Privacy Policy

eJAmerica.ai — The eJAmerica Business Suite

This Privacy Policy (“Policy”) explains how ANB Global Consulting LLC, doing business as eJAmerica.ai (“eJAmerica,” “we,” “us,” or “our”), collects, uses, stores, discloses, and otherwise processes Personal Data in connection with the eJAmerica.ai website and Services, including eJCRM, eJRekruit, eJBooks, eJTime, eJAsset, eJConnect, eJWorkload, eJSD AI Agent, eJHRMS, and related products. This Policy applies to Clients, Users, and Visitors. Where eJAmerica processes Personal Data on behalf of a Client, the Client remains responsible for that data and eJAmerica acts as a service provider or processor, as applicable.

1. SCOPE and Roles

eJAmerica acts as a controller and, where applicable, a “business” under the CCPA, when determining the purposes and means of processing Personal Data for its own operations, including Account management, billing, marketing, security, analytics, and service improvement. When processing Client Data solely on Client’s behalf and instructions, eJAmerica acts as a processor or service provider, as applicable. Client is responsible for ensuring that its collection and use of Client Data complies with applicable privacy laws, including providing required notices and obtaining any necessary consents or other lawful basis for processing.

2. Personal Data We Collect

2.1 Account and User Information

Name, business email address, phone number, company name, job title, login credentials, account settings, and Subscription details provided during registration or Account administration.

2.2 Client Data, By Product

The eJAmerica.ai Suite spans multiple business functions, and the categories of Client Data submitted depend on which Products Client uses:

1. eJCRM — contact, lead, deal, pipeline, and customer communication data;

2. eJRekruit — candidate names, resumes, application history, interview notes, and recruiter communications;

3. eJHRMS — employee onboarding records, personnel files, performance data, leave records, and, where applicable, payroll-adjacent identifiers such as national identification or tax identification numbers and bank account details necessary to process payroll;

4. eJBooks — invoicing, expense, payment, and financial reporting data, which may include vendor and customer banking details;

5. eJTime — timesheets, attendance records, and project-hour data;

6. eJAsset — device assignments, asset ownership records, and lifecycle history;

7. eJConnect — voice and contact center interaction data, including call recordings and transcripts where enabled by Client;

8. eJWorkload and eJSD AI Agent — system logs, alerts, incident tickets, and operational diagnostic data; and

9. Custom AI Agents — any data Client configures the agent to access or process, as agreed in the applicable scope of work.

Where a Product has its own separately published product-specific privacy policy, that product-specific privacy policy governs data processed specifically through that Product and shall control over this Policy with respect to that Product to the extent of any conflict. This Policy governs all other Products and applies in full to any Product that does not have a separately published product-specific privacy policy.

2.3 Billing and Payment Information

Billing contact details, payment method information (processed by third-party payment processors), tax identification information, invoice history, and transaction records.

2.4 Support and Communications Information

Information submitted through support requests, the contact form at ejamerica.ai/contact, demo bookings, sales inquiries, and other communications with eJAmerica.

2.5 Usage, Device, and Log Information

IP address, browser and device information, pages and features accessed, session activity, system logs, and diagnostic and performance data collected automatically when Users or Visitors access any Product or the website.

2.6 Cookies and Similar Technologies

eJAmerica uses cookies and similar technologies for authentication, security, preferences, analytics, and, where permitted by applicable law, marketing and advertising measurement. Cookie controls are available through browser settings.

2.7 Information from Third Parties

Information received from authentication providers, payment processors, integration partners, analytics providers, marketing data vendors, and publicly available business sources.

3. HOW We Use Personal Data

eJAmerica may use Personal Data to provide, operate, maintain, and support the Services; manage Accounts, Subscriptions, billing, and customer relationships; maintain security and prevent fraud, abuse, and unauthorized access; respond to support and sales inquiries; analyze, develop, improve, and personalize the Services, including through aggregated or de-identified data; send service, administrative, marketing, and product communications, subject to applicable law and opt-out rights; comply with applicable law; enforce our agreements and policies; and protect eJAmerica’s rights, property, and Services.

4. AI Functionality and Custom AI Agents

Products may include AI Functionality, including Custom AI Agents configured for a Client’s use case. Input submitted to AI Functionality, which may include Client Data, may be processed to generate Output and to provide, secure, maintain, and improve the applicable AI Functionality. AI Functionality may use third-party AI providers, and Input may be shared with such providers solely as necessary to provide the applicable functionality. eJAmerica does not authorize such providers to independently use Client Data to train their models outside the scope of providing services to eJAmerica. AI Output may be inaccurate, incomplete, or unsuitable for a particular purpose, and Client and Users are solely responsible for reviewing and validating Output before relying on it, particularly for HR, financial, legal, or operational decisions. eJAmerica may use Client Data to improve the Services only in accordance with applicable agreements and law. eJAmerica will not use Client Data to train general-purpose AI models except as expressly agreed with Client

5. HOW We Disclose Personal Data

eJAmerica may disclose Personal Data to service providers and subprocessors supporting infrastructure, hosting, analytics, payment processing, security, and customer support; eJAmerica’s affiliates; third-party integrations enabled by Client; resellers and channel partners involved in providing the Services; parties involved in a merger, acquisition, financing, reorganization, or sale of assets; and governmental, legal, or regulatory authorities where required by law or reasonably necessary to protect eJAmerica’s rights, property, Services, or the safety of any person. eJAmerica may also disclose aggregated, anonymized, or de-identified information for any lawful purpose.

6. CLIENT Data

Client controls the content and categories of Client Data submitted to the Services and is solely responsible for its accuracy, legality, collection, use, and the notices, consents, permissions, and lawful basis required for its processing. eJAmerica processes Client Data in accordance with Client’s instructions and applicable agreements. Where eJAmerica receives a data subject request relating to Client Data for which Client is the controller, eJAmerica may, at its discretion, refer the requester to Client or respond as required by applicable law. Client shall reasonably cooperate with eJAmerica in responding to such requests and shall be responsible for any resulting obligations or costs attributable to Client’s instructions or use of the Services.

7. SENSITIVE Personal Information

7.1 Permitted Sensitive Information for HR and Payroll Functions

Because certain Products support payroll, tax, and benefits administration, Client may submit government-issued identification and tax numbers, bank and direct-deposit information, and salary, compensation, and benefits information where reasonably necessary for the applicable functionality. Client is solely responsible for ensuring that its collection, disclosure, and use of such information is lawful and that appropriate access controls and permissions are configured within its Account.

7.2 Sensitive Information Not Otherwise Permitted

Except as expressly permitted under Section 7.1 or agreed by eJAmerica in writing, Client shall not submit Sensitive Personal Information, including protected health information, biometric information, criminal history information, or information concerning racial or ethnic origin, religious beliefs, or sexual orientation. eJAmerica does not undertake any obligation to process such information unless expressly agreed in writing. Client assumes all responsibility for any unauthorized submission and any resulting claims, losses, or liabilities arising from such submission.

8. DATA Retention

eJAmerica retains Personal Data for as long as reasonably necessary to provide and secure the Services, fulfill contractual and business purposes, comply with applicable legal and regulatory obligations, resolve disputes, enforce agreements, and protect its rights and property. Different categories of Personal Data may be retained for different periods based on their nature and applicable requirements. Following termination of an Account, Client Data will generally be available for export for thirty (30) days, after which eJAmerica may delete or anonymize it in accordance with its retention practices and applicable law. Data may remain in backups or archival systems for a limited period following deletion and may be retained where necessary for legal, security, fraud-prevention, or compliance purposes.

9. SECURITY

eJAmerica maintains reasonable administrative, technical, and physical safeguards designed to protect Personal Data against unauthorized access, disclosure, alteration, loss, or destruction, including encryption in transit and at rest, access controls, and security monitoring appropriate to the Services and data processed. No security measure or system is completely secure, and eJAmerica does not guarantee that unauthorized access, security incidents, or data loss will never occur.

10. DATA Breach Notification

In the event of a confirmed security incident affecting Personal Data, eJAmerica will notify affected Clients without undue delay and as required by applicable law, providing information reasonably available regarding the nature of the incident, affected data, and mitigation measures. eJAmerica may provide updates as additional information becomes available and will not be required to disclose information that could compromise security, legal obligations, or investigations. Client is solely responsible for determining and making any notifications required to its employees, candidates, customers, regulators, or other affected individuals, unless applicable law expressly requires eJAmerica to make such notification.

11. INTERNATIONAL Data Transfers

eJAmerica operates globally and may transfer, store, access, or process Personal Data in the United States and other countries where eJAmerica, its affiliates, service providers, or subprocessors operate. Where applicable law restricts international transfers of Personal Data, eJAmerica will use an appropriate legally recognized transfer mechanism, which may include an adequacy decision, Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, Swiss-approved mechanisms, or another lawful safeguard. Where required by applicable law, eJAmerica will implement reasonable supplementary technical, contractual, or organizational safeguards in connection with such transfers. eJAmerica may transfer Personal Data to jurisdictions that do not provide an equivalent level of protection where a lawful transfer mechanism or applicable legal exception permits the transfer.

12. CALIFORNIA Privacy Notice

This Section applies to California residents to the extent required by the California Consumer Privacy Act, as amended (“CCPA/CPRA”). eJAmerica may collect categories of Personal Information including identifiers, commercial information, internet or electronic network activity, professional information, geolocation information, and Sensitive Personal Information, depending on the Services used and the circumstances of collection. eJAmerica does not sell Personal Information for monetary consideration. To the extent eJAmerica engages in activities legally considered a “sale” or “sharing” of Personal Information, California residents may exercise applicable opt-out rights through the mechanisms provided by eJAmerica. Subject to applicable law and verification requirements, California residents may have rights to know/access, correct, delete, opt out of sale or sharing, and limit certain uses of Sensitive Personal Information, as well as other rights provided under the CCPA/CPRA.

13. Other U.S. State Privacy Rights

Residents of U.S. states with applicable comprehensive privacy laws may have rights to access, correct, delete, or obtain a copy of their Personal Data, and to opt out of certain processing, subject to applicable law and any applicable exceptions. eJAmerica will honor such rights to the extent required by applicable law. Requests may be submitted portal of ejamerica.ai and will be handled in accordance with applicable law.

14. INDUSTRY-Specific Notices

14.1 Healthcare Clients

eJAmerica does not act as a HIPAA Business Associate, and the Services are not intended for processing Protected Health Information (“PHI”) unless eJAmerica has expressly agreed to do so under a separately executed Business Associate Agreement (“BAA”). Healthcare and life sciences Clients must not submit PHI to any Service unless an applicable BAA is in effect.

14.2 Financial Services and Public Sector Clients

Clients operating in financial services, government, public sector, or other regulated industries are solely responsible for determining whether their use of the Services complies with applicable regulatory requirements and whether additional contractual, security, or data protection commitments are required. Any such additional commitments will apply only if expressly agreed in a written agreement signed by eJAmerica.

15. CHILDREN’S Privacy

The eJAmerica.ai Suite is intended for business and professional use and is not directed to individuals under eighteen (18). eJAmerica does not knowingly collect Personal Data directly from individuals under eighteen (18). Where information relating to a minor is included in Client Data submitted by a Client, the Client is solely responsible for ensuring that such collection, use, and disclosure is lawful and complies with all applicable requirements.

16. THIRD-Party Websites and Services

The eJAmerica.ai Suite may link to, integrate with, or enable access to third-party websites, applications, platforms, or services. Such third-party services are controlled by their respective providers and are subject to their own terms and privacy policies. eJAmerica is not responsible for the availability, security, privacy practices, content, or processing of Personal Data by any third party. Client is responsible for reviewing applicable third-party terms and privacy policies and for configuring and authorizing integrations appropriately.

17. CHANGES to This Policy

eJAmerica may update this Policy from time to time to reflect changes in the Services, applicable laws, or our privacy practices. eJAmerica will post the updated Policy on the eJAmerica.ai website and update the “Last Updated” date. Where required by applicable law, eJAmerica will provide additional notice or obtain any required consent. The updated Policy will apply from its stated effective date.

18. LEGAL BASES FOR PROCESSING

Where eJAmerica acts as a controller, it processes Personal Data on one or more lawful bases permitted by applicable law, including performance of a contract, compliance with legal obligations, legitimate interests, and consent where required. eJAmerica may rely on different lawful bases depending on the purpose and circumstances of processing.

19. DATA SUBJECT RIGHTS AND REQUESTS

Subject to applicable law and verification requirements, individuals may have rights to access, correct, delete, restrict, object to, or receive a copy of their Personal Data, and to withdraw consent where processing is based on consent. Requests may be submitted to portal of ejamerica.ai. Where eJAmerica processes Personal Data on behalf of a Client, eJAmerica may refer the request to the applicable Client and reasonably assist the Client as required by applicable law.

20. SUBPROCESSORS AND SERVICE PROVIDERS

eJAmerica may engage affiliates, subprocessors, and third-party service providers to process Personal Data on its behalf for purposes including hosting, infrastructure, security, analytics, payment processing, communications, and AI functionality. eJAmerica may replace or engage additional service providers from time to time, subject to applicable legal requirements. Such providers will be required to maintain appropriate protections for Personal Data.

21. MARKETING AND COMMUNICATIONS

eJAmerica may use Personal Data to send service, transactional, administrative, and product-related communications and, where permitted by applicable law, marketing communications. Individuals may opt out of marketing communications at any time using the unsubscribe mechanism provided or by contacting eJAmerica. Opting out of marketing communications will not affect essential service or transactional communications.

22. AUTOMATED DECISION-MAKING AND PROFILING

eJAmerica may use automated processing, analytics, and AI functionality to provide and improve the Services. Unless expressly disclosed and permitted by applicable law, eJAmerica does not intend for its AI Functionality to make decisions based solely on automated processing that produce legal or similarly significant effects on individuals. Where applicable law requires safeguards for automated decision-making, eJAmerica will implement such safeguards.