Privacy Policy

Effective date: March 31, 2026

1. Introduction

1.1. This Privacy Policy explains how CARTER & CUSTER LLC ("Company", "we", "us", or "our") collects, uses, shares, and protects information in connection with your use of the Jim Carter III AI service, including the website located at https://ai.jimcarter.me and related applications on iOS and Android (collectively, the "Service").

1.2. This Policy applies to all users of the Service and should be read together with our Terms of Service.

2. Data Controller and Contact

2.1. CARTER & CUSTER LLC is the controller of your personal data where applicable law recognizes such a concept.

2.2. If you have questions or requests regarding this Policy or our data practices, you can contact us at:

support@jimcarter.me

15766 LA FORGE ST #118 WHITTIER, CA 90603

3. Information We Collect

We collect the following categories of information, depending on how you use the Service.

3.1. Information you provide directly

Account details such as email address and any optional profile information you choose to provide (for example, name or organization).
Content you submit to us directly (not via Delphi), such as support requests, feedback forms, or onboarding information.
Communications you send us, including support tickets and survey responses.

3.2. Information collected automatically

Device and usage data, such as IP address, browser type, device identifiers, operating system, app version, and pages or screens you view.
Log data about your interactions with our website or apps, such as timestamps, feature usage, and performance metrics.
Approximate location information derived from your IP address (where permitted by law).

3.3. Cookies and similar technologies

We and our service providers may use cookies, local storage, and similar technologies to remember your settings, maintain your session, and understand how you use the Service. You can control cookies through browser settings, though disabling certain cookies may affect some functionality.

3.4. Payment and transaction information

If you purchase Paid Services via our website or hosted checkout pages, third-party payment processors, including Stripe and Spiffy, collect and process your payment information.
We may receive limited information about your transactions (for example, payment status or plan type) for billing, recordkeeping, and support. We do not store your full payment card information.

3.5. Conversation data and technical metadata processed by Delphi

When you interact with the AI chat experience, your prompts, messages, and related metadata are sent to our AI provider, Delphi AI, Inc. ("Delphi"), for processing. Depending on your settings and Delphi's configuration, Delphi may:

Receive and store your text inputs and AI outputs (together, "Conversation Data").
Receive audio of your voice if you use voice features, for transcription and response generation.

CARTER & CUSTER LLC does not maintain a separate full copy of your conversation transcripts for this app. Conversation Data is primarily stored and managed on Delphi's systems.

3.6. Voice and audio data if voice features are enabled

If you choose to use voice features, your microphone audio is captured and sent to Delphi so it can perform speech-to-text and generate AI responses. Delphi may retain audio of your voice for a limited period to provide and improve its services, including up to three years from your last interaction, subject to applicable law and Delphi's own policies and terms.

4. How We Use Information

We use the information we collect for the following purposes:

4.1. To provide and operate the Service

Deliver AI-generated responses and related features.
Maintain your account, authentication, and session.
Process payments and manage subscriptions through web checkout providers.

4.2. To improve and personalize the Service

Understand how users interact with the Service to fix bugs, optimize performance, and develop new features.
Personalize certain aspects of the experience (for example, saved preferences), where enabled.

4.3. To communicate with you

Send service-related messages (for example, onboarding, security alerts, and subscription notices).
Respond to support requests and feedback.
Where permitted by law and your preferences, send marketing or product-update communications (you can opt out at any time).

4.4. To secure and protect the Service

Detect, investigate, and prevent fraud, abuse, and security incidents.
Enforce our Terms of Service and other policies.

4.5. To comply with legal obligations

Comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
Maintain appropriate business records.

5. Legal Bases for Processing (EEA/UK/Similar Jurisdictions)

Where required by law (for example, in the European Economic Area or United Kingdom), we rely on the following legal bases:

Contract performance, for processing needed to provide the Service and fulfill our contract with you.
Legitimate interests, for processing such as improving and securing the Service, provided our interests are not overridden by your rights.
Consent, for certain marketing communications, cookie uses, and specific data-sharing scenarios where required by law.
Legal obligations, when we process data to comply with law.

6. Cookies and Tracking Technologies

6.1. We use cookies, local storage, and similar technologies to operate, secure, and improve the Service.

6.2. We do not currently provide a separate cookie preference banner. You can control cookies through your browser settings.

We may share information in the following circumstances:

7.1. Service providers and processors

We engage third parties that process data on our behalf to provide elements of the Service, such as:

Cloud hosting and infrastructure providers.
AI model providers and related tooling (including Delphi).
Email delivery and communication providers.
Analytics, A/B testing, and performance monitoring tools.
Payment and subscription management providers.

These providers are contractually obligated to process data only as instructed by us and to implement appropriate security measures.

7.2. Delphi AI as AI provider

We use Delphi AI, Inc. ("Delphi") to power the conversational experience. When you chat with the AI or, where available, use voice features, text and audio you provide ("Conversation Data") are sent to Delphi so Delphi can generate responses and provide AI functionality.

Key points:

CARTER & CUSTER LLC does not maintain a separate full copy of your conversation transcripts in a dedicated database for this app; Conversation Data is primarily stored in Delphi's systems to maintain context, provide features, and support safety and quality measures.
Delphi processes this information under its own Terms of Use, which describe how Delphi handles user submissions, voice data, billing, and other information (see https://www.delphi.ai/terms).

We do not control Delphi's independent services or policies, but we work with Delphi in ways designed to respect your privacy and comply with applicable rules.

7.3. Business transfers

If we are involved in a merger, acquisition, financing, or sale of all or part of our business, information may be transferred as part of that transaction, subject to confidentiality protections.

7.4. Legal and safety purposes

We may disclose information if we believe in good faith that it is reasonably necessary to:

Comply with any applicable law, regulation, legal process, or governmental request.
Enforce applicable terms or policies.
Protect the rights, property, or safety of us, our users, or the public.

7.5. Aggregated or de-identified information

We may share aggregated or de-identified information that does not reasonably identify you, for purposes such as analytics, research, or industry reporting.

8.1. When you use AI Features, we process your prompts and other inputs to generate AI Output. Depending on configuration and account settings, Delphi may store conversation history to provide context and may log limited data for debugging, safety, and quality assurance.

8.2. If you use voice features, your audio is captured and sent to Delphi to perform speech-to-text and generate AI responses. Delphi may derive technical features from recordings, which may qualify as biometric information under some laws. Delphi states such data is retained only as long as needed to provide services, or for up to three years from your last interaction, unless a longer period is required by law.

8.3. CARTER & CUSTER LLC does not itself create separate biometric templates for users of this app outside Delphi's systems.

9. Data Retention

9.1. We retain account and usage data that we control only as long as reasonably necessary to provide the Service, comply with legal obligations, resolve disputes, and enforce agreements.

For example:

Account information is retained while your account is active and for a limited period afterward as needed for legal, accounting, or security purposes.
Basic logs and analytics data are generally retained for a shorter period needed for security and performance analysis, after which they are aggregated or deleted.

9.2. Delphi may retain Conversation Data and voice recordings in its own systems in accordance with its published terms and privacy notices, including for safety, quality, and operational reasons.

9.3. We may retain certain information longer where required by law or to protect our legal rights (for example, records of your consents).

10. International Data Transfers

10.1. We may process and store information on servers located in countries other than your own.

10.2. Where we transfer personal data from jurisdictions with data transfer restrictions (such as the EEA or UK) to countries without an adequacy decision, we rely on appropriate safeguards, such as standard contractual clauses approved by the European Commission, and implement additional measures where necessary.

11. Security

11.1. We implement technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access.

11.2. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

12. Your Rights and Choices

Your rights depend on your jurisdiction, but may include:

Access and correction: Request access to personal data we hold about you and ask us to correct inaccurate or incomplete information.
Deletion: Request deletion of personal data, subject to certain exceptions (for example, where we are required to retain it by law).
Restriction and objection: Request restriction of certain processing or object to processing based on legitimate interests, where applicable.
Data portability: Request a copy of certain personal data in a structured, commonly used, machine-readable format, and ask us to transmit that data to another controller where technically feasible.
Marketing communications: Opt out of marketing emails by using unsubscribe links or contacting us. You may still receive transactional or service-related messages.
Cookie and tracking choices: Control cookies through browser settings.
Regulator complaints: Where available, lodge a complaint with your local data protection authority.

When you exercise rights with us, we will act on data we control (such as account details, billing records, and certain usage logs). For conversation and voice data primarily stored by Delphi, we will either route your request to Delphi where we have an appropriate mechanism to do so, or explain how you can contact Delphi directly where required by applicable law.

Because Delphi operates its own infrastructure and maintains backups and aggregated data, some information may continue to be retained by Delphi even after we delete data from our own systems, as described in Delphi's own terms.

13. Account Deletion

13.1. To request deletion of your account and associated personal data, contact support@jimcarter.me.

13.2. When you request deletion, we stop using your personal data for active Service purposes and, subject to legal and contractual requirements, delete or anonymize the data we control within reasonable timeframes.

13.3. As noted above, certain Conversation Data or voice data processed and stored by Delphi may continue to be retained by Delphi under its own retention policies, even after we delete data from our systems.

14. Children's Privacy

14.1. The Service is not directed to children under 18, and we do not knowingly collect personal data from children under 18 without legally required consent.

14.2. If you believe a child has provided personal data in violation of this Policy, contact us at support@jimcarter.me so we can investigate and take appropriate action.

15. Changes to This Privacy Policy

15.1. We may update this Privacy Policy from time to time. When we do, we update the effective date and provide additional notice where required by law.

15.2. Continued use of the Service after an updated Policy becomes effective constitutes your acknowledgment of the updated Policy.

16. Contact

If you have questions about this Privacy Policy or want to exercise your privacy rights, contact us at: