PRIVACY POLICY

PRIVACY POLICY

Effective Date: April 22, 2026

1. Introduction

This Privacy Policy describes how By the Grace of Code L.L.C. ("By the Grace of Code," the "Company," "we," "us," or "our") collects, uses, and shares information when you:

  • Visit www.bythegraceofcode.com or any subdomain (the "Website");

  • Use or interact with the AI coaching experience known as Order of Charity (the "AI Experience"), accessible at bythegraceofcode.com/charity through the ChatGPT Atlas side panel; or

  • Engage with any related content, features, tools, or services we provide (together with the Website, the "Services").

This Policy is intended to complement our Terms of Use. If you do not agree with this Policy, please do not use the Services.

By the Grace of Code L.L.C. is a Wyoming limited liability company formed in 2024. We directly own and operate the Website.

2. Scope and Relationship with OpenAI

2.1 What This Policy Covers. This Privacy Policy describes how we handle information we collect through our Website and Services.

2.2 What This Policy Does Not Cover. This Policy does not govern how OpenAI OpCo, LLC ("OpenAI") handles information when you use ChatGPT, ChatGPT Atlas, or other OpenAI services. The AI Experience is delivered through the ChatGPT Atlas side panel, which is operated independently by OpenAI. When you interact with the AI Experience, your inputs and conversation content are processed by OpenAI under OpenAI's own privacy policies and data controls, not ours.

For details on OpenAI's data practices, please review:

We do not control OpenAI's internal data practices, retention, or security measures.

2.3 No Independent Storage of Conversation Content. By the Grace of Code L.L.C. does not independently store or retain the content of user conversations with the AI Experience. Conversation data is processed by OpenAI and governed by OpenAI's policies and your personal Data Controls within your ChatGPT or Atlas account.

3. Eligibility, Age, and Geographic Requirements

3.1 Adults 18 and Older Only. The Services, including the AI Experience, are intended only for adults ages 18 and older, as described in our Terms of Use. By using the Services, you represent and warrant that you are at least 18 years old.

3.2 United States Residents Only. The Services are offered only to residents of the United States who are physically located in the United States. The Company does not intend to offer the Services in any non-U.S. jurisdiction and does not direct the Services to users outside the United States. If you access the Services from outside the United States despite these restrictions, you do so at your own risk.

3.3 No Collection from Minors. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from someone under 18, we will take reasonable steps to delete it. If you believe a minor has provided us information, please contact us using the details in Section 13.

4. Information We Collect

We use the term "Personal Data" to mean information that identifies or relates to an identifiable individual, and "Non-Personal Data" for other information.

4.1 Information You Provide Directly Through the Contact Form. When you submit the contact form at bythegraceofcode.com/contact, we collect:

  • Your name;

  • Your email address; and

  • The content of your message.

We encourage you not to include in your message any highly sensitive information — such as passwords, government-issued identifiers, financial account numbers, or detailed medical or mental-health histories.

4.2 Information Collected Automatically (Website Analytics). The Website is hosted on Squarespace, which automatically collects certain information when you visit the site. This includes:

  • Information about your browser, network, and device (for example, browser type, operating system, device identifiers);

  • Your IP address and approximate location derived from it;

  • The pages you visit on the Website and how you interact with them (clicks, internal links, scrolling, timestamps);

  • The referring URL (the page you visited before coming to our Website).

We primarily use this information in aggregated or de-identified form to understand traffic patterns, diagnose issues, and improve Website performance and security.

4.3 Fonts. The Website uses Google Fonts and Adobe Fonts to display certain typefaces. When these fonts are loaded, Google or Adobe may receive information such as your IP address, information about your browser, network, or device, and the URL of the page you are viewing. Those providers handle any such data under their own privacy policies.

4.4 Interactions with the AI Experience (Order of Charity). When you use the AI Experience through ChatGPT Atlas, your prompts, messages, and conversation history are entered into and processed by ChatGPT Atlas. Because the AI Experience is delivered through the Atlas side panel rather than through a form on our Website, your conversation content does not flow through our Website's data collection systems. We see normal Website analytics (for example, page-load statistics for bythegraceofcode.com/charity) but we do not see the content of your conversations with the AI Experience, unless you intentionally share that content with us — for example, by copying it into the contact form.

5. Cookies and Similar Technologies

5.1 What Cookies We Use. We and our service providers (including Squarespace) use cookies and similar technologies to:

  • Operate basic site functions, including page rendering and security;

  • Understand Website traffic and performance through aggregated analytics; and

  • Remember limited preferences where applicable.

Cookies are small text files stored on your device when you visit a website.

5.2 Types of Cookies.

  • Strictly necessary cookies allow Squarespace to securely serve the Website to you and cannot be easily disabled.

  • Analytics and performance cookies are used to help us see aggregate site usage and are configured through our cookie banner where enabled.

5.3 Managing Cookies. You can manage cookies through your browser settings and, where available, through our cookie banner preferences. If you disable certain cookies, parts of the Website may not function properly.

6. How We Use Personal Data

We use the information we collect for the following purposes:

6.1 Providing and Maintaining the Services. Operating, hosting, and securing our Website; enabling access to pages including the Order of Charity AI Experience; and responding to inquiries and support requests submitted through the contact form.

6.2 Understanding and Improving the Services. Monitoring and analyzing Website usage and performance; improving content, layout, and user experience.

6.3 Communicating with You. Responding to messages you send through the contact form.

6.4 Compliance, Safety, and Protection. Protecting the security and integrity of our Services; detecting and preventing fraud, abuse, or policy violations; complying with legal obligations and responding to lawful requests.

6.5 We Do Not Sell or Share Personal Data for Advertising. By the Grace of Code L.L.C. does not sell your Personal Data. We do not share Personal Data for "cross-contextual behavioral advertising" (as that term is defined under applicable state privacy laws), and we do not process Personal Data for "targeted advertising" purposes. We do not process sensitive Personal Data for the purpose of inferring characteristics about consumers.

7. How We Share Personal Data

We share Personal Data only in the following circumstances:

7.1 Service Providers. We share information with third-party service providers who help us operate our Services, such as:

  • Squarespace (website hosting, analytics, email notification services associated with the contact form);

  • Google Fonts and Adobe Fonts (font rendering, as described in Section 4.3); and

  • Other infrastructure providers as needed.

These providers are authorized to use any Personal Data only as necessary to provide services to us and in accordance with our instructions and their own privacy practices.

7.2 OpenAI. When you use the AI Experience, your inputs and conversation content are processed by OpenAI through ChatGPT Atlas. That data flow is governed by OpenAI's own terms and privacy policies, not ours. We rely on OpenAI to provide the underlying technology for the AI Experience; we do not use your conversation content for our own advertising, profiling, or marketing; and we do not control OpenAI's retention, training use, or security controls. For details, see OpenAI's Privacy Policy at https://openai.com/policies/privacy-policy/ and OpenAI's data-control documentation in your ChatGPT or Atlas account settings.

7.3 Legal and Safety Disclosures. We may disclose Personal Data if we believe in good faith that such disclosure is reasonably necessary to:

  • Comply with applicable law, regulation, legal process, or governmental request;

  • Protect the rights, property, or safety of By the Grace of Code L.L.C., our users, or the public;

  • Enforce our Terms of Use;

  • Detect, prevent, or address fraud, security issues, or technical problems.

7.4 Business Transfers. In connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, Personal Data may be transferred to another entity, subject to this Policy or a policy that is at least as protective.

8. Your Rights and Choices

8.1 General Right to Limit What You Share. You can choose what information to share with us. In particular, we encourage you not to share:

  • Passwords or authentication credentials;

  • Government-issued identifiers;

  • Detailed financial account information;

  • Detailed medical or mental-health histories.

This guidance applies to both the contact form and your interactions with the AI Experience.

8.2 ChatGPT and Atlas Data Controls. Within ChatGPT and ChatGPT Atlas, OpenAI provides additional controls, including:

  • Turning off chat history or model training for your conversations;

  • Managing Atlas page visibility and browser memories;

  • Exporting or deleting your ChatGPT data and account.

These settings are managed in your ChatGPT or Atlas account — not by us. We cannot access or change those settings on your behalf. For more information, see OpenAI's documentation at https://privacy.openai.com/ and OpenAI's Help Center at https://help.openai.com.

8.3 Cookies. You can control cookies through your browser settings and our cookie banner, as described in Section 5.

8.4 California Residents — Your CCPA Rights. If you are a California resident, you have the following rights under the California Consumer Privacy Act ("CCPA"), as amended:

  • Right to Know. You may request that we disclose the categories and specific pieces of Personal Data we have collected about you, the sources of that data, the purposes for collecting it, and the categories of third parties with whom we share it.

  • Right to Delete. You may request that we delete Personal Data we have collected from you, subject to certain exceptions required or permitted by law.

  • Right to Correct. You may request that we correct inaccurate Personal Data we maintain about you.

  • Right to Opt Out of Sale or Sharing. We do not sell Personal Data or share Personal Data for cross-contextual behavioral advertising, so this right does not require any opt-out action from you.

  • Right to Limit Use of Sensitive Personal Data. We do not use sensitive Personal Data for the purpose of inferring characteristics about consumers, so this right does not require any action from you.

  • Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights.

To exercise these rights, contact us at the address in Section 13. We will respond to verifiable requests within the 45-day period required by CCPA (extendable once by an additional 45 days if necessary, with notice to you). We may need to verify your identity before fulfilling your request.

For conversation data and account-level requests related to OpenAI services, you must exercise those rights directly with OpenAI through its tools at https://privacy.openai.com/.

8.5 Other State Privacy Laws. Residents of other U.S. states with comprehensive privacy laws (including Colorado, Connecticut, Virginia, Utah, and others as enacted) may have analogous rights. To exercise those rights, contact us at the address in Section 13.

8.6 Email Communications. If at any future point we send you marketing emails, you will be able to unsubscribe at any time by clicking the "unsubscribe" link in any such email or contacting us directly. As of the Effective Date of this Policy, we do not send marketing emails.

9. The AI Experience Safety Protocol and Data

The AI Experience operates under a published Safety Protocol available at bythegraceofcode.com/safety-protocol. The Safety Protocol describes how the AI Experience handles situations involving user distress, suicidal ideation, self-harm, and other crisis scenarios.

For the purposes of this Privacy Policy:

  • Crisis detection and response occurs within the ChatGPT Atlas environment and is governed by OpenAI's data handling;

  • By the Grace of Code L.L.C. does not independently receive or store the content of crisis interactions;

  • The Safety Protocol's privacy-relevant commitments are consistent with this Privacy Policy.

The Safety Protocol is part of the overall governance framework for the AI Experience. Its privacy-relevant commitments are intended to be consistent with this Privacy Policy and the Terms of Use.

10. The AI Experience Is Not Automated Decision-Making

The AI Experience is a coaching tool designed to support reflection, clarification, and action. It does not make automated decisions about users in domains typically covered by "automated decision-making technology" (ADMT) regulations, including employment, credit, insurance, housing, essential services, or healthcare. The AI Experience does not produce outputs that have legal or similarly significant effects on users. Users make their own decisions; the AI Experience provides coaching support for thinking and planning.

11. Data Security

We use reasonable technical and organizational measures designed to protect Personal Data from unauthorized access, use, or disclosure. These measures include safeguards provided by our infrastructure and hosting providers (including Squarespace) and our own access controls.

No system can be guaranteed 100% secure, and we cannot guarantee absolute security of your information. You are responsible for maintaining the security of your own devices, accounts, and credentials.

12. Data Retention

12.1 Contact Form Submissions. We generally retain contact form submissions for no longer than twenty-four (24) months from the date of submission, after which they are subject to deletion. We may retain contact form submissions longer than twenty-four (24) months to the extent necessary for legal, regulatory, or dispute-related purposes.

12.2 Website Analytics. Aggregated or de-identified Website analytics may be retained for longer periods in accordance with Squarespace's default retention settings.

12.3 Conversation Content. As described in Section 2.3, we do not independently store conversation content. Retention of conversation data within ChatGPT Atlas is governed by OpenAI's retention policies and your personal Data Controls.

12.4 Compliance and Legal Retention. We may retain Personal Data longer than the periods above to the extent necessary to comply with legal obligations, resolve disputes, or enforce our agreements.

13. Contact Us

If you have questions about this Privacy Policy or our data practices, or if you wish to exercise your privacy rights with respect to data we control, you may contact us at:

By the Grace of Code L.L.C.
30 N Gould St, Suite N
Sheridan, WY 82801

You may also submit a request through the contact form at bythegraceofcode.com/contact.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. For material changes:

  • We will revise the "Effective Date" and "Version" at the top of this page;

  • We will provide reasonable advance notice by posting a prominent notice on the Website; and

  • Where feasible, we will provide additional notice (such as by email if you have provided an email address).

Your continued use of the Services after the revised Effective Date of an updated Privacy Policy constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, please stop using the Services.

15. Third-Party Websites and Services

The Website may contain links to third-party websites or services (including OpenAI properties, social media platforms, or other resources). We are not responsible for the privacy practices or content of those third parties. Your use of third-party sites and services is governed by their own terms and privacy policies, not this Privacy Policy.

16. Supplemental Disclosures

16.1 "Do Not Track" Signals. Our Website does not respond to "Do Not Track" browser signals at this time.

16.2 Minors Clause Re-Affirmed. As described in Section 3.3, we do not knowingly collect personal information from individuals under 18. To the extent any information we receive indicates a user is under 18, we will take reasonable steps to delete it.

16.3 Not a Data Broker. By the Grace of Code L.L.C. is not a "data broker" as that term is defined under California law or other U.S. state data-broker registration laws.

//END PRIVACY POLICY//