" means any documents, text, audio, video, images, frameworks, methodologies, prompts, instructions, or other materials uploaded by Creators to train their Agents.
• "Conversation Data" means the content of interactions between Clients and Agents.
• "Personal Data" means any information that identifies or can be used to identify an individual.
• "Platform" means the ProAgentMe website, applications, APIs, MCP server, and all related services.
• "Sensitive Personal Information" means information treated as "sensitive personal information," "sensitive data," or an equivalent category under the California Privacy Rights Act, the Virginia Consumer Data Protection Act, the GDPR, or analogous privacy laws.
• "User" means any individual who accesses or uses the Platform, including Creators and Clients.

2. Information We Collect

2.1 Information You Provide Directly

Account Information:

• Full name
• Email address
• Password (encrypted; managed by our authentication provider, Clerk)
• Phone number (optional)
• Profile photo (optional)
• Professional title and expertise areas
• Company or organization name (optional)
• Billing address
• Payment information (processed by third-party payment processors)

Creator-Specific Information:

• Professional background and credentials
• Areas of expertise
• Pricing preferences for Human Expert Sessions
• Payout information (collected by Stripe Connect; Telos Technologies LLC does not separately store this data)
• Tax identification information (collected by Stripe Connect; Telos Technologies LLC does not separately store this data)
• Training Materials and Creator Content (see Section 4 for special protections)
• Agent configuration settings

Client-Specific Information:

• Company information
• Project requirements and needs
• Feedback and reviews

Communications:

• Customer support inquiries
• Emails and messages sent through the Platform
• Survey responses
• Feedback and testimonials

2.2 Information Collected Automatically

Device and Usage Information:

• IP address
• Browser type and version
• Operating system
• Device identifiers
• Pages visited and features used
• Time and date of visits
• Referring URLs
• Click patterns and navigation paths

Conversation and Interaction Data:

• Interactions between Clients and Agents (Conversation Data)
• Human Expert Session requests and outcomes
• Usage patterns and frequency
• Task completion data

Log Data:

• Server logs
• Error reports
• Performance data

2.3 Information from Third Parties

• Payment processors (transaction confirmations, not full payment details)
• Identity verification services (if applicable)
• Social media platforms (if you choose to link accounts)
• Analytics providers
• Marketing partners (with your consent)

2.4 Sensitive Personal Information

The Platform does not require you to share sensitive categories of personal information to use its core functionality. However, when you interact with an Agent, the content of your queries is entirely under your control, and you may choose to share sensitive information — including information about your health, finances, legal situation, mental health, family, employment, or proprietary business affairs — in the course of seeking expert guidance.

You are not required to share such information to receive Agent responses. If you choose to share sensitive personal information:

(a) that information is processed under the same technical and organizational safeguards as other Platform data (see Section 7);

(b) it may be transmitted to our AI infrastructure provider for response generation, subject to the restrictions in Section 5;

(c) it may be visible to the Creator whose Agent you are using, consistent with Section 4.2;

(d) the Platform does not claim that inputting such information creates any privilege, confidentiality obligation, or special legal relationship.

Where applicable law (including the California Privacy Rights Act, the Virginia Consumer Data Protection Act, the GDPR, and similar frameworks) provides additional rights over sensitive personal information or equivalent categories, those rights are described in Sections 14, 15, and 16 and in Section 8 (Your Privacy Rights).

3. How We Use Your Information

3.1 To Provide and Maintain the Platform

• Create and manage your Account
• Process transactions and send related information
• Enable Creators to build, train, and deploy Agents
• Enable Clients to discover, subscribe to, and interact with Agents
• Facilitate Human Expert Sessions between Clients and Creators
• Process payments and payouts
• Provide customer support

3.2 To Improve and Personalize the Platform

• Analyze usage patterns to improve features
• Personalize your experience and recommendations
• Develop new products, services, and features
• Conduct research and analytics
• Monitor and analyze trends

3.3 To Communicate With You

• Send administrative information (updates, security alerts, support messages)
• Respond to inquiries and provide support
• Send marketing communications (with your consent)
• Notify you of changes to our services or policies

3.4 To Ensure Safety and Security

• Detect, prevent, and address fraud and abuse
• Enforce our Terms of Service
• Protect the rights, property, and safety of our Users
• Comply with legal obligations

3.5 To Process Payments

• Facilitate payments from Clients to the Platform
• Process payouts to Creators (via Stripe Connect)
• Manage billing and invoicing
• Handle refunds and disputes

4. Creator Content and Training Data Protection

This section contains our most important privacy commitments to Creators.

4.1 Our Creator Privacy Commitments

We understand that your Training Materials represent your valuable intellectual property, professional expertise, and competitive advantage. We make the following binding commitments:

We Will NEVER:

1. Share your Training Materials with third parties. Your documents, frameworks, methodologies, prompts, and other content uploaded to train your Agent will never be shared with any third party, including other Users, partners, advertisers, or data brokers.
2. Use your Training Materials to train our own AI models. Your content will never be used to train, fine-tune, improve, or develop any AI models owned or operated by Telos Technologies LLC, ProAgentMe, or any affiliated entity.
3. Use your Training Materials to train other Creators' Agents. Your content is exclusively used to power YOUR Agent and will never be used to benefit other Creators or their Agents.
4. Sell, license, or monetize your Training Materials. Your intellectual property belongs to you.
5. Access your Training Materials except as necessary for technical operations. Access is limited to: (a) providing the service, (b) troubleshooting technical issues at your request, (c) ensuring compliance with our Terms of Service, or (d) responding to valid legal requirements.

We Will ALWAYS:

1. Treat your Training Materials as confidential information.
2. Store your Training Materials securely using industry-standard encryption at rest and in transit.
3. Delete your Training Materials upon request or upon termination of your Account, subject to legal retention requirements.
4. Notify you if we receive any legal request for access to your Training Materials, unless prohibited by law.
5. Maintain technical and organizational measures to prevent unauthorized access to your content.

4.2 Conversation Data

For Creators:

• You may access transcripts and analytics of conversations between Clients and your Agent, subject to shipped product functionality.
• You may anonymize or delete conversation data at any time, subject to shipped product functionality.

For Clients:

• Your conversations with Agents may be visible to the Creator who built that Agent.
• When you interact with an Agent, you consent to the Creator's access to Conversation Data associated with your interactions.
• You may request deletion of your conversation history.

4.3 Human Expert Session Data

When a Client requests a Human Expert Session with a Creator:

• The Creator receives relevant conversation context to provide assistance;
• Both parties consent to direct communication through Platform messaging;
• Session data is subject to the same protections as other Conversation Data.

4.4 Technical Processing

To provide our service, we must technically process your Training Materials to:

• Generate vector embeddings for retrieval-augmented generation (RAG);
• Store content in encrypted databases;
• Enable your Agent to respond to Client queries.

This technical processing is solely for powering YOUR Agent and does not constitute "use" of your content for any other purpose.

5. Information Sharing and Disclosure

5.1 We Do NOT Sell Your Personal Information

We do not sell, rent, or trade your Personal Data to third parties for their marketing purposes. Under the California Privacy Rights Act and analogous state laws that define "sharing" (including sharing for cross-context behavioral advertising), we do not "share" your Personal Data as so defined.

5.2 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Payment Processing: Stripe, Inc. (payment intake, subscription management, Connect payouts to Creators), subject to Stripe's own privacy policy.
• Database Hosting: Neon, Inc. (managed PostgreSQL; stores account data, conversation metadata, subscription and payout records). US-based.
• File Storage: Cloudflare, Inc. (R2 object storage; holds Creator skill files, knowledge-base documents, and uploaded attachments, each encrypted at rest).
• Authentication: Clerk, Inc. (user sign-in, session management, and multi-factor authentication).
• AI Infrastructure: Our AI infrastructure provider(s) (generate Agent responses via their commercial APIs). Queries submitted through these APIs are not used to train the provider's models, per their commercial terms. The provider retains limited query data solely for abuse-prevention purposes as described in their policies. The specific vendor identity is disclosed in our Data Processing Addendum upon request from Enterprise customers.
• Web Hosting: Vercel, Inc. (frontend and documentation hosting; request logs, static assets).
• Backend Hosting: Railway (backend API hosting; request logs, error telemetry).
• Transactional Email: Resend (delivers escalation notifications, waitlist confirmations, and billing alerts).
• Waitlist / Marketing CRM: HubSpot (captures waitlist form submissions).
• Analytics: Services that help us understand Platform usage in aggregate.
• Customer Support: Tools to help us respond to inquiries.

All service providers are contractually obligated to use your information only for the purposes of providing services to us and must maintain confidentiality.

Important Note on AI Infrastructure Providers:

When your Agent generates responses, the Client's query and relevant conversation context are transmitted to our AI infrastructure provider solely to generate that response. In addition:

• We do NOT send your Training Materials (raw skill files, uploaded knowledge-base documents, or the persona configuration) to AI infrastructure providers;
• We send only the specific query from the Client and the relevant context from the current conversation needed to generate a response;
• Per our AI infrastructure provider's commercial terms, the provider does not train its models on data submitted through its API. Queries are retained by the provider only for the limited period required for abuse detection as described in their policies;
• Your Training Materials remain stored securely on our infrastructure, encrypted at rest.

5.3 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Court orders, subpoenas, or legal process;
• Requests from government authorities;
• To protect our legal rights or defend against legal claims;
• To prevent fraud or illegal activity;
• To protect the safety of Users or the public.

If we receive a legal request for Creator Training Materials, we will notify the affected Creator before disclosure unless prohibited by law.

5.4 Business Transfers

If Telos Technologies LLC is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.

5.5 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so.

5.6 Aggregated or De-identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you for research, marketing, analytics, and other purposes.

6. Data Retention

6.1 General Retention Periods

6.2 Creator Content Deletion

Upon Account termination or deletion request:

• Training Materials will be deleted within 30 days;
• Vector embeddings will be purged from active systems within 30 days;
• Backup copies will be deleted within 90 days;
• We may retain anonymized, aggregated data that cannot identify you.

6.3 Legal Holds

We may retain information longer if required for:

• Ongoing legal proceedings;
• Regulatory investigations;
• Compliance with legal obligations;
• Enforcement of our Terms of Service.

7. Data Security

7.1 Security Measures

We implement security measures designed to protect your information. Our current security posture includes:

Technical Safeguards:

• Encryption of data in transit (TLS 1.2 or higher);
• Encryption of data at rest (provider-managed encryption, including AES-256 where applicable);
• Password hashing managed by our authentication provider (Clerk);
• Access logging and monitoring for production infrastructure;
• Isolated per-tenant storage for Creator Content;
• Automated refusal patterns designed to reduce the incidence of prompt-injection and extraction attempts in Agent interactions.

Organizational Safeguards:

• Role-based access to production systems;
• Confidentiality obligations for all personnel with data access;
• Incident response procedures;
• Regular review of access and security practices.

We do not represent that our security measures are comprehensive, incident-proof, or immune from compromise. We improve our security posture continuously and will update this Privacy Policy as our practices evolve.

7.2 Data Breach Notification

If we become aware of a data breach that affects your Personal Data and triggers a notification obligation under applicable law, we will:

(a) notify affected Users without unreasonable delay and in any event within the window required by applicable law (including, where applicable, the 72-hour window of Article 33 of the GDPR for notification of supervisory authorities, and the timing required by applicable US state breach notification statutes);

(b) notify relevant regulatory authorities as required by law;

(c) take immediate steps to investigate, mitigate, and contain the breach;

(d) provide information, where reasonable, about the nature of the breach, the data affected, the steps we are taking, and any recommended steps Users may take to protect themselves.

7.3 Your Responsibilities

You are responsible for:

• Maintaining the confidentiality of your Account credentials;
• Using strong, unique passwords;
• Notifying us immediately of any unauthorized access;
• Ensuring the security of devices you use to access the Platform.

8. Your Privacy Rights

8.1 Access and Portability

You have the right to:

• Access the Personal Data we hold about you;
• Receive a copy of your data in a portable format;
• Request information about how your data is processed.

8.2 Correction

You have the right to correct inaccurate Personal Data and to complete incomplete Personal Data.

8.3 Deletion

You have the right to request deletion of your Personal Data, subject to:

• Legal retention requirements;
• Ongoing contractual obligations;
• Legitimate business interests (fraud prevention, legal claims).

8.4 Restriction and Objection

You have the right to:

• Restrict processing of your Personal Data in certain circumstances;
• Object to processing based on legitimate interests;
• Object to direct marketing.

8.5 Withdrawal of Consent

Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

8.6 Exercising Your Rights

To exercise any of these rights, contact us at:

• Email: support@proagentme.com
• Mail: Telos Technologies LLC, Berryville, Virginia, USA

We will respond to requests within 30 days (or as required by applicable law). Where applicable law allows authorized agents to submit requests on your behalf, we will verify the authorization before responding.

9. International Data Transfers

9.1 Data Location

Our Platform is operated from the United States. If you access the Platform from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate.

9.2 Transfer Safeguards

For transfers of Personal Data from the European Economic Area (EEA), United Kingdom, or Switzerland to the United States or other countries, we rely on one or more of the following mechanisms:

• The EU-US Data Privacy Framework (DPF) and its UK Extension, where Telos Technologies LLC or our relevant sub-processor is self-certified (status confirmed upon request);
• Standard Contractual Clauses approved by the European Commission (including the UK International Data Transfer Addendum and the Swiss SCCs as applicable);
• Transfer Impact Assessments for high-risk recipients where required;
• Other lawful mechanisms, including your consent where applicable.

Copies of our Standard Contractual Clauses and DPF self- certification status are available to Users and regulators on request to support@proagentme.com.

10. Children's Privacy

ProAgentMe is not intended for children under the age of 18. We do not knowingly collect Personal Data from children under 18. If you are a parent or guardian and believe your child has provided us with Personal Data, please contact us immediately at support@proagentme.com. If we discover that we have collected Personal Data from a child under 18, we will delete that information promptly.

11. Third-Party Services

11.1 Third-Party Links

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information.

11.2 Third-Party Integrations

If you choose to integrate third-party services with your Account (such as social media or productivity tools), those services may receive information from or send information to our Platform in accordance with their own privacy policies.

11.3 AI Infrastructure Providers

Our Agents are powered by third-party AI infrastructure providers. While we have contractual protections in place:

• We recommend not sharing highly sensitive personal information in conversations with Agents (see Section 2.4);
• AI responses are generated by third-party models;
• We do not control the training data or behavior of underlying AI models.

12. Cookies and Tracking Technologies

12.1 Types of Cookies We Use

12.2 Managing Cookies

You can manage cookies through the Cookie Settings link in our site footer (which opens the preferences modal at any time), through your browser settings, or through opt-out links for specific providers. Analytics cookies are collected by default under a CCPA-style "collect-and-opt-out" model; advertising cookies are never set until you explicitly accept them.

Note that disabling certain cookies may affect Platform functionality.

12.3 Other Tracking Technologies

We may use:

• Pixel tags (web beacons);
• Local storage;
• Session storage;
• Device fingerprinting (for fraud prevention only).

12.4 Global Privacy Control (GPC)

We honor the Global Privacy Control browser signal where it is required by applicable law (including, for California residents, for purposes of the CPRA "Do Not Sell or Share" right). When your browser sends a GPC signal and you have not yet made an explicit cookie choice on our site, we automatically disable advertising cookies for your session and record that preference for future visits. You can still opt in to advertising cookies later via Cookie Settings. Analytics cookies continue under our default opt-out model described in §12.1.

13. Do Not Track Signals

There is no industry standard for responding to "Do Not Track" (DNT) signals. Currently, our Platform does not respond to DNT signals; however, we honor Global Privacy Control (GPC) signals as described in Section 12.4 and allow you to manage tracking through your cookie preferences.

14. California Privacy Rights (CCPA / CPRA)

14.1 Rights of California Residents

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

Right to Know:

• Categories of Personal Information collected about you;
• Sources of Personal Information;
• Purposes for collection;
• Categories of third parties with whom we share Personal Information;
• Specific pieces of Personal Information collected about you.

Right to Delete:

• Request deletion of Personal Information about you, subject to legal exceptions.

Right to Correct:

• Request correction of inaccurate Personal Information about you.

Right to Opt-Out of Sale or Sharing:

• We do not "sell" or "share" Personal Information as those terms are defined under the CCPA/CPRA. If our practices change, we will offer a prominent "Do Not Sell or Share My Personal Information" link as required by law. We honor Global Privacy Control signals for purposes of this right.

Right to Limit Use of Sensitive Personal Information:

• You have the right to request that we limit our use of "sensitive personal information" (as defined by CPRA). We do not use sensitive personal information for purposes beyond those necessary to provide the Platform. If our practices change, we will offer a "Limit the Use of My Sensitive Personal Information" option as required by law.

Right to Non-Discrimination:

• We will not discriminate against you for exercising any right under the CCPA/CPRA.

14.2 California Shine the Light Law

California residents may request information about disclosure of Personal Information to third parties for direct marketing purposes. As we do not share Personal Data for third-party marketing, this does not apply.

14.3 Exercising California Rights

To exercise your rights:

• Email: support@proagentme.com
• Include "California Privacy Request" in the subject line;
• We will verify your identity before processing requests;
• We will respond within 45 days (extendable by 45 days for complex requests).

14.4 Authorized Agents

If you designate an authorized agent to make a request on your behalf, we will require written authorization and, in some cases, verification directly with you.

15. European Privacy Rights (GDPR / UK GDPR)

15.1 Legal Basis for Processing

If you are in the EEA, UK, or Switzerland, we process your Personal Data based on:

15.2 Additional Rights

In addition to the rights in Section 8, if you are in the EEA, UK, or Switzerland you have the right to:

• Lodge a complaint with your local data protection authority;
• Receive meaningful information about any automated decision-making affecting you (see Section 15.3).

15.3 Automated Decision-Making and Profiling

Your interaction with an Agent involves automated processing of your input by AI systems to generate a response. The response may be used by you to make decisions; the decision to rely on Agent output remains yours.

The Platform does not use automated decision-making or profiling to make decisions about you that produce legal or similarly significant effects (such as subscription approval, creditworthiness, or employment decisions) within the meaning of Article 22 of the GDPR or analogous provisions of applicable state law.

If the Platform introduces automated decision-making that would have such effects, we will update this Privacy Policy, provide meaningful information about the logic involved and the expected consequences, and offer the right to request human review of any individual decision.

15.4 Data Protection Officer / EU Representative

For GDPR-related inquiries, contact support@proagentme.com with "Privacy" in the subject line. If and when our processing activities require formal DPO designation under GDPR Article 37 or EU-representative designation under Article 27, we will update this Privacy Policy accordingly.

15.5 Supervisory Authority

You have the right to lodge a complaint with your local supervisory authority if you believe we have violated your privacy rights.

16. Virginia Privacy Rights (VCDPA)

16.1 Rights of Virginia Residents

If you are a Virginia resident, you may have the following rights under the Virginia Consumer Data Protection Act (VCDPA), to the extent the VCDPA applies to our processing of your Personal Data:

• Right to access Personal Data we process about you;
• Right to correct inaccurate Personal Data;
• Right to delete Personal Data you have provided;
• Right to data portability in a structured, commonly used, and machine-readable format;
• Right to opt out of certain processing for targeted advertising, sale of Personal Data, or profiling for decisions that produce legal or similarly significant effects.

We do not engage in the sale of Personal Data or in profiling for decisions with legal or similarly significant effects within the meaning of the VCDPA.

16.2 Appeals

If we deny a VCDPA request, you have the right to appeal our decision within 30 days by contacting support@proagentme.com with "VCDPA Appeal" in the subject line. If we deny your appeal, you may contact the Virginia Attorney General at https://www.oag.state.va.us.

16.3 Exercising Virginia Rights

• Email: support@proagentme.com
• Include "Virginia Privacy Request" in the subject line;
• We will verify your identity before processing requests.

17. Other State Privacy Rights

If you reside in Colorado, Connecticut, Utah, Texas, Oregon, Delaware, Iowa, Nebraska, New Jersey, Florida, or another state with a comprehensive privacy law, you may have rights similar to those described in Sections 14 (California) and 16 (Virginia). We will honor such rights in the manner required by the applicable state law. To exercise these rights, contact support@proagentme.com and identify the state whose rights you are exercising.

18. HIPAA, GLBA, and Regulated-Data Positioning

18.1 HIPAA Positioning

The Platform operates as a direct-to-consumer service and is not a HIPAA Covered Entity or Business Associate under the Health Insurance Portability and Accountability Act of 1996, as amended ("HIPAA"), unless the Platform has separately executed a Business Associate Agreement (BAA) with a HIPAA Covered Entity. Health information you share in the course of using the Platform is handled under this Privacy Policy and the Terms of Service, not under HIPAA. If you are a HIPAA Covered Entity considering use of the Platform in connection with protected health information, contact us before use to discuss whether a BAA is possible.

18.2 GLBA and Financial Data Positioning

The Platform is not a "financial institution" under the Gramm-Leach-Bliley Act (GLBA). Payment card data entered on the Platform is tokenized and handled by Stripe, Inc. (our payment processor) under Stripe's PCI DSS-compliant environment; we do not store payment card numbers on Platform infrastructure. Financial information you share in the course of interacting with an Agent is handled under this Privacy Policy and the Terms of Service.

19. Changes to This Privacy Policy

19.1 Notification of Changes

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting a notice on our Platform;
• Sending an email to registered Users;
• Updating the "Last Updated" date.

19.2 Your Continued Use

Your continued use of the Platform after changes become effective constitutes acceptance of the revised Privacy Policy.

19.3 Review Regularly

We encourage you to review this Privacy Policy periodically to stay informed about our data practices.

20. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Telos Technologies LLC
(d/b/a ProAgentMe)

• Email: support@proagentme.com (include "Privacy" in the subject for privacy or GDPR-related requests)
• Mail: Telos Technologies LLC, Berryville, Virginia, USA

We will respond to your inquiry within 30 days (or earlier where required by applicable law).

Summary of Key Points

By using ProAgentMe, you acknowledge that you have read and understood this Privacy Policy.

© 2026 Telos Technologies LLC. All rights reserved.
ProAgentMe is a trademark of Telos Technologies LLC.