Privacy Policy

Effective (draft date): September 5, 2026 Operator: Caldwell Soames Inc. (EIN 82-3061873) Service: ORGANO Distribution Partner Pro Recruiting Assistant (“Partner Pro”) Status: DRAFT — for counsel review only File: Partner_Pro_Privacy_Policy_DRAFT_20260905.html

1. Who Is the Controller

For personal information processed to provide Partner Pro, the controller is Caldwell Soames Inc., EIN 82-3061873, 1700 Post Oak Blvd Ste 600, Houston, TX 77056. Privacy: [email protected]. Legal: [email protected].

Organo corporate systems remain governed by Organo’s own policies. This Policy covers Partner Pro only. Partner Pro is not Organo Back Office / not Organo SSO; seats are keyed to Organo DP IDs (human-verified with storefront URL).

2. Scope

Applies to seat holders, private/soft-launch URL visitors, optional SMS users (+1 346 375-7942), and support contacts.

3. Information We Collect

3.1 You provide

3.2 Generated through use

3.3 Payments (when Stripe enabled)

Stripe processes cards; we receive billing metadata only. Month-1 free framing may apply when billing exists.

4. Purposes

5. AI Processing Note

Prompts and drafts may be processed by AI systems/subprocessors. Outputs are tools; humans remain senders. Filters discourage hard-banned claims but are not perfect.

6. Sharing

We do not sell personal data. We may share with subprocessors, ops staff, advisors, authorities as required, and successors in corporate transactions — under purpose limits.

7. Retention

Retained as needed for Service, compliance, legal, and security; SMS consent logs may be kept longer for defensibility. Schedule to be finalized with counsel.

8. Security

Administrative, technical, and organizational measures; no system is 100% secure.

9. Rights & Choices

Access, correction, deletion, restriction, portability, and consent withdrawal (including STOP) where applicable. Contact [email protected]. Verification required.

10. Cookies

Essential cookies/storage for auth and security; analytics/non-essential to be noticed if enabled.

11. Children

Adults / eligible DPs only. No knowing collection under 16 (or higher where required).

12. International

U.S.-based processing; safeguards for cross-border transfers to be finalized with counsel.

13. California / U.S. State Privacy (High Level)

Know/access/delete/correct/opt-out rights where applicable. We do not sell personal information. [email protected]

14. GDPR-Style (High Level)

Bases may include contract, legitimate interests, consent, legal obligation. Supervisory authority complaints available where applicable.

15. Optional SMS

Not required for core use. From +1 346 375-7942; START opt-in; STOP opt-out. See SMS Terms.

16. Changes & Contact

Material changes noticed via Service/email when appropriate. Contact: Caldwell Soames Inc., 1700 Post Oak Blvd Ste 600, Houston, TX 77056; [email protected]; [email protected].

Contact addresses may be updated by Paul Caldwell / Melia operations; placeholders [email protected] and [email protected] are used until confirmed.