A division of PrimeIQ, Inc.

Privacy & Cookie Policy

Effective Date: June 1, 2026

This Privacy Policy governs the manner in which Concerto Labs, a division of PrimeIQ, Inc. ("Concerto Labs," "PrimeIQ," "we," or "us"), collects, uses, maintains, and discloses information collected from users (a "user," "you," or "your") through our website at concertolabs.ai and any other online services that link to this Privacy Policy (collectively, the "Online Resources").

By using the Online Resources, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Online Resources.

1. What Information Do We Collect?

Personal Information

"Personal Information" is information you provide to us that can be used to identify you. This may include:

• Your name, email address, phone number, and mailing address when you register for a course, coaching engagement, or membership.
• Billing address and payment details (processed through our secure third-party payment processor — we do not store full credit card numbers).
• Professional information such as your job title, company name, and industry, provided during registration or profile setup.
• Coaching session context — information you voluntarily share during or in preparation for 1:1 coaching sessions, such as goals, work challenges, and AI maturity assessments.
• Communications — your email address and the content of any messages you send to us.

Aggregate and Usage Information

"Aggregate Information" is data that is not tied to any individual user. We may automatically collect:

• Browser type, operating system, and device information.
• Internet or mobile service provider information.
• Pages visited, time spent on pages, links clicked, and other site-activity data.
• IP address and approximate geographic location derived from IP.
• Referral source (the site you visited before arriving at ours).

Cookies and Tracking Technologies

A cookie is a small data file placed on your device when you visit our Online Resources. We use cookies and similar tracking technologies (such as pixel tags and web beacons) to maintain your session, analyze site traffic, and measure marketing effectiveness. Most browsers allow you to disable or remove cookies through their settings. See our Cookie Policy for full details.

2. How Do We Use the Information We Collect?

Personal Information

We use Personal Information only for the purposes for which it was provided. Specifically, we use it to:

• Deliver and administer coaching sessions, courses, and membership services.
• Process payments and send transactional confirmations.
• Respond to your inquiries and provide customer support.
• Send administrative communications (e.g., session reminders, account notices).
• Send marketing communications where you have opted in — you may opt out at any time.
• Personalize your experience on the Online Resources.

We will not sell your Personal Information or use it for any purpose beyond what is described in this Policy, except with your explicit consent.

Aggregate Information

We use Aggregate Information to understand how users interact with our Online Resources, to improve our services, to identify usage trends, and to measure the performance of our marketing efforts. No personally identifiable information is available or used in this process.

Coaching Session Data

Information shared during coaching sessions is treated as confidential and is used solely to deliver and improve your coaching experience. Concerto Labs does not use the content of individual coaching sessions to train AI models, share session content with third parties, or disclose it to other clients. Aggregate, anonymized insights may be used to improve our curriculum and assessment tools.

3. When Do We Share Information With Third Parties?

Service Providers

We may engage third-party service providers to perform services on our behalf, including website hosting, payment processing, email delivery, scheduling, and analytics. We provide these providers with access to your information only to the extent necessary for them to perform those services. They are not authorized to retain, share, or use your Personal Information for any other purpose.

Analytics

We use Google Analytics to help us understand how users interact with our Online Resources. You can learn more about how Google uses your data at google.com/policies/privacy/partners.

Affiliates

As Concerto Labs is a division of PrimeIQ, Inc., we may share your information with PrimeIQ and its other divisions or subsidiaries for the purpose of providing and improving our services. Any sharing within the PrimeIQ family of products is governed by this Privacy Policy.

Legal Compliance

We may disclose your Personal Information to third parties when required to: (i) comply with applicable law, regulation, subpoena, or governmental request; (ii) enforce our policies or agreements; (iii) protect the rights, safety, or property of Concerto Labs, PrimeIQ, or any third party; or (iv) detect, prevent, or address fraud, security, or technical issues.

Business Transitions

We reserve the right to disclose and transfer all user information: (a) to a subsequent owner, co-owner, or operator of the Online Resources; or (b) in connection with a merger, acquisition, consolidation, restructuring, or sale of substantially all of PrimeIQ's interests and/or assets, including during any due diligence process.

4. How Long Do We Retain Your Data?

We retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and processed — including legal, regulatory, accounting, or reporting requirements. When your data is no longer needed, we will either delete it or anonymize it so it can no longer be associated with you.

5. How Do I Update My Information or Communication Preferences?

You may request updates or corrections to your Personal Information by contacting us at hello@concertolabs.ai. We will make good-faith efforts to apply requested changes to our active databases as soon as reasonably practicable.

You may opt out of marketing communications at any time by using the unsubscribe link in any email we send or by contacting us directly. We reserve the right to send administrative and service-related communications regardless of your marketing preferences.

6. Children's Privacy

The Online Resources are intended for adults and are not designed to attract users under the age of 16. We do not knowingly collect Personal Information from anyone younger than sixteen. If we discover that we have inadvertently collected information from a user under sixteen, we will promptly delete it. If you are a parent or guardian and believe your child has provided us with Personal Information, please contact us at hello@concertolabs.ai.

7. Do Not Track Signals

We do not honor "Do Not Track" signals from web browsers. We do not authorize the collection of personally identifiable information from our users for third-party advertising purposes through advertising technologies deployed on our Online Resources.

8. Your Privacy Rights

If you are a resident of the European Union, the United Kingdom, or the State of California, you have the following rights regarding your Personal Information:

• Right to Access: Request a copy of all Personal Information we hold about you, delivered in electronic format.
• Right to Correction: Request that we correct inaccurate Personal Information.
• Right to Deletion: Request that we delete some or all Personal Information about you, subject to applicable legal retention requirements.
• Right to Restriction: Request that we cease processing your Personal Information, with respect to future processing only.
• Right to Non-Discrimination: Exercise any of the rights above without fear of discrimination or retaliation.

To exercise any of these rights, please contact us at hello@concertolabs.ai. If you are a resident of the EU and believe we have misused your personal data, you have the right to lodge a complaint with your national Data Protection Authority.

9. Users in the European Union

For users within the European Union, we transfer data from the EU to data centers located in the United States for processing, pursuant to your consent. Such processing is performed in accordance with the GDPR, including the application of required safeguards. We rely on applicable transfer mechanisms (such as Standard Contractual Clauses) where required.

10. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your Personal Information against unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet is completely secure, and we cannot guarantee absolute security.

11. Changes to This Policy

We reserve the right to update or change this Privacy Policy at any time. Changes are effective immediately upon posting. Your continued use of the Online Resources following the posting of changes constitutes your acceptance of the revised Policy. The effective date at the top of this Policy will be updated with each revision.

12. Governing Law

PrimeIQ, Inc. is incorporated in the State of Delaware and headquartered in California. This Privacy Policy is governed by and construed in accordance with the laws of the State of Delaware, USA, without regard to its conflict-of-law principles.

13. Questions or Concerns

Concerto Labs — Privacy Team
A division of PrimeIQ, Inc.
hello@concertolabs.ai

Concerto Labs is a division of PrimeIQ, Inc. · Effective June 1, 2026