Privacy Policy

1. Overview

This Privacy Policy ("Policy") explains how Hodos360 PLLC ("Hodos360," "we," "us," or "our") collects, uses, discloses, and protects personal information when you:

• Visit or interact with our websites and online properties;
• Use our platform and Services (including social media manager, ads manager, blog generation, image/video generation, voice and video agents, and law firm management tools); or
• Communicate or interact with us as a customer, prospective customer, or user.

This Policy applies to personal information we process as a business or controller. It does not apply to information we process solely on behalf of our business customers about their own leads, clients, and users ("Customer Content") where we act as a service provider or processor.

We operate from Puerto Rico and serve customers across the United States. Our practices are intended to align with applicable U.S. federal, Puerto Rico, and certain U.S. state privacy and data protection laws, where those laws apply to our activities.

2. Roles and Responsibilities

When we determine the purposes and means of processing certain personal information (for example, our own website analytics, billing, account management, and direct marketing), we act as a "controller" or "business."

When we process personal information strictly on behalf of our business customers (for example, their imported contact lists, client information, call recordings, transcripts, and campaign data), we act as a "service provider" or "processor" and process that data only in accordance with our customer agreements and their instructions.

If you are an end user (for example, a client or lead) of one of our business customers, please refer to that organization's privacy notice for information about how they handle your personal information. Our customers are responsible for providing necessary privacy notices and obtaining any consents from their end users.

3. Information We Collect

The information we collect depends on how you interact with us and the Services.

3.1 Information You Provide

Account and Profile Information

Name, business name, role or title, email address, phone number, time zone, login credentials, and similar details.

Billing and Payment Information

Billing contact details, billing address, tax identifiers, and payment-related information (payment cards are generally processed by our payment processor on our behalf).

Customer Content

Information, files, and content you upload, connect, or generate using the Services, including:

• Social media posts, ad copy, videos, images, blog posts, landing pages, and other marketing content;
• Lead, prospect, and client information you import or collect (names, contact details, notes, matter or case details, scheduling information, and similar);
• Scripts, prompts, templates, call flows, and agent configurations;
• Any other content you choose to store or process in the Services.

Communications with Us

Information you provide when you contact us, including emails, chats, support tickets, feedback, surveys, and other correspondence.

3.2 Information From Integrations and Third Parties

When you connect Third-Party Platforms to Hodos360, we may receive:

Social and Advertising Platforms

Account identifiers, page or profile information, permissions, campaign and ad performance data (impressions, clicks, conversions, spend, etc.), and content we are authorized to manage or access.

Law Firm / CRM / CMS / Telephony Tools

Contact details, lead and client records, notes, matter or case details, appointment data, and website or CMS information necessary for publishing or syncing data.

Other Partners and Service Providers

Analytics or referral information, such as how you discovered Hodos360, and limited business contact details from third parties.

The data received depends on the specific integration and permissions you grant.

3.3 Voice, Video, and Communication Data

If you use our voice agents, video agents, SMS, or telephony features, we may process:

• Phone numbers, caller IDs, call times, durations, and other call detail records;
• Audio recordings and/or transcripts of calls and voice interactions, if enabled by you;
• Chat transcripts and messages for web or messaging-based agents;
• Outcome data and metrics (for example, "qualified lead," "booked consultation," or other categories you define).

You decide whether and how these features are used and are responsible for obtaining any legally required consent for recording and automated communications.

3.4 Automatically Collected Information

When you use our Site or Services, we and our service providers may automatically collect:

Device and Usage Information

IP address, browser type and version, operating system, device identifiers, language settings, pages viewed, time spent, and similar technical data.

Log Data

Logs of access, usage, errors, configuration changes, and other events within the Services.

Cookies and Similar Technologies

Cookies, pixels, web beacons, and similar technologies used for authentication, functionality, analytics, and—where permitted—marketing.

3.5 Sensitive Information

We do not intentionally seek to collect sensitive personal information (such as health data, financial account numbers, government identifiers, or information about children) through our own operations. Our customers may choose to store or process such data in the Services; they are responsible for ensuring any such use is lawful and appropriately disclosed.

If you believe we have received sensitive information directly from you in error, please contact us so that we can address it.

3.6 Children's Information

The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete it or otherwise comply with applicable law.

4. How We Use Information

We use personal information for the following purposes:

Providing and Operating the Services

• Creating and managing accounts and user profiles;
• Providing, operating, and maintaining the Services and their features;
• Processing transactions and billing.

AI, Automation, and Product Functionality

• Generating content and suggestions based on your prompts and configurations;
• Supporting voice agents, video agents, and automated workflows;
• Improving models and algorithms, where permitted by law and our agreements.

Improving and Securing the Services

• Monitoring performance and usage trends;
• Debugging, troubleshooting, and fixing issues;
• Detecting, preventing, and responding to security incidents, fraud, and abuse.

Customer Support and Communications

• Responding to requests, questions, and support inquiries;
• Sending administrative information such as service announcements, policy updates, and security notices.

Marketing and Business Development

• Sending you information about new features, services, or events where permitted by law;
• Personalizing or tailoring marketing based on how you use the Services (subject to your choices and applicable law).

Legal and Compliance

• Complying with applicable laws, regulations, and legal processes;
• Enforcing our agreements and protecting the rights, property, and safety of Hodos360, our users, and others.

Where required by law, we rely on specific legal bases (for example, performance of a contract, legitimate interests, consent, or compliance with legal obligations). If you are located in a jurisdiction requiring additional detail on legal bases, you may contact us for more information.

5. Cookies and Similar Technologies

We and our service providers use cookies and similar technologies to:

• Authenticate users and maintain sessions;
• Remember preferences and settings;
• Understand how visitors use our Site and Services;
• Support certain marketing and advertising activities, where permitted.

You may manage cookies through your browser settings and, where provided, our cookie or privacy banner. If you disable certain cookies, some functionality of the Services may be limited.

6. How We Share Information

We may share personal information as follows:

Service Providers and Vendors

With third-party companies that provide services to us, such as hosting, infrastructure, analytics, payment processing, communications, AI and telephony service providers, and professional advisors. These providers are contractually obligated to use the information only to provide services to us or on our behalf and to safeguard it appropriately.

Third-Party Platforms You Connect

With social networks, advertising platforms, CRMs, telephony providers, law firm tools, website/CMS systems, or other services that you choose to integrate. We share only the information necessary to enable each integration, and their use of data is governed by their own privacy policies.

Business Customers (as Controller)

If you are an end user of one of our business customers, we share your data with that customer or process it on their behalf. Their privacy notice and agreements with you govern their use of that data.

Affiliates and Corporate Transactions

With our affiliates for purposes consistent with this Policy, or in connection with a merger, acquisition, reorganization, or sale of assets, subject to confidentiality and any applicable legal requirements.

Legal and Safety

When we believe it is necessary to:

• Comply with applicable law, regulation, or legal process;
• Respond to lawful requests or legal authorities;
• Protect the rights, property, or safety of Hodos360, our users, or the public.

Aggregated or De-Identified Information

We may use and share aggregated or de-identified information that does not identify any individual, for research, reporting, or product improvement.

We do not use Customer Content to advertise unrelated third-party services to you or to others. We do not "sell" personal information in the traditional sense. Where state law defines "sale" or "sharing" more broadly (for example, including certain analytics or advertising activities), we will comply with applicable opt-out requirements.

7. International Data Transfers

Because we are based in Puerto Rico and use service providers in the United States and other countries, personal information may be transferred, stored, and processed in jurisdictions that may have different data protection laws than where you live.

We take steps designed to ensure that such transfers comply with applicable law and that personal information receives an appropriate level of protection.

8. Data Security

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

However, no security measure is completely effective. You are responsible for maintaining the security of your account credentials and for securing your own systems and devices. If you believe your interaction with us is no longer secure, please contact us immediately.

If we detect a security incident affecting personal information, we will investigate and, where required by law, notify affected individuals and/or regulators.

9. Data Retention

We retain personal information for as long as reasonably necessary to:

• Provide and support the Services;
• Comply with legal, accounting, or reporting obligations;
• Resolve disputes and enforce our agreements;
• Support legitimate business interests such as security, fraud prevention, and product improvement.

Retention periods vary based on the type of information and the purposes for which we process it. We may anonymize or aggregate data so that it no longer identifies you and retain that data for longer periods.

10. Your Rights and Choices

Your rights depend on your relationship with us and the laws in your place of residence.

10.1 Rights as Our Direct User or Customer

If you are a direct user or customer of Hodos360, you may:

• Access and update certain account information through your account settings;
• Close your account (subject to our legal and contractual obligations);
• Opt out of marketing emails by following the instructions in those emails.

Depending on applicable law, you may also have the right to:

• Request access to personal information we hold about you;
• Request correction of inaccurate personal information;
• Request deletion of personal information;
• Request a copy of certain personal information in a portable format;
• Opt out of certain types of targeted advertising or "sale"/"sharing" of personal information where such concepts apply;
• Limit the use and disclosure of sensitive personal information where applicable.

To exercise these rights, contact us using the contact information in Section 15, clearly describing your request. We may need to verify your identity before responding. Where applicable law provides for it, you may also designate an authorized agent to submit certain requests on your behalf.

10.2 Rights as an End User of Our Customers

If you are an end user (for example, a client or lead of a law firm or other business that uses Hodos360):

• We generally process your information on behalf of that business.
• Requests to access, correct, or delete your information should typically be directed to that business.
• If you send a request to us, we may forward it to the relevant business or instruct you to contact them directly, to the extent we act as their service provider.

11. State- and Territory-Specific Disclosures

Certain U.S. states and territories provide additional rights or disclosures. Examples include:

California Residents

If you are a California resident, you may have rights under the California Consumer Privacy Act (as amended) related to access, deletion, correction, opt-out of certain uses, and non-discrimination. We will process requests in accordance with California law, to the extent it applies.

Other U.S. State Privacy Laws

Residents of other states with comprehensive privacy laws may have similar rights (for example, Colorado, Virginia, Connecticut, Utah, and others as laws are enacted and become applicable). We will honor valid, verifiable requests under those laws, when they apply to our activities.

Puerto Rico

Puerto Rico law imposes obligations on entities handling certain types of personal information, including requirements regarding data security and breach notification. We maintain policies and controls intended to comply with applicable Puerto Rico requirements and will provide notifications as required by Puerto Rico law in the event of a covered data incident.

If you have questions about how this Policy applies in your jurisdiction, please contact us.

12. Law Firm and Professional-Services Data

For law firms and professional-services customers:

• You are responsible for determining how you use Hodos360 with client and matter information, including any confidential or privileged information.
• You must configure the Services (e.g., user access, retention, and integrations) in a manner consistent with your professional and legal obligations.
• You are responsible for providing privacy notices to your clients and leads and obtaining any necessary consents.

We process such data as your service provider and do not independently determine how your client information is used outside the limited purposes described in our agreements and this Policy (for example, providing and securing the Services and complying with law).

13. Third-Party Sites and Services

The Services may link to or integrate with sites and services operated by third parties. We are not responsible for the privacy or security practices of those third parties. We encourage you to review the privacy policies of any third-party services you use.

14. Changes to This Privacy Policy

We may update this Policy from time to time. When we make material changes, we will provide notice, for example by posting the updated Policy within the Services or on our website, or by sending an email. The "Effective date" at the top of this Policy will show the date of the latest revision.

Your continued use of the Services after the effective date of the updated Policy indicates your acceptance of the changes.

15. Contact Us

If you have any questions, requests, or complaints regarding this Privacy Policy or our privacy practices, you may contact us at: