Constructive Privacy Policy

Power Wave Holdings LLC dba Constructive
Effective Date: September 4, 2026
Last Updated: September 4, 2026

1. INTRODUCTION

This Privacy Policy explains how Power Wave Holdings LLC, doing business as Constructive ("Constructive," "we," "us," or "our"), collects, uses, discloses, and protects information in connection with our website at trainwithconstructive.com (the "Site") and our AI-powered training platform for customer-facing teams (the "Platform").

Constructive is a business-to-business service. The Platform is purchased by organizations ("Customers") for use by their employees and authorized users. This policy covers two distinct groups: visitors to our Site, and users of the Platform provided through a Customer account.

For information Customers provide or generate through the Platform, the Customer is the controller of that information and Constructive acts as the Customer's service provider and processor. Our handling of that information is governed by our agreement with the Customer, including our Terms of Service and Data Security Policy.

2. INFORMATION WE COLLECT

A. Information from Site visitors.

When you visit our Site or submit a contact or demo request form, we collect the information you choose to provide, such as your name, work email address, company name, and any message content. We also collect basic analytics data automatically, as described in Section 5.

B. Information from Platform users.

When your organization provides you access to the Platform, we handle:

• Account information: your name and work email address, used to create and secure your login. We do not store passwords; sign-in is by Google single sign-on or expiring one-time email links.
• Customer Content: call recordings, transcripts, training materials, scripts, and similar materials that the Customer chooses to provide or upload, used solely to build that Customer's private training scenarios and coaching feedback.
• Generated Content: practice-session audio, transcripts, and performance scores created when users of the Platform complete training exercises.

C. Information we do not collect.

Constructive does not collect or store consumer payment card numbers, Social Security numbers, credit applications, or financial account records.

3. HOW WE USE INFORMATION

We use information to:

• provide, operate, secure, and improve the Platform and Site;
• create training scenarios, coaching feedback, and performance scores for the providing Customer;
• authenticate users and maintain account security;
• respond to contact and demo requests and communicate about the service;
• send transactional messages such as login links;
• comply with legal obligations and enforce our agreements.

We do not use Customer Content or Generated Content to train AI models, and we do not use one Customer's data to build features, scenarios, or models for any other Customer.

4. HOW WE SHARE INFORMATION

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

We disclose information only to the subprocessors listed in Section 6, who process it on our behalf to deliver the service, and in the following limited circumstances: to comply with law or valid legal process; to protect the rights, safety, or property of Constructive, our Customers, or others; and in connection with a merger, acquisition, or sale of assets, subject to the confidentiality commitments in our Terms of Service.

5. COOKIES AND ANALYTICS

Our Site does not use advertising or cross-site tracking cookies. To understand aggregate Site traffic, we use Cloudflare's privacy-first analytics, which measures visits at the network edge without setting cookies or tracking visitors across sites. We do not use analytics information for advertising, and we do not combine it with Platform data.

The Platform itself uses only the cookies necessary to keep you signed in and secure. You can control cookies through your browser settings. Our Site does not currently respond to Do Not Track browser signals.

6. SUBPROCESSORS

We use the following subprocessors to deliver the service. Each processes information only as needed to perform its function and under contractual confidentiality and security obligations. None of them receives Customer Content or Generated Content for its own independent model training. Some infrastructure providers may process content on a de-identified basis solely to maintain and improve the reliability of their own services.

• Render: application and database hosting
• Cloudflare: network security and encrypted audio storage
• Vapi: voice AI infrastructure for practice calls
• Deepgram: speech-to-text transcription for practice calls
• ElevenLabs: AI voice generation for practice calls
• Anthropic: AI scenario generation, scoring, and feedback
• Google: single sign-on and business email
• Resend: transactional email delivery, such as login links
• Stripe: payment processing for Customer billing

Voice infrastructure providers used for live practice calls may retain call recordings, transcripts, and logs on their systems for a limited period to operate and secure their services. A current list of subprocessors is available on request and is updated as the Platform evolves.

7. DATA RETENTION AND DELETION

We retain Customer Content and Generated Content for the duration of the service agreement. On written request or on termination, we provide a 30-day window for the Customer to export its data, delete that data from our active systems within 60 days, and remove it from routine backups within 90 days. On completion we provide written confirmation of deletion. Site contact-form information is retained only as long as needed to respond and for reasonable business records.

8. HOW WE PROTECT INFORMATION

We apply the safeguards described in our Data Security Policy, including encryption in transit and at rest, tenant isolation with row-level security, single sign-on and one-time-link authentication with no stored passwords, least-privilege production access protected by multi-factor authentication, a default-deny database network posture, and automated backups. No system is perfectly secure, but data protection is a founding design requirement of the Platform.

9. YOUR PRIVACY RIGHTS

Depending on where you live, you may have rights to access, correct, delete, or obtain a copy of your personal information, and to be free from discrimination for exercising those rights.

For Platform users: because your organization controls the Customer Content and account data in its Platform instance, please direct requests to your organization, and we will assist the Customer in responding as its service provider.

For Site visitors and other requests: contact us using Section 11. We do not sell personal information or share it for cross-context behavioral advertising, so no opt-out of those activities is necessary.

10. CHILDREN

The Platform and Site are intended for business use by individuals who are at least 18 years old. We do not knowingly collect personal information from children.

11. CONTACT US

Questions, deletion requests, or documentation requests:
legal@trainwithconstructive.com
Power Wave Holdings LLC dba Constructive
trainwithconstructive.com

We respond within one business day.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy as the Platform evolves. When we make material changes, we will update the "Last Updated" date above and, where appropriate, notify Customers through the account contact on file. The current version is always available on the Site.