PRIVACY POLICY

PRIVACY POLICY

Effective Date: January 30, 2026

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 LORD AI™, LORD AI+™, or CROSS AI™ (collectively, the “Products”); 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.

We are a Wyoming limited liability company formed in 2024 by American entrepreneur James Edward Billetz. We directly own and operate the Website.

1. Scope and Relationship with OpenAI

We build certain experiences—especially LORD AI™—on top of OpenAI technologies, including ChatGPT and ChatGPT Atlas, which are operated independently by OpenAI OpCo, LLC (“OpenAI”) (https://openai.com).

This Privacy Policy:

  • Describes how we handle information we collect through our Website and Services;

  • Does not govern how OpenAI handles information when you use ChatGPT, ChatGPT Atlas, or other OpenAI services. OpenAI’s own privacy notices apply to those services.

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

OpenAI’s Privacy Policy and related notices, available via its Privacy Center and Terms & policies page:

  • https://privacy.openai.com/

  • https://openai.com/policies/

OpenAI’s ChatGPT Atlas – Data Controls and Privacy help article:

  • https://help.openai.com (search “ChatGPT Atlas - Data Controls and Privacy”).

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

2. Eligibility and Age Requirements

Our Services—including LORD AI™—are intended only for adults age 18 and older, as described in our Terms of Use.

We do not knowingly collect Personal Data (defined below) from anyone under 18. If we learn that we have collected Personal Data 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.

3. 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.

3.1 Information You Provide to Us Directly

We may collect Personal Data that you provide when you:

  • Fill out forms or contact us via the Website (for example, via a contact form or newsletter sign-up);

  • Request information, send us an email, or otherwise communicate with us;

  • Interact with any future account, waitlist, or application flows we may introduce.

Depending on how you interact with us, this may include:

  • Contact details (name, email address, phone number);

  • Professional or demographic information (role, company, region, interests);

  • Any content you include in free-text fields (for example, messages explaining your situation or feedback).

We encourage you not to include highly sensitive information (such as full medical histories, financial account numbers, or government-issued identifiers) in these communications.

3.2 Information Collected Automatically (Website & Analytics)

The Website is hosted on Squarespace, which, together with our own configurations, may automatically collect certain information when you visit the site. This includes:

  • Information about your browser, network, and device (e.g., 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, searches, timestamps);

  • The web pages you visited before coming to our Website.

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

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;

  • The URL of the page you are viewing.

Those providers handle your data under their own privacy policies.

3.3 Cookies and Similar Technologies

We and our service providers (including Squarespace) use cookies and similar technologies to:

  • Operate basic site functions (e.g., page rendering, security);

  • Understand Website traffic and performance;

  • Remember certain preferences where applicable.

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

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

  • Analytics and performance cookies are used only after you acknowledge our cookie banner (where enabled) and help us see aggregate site usage.

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.

3.4 Information Related to LORD AI™, LORD AI+™, and CROSS AI™

a. Prompts and Conversations with LORD AI™

When you use LORD AI™ via ChatGPT or ChatGPT Atlas, your prompts, follow-up questions, and conversation history are handled primarily by OpenAI within the ChatGPT environment.

Key points:

  • Your chat content is entered into ChatGPT / Atlas, not directly into our Website;

  • That content is processed by OpenAI’s models to generate responses;

  • OpenAI may retain and use that data in accordance with its own Privacy Policy and Data Controls settings (for example, whether your chats are used to improve OpenAI’s models), which you can review at https://privacy.openai.com/ and https://openai.com/policies/.

By the Grace of Code does not automatically receive or store your full ChatGPT or Atlas conversation history. We may see aggregated performance or usage statistics (e.g., how often the LORD AI™ page is loaded in Atlas), but not the detailed content of your private chats, unless you intentionally share that content with us—for example, by emailing it to us or submitting it through a form on our Website.

b. Page Content Viewed in ChatGPT Atlas

When you use ChatGPT Atlas to browse our Website, Atlas may:

  • Access and process the content of the page you are viewing;

  • Use that content in the ChatGPT sidebar to answer questions, summarize, or compare information;

  • Store page-related context as part of your ChatGPT conversations or Atlas memories, depending on your settings.

We do not control how Atlas stores or uses this page content—those practices are governed by OpenAI’s policies (https://openai.com/policies/) and your personal Data Controls within ChatGPT / Atlas.

From our side, we simply see normal web server logs and analytics, just as we would for any other browser visit.

4. How We Use Personal Data

We use the information we collect for purposes such as:

Providing and maintaining the Services

  • Operating, hosting, and securing our Website;

  • Enabling access to pages like LORD AI™, LORD AI+™, and CROSS AI™;

  • Responding to inquiries and support requests.

Understanding and improving the Services

  • Monitoring and analyzing usage and performance;

  • Improving content, layout, and user experience;

  • Evaluating interest in future offerings related to workforce initiatives, training, or AI coaching.

Communicating with you

  • Responding to messages or questions;

  • Sending newsletters or marketing communications (if you sign up), which you may opt out of at any time.

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.

We do not sell your Personal Data.

5. How We Share Personal Data

We may share Personal Data in the following circumstances:

5.1 Service Providers

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

  • Squarespace (website hosting, analytics, email campaigns);

  • Email and communications providers;

  • Analytics and security tools;

  • Other infrastructure providers as needed.

These providers are authorized to use your Personal Data only as necessary to provide services to us.

5.2 OpenAI

When you use LORD AI™ or other experiences built on ChatGPT / ChatGPT Atlas, your chat content and browsing context are transmitted to OpenAI and handled under OpenAI’s own privacy policies and data controls (https://privacy.openai.com/ and https://openai.com/policies/).

From our perspective:

  • We rely on OpenAI to process that data so the Products can function;

  • We do not use that chat content for our own independent advertising or profiling;

  • We do not control OpenAI’s retention, training use, or security controls.

Please see OpenAI’s Privacy Policy and Data Controls documentation for details and your options (https://privacy.openai.com/ and https://openai.com/policies/).

5.3 Legal and Safety

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, our users, or the public;

  • Enforce our Terms of Use;

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

5.4 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.

6. Your Choices and Controls

6.1 Limit the Information You Provide

You can choose what information to share with us. In particular, we encourage you not to include:

  • Passwords or sensitive authentication data;

  • Government-issued ID numbers;

  • Detailed financial account information;

  • Detailed medical or mental-health histories.

6.2 Email Communications

If you receive marketing emails from us, you can unsubscribe at any time by clicking the “unsubscribe” link in the email or contacting us directly. We may still send you non-marketing messages (for example, replies to inquiries).

6.3 Cookies and Tracking

You can control cookies and similar technologies via:

  • Browser settings (e.g., blocking or deleting cookies);

  • Our cookie banner, where enabled, to adjust analytics preferences.

If you block cookies, some site features may not function properly.

6.4 ChatGPT and Atlas Data Controls

Within ChatGPT and ChatGPT Atlas, you have additional controls provided by OpenAI, such as:

  • 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 / Atlas account—not by us. We cannot access or change those settings on your behalf. For more information, see OpenAI’s documentation on Data Controls and Atlas privacy at https://privacy.openai.com/ and https://help.openai.com.

6.5 Access, Correction, and Deletion

Depending on where you live, you may have certain rights regarding your Personal Data, such as:

  • Accessing the Personal Data we hold about you;

  • Requesting correction of inaccurate Personal Data;

  • Requesting deletion of certain Personal Data.

To exercise these rights with respect to data we control, please contact us using the details in Section 13. We may need to verify your identity before fulfilling your request.

For ChatGPT / Atlas conversation data and account-level privacy requests, you must use OpenAI’s tools and processes, as described in its privacy documentation (https://privacy.openai.com/ and https://openai.com/policies/).

7. 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 (such as Squarespace) and our own access controls.

However, 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.

8. Data Retention

We retain Personal Data for as long as reasonably necessary to:

  • Provide the Services;

  • Comply with our legal obligations;

  • Resolve disputes;

  • Enforce our agreements.

We may retain Non-Personal Data (for example, aggregated analytics) for longer periods.

For data processed by OpenAI when you use ChatGPT and ChatGPT Atlas, retention is governed by OpenAI’s policies, not ours. You can learn more at https://privacy.openai.com/ and https://openai.com/policies/.

9. International Users

Our Services are operated from the United States. If you access the Services from outside the United States, you understand that:

  • Your information may be transferred to, stored in, and processed in the United States or other countries where our service providers operate;

  • These locations may have data protection laws that differ from those in your jurisdiction.

By using the Services, you consent to the transfer of your information as described in this Policy.

10. Third-Party Websites and Services

Our Website may contain links to third-party websites or services (including OpenAI, 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 policies, not this Privacy Policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do:

  • We will revise the “Effective Date” at the top of this page; and

  • In some cases, we may provide additional notice (such as posting a banner or sending an email, if appropriate).

Your continued use of the Services after any changes become effective means you accept the updated Policy.

12. 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

13. Additional Notices for U.S. State Laws (If Applicable)

If and when we are required to provide additional notices under specific U.S. state privacy laws (such as California, Colorado, or others), we may supplement this Policy with jurisdiction-specific disclosures. Those supplements will apply to residents of those jurisdictions in addition to this Policy.