Legal

Privacy Notice

SJA TD Holdings LLC d/b/a Unblinded and Actualized Intelligence LLC d/b/a ACTi

Last Updated: June 3, 2026

1. Introduction

We are Actualized Intelligence, LLC (“ACTi”) and SJA TD Holdings LLC (“Unblinded”) – two separate entities that collaborate on technology-enabled coaching, education, and AI-powered solutions.

We care about protecting your information and using it responsibly. This Privacy Notice explains what data we collect, how we use it, and the choices you have.

We provide coaching, education, technology, and AI-powered solutions that help individuals and organizations grow. These services include our websites, digital platforms, mobile apps, software, and AI-powered conversational agents (“ACTi Beings”) (together, the “Services”). Our Services are primarily designed for business-to-business (B2B) use, though individuals may interact with them directly through our websites or through organizations that use our platform.

This Notice applies when you:

  • Visit our websites (unblindedmastery.com or acti.ai)
  • Use our apps or other digital tools
  • Interact with us directly (for example, by email, chat, or events)
  • Engage with a brand or organization that uses our Services

This Privacy Notice should be read together with our Terms of Service.

2. How We Work Together

Unblinded and ACTi are separate companies with shared leadership and technology. Each manages its own operations and data.

  • Independent use: When each company uses your information for its own business, we act as separate “data controllers.”
  • Shared programs: When we work together, like co-hosted events, we act as joint controllers and coordinate privacy responsibilities.
  • Service delivery: Sometimes ACTi processes data for Unblinded or its clients as a data processor, under strict contractual rules.

This structure helps us serve you efficiently while maintaining accountability and privacy protection.

3. What We Collect

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

Information You Provide

  • Contact details (like name, email, phone number)
  • Professional information (company, title)
  • Messages, feedback, or content you share with us
  • Event or registration details
  • Contact and registration forms: When you submit a contact form, we collect the fields you complete, which typically include name, email address, subject, and message content. Event registrations may collect additional details such as phone number, company name, and role.
  • Conversational content: When you interact with an ACTi Being via text or voice, we process your inputs to generate real-time responses. For voice interactions, audio is processed by a third-party voice technology provider to produce the Being’s spoken response. We may retain conversation transcripts in de-identified or pseudonymized form to improve our AI systems, subject to the controls described in Section 15.
  • Input content: Documents, prompts, contextual information, and other materials you or your organization submit to our platform for AI-assisted processing. This includes, but is not limited to:
    • Text prompts, queries, and instructions directed to AI-powered features
    • Uploaded documents, files, presentations, or reference materials
    • Contextual data provided to inform, customize, or direct AI responses (such as background information, organizational data, coaching frameworks, or participant profiles)
    • Structured inputs submitted through platform workflows or integrations

Input content (such as uploaded documents and reference materials) is retained for the duration of the service relationship or as directed by the Customer, and deleted or returned upon termination of services unless retention is required by law.

Information from Brands and Customers

If you engage with a company that uses our Services, that company (our “Customer”) may share certain data with us—like transcripts, recordings, or interaction details. In those cases, we process the data only on that Customer’s instructions and under contract.

Information We Collect Automatically

When you visit our websites or apps, we collect:

  • Browser and device details
  • IP address and location (approximate)
  • Usage data such as pages visited or features used
  • Cookies or similar technologies (see Section 7)

We may also receive limited information from partners or publicly available sources where permitted by law.

4. How We Use Your Information

We use your information to deliver our Services, operate securely, and continuously improve your experience.

We Use Information To:

  • Provide and maintain our Services
  • Support, troubleshoot, and respond to your requests
  • Improve performance, features, and usability
  • Communicate updates, events, and opportunities
  • Protect against fraud, misuse, and security threats
  • Comply with legal obligations

Customer Responsibilities. If you use our Services as a business or Brand, you are responsible for ensuring that:

  • You have the right to share data with us,
  • You manage your users’ permissions responsibly, and
  • You inform your users if AI-enabled features are involved.

We don’t sell your information. We may use aggregated, de-identified data to understand trends or improve how our technology works.

5. Legal Basis for Processing

Depending on your location, we process personal data under one or more lawful bases:

  • Contract: To provide Services you’ve requested.
  • Consent: When you’ve opted in (for example, to marketing or cookies).
  • Legal obligation: To comply with applicable laws.
  • Legitimate interests: To improve our products and secure our systems, balanced against your rights.

You can withdraw consent at any time by contacting us.

6. Retention

We keep your personal information only as long as needed for the purposes described here or as required by law. Interaction and analytics data used to improve our Services are typically de-identified or deleted within 13 months of collection.

7. Cookies and Similar Technology

We use cookies and similar tools to make our Services work better. We use privacy-focused analytics for website performance and usage metrics, which collect anonymized page views, referrers, and web performance data. We do not use cross-site tracking cookies on our websites. Advertising or targeting cookies, if any, are loaded only with your consent.

Types of cookies we use:

  • Essential cookies: Help the site function properly.
  • Functional cookies: Remember your preferences.
  • Analytics cookies: Help us understand usage and improve performance.
  • Advertising cookies: Show relevant content (with consent).

You can manage your cookie settings in our cookie banner or browser preferences. We also honor valid Global Privacy Control (GPC) signals where required by law.

8. Sharing Information

We share information only when necessary to operate our Services or comply with the law.

We may share information with:

  • Service providers who help us operate our Services, including:
    • AI language model providers that process text inputs for AI features
    • Voice technology providers that process voice interactions with ACTi Beings
    • Cloud hosting, database, and authentication providers
    • Website hosting and analytics providers

Each provider operates under contractual obligations that prohibit them from using your data for their own purposes, including training their general AI models. A complete list of our sub-processors is available upon request.

  • Within our corporate group (Unblinded and ACTi) for operational support, governed by our Intercompany Data Processing and Transfer Agreement
  • If required by law, regulation, or legal process, or to protect rights and safety
  • In connection with a merger, acquisition, sale, or reorganization, with equivalent privacy protections maintained
  • As de-identified or aggregated data for analysis and product improvement

We never sell or trade your personal information for marketing purposes.

9. Your Choices and Rights

Depending on where you live, you may have rights to:

  • Access or receive a copy of your data
  • Correct inaccurate information
  • Request deletion or restriction of processing
  • Object to certain uses
  • Withdraw consent
  • Request data portability

To exercise these rights, contact: ACTi: info@acti.ai. We’ll respond within the time required by law. You can also contact your local data protection authority if you believe we haven’t addressed your concern.

Opt out of model and product improvement. You may opt out of having your interaction data — including your conversations with our ACTi Beings — used for model improvement or product development by emailing info@acti.ai.

We do not sell or share your personal information as those terms are defined under the California Consumer Privacy Act. If this changes, we will provide a “Do Not Sell or Share My Personal Information” link on our websites.

10. Security

We take security seriously. We use administrative, technical, and physical safeguards such as encryption, access controls, network segmentation, and continuous monitoring to protect your information.

Our systems follow recognized frameworks like ISO 27001 and the NIST Cybersecurity Framework. We maintain separate data environments for Unblinded and ACTi, with limited cross-access.

If a security incident occurs, we’ll take prompt action and notify affected parties as required by law.

11. Mobile and Messaging

When you use our mobile apps or mobile-optimized websites, we may collect limited device data to improve performance. Some features require device permissions. For example, voice interactions with ACTi Beings require microphone access, which your browser or device will prompt you to grant. You can use our websites and text-based features without enabling microphone access. You can revoke microphone or camera permissions at any time in your browser or device settings.

If you receive SMS messages from us, you can opt out by following the instructions in the message or emailing us directly.

12. Communities and Forums

Our online communities and discussion spaces are public. Anything you post may be seen or shared by others. Please avoid sharing personal or sensitive information in public areas.

We may moderate or remove posts that violate our terms or applicable law. Individuals under 18 should not post personal information publicly.

13. International Data Transfers

We operate globally. When data moves across borders, we use recognized safeguards such as Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum (IDTA), or other lawful mechanisms.

Transfers between Unblinded and ACTi are covered by an intercompany data transfer agreement ensuring equivalent protection. If we participate in a formal framework like the EU-U.S. Data Privacy Framework, we’ll post details on our websites.

14. Children

Our Services are not directed to children. We don’t knowingly collect personal information from individuals under 13 in the United States, under 16 in the EU/UK, or under the applicable minimum age in other jurisdictions. If you believe a child has provided us data, please contact us so we can delete it promptly.

California residents under 18 may request removal of public posts as allowed by law.

15. AI and Ethical Use

We use AI and automation to make our tools more effective — but always responsibly.

We’re committed to:

  • Fairness and non-discrimination: Testing for bias and promoting inclusive design.
  • Transparency: Being clear about when and how AI is used.
  • Human oversight: People remain accountable for key decisions.
  • Data minimization: Using only the data needed for our AI features.
  • Vendor governance: Our AI technology partners are contractually prohibited from using your data to train their own general models.

How AI works in our Services

ACTi Beings use large language models to generate conversational responses. Voice responses are synthesized by a third-party voice technology provider. Your conversation inputs are processed in real time and are not used by these providers to train their general-purpose AI models — we maintain contractual and technical controls to ensure this. We may use de-identified conversation data to improve our own AI features, subject to your right to opt out described in Your Choices and Rights (Section 9).

We may use de-identified or aggregated data to improve our algorithms.

Any use of conversation data to improve or develop ACTi’s products or services is subject to the opt-out right described in Your Choices and Rights (Section 9).

Opt out: You can opt out of having your interaction data used for model improvement by contacting: info@acti.ai.

We follow evolving standards including the EU AI Act and NIST AI Risk Management Framework to ensure our AI systems remain ethical, secure, and accountable.

16. Updates to This Notice

We’ll notify you of significant changes through our websites or by other appropriate means. Material changes will be highlighted at the top of the relevant privacy page for at least thirty (30) days before taking effect, except where immediate changes are required by law.

17. Contact Us

We welcome your questions and feedback.

Privacy inquiries: ACTi: info@acti.ai

General inquiries: ACTi: info@acti.ai

Supervisory authorities: If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with your local supervisory authority. A list of EEA supervisory authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you are in Australia, you can also contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

We take your privacy seriously, we use AI responsibly, and we’re committed to earning your trust every day.

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