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Privacy Policy

ICT Holdings, LLC | ICT+

Draft for review · Not yet in effect

ICT Holdings, LLC (“ICT,” “we,” “us,” or “our”) operates ICT+, innerct.com, and related digital educational services.

We recognize that personal formation may involve private observations, decisions, and reflections. This Privacy Policy explains how information is handled when you interact with our services.

1. Information We Collect

Depending on the features you use, ICT may process:

  • Account information: Your name, email address, username, account identifier, and profile information.
  • Formation information: Orientation activity, lesson progress, practice records, written reflections, daily instruments, Stability Window Sheets, accountability records, and submissions.
  • Community information: Content you voluntarily publish in Circles, along with interactions associated with your posts.
  • Purchase information: Transaction references, purchases, payment status, purchased-resource entitlements, and information needed to provide access through My Bundle.
  • Communications: Inquiries, support requests, and communications relating to your account or formation activity.
  • Technical information: Information necessary to operate, secure, troubleshoot, and maintain the service, which may include device, browser, session, and activity information.

Some formation records may contain sensitive personal information that you choose to provide. Please avoid including unnecessary medical, financial, identifying, or third-party confidential information.

2. How We Use Information

We process information as needed to:

  • Create and maintain ICT+ accounts.
  • Provide orientation, lessons, and formation instruments.
  • Save records and display progress.
  • Operate Circles and other available features.
  • Process purchases and grant access to purchased materials.
  • Deliver account-related and formation-related communications.
  • Respond to inquiries and support requests.
  • Prevent misuse, investigate security incidents, and maintain the service.
  • Meet applicable legal, accounting, and recordkeeping obligations.

We will disclose any additional purposes that require separate notice or consent.

3. Private Formation Records

Formation instruments and personal reflections are intended to support honest self-observation.

Draft instruments and private formation records are not intended for automatic publication to Circles.

Authorized submission to an Observer Portal, when available, is a separate action from saving a draft or completing an instrument.

Submitted records may be retained as institutional records according to the applicable recordkeeping policy.

Private records should only be accessible to the account holder and authorized personnel or service providers with a legitimate operational purpose, subject to the actual permissions implemented in ICT+.

4. Circles and Shared Content

Circles is a community participation feature.

Information you choose to post may be visible to other users or audiences permitted by the feature’s visibility settings.

Do not publish another person’s private information without authorization.

Deleting a community post may not remove copies already seen, saved, or lawfully retained by others.

5. Purchases and Payment Processing

ICT uses Stripe for applicable payment processing.

Stripe may collect payment information directly when you complete a transaction. ICT may receive transaction information needed to confirm payment, maintain financial records, and grant purchased-resource access.

Purchased resources are made available through My Bundle according to the applicable purchase terms.

Payment processing is also subject to Stripe’s own privacy practices.

6. Service Providers and Information Sharing

ICT uses external technology providers to support its digital services. Depending on the active workflow, these may include:

  • Base44 for application infrastructure and functionality.
  • Stripe for payment processing.
  • Zapier for authorized workflow automation.
  • Google email services for applicable communications.

Information may be processed by these providers to the extent required for their services.

ICT may also disclose information when legally required or reasonably necessary to protect users, enforce applicable terms, or address security incidents.

7. Data Retention

ICT retains information for operational, educational, security, financial, or legal purposes only for periods justified by those purposes and applicable obligations.

Draft instruments, submitted formation records, deleted items, community content, account information, and purchase records may have different retention requirements.

8. Your Privacy Choices

You may contact ICT to request information about personal data associated with your account, correct inaccurate information, or request deletion.

Additional rights, including access, portability, or opt-out rights, may apply under your jurisdiction’s laws.

ICT may need to verify your identity before processing a request. Certain information may need to be retained to satisfy legal obligations, resolve disputes, document transactions, or preserve records where legally permitted.

Requests and privacy questions may be directed to: mackenzie@innerct.com

If applicable law provides an appeal right concerning a privacy decision, you may use this contact address to request review.

9. Account and Information Security

ICT aims to use appropriate technical and administrative safeguards to protect account information and formation records.

No digital platform can guarantee absolute security.

Users are responsible for protecting their account credentials and promptly reporting suspected unauthorized access.

11. Changes to This Policy

ICT may update this Privacy Policy to reflect changes in services, information practices, or legal obligations.

The current version and its effective date will be made available through ICT+.

Where legally required, ICT will provide additional notice or obtain consent before implementing materially different information practices.

ICT Holdings, LLC

Middletown, Connecticut

mackenzie@innerct.com

Website: innerct.com

The work is personal.