1. Introduction

Firestarter Labs, LLC (“Firestarter,” “we,” “our,” or “us”) operates the FirestarterMarketing.ai platform and the Moxie application (collectively, the “Platform”). We are committed to protecting the privacy of everyone who uses our Platform, visits our website, or engages with our agency services.

This Privacy Policy explains:

• What personal information we collect and why
• How we use, share, and protect that information
• Your rights and choices regarding your data
• How to contact us with questions or requests

This policy applies to all users of FirestarterMarketing.ai and Moxie, including individual subscribers (B2C), business account holders, and clients of Firestarter’s agency services (B2B). If you are using Moxie on behalf of a business, you represent that you have authority to bind that business to this policy.

2. Information We Collect

2.1  Information You Provide Directly

When you create an account, use our services, or communicate with us, you may provide:

• Account and identity information: name, email address, phone number, business name, job title
• Billing information: credit card details and billing address (processed by Stripe — we do not store raw card numbers)
• Business content: marketing copy, campaign assets, social media content, brand guidelines, and other materials you upload or create within Moxie
• Communications: messages to our support team, feedback, and survey responses
• Agency client data: information provided in the context of managed marketing services, including business goals, target audiences, and campaign performance data

2.2  Information Collected Automatically

When you visit our website or use the Platform, we automatically collect:

• Usage data: pages visited, features used, time spent, clicks, and interactions within the Platform
• Device and technical data: IP address, browser type and version, operating system, and device identifiers
• Log data: server logs, error reports, and diagnostic information
• Cookies and similar tracking technologies: see Section 6 (Cookies) for details

2.3  Information from Third Parties

We may receive information from:

• Connected platforms: if you connect Moxie to third-party services (e.g., Google, Meta, Stripe), we receive data those platforms share pursuant to your authorization and their own privacy policies
• Analytics and advertising partners: aggregated or pseudonymous data to help us understand usage patterns
• Publicly available sources: business information relevant to agency service delivery

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1  To Provide and Operate the Platform

• Create and manage your account
• Deliver the features and functionality of Moxie and FirestarterMarketing.ai
• Process transactions and send related communications (receipts, invoices, renewal notices)
• Provide customer support and respond to inquiries
• Deliver agency services and manage client engagements

3.2  To Improve and Develop Our Services

• Analyze usage patterns and Platform performance
• Conduct research and testing to improve existing features
• Develop new features, products, and services
• Train and improve AI-assisted tools using aggregated, de-identified data only — we do not use your individual business content to train shared models without explicit consent

3.3  To Communicate With You

• Send transactional emails (account verification, password reset, billing notifications)
• Share product updates, feature announcements, and educational content (opt out any time)
• Respond to questions and requests
• Send marketing communications where permitted and with appropriate consent

3.4  For Safety, Security, and Legal Compliance

• Detect, investigate, and prevent fraud, abuse, and security incidents
• Enforce our Terms of Service and other agreements
• Comply with applicable laws, regulations, and legal process
• Protect the rights, property, and safety of Firestarter, our users, and the public

4. How We Share Your Information

We do not sell your personal information. We share information only in the following circumstances:

4.1  Service Providers

We work with trusted vendors who process data on our behalf, including:

• Payment processing: Stripe
• Cloud infrastructure and hosting: Vercel, Supabase
• Email delivery and marketing automation tools
• Analytics platforms
• Customer support software

All service providers are contractually required to use your data only to perform services for us and to maintain appropriate security standards.

4.2  Business Transfers

If Firestarter is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent Platform notice prior to any such transfer.

4.3  Legal Requirements

We may disclose your information if we believe in good faith that doing so is necessary to: (a) comply with applicable law or valid legal process; (b) protect the rights or safety of Firestarter, our users, or others; or (c) detect or prevent fraud or security incidents.

4.4  With Your Consent

We may share your information for other purposes with your explicit consent.

5. Data Retention

We retain personal information for as long as necessary to provide the Platform, fulfill the purposes described in this policy, and comply with our legal obligations:

• Account data is retained for the duration of your account and up to 3 years after account closure, unless a longer period is required by law
• Billing records are retained for 7 years in accordance with financial recordkeeping requirements
• Usage logs are retained for 24 months in identifiable form, after which they may be retained in aggregated, de-identified form
• Agency client data is retained per the terms of the applicable service agreement

You may request deletion of your account and data at any time (see Section 8 — Your Rights and Choices).

6. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to operate and improve the Platform.

6.1  Types of Cookies We Use

• Essential cookies: Required for Platform functionality (e.g., session authentication, security). These cannot be disabled.
• Performance and analytics cookies: Help us understand how users interact with the Platform.
• Functional cookies: Remember your preferences and settings to personalize your experience.
• Marketing cookies: Deliver relevant content and measure marketing effectiveness. You may opt out.

6.2  Your Cookie Choices

You can control cookies through your browser settings. Disabling certain cookies may impact Platform functionality. You may also opt out of interest-based advertising through the Digital Advertising Alliance (optout.aboutads.info) or the Network Advertising Initiative (optout.networkadvertising.org).

7. Data Security

We implement industry-standard security measures to protect your information, including:

• Encryption of data in transit (TLS/HTTPS) and at rest
• Access controls limiting employee access to personal data on a need-to-know basis
• Regular security assessments and monitoring
• Incident response procedures

No security system is impenetrable. In the event of a data breach that affects your rights or freedoms, we will notify affected users and relevant authorities as required by applicable law.

8. Your Rights and Choices

8.1  All Users

Regardless of your location, you have the right to:

• Access and update your account information at any time through Platform settings
• Opt out of marketing emails by clicking Unsubscribe in any marketing message or by contacting us
• Request deletion of your account by contacting us at privacy@firestarter-labs.com

8.2  California Residents — CCPA/CPRA Rights

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with additional rights:

Right to Know

You may request disclosure of: (a) the categories and specific pieces of personal information we have collected about you; (b) the categories of sources; (c) the business or commercial purpose for collecting it; and (d) the categories of third parties with whom we share it.

Right to Delete

You may request deletion of personal information we have collected from you, subject to certain exceptions (e.g., where retention is required by law or necessary to complete a transaction).

Right to Correct

You may request that we correct inaccurate personal information we maintain about you.

Right to Opt Out of Sale or Sharing

We do not sell personal information as defined under the CCPA. We also do not share personal information for cross-context behavioral advertising purposes.

Right to Limit Use of Sensitive Personal Information

We collect sensitive personal information only as described in this policy and do not use it beyond the purposes permitted under the CCPA without your consent.

Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. We will not deny you goods or services, charge different prices, or provide a different level of service based on the exercise of your privacy rights.

How to Submit a Request

To exercise your CCPA rights:

• Email privacy@firestarter-labs.com with the subject line “CA Privacy Request”
• We will acknowledge your request within 10 business days and respond within 45 calendar days (with possible 45-day extension)
• We may verify your identity before processing your request
• You may designate an authorized agent. We may require written proof of authorization.

Categories of Personal Information Collected (Past 12 Months)

• Identifiers: name, email address, IP address, device identifiers, account username
• Customer records information: billing address, payment method details (tokenized via Stripe)
• Commercial information: products or services purchased, subscription tier, transaction history
• Internet or electronic network activity: Platform usage data, log data, cookies
• Geolocation data: approximate location inferred from IP address
• Professional or employment-related information: business name, job title, industry
• Inferences: user preferences and usage patterns to personalize the experience

9. Children’s Privacy

The Platform is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without verified parental consent, we will delete that information promptly. If you believe we may have inadvertently collected such information, please contact us at privacy@firestarter-labs.com.

10. Third-Party Links and Integrations

The Platform may contain links to third-party websites or offer integrations with third-party services (e.g., Meta, Google, Stripe). This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you connect to or visit. We are not responsible for their privacy practices.

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically. When we make material changes, we will:

• Post the updated policy with a new effective date
• Send an email notification to registered users
• Display a prominent notice within the Platform

Your continued use of the Platform after the effective date of a revised policy constitutes your acceptance of the changes. If you disagree, you may close your account and discontinue use of the Platform.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy, please contact us:

Firestarter Labs, LLC

Privacy Inquiries: privacy@firestarter-labs.com

General Contact: jeff@firestarter-labs.com

Website: FirestarterMarketing.ai

We take privacy concerns seriously and will respond to your inquiry within 10 business days.