Privacy Policy

1. Who We Are

Gcexperts LLC ("Company," "we," "us," or "our") is a Texas limited liability company headquartered in Austin, Texas. We operate FedPrimer, a mobile application designed to assist small trade contractors in pursuing federal government contracting opportunities. This Privacy Policy ("Policy") describes how we collect, use, disclose, retain, and protect information obtained from or about users ("User," "you," or "your") of the FedPrimer application and related services (collectively, the "Services").

This Policy applies to all information collected through the Services. By downloading, installing, accessing, or using the Services, you acknowledge that you have read, understood, and agree to be bound by this Policy in its entirety. If you do not agree to this Policy, you must immediately cease all use of the Services and delete the Application from all devices.

For questions or concerns regarding this Policy, you may contact us at: [email protected] — Gcexperts LLC, Austin, Texas, United States.

2. Information We Collect

We collect the following categories of information in connection with your use of the Services:

• Registration Information. When you create an account, we collect your full name, phone number, email address, ZIP code, trade or business category, and crew or company size. This information is required to provide core features of the Services.
• Profile Information Built via Coach Conversations. Through your use of the AI coaching feature, we may collect and retain information that you voluntarily disclose during coaching sessions, including information about your business experience, past projects, capability statements, licensing, certifications, geographic service area, and goals related to federal contracting. This information may be used to personalize your experience and populate your subcontractor profile.
• Chat and Coaching History. We collect and retain records of your conversations with the AI coaching feature, including the prompts you submit and the responses generated, for the purposes described in Section 3 below.
• Bid and Opportunity Activity. We collect records of which federal procurement opportunities you have viewed, saved, or interacted with within the Services, as well as any bid tracking data you enter.
• SAM Registration Progress Data. We collect information you enter or confirm regarding the status of your SAM.gov registration process for the purpose of powering the SAM registration tracker feature.
• Device Push Notification Token. If you grant permission, we collect your device's push notification token for the purpose of delivering notifications related to bid alerts and service updates.
• Technical and Device Information. We automatically collect certain technical information when you use the Services, including your IP address, device type, operating system version, app version, and general device identifiers. This information is collected for security, fraud prevention, and service reliability purposes.
• Usage and Interaction Data. We may collect information about how you interact with the Services, including features accessed, screens viewed, session duration, and the frequency of use, for the purpose of improving the Services.

3. How We Use Your Information

We use the information we collect for the following purposes:

• Service Delivery. To create and maintain your account, provide access to the Services, and deliver the core features of FedPrimer, including AI coaching, bid matching, SAM tracking, scorecard tools, and subcontractor matching;
• AI Coaching. To transmit your inputs to third-party AI providers and deliver coaching responses personalized to your profile and business context;
• Bid Matching and Opportunity Surfacing. To identify and display federal procurement opportunities that may be relevant to your trade, geographic area, and business profile;
• SAM Registration Tracking. To display your SAM.gov registration progress and, where applicable, to send notifications regarding registration steps or deadlines based on information you have provided;
• Subcontractor Network. To display your profile to prime contractors and general contractors within the Subcontractor Network feature, as described in the Terms of Use;
• Push Notifications. To send you bid alerts, service updates, and other relevant notifications, subject to your device-level permission settings;
• Service Improvement. To analyze usage patterns, diagnose technical issues, test new features, and improve the overall quality and reliability of the Services;
• Fraud Prevention and Security. To detect, investigate, and prevent fraudulent activity, unauthorized access, abuse of the Services, and violations of our Terms of Use;
• Free Access Administration. To monitor publicly available government contracting records for the purpose of administering the conditional free access program described in the Terms of Use;
• Legal Compliance. To comply with applicable federal, state, and local laws, regulations, legal process, and governmental requests, and to enforce our Terms of Use and other agreements.

4. AI Processing — Third-Party AI Disclosure

The AI coaching feature within FedPrimer is powered by artificial intelligence services provided by one or more third-party technology companies, which may include without limitation Anthropic, PBC (developer of the Claude AI system) and OpenAI, LLC (collectively, "AI Providers"). By accessing or using the AI coaching feature, you expressly acknowledge and consent to the following:

• Your conversational inputs, coaching session data, and related interaction data are transmitted to and processed by one or more AI Providers in order to generate coaching responses. This transmission is a fundamental and necessary aspect of the AI coaching feature and cannot be disabled while using that feature;
• The data practices of each AI Provider are governed exclusively by that AI Provider's own privacy policy and terms of service, which are entirely separate from and independent of this Policy. We do not control, and expressly disclaim any responsibility for, the data collection, use, retention, security, or disclosure practices of any AI Provider;
• We encourage you to review the privacy policies of our current AI Providers prior to using the AI coaching feature: Anthropic's Privacy Policy is available at anthropic.com/legal/privacy and OpenAI's Privacy Policy is available at openai.com/privacy;
• We make no representations or warranties regarding the data security, retention practices, or privacy compliance of any AI Provider, and we shall not be liable for any data breach, unauthorized disclosure, or other privacy incident occurring at the level of any AI Provider;
• You should not submit through the AI coaching feature any information that you deem confidential, proprietary, or sensitive, including without limitation trade secrets, personally identifiable financial information, social security numbers, government-issued identification numbers, or attorney-client privileged communications.

5. How We Share Your Information

We do not sell your personal information to third parties for monetary compensation. We do not share your personal information with data brokers or advertising networks. We may share your information in the following limited circumstances:

• Subcontractor Network — Core Feature. As described in the Terms of Use, certain profile information (including your trade, geographic service area, crew size, and business capabilities) may be displayed to prime contractors and general contractors participating in the Subcontractor Network feature. This sharing is a core and intended feature of the Services and is consented to by your use of the Services. You may request removal from the Subcontractor Network at any time by contacting [email protected];
• AI Providers. As described in Section 4, your coaching session inputs and related data are transmitted to AI Providers for the purpose of generating coaching responses;
• Legal Compliance and Governmental Requests. We may disclose your information to the extent required by applicable law, regulation, legal process, or enforceable governmental or regulatory request, including without limitation in response to a valid subpoena, court order, or law enforcement demand. Where permitted by law, we will endeavor to provide you with reasonable notice of such disclosure;
• Business Transfers. In the event of a merger, acquisition, reorganization, sale of all or substantially all of our assets, or other similar corporate transaction, your information may be transferred to the successor entity. We will provide notice of any such transfer and the opportunity to review the successor entity's privacy practices to the extent practicable;
• Service Providers. We may share your information with third-party vendors and service providers that perform services on our behalf, including without limitation cloud hosting providers, database services, push notification delivery services, and analytics providers. Such service providers are authorized to use your information only as necessary to provide services to us and are contractually obligated to maintain reasonable confidentiality and security standards;
• Protection of Rights. We may disclose your information to the extent we reasonably believe disclosure is necessary to protect the rights, property, or safety of the Company, our users, or the public, including for the investigation or prevention of fraud, security threats, or illegal activity.

6. Data We Do Not Sell

We do not sell, rent, lease, or otherwise transfer your personal information to third parties for monetary or other valuable consideration for the purpose of those third parties' independent use or marketing. We do not share your personal information with advertising networks, data brokers, or consumer profiling services. We do not use your personal information to serve you third-party targeted advertising within the Services or on other platforms.

7. Data Retention

We retain your personal information for as long as your account remains active and for a reasonable period thereafter as necessary to fulfill the purposes described in this Policy. Specifically:

• Active Accounts. We retain all information associated with your account for the duration of your active use of the Services;
• Post-Deletion. Following your request to delete your account, we will use commercially reasonable efforts to delete or de-identify your personal information within thirty (30) calendar days of receiving your verified deletion request, except as provided below;
• Legal Retention Obligations. Notwithstanding the foregoing, we may retain certain information for longer periods to the extent required by applicable law, regulation, or legal process; to resolve disputes or enforce our agreements; to detect and prevent fraud or abuse; or to comply with technical or operational requirements. In such cases, we will retain the minimum information necessary for the applicable retention purpose;
• Aggregate and De-identified Data. We may retain aggregate, anonymized, or de-identified data derived from your information indefinitely, as such data does not constitute personal information.

8. Your Rights and Controls

Depending on your jurisdiction, you may have certain rights with respect to your personal information. We honor the following rights for all users:

• Account Deletion. You may request deletion of your account and associated personal information at any time by using the account deletion feature within the Application or by emailing us at [email protected] with a deletion request. Deletion requests will be processed within a reasonable timeframe, generally not to exceed thirty (30) days;
• Access and Correction. You may request access to the personal information we hold about you, or request correction of inaccurate information, by contacting us at [email protected]. We will honor such requests within a reasonable timeframe, generally not to exceed thirty (30) days, subject to applicable law;
• Notification Opt-Out. You may opt out of push notifications at any time through your device's notification settings. Opting out of notifications does not affect your account or access to the Services;
• Subcontractor Network Opt-Out. You may request removal of your profile from the Subcontractor Network at any time by contacting [email protected].

California Residents — CCPA Rights. Residents of California have additional rights under the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"). California residents have the right to: (a) know what categories of personal information we collect, the sources of such information, the purposes for which we use it, and the categories of third parties with whom we share it; (b) request access to the specific pieces of personal information we hold about them; (c) request deletion of their personal information, subject to applicable exceptions; (d) request correction of inaccurate personal information; (e) opt out of the sale or sharing of personal information (we do not sell or share personal information for cross-context behavioral advertising); and (f) not be subject to discriminatory treatment for exercising CCPA rights. To exercise any of the foregoing rights, California residents may contact us at [email protected]. We do not discriminate against users who exercise their privacy rights.

9. Third-Party SDKs and Libraries

The Application is built using Expo and React Native, which may include third-party software development kits ("SDKs") and libraries. We use only those third-party components reasonably necessary to deliver the Services. Any third-party SDKs included in the Application are limited to functional purposes such as crash reporting, diagnostics, and core mobile platform functionality. We do not include advertising SDKs, behavioral tracking SDKs, or SDKs designed for cross-application user profiling within the Application. Third-party SDK providers may collect limited technical data as described in their respective privacy policies. We do not control and are not responsible for the data practices of third-party SDK providers.

10. Security

We employ commercially reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include, without limitation, the use of Transport Layer Security ("TLS") encryption for data in transit. However, no method of electronic transmission or data storage is absolutely secure, and we cannot guarantee the absolute security of your information. You acknowledge and agree that you provide your personal information to us at your own risk, and we shall not be liable for any security breach that occurs despite our reasonable security measures, except to the extent required by applicable law.

11. Tracking Technologies

We employ minimal tracking technologies within the Services. Specifically:

• We may log your IP address and request metadata (such as timestamps and accessed endpoints) for security monitoring, fraud prevention, and service reliability purposes;
• We do not use cookies within the mobile Application;
• We do not engage in cross-application tracking, cross-device tracking for advertising purposes, or behavioral profiling for the benefit of third-party advertisers;
• We may use limited analytics tools to understand aggregate usage patterns and improve the Services. Such tools are configured to collect only the minimum data necessary for service improvement purposes.

12. Children's Privacy

The Services are intended exclusively for individuals who are at least eighteen (18) years of age. We do not knowingly collect personal information from individuals under the age of eighteen (18). If you are under the age of eighteen (18), you are strictly prohibited from using the Services. If you are a parent or legal guardian and believe that a minor has provided personal information to us through the Services, please contact us immediately at [email protected] and we will take prompt steps to delete such information in accordance with the Children's Online Privacy Protection Act ("COPPA") and applicable law. We reserve the right to terminate any account we determine, in our reasonable judgment, to belong to a user under the age of eighteen (18).

13. Changes to This Policy

We reserve the right to modify, amend, supplement, or replace this Privacy Policy at any time and for any reason, at our sole discretion. When we make changes to this Policy, we will update the "Last updated" date at the top of this page and post the revised Policy within the Application or at the URL where this Policy is hosted. Your continued access to or use of the Services following the posting of any modification to this Policy constitutes your unconditional acceptance of the modified Policy. We encourage you to review this Policy periodically. If you do not agree to any modification of this Policy, your sole remedy is to discontinue all use of the Services and request deletion of your account.

14. Contact Us

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

• Email: [email protected]
• Gcexperts LLC, Austin, Texas, United States

Please note that contacting us by any means does not create an attorney-client relationship, professional relationship, or any other special relationship. We will endeavor to respond to privacy-related inquiries within a reasonable timeframe. Response times are not guaranteed.