Platform Privacy Policy

1. Identity and Scope

This Privacy Policy applies to Public Visitors (individuals who browse public pages or interact with public forms), Applicants (individuals applying to become an Approved Provider), Active Clients (registered individuals with an active paid or authorized engagement), Approved Providers (authorized independent contractors, including Coaches, Counselors, and Strategists), Platform Administrators (authorized individuals with elevated-access permissions), and any other individual whose Personal Information JBN Global processes in connection with the Platform or Services.

"Platform" means the JBN Global website at jbnglobal.co, client and provider portals, Care Navigation routes, administrative dashboards, workflows, forms, content, communications tools, databases, and related digital services operated by or for Just Breathe Now LLC (d/b/a JBN Global).

2. JBN Global's Non-Clinical Scope

JBN Global is an independent, non-clinical, coaching, operational-support, education, coordination, and navigation network. JBN Global does not provide medical care, psychotherapy, clinical counseling, trauma processing, legal representation, tax preparation, credit repair, or insurance/investment/fiduciary financial advice.

JBN Global is not intended to operate as a HIPAA-covered entity or business associate and does not represent that the Platform is HIPAA compliant or suitable for protected health information. Even when an Approved Provider holds an active clinical license, all Services delivered through JBN Global remain limited to JBN Global's approved non-clinical scope; a license is an eligibility and safety-recognition requirement and does not convert JBN Global Services into therapy or another regulated professional service.

3. Definitions

• "Active Client" means an individual with an active paid or authorized JBN Global engagement.
• "Approved Provider" means an independent contractor approved by JBN Global to provide authorized Services through the Platform, including a Coach, Counselor, Strategist, or other approved provider role.
• "Care Navigation" means JBN Global's private, internal, authenticated operational-coordination process available exclusively to Active Clients and authorized Approved Providers. Care Navigation is not a public referral service, therapist-matching engine, crisis line, emergency service, diagnostic service, or treatment service.
• "Consumer Health Data" means personal information that may be treated as consumer health data, health data, or a similar category under applicable law.
• "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household.
• "Platform Administrator" means an authorized person with elevated permissions to support, administer, secure, maintain, audit, or operate the Platform.
• "Sensitive Personal Information" means information designated as sensitive under applicable law, including government identifiers, account credentials, payment-related information, precise geolocation, racial or ethnic origin, religious beliefs, health-related information, sexual-orientation information, biometric information, union membership, and certain communications contents.
• "Services" means JBN Global's authorized non-clinical coaching, strategic, operational, educational, planning, accountability, coordination, and navigation services.
• "Third-Party Directory" means an independent, neutral, publicly available third-party directory that may be accessed through a link within Care Navigation or elsewhere on the Platform.

4. Information We Collect

JBN Global may collect Personal Information directly from you, automatically through your use of the Platform, from Approved Providers and other authorized users, from service providers acting for JBN Global, and from lawful third-party sources.

4.1 Information You Provide

• Name, preferred name, pronouns, mailing address, email address, telephone number, and other contact information;
• Account username, password, authentication credentials, communication preferences, and account settings;
• Information included in inquiry forms, application forms, contact forms, surveys, questionnaires, feedback submissions, support requests, messages, and correspondence;
• Information you voluntarily provide regarding goals, priorities, interests, availability, scheduling needs, transition plans, milestones, professional experience, and other non-clinical matters;
• Payment, billing, invoice, refund, transaction, subscription, and service-package information;
• Information voluntarily submitted for webinars, training, certification, events, newsletters, waitlists, or applications.

JBN Global does not intentionally collect full payment-card numbers, payment-card security codes, or complete banking credentials through unstructured notes, ordinary messages, general document-upload fields, or email. Payment information must be submitted only through an approved secure payment gateway.

4.2 Active Client Information

• Account registration and authentication information;
• Contact, scheduling, availability, attendance, cancellation, and no-show information;
• Engagement enrollment, service-package, payment, invoice, refund, and billing information;
• Client-selected goals, priorities, planning information, action steps, accountability items, pathway selections, and non-clinical progress information;
• Non-clinical session summaries, operational notes, roadmaps, milestones, feedback, and survey responses;
• Provider-assignment, availability, coordination, and service-history information;
• Care Navigation Flags, scope-boundary flags, safety-escalation flags, state-clearance records, and related operational communications;
• Communications with JBN Global, Approved Providers, or JBN Global support through approved Platform channels;
• Device, login, security, audit, and technical-log information.

Active Clients must not submit medical records, psychotherapy notes, clinical diagnoses, clinical assessment reports, laboratory results, medication histories, psychiatric evaluations, treatment plans, hospital records, insurance claims, or other clinical records through the Platform unless JBN Global expressly identifies a limited, secure, authorized workflow for a specific administrative purpose.

4.3 Provider Applicant and Approved Provider Information

• Name, professional name, contact information, professional biography, profile image, resume, education, work history, certifications, skills, languages, availability, and service preferences;
• Coaching credentials, including ICF credentials or equivalent qualifying accredited training information;
• Professional licenses, license numbers, states of issuance, renewal dates, status, verification status, disciplinary information, compact privileges, and state-clearance information;
• Professional-liability insurance certificates, insurer information, policy terms, coverage limits, and related exclusions;
• Government-issued identification and identity-verification information where reasonably necessary for onboarding, fraud prevention, security, or legal compliance;
• W-9 information, business-entity information, taxpayer-identification information, payment-routing information, invoices, contractor payments, and tax-administration records;
• Professional references and related credential-verification records;
• Background-check verification information, where lawful and subject to any required notice, authorization, and adverse-action process;
• JBN Certification enrollment, completion, module scores, safety-simulation records, annual attestations, continuing-development records, and compliance status;
• Assignment, availability, capacity, pathway authorization, quality-assurance, documentation, professional-conduct, escalation, and audit records.

4.4 Non-Clinical Operational Data

JBN Global may process non-clinical operational data to deliver and coordinate Services, including client goals and roadmaps, non-clinical session notes, session scheduling and attendance information, client-provider coordination records, provider pathway eligibility and assignment information, client feedback and survey data, Care Navigation and safety flags, support and compliance communications, and administrative access logs. JBN Global does not use the Platform as a clinical electronic-health-record system, and users may not submit clinical treatment information, psychotherapy notes, diagnostic records, clinical treatment plans, medical records, or medication information.

4.5 Automated Technical Data

• Internet protocol address;
• Browser type, browser language, operating system, device type, device identifiers, and device settings;
• Pages visited, routes accessed, Platform features used, links clicked, referral sources, exit pages, access times, and navigation patterns;
• Account login and logout events, session identifiers, failed login attempts, password resets, security events, authentication status, and access-control data;
• Approximate location derived from IP address;
• Cookies, local storage, pixels, tags, scripts, software development kits, and comparable technologies;
• Error logs, diagnostic information, performance information, security monitoring records, and audit trails.

4.6 Information From Other Sources

JBN Global may receive Personal Information from payment processors, authorized hosting/authentication/analytics/security service providers, credentialing and background-check providers, public licensing boards and professional sources, authorized Approved Providers or Active Clients in a permitted operational workflow, individuals who refer a provider applicant where lawful, and other lawful sources relevant to fraud prevention, safety, credentialing, compliance, or Platform security.

5. Prohibited Data

Unless JBN Global expressly identifies a secure and authorized workflow for a limited administrative purpose, you must not submit, upload, transmit, or store through the Platform: medical records; psychotherapy notes; psychiatric, psychological, or clinical evaluation reports; clinical diagnostic records; treatment plans; medication lists or prescription data; laboratory or hospital records or health-insurance claims; full payment-card numbers or security codes, or complete bank-account credentials; Social Security numbers or government identifiers in free-text notes or ordinary messages; another person's confidential information without lawful authority; or information that is false, unlawful, harmful, threatening, discriminatory, harassing, abusive, or infringing.

JBN Global may remove, quarantine, restrict access to, preserve, or delete prohibited data where legally permitted and may suspend or terminate access under the Terms and Conditions.

6. How We Use Personal Information

• Operate, maintain, secure, support, and improve the Platform and Services;
• Create, verify, manage, authenticate, and protect accounts;
• Verify identity, credentials, licensure, insurance, references, eligibility, state clearance, and provider qualifications;
• Process provider applications, onboarding, JBN Certification, credentialing, compliance monitoring, and contractor payments;
• Process payments, manage invoices, subscriptions, refunds, transaction records, service packages, and fraud prevention;
• Schedule and administer Services, communications, authorized client-provider alignment, and coordination;
• Support operational alignment based on authorized role, pathway, state, availability, and capacity;
• Maintain non-clinical client roadmaps, session summaries, Care Navigation records, and administrative records;
• Identify, investigate, document, and respond to potential fraud, misuse, security incidents, prohibited conduct, safety concerns, and compliance matters;
• Facilitate appropriate non-clinical navigation or escalation when information indicates a matter may be outside JBN Global's approved scope;
• Send transactional, operational, security, billing, account, application-status, policy, and support communications;
• Send marketing communications where permitted by law and subject to your communication preferences;
• Understand public-site use, improve accessibility, identify technical issues, and evaluate system performance;
• Comply with legal, regulatory, contractual, tax, audit, insurance, court-order, and lawful government-request obligations;
• Establish, exercise, or defend legal claims;
• Create aggregated, anonymized, or de-identified information for lawful analytics, business operations, and improvement purposes.

JBN Global does not use Sensitive Personal Information or Consumer Health Data to infer characteristics about an individual, to make automated decisions with legal or similarly significant effects, or for targeted advertising.

7. Legal Bases for Processing

Where the GDPR or UK GDPR applies, JBN Global processes Personal Information on one or more of these legal bases: performance of a contract with you or steps taken at your request before a contract; JBN Global's legitimate interests in operating, securing, and protecting the Platform, provided those interests are not overridden by your rights; compliance with legal obligations; consent, where relied upon; protection of vital interests where permitted; and establishment, exercise, or defense of legal claims. You may withdraw consent when processing is based on consent; withdrawal does not affect prior lawful processing.

8. How We Disclose Personal Information

JBN Global does not sell or rent Personal Information, does not share Personal Information for cross-context behavioral advertising, and does not knowingly permit third-party advertising technologies to collect Personal Information within authenticated client, provider, Care Navigation, or administrative portal routes.

JBN Global may disclose Personal Information to authorized JBN Global personnel with a legitimate business need; Approved Providers only to the extent necessary to provide authorized Services or coordination; authorized processors providing hosting, infrastructure, payment processing, communications, analytics, security, and support functions; professional advisors including attorneys, accountants, auditors, and insurers where necessary for lawful purposes; government agencies, regulators, or courts where required by law or legal process; a purchaser or successor in a merger, acquisition, or similar transaction; and other parties with your direction, consent, or authorization.

8.1 Platform Infrastructure

JBN Global uses third-party infrastructure, hosting, database, authentication, workflow, communications, and security services to operate the Platform. Those service providers may process Personal Information as JBN Global's service providers or processors to the extent necessary to provide configured Platform functionality.

8.2 Payment Processors

Payment information submitted through designated payment flows may be collected and processed directly by JBN Global's selected secure third-party payment processor. JBN Global does not intend to store full payment-card numbers or security codes within general Platform fields.

8.3 Credentialing and Background-Check Providers

JBN Global may use authorized third parties to verify provider identity, credentials, licensure, insurance, references, and background information where lawful. Where a consumer report is used, JBN Global will provide any legally required disclosures, obtain authorization, and follow applicable adverse-action procedures.

8.4 Independent Third-Party Directories

Care Navigation may provide access to a neutral, independent Third-Party Directory of publicly available listings. JBN Global does not control the Third-Party Directory's content, privacy practices, or services. When you access an external directory, the third party's privacy policy and terms, not this Privacy Policy — govern information you provide to that third party.

9. Care Navigation Privacy Rules

Care Navigation is a private, internal, authenticated operational-coordination process available exclusively to Active Clients and authorized Approved Providers. It is not publicly accessible; not a public referral, therapist-matching, or clinician-recommendation service; not an emergency-response or clinical-intervention system; and is not monitored continuously. It does not create a treatment relationship or constitute an endorsement, ranking, or suitability determination. It is limited by role-based access controls, operational logging, audit review, and Platform security measures.

Users must not use Care Navigation to request emergency assistance, submit clinical records, seek immediate crisis support, or obtain medical, therapeutic, legal, tax, credit, insurance, or investment advice. If you are experiencing an emergency or immediate danger, call 911, call or text 988 in the United States, contact local emergency services, or go to the nearest emergency department.

10. Consumer Health Data

JBN Global does not sell Consumer Health Data and does not use Consumer Health Data for targeted advertising. If information submitted by a user could be treated as Consumer Health Data under applicable law, JBN Global will process it only as reasonably necessary to provide requested functionality, maintain security and access control, comply with law, respond to a user request, investigate or prevent misuse, or carry out another purpose expressly permitted by law. JBN Global does not permit third-party advertising pixels, retargeting tags, or cross-context behavioral-advertising technologies within authenticated portal areas.

11. Retention of Personal Information

JBN Global retains Personal Information only as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, deliver Services, meet legal and contractual obligations, maintain security and audit records, resolve disputes, and enforce agreements.

JBN Global may retain information after a deletion request where retention is required or permitted by law, including to complete a transaction, comply with legal obligations, maintain security, detect or prevent fraud, preserve evidence, establish or defend legal claims, or enforce agreements.

12. Security

JBN Global uses reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, loss, misuse, or destruction. Subject to the services selected and configured through JBN Global's technology providers, those safeguards may include encryption in transit and at rest where supported, role-based access controls, authentication and multi-factor controls, session-management and inactivity timeout controls, logging and audit trails for account access and data exports, security monitoring and incident-response processes, vendor diligence appropriate to each vendor's role, confidentiality duties and training for personnel, and secure data disposal practices.

No system, website, transmission method, or storage environment can be guaranteed completely secure. You are responsible for safeguarding your account credentials and promptly reporting suspected unauthorized access.

13. Privacy Rights

Subject to applicable law, identity verification, and legal exceptions, you may have the right to confirm whether JBN Global processes your Personal Information; request access, correction, or deletion; request a portable copy; opt out of sale, sharing, targeted advertising, or certain profiling where applicable; limit certain uses of Sensitive Personal Information; object to processing based on legitimate interests or direct marketing; withdraw consent; appeal a decision; and lodge a complaint with an appropriate supervisory authority.

13.1 Submitting a Privacy Request

To submit a privacy-rights request, email compliance@jbnglobal.co with the subject line "Privacy Rights Request," including your full name, the email address associated with your account (if applicable), your relationship to JBN Global, the privacy right you seek to exercise, a description of your request, and information reasonably necessary to verify your identity. JBN Global may take reasonable steps to verify your identity before responding and will not require you to create an account solely to exercise a privacy right. An authorized agent may submit a request where permitted by law.

13.2 Appeals

If JBN Global denies your request in whole or in part, you may appeal by replying to the decision notice or emailing compliance@jbnglobal.co with the subject line "Privacy Rights Appeal," stating why you believe the decision should be reconsidered.

13.3 California Privacy Rights

California residents may have rights under the CCPA/CPRA, subject to applicable thresholds and exceptions, including rights to know, access, delete, correct, limit certain uses of Sensitive Personal Information, opt out of sale or sharing where applicable, and receive non-discriminatory treatment. JBN Global does not sell Personal Information and does not share Personal Information for cross-context behavioral advertising as defined by California law, and does not currently provide a "Do Not Sell or Share My Personal Information" link because it does not engage in those activities. This Privacy Policy is intended to function as JBN Global's online notice at collection.

13.4 Virginia and Other U.S. State Rights

Residents of Virginia and other states with applicable privacy laws may have rights to confirm processing, access, correct, delete, obtain a portable copy, opt out of targeted advertising, sale, or certain profiling, and appeal decisions. JBN Global does not currently sell Personal Information, use Personal Information from authenticated portals for targeted advertising, or conduct profiling in furtherance of decisions producing legal or similarly significant effects.

14. International Users and GDPR/UK GDPR

The Platform is intended primarily for users located in the United States. If you access the Platform from another country, your Personal Information may be transferred to, stored in, and processed in the United States and other countries in which JBN Global or its authorized processors operate. Where GDPR or UK GDPR applies, you may have rights to access, rectify, erase, restrict processing, object to certain processing, receive portable data, withdraw consent, and complain to a relevant data-protection authority. JBN Global will use an appropriate transfer mechanism where legally required.

15. Children

The Platform and Services are intended only for individuals 18 years of age or older. JBN Global does not knowingly collect Personal Information from children under 18. If you believe a person under 18 has provided Personal Information without legally valid authorization, contact compliance@jbnglobal.co.

16. Third-Party Services

The Platform may link to third-party websites, directories, payment pages, applications, social-media platforms, or other services. JBN Global does not control those third parties and is not responsible for their content, security, availability, privacy practices, terms, services, or conduct. Your interaction with a third-party service is governed by that third party's terms and privacy policy.

17. Changes to This Privacy Policy

JBN Global may update this Privacy Policy to reflect changes in the Platform, Services, legal requirements, vendors, data practices, or business operations. JBN Global will revise the "Last Updated" date when changes are made. If a change is material, JBN Global may provide additional notice through the Platform, by email, within your account, or by another legally appropriate method.

18. Contact Us

For questions, concerns, or requests regarding this Privacy Policy, contact: Just Breathe Now LLC (d/b/a JBN Global), Attn: Privacy Team, Floral Park, New York, United States, compliance@jbnglobal.co.