Effective Date: June 1, 2025

APM Labs LLC, doing business as Shapeshifter (hereinafter referred to as

"Shapeshifter," "we," "us," or "our"), a limited liability company duly organized and

existing under the laws of the State of Delaware, with its principal place of business at

2093 Philadelphia Pike #4840, Claymont, Delaware 19703, United States, is committed

to safeguarding the privacy and security of personal data processed through its

proprietary software-as-a-service (SaaS) platform, powered by artificial intelligence,

including associated websites, mobile applications, tools, and support services

(collectively, the "Services"). This Privacy Policy (hereinafter referred to as the "Policy")

governs the collection, use, processing, storage, and disclosure of personal data from

all users of the Services, including career coaches ("Coaches"), their clients ("Clients"),

and other end-users (collectively, "End-users"). By accessing or using the Services, you

acknowledge and agree to the practices described in this Policy.

Article 1: Definitions

1.1 Defined Terms. For the purposes of this Policy, the following terms shall have the

meanings ascribed to them below unless otherwise expressly provided:

1.1.1 Services. The term "Services" shall mean Shapeshifter’s proprietary SaaS

platform, powered by artificial intelligence, including but not limited to associated

websites, mobile applications, tools, features, integrations, content, data processing

capabilities, and support services, designed exclusively for career coaching

management and related functionalities.

1.1.2 Coach. The term "Coach" shall mean a paying subscriber, whether an individual

or entity, who licenses the Services for the purpose of delivering career coaching

services to their Clients.

1.1.3 Client. The term "Client" shall mean an individual or entity receiving career

coaching services from a Coach through the Services.1.1.4 End-user. The term "End-user" shall mean any individual or entity, including a

Coach or Client, who interacts with or accesses the Services, whether directly or

indirectly, in connection with the delivery or receipt of career coaching services.

1.1.5 Personal Data. The term "Personal Data" shall mean any information relating to

an identified or identifiable natural person, as defined under applicable data protection

laws, including but not limited to the General Data Protection Regulation (GDPR) and

the California Consumer Privacy Act (CCPA), submitted, uploaded, or processed

through the Services.

1.1.6 Third-Party Data. The term "Third-Party Data" shall mean any data, information,

or content sourced from third-party websites, platforms, or services (e.g., social media

career-based platforms, job aggregators, company websites) through direct scraping,

application programming interfaces (APIs), or third-party data providers.

1.1.7 Data Controller. The term "Data Controller" shall mean the entity that determines

the purposes and means of processing Personal Data, as defined under applicable data

protection laws.

1.1.8 Data Processor. The term "Data Processor" shall mean the entity that processes

Personal Data on behalf of the Data Controller, as defined under applicable data

protection laws.

Article 2: Collection of Information

2.1 Categories of Information Collected. We collect the following categories of

information through the Services:

2.1.1 Personal Data Provided by Users. Coaches and Clients may submit Personal

Data, including but not limited to names, email addresses, telephone numbers,

resumes, job preferences, educational background, professional experience, or other

career-related information, through the Services.

2.1.2 Third-Party Data. The Services may incorporate Third-Party Data sourced from

external platforms, such as social media career-based platforms, job aggregators, orcompany websites, via APIs, third-party providers, or other lawful means, to enhance

career coaching functionalities.

2.1.3 Usage Data. We automatically collect information about End-users’ interactions

with the Services, including but not limited to IP addresses, device identifiers, browser

types, operating systems, access times, and usage patterns, to monitor and improve the

performance and security of the Services.

2.1.4 AI-Processed Data. The Services utilize artificial intelligence technologies to

process Personal Data and Third-Party Data, generating insights, recommendations, or

analytics for career coaching purposes.

2.2 Methods of Collection. Personal Data and Third-Party Data are collected through

direct submissions by Coaches and Clients, automated data collection tools (e.g.,

cookies, web beacons), integrations with third-party platforms, or lawful data acquisition

from third-party providers.

Article 3: Use of Information

3.1 Purposes of Processing. We process the collected information for the following

purposes:

3.1.1 Service Delivery. To provide, maintain, and enhance the Services, including

delivering career coaching tools, features, and support to Coaches and Clients.

3.1.2 AI-Driven Processing. To utilize artificial intelligence technologies for analyzing

Personal Data and Third-Party Data, generating career insights, job recommendations,

resume optimization, and other coaching-related analytics.

3.1.3 Communication. To communicate with End-users, including responding to

inquiries, providing technical support, and sending service-related notifications or

updates.

3.1.4 Legal Compliance. To comply with applicable local, state, national, and

international laws, regulations, and legal processes, including but not limited to GDPR

and CCPA.3.1.5 Analytics and Improvement. To monitor, analyze, and improve the functionality,

performance, and security of the Services through aggregated and anonymized usage

data.

Article 4: Data Sharing and Disclosure

4.1 Authorized Sharing. We may share Personal Data and other information as

follows:

4.1.1 With Coaches. Personal Data provided by Clients is shared with the respective

Coach providing career coaching services, as authorized by the Client’s explicit

consent.

4.1.2 With Service Providers. We engage trusted third-party service providers (e.g.,

cloud hosting, analytics, payment processors) to perform functions necessary for the

operation of the Services. Such providers are contractually bound to maintain

confidentiality and comply with data protection obligations.

4.1.3 Legal and Regulatory Requirements. We may disclose Personal Data to comply

with applicable laws, regulations, court orders, or legal processes, or to protect the

rights, property, or safety of Shapeshifter, its End-users, or third parties.

4.1.4 Business Transfers. In the event of a merger, acquisition, reorganization, or sale

of all or substantially all of Shapeshifter’s assets, Personal Data may be transferred to a

successor entity, subject to the terms of this Policy.

4.2 No Sale of Personal Data. Shapeshifter does not sell, rent, or lease Personal Data

to third parties for monetary consideration, as defined under applicable data protection

laws.

Article 5: Data Protection Rights

5.1 Rights Under Applicable Laws. Depending on your jurisdiction, you may have the

following rights with respect to your Personal Data, subject to applicable data protection

laws (e.g., GDPR, CCPA):5.1.1 Right to Access. You may request confirmation of whether your Personal Data is

being processed and obtain a copy of such data.

5.1.2 Right to Rectification. You may request correction of inaccurate or incomplete

Personal Data.

5.1.3 Right to Erasure. You may request deletion of your Personal Data, subject to

exceptions for legal obligations or other permitted purposes.

5.1.4 Right to Restrict Processing. You may request restriction of processing of your

Personal Data under certain circumstances.

5.1.5 Right to Data Portability. You may request a copy of your Personal Data in a

structured, commonly used, and machine-readable format.

5.1.6 Right to Object. You may object to certain processing activities, including those

based on legitimate interests, where applicable.

5.1.7 Right to Opt-Out. You may opt out of certain data processing activities, such as

targeted advertising, where applicable under laws like the CCPA.

5.2 Exercising Your Rights. To exercise any of the above rights, please contact us at

team@apm-labs.com. Coaches, as Data Controllers, are responsible for handling Client

data rights requests and ensuring compliance with applicable laws. Shapeshifter, as a

Data Processor, will provide reasonable assistance to Coaches in fulfilling such

requests.

Article 6: Data Security

6.1 Security Measures. Shapeshifter implements and maintains industry-standard

technical and organizational measures to protect Personal Data against unauthorized

access, loss, alteration, or disclosure, including encryption, access controls, and regular

security assessments.

6.2 Limitations. Notwithstanding the foregoing, no security measures are infallible.

Shapeshifter disclaims liability for data breaches, losses, or damages resulting fromexternal cyberattacks, unauthorized access, or other incidents beyond our reasonable

control, provided we have complied with our obligations under applicable laws.

Article 7: Data Retention

7.1 Retention Period. Personal Data is retained only for the duration necessary to fulfill

the purposes outlined in Article 3 or to comply with legal, regulatory, or contractual

obligations. Coaches, as Data Controllers, determine the retention period for Client

Personal Data processed through the Services.

7.2 Data Deletion. Upon termination of a Coach’s account or a Client’s request for

deletion, Shapeshifter will delete or anonymize Personal Data in accordance with

applicable laws, unless retention is required for legal purposes (e.g., tax or audit

obligations).

Article 8: International Data Transfers

8.1 Cross-Border Transfers. Personal Data collected from End-users outside the

United States may be transferred to and processed in the United States, where our

servers are located. Shapeshifter ensures that such transfers comply with applicable

U.S. data protection laws. For users in jurisdictions with specific data protection

requirements, Shapeshifter employs lawful transfer mechanisms as required by those

jurisdictions.

8.2 Coach Responsibilities. Coaches are responsible for ensuring that any

cross-border transfers of Client Personal Data comply with applicable data protection

laws, including obtaining necessary consents.

Article 9: Third-Party Data

9.1 Use of Third-Party Data. The Services may incorporate Third-Party Data sourced

from external platforms, such as social media career-based platforms or job boards, to

enhance career coaching functionalities. Coaches are solely responsible for ensuring

that their use of Third-Party Data complies with all applicable laws, regulations, and

third-party terms of service or policies.9.2 Disclaimer. Shapeshifter disclaims all liability for claims, damages, or losses arising

from the use of Third-Party Data by Coaches, including but not limited to claims for

intellectual property infringement, data privacy violations, or breach of third-party terms

of service.

Article 10: Artificial Intelligence Processing

10.1 AI Utilization. The Services employ artificial intelligence technologies to process

Personal Data and Third-Party Data, generating career coaching insights,

recommendations, and analytics. Such processing may include resume analysis, job

matching, or other automated decision-making processes.

10.2 Coach Obligations. Coaches represent and warrant that they have obtained

explicit, documented, and legally sufficient consents from Clients for AI-driven

processing of their Personal Data, as required under the Terms and Conditions of Use.

Shapeshifter disclaims liability for any claims arising from such processing, provided we

act as a Data Processor under the Coach’s instructions.

Article 11: Modifications to This Policy

11.1 Right to Modify. Shapeshifter reserves the right to modify, amend, or update this

Policy at its sole discretion to reflect changes in our practices or applicable laws,

provided such modifications do not materially diminish your rights without your consent.

11.2 Notification of Changes. We will provide notice of material changes to this Policy

via email or in-app notifications at least thirty (30) days prior to their effective date. Your

continued use of the Services after the effective date of any modifications constitutes

your acceptance of the updated Policy.

Article 12: Contact Information

12.1 Contact Details. For any questions, requests, or concerns regarding this Policy,

please contact:

APM Labs LLC (dba Shapeshifter)

2093 Philadelphia Pike #4840Claymont, Delaware 19703

Email: team@apm-labs.com