Introduction

Kaiban Consulting LLC ("Kaiban," "we," "us," or "our") is a Virginia limited liability company providing supply chain strategy, revenue operations, third-party risk management, and related consulting services. This Privacy Policy explains how we collect, use, disclose, and protect information we receive through our website at kaibanconsulting.com (the "Site"), through contact and inquiry forms, and through general website interactions.

This Policy applies to information collected through the Site. It does not govern information collected under signed client engagement agreements, statements of work, or data processing addenda, which are addressed in separate project-level privacy documentation.

By using the Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, please discontinue use of the Site.

1. Information We Collect

Information you provide directly:

• Name, title, company name, email address, phone number submitted through contact or inquiry forms

• Content of messages, questions, or proposals submitted via the Site

• Information provided through scheduling tools (Calendly) linked from the Site

• Any attachments or files you voluntarily submit

Information collected automatically when you visit the Site:

• IP address, browser type, operating system, referring URL, and pages visited

• Date and time of visits and general geographic region (country/state level)

• Cookie identifiers and similar tracking technologies placed by Squarespace (our website platform) and any analytics tools enabled on the Site

Information we do not collect through the Site:

• Social Security numbers, government identification numbers, or financial account numbers

• Payment card information (we do not accept payments through the Site)

• Health information, biometric data, or precise geolocation

2. How We Use Your Information

We use information collected through the Site for the following purposes:

• Responding to inquiries: To respond to contact form submissions, scheduling requests, and business inquiries you initiate

• Business development: To evaluate potential consulting engagements and follow up on proposals

• Site operation and security: To maintain, improve, and secure the Site and detect unauthorized activity

• Marketing communications: To send relevant consulting insights, newsletters, or event information — only to contacts who have opted in or who have an existing business relationship with Kaiban consistent with applicable law

• Legal compliance: To comply with applicable federal, state, and local laws, regulations, and legal processes

We do not sell, rent, or share your personal information with third parties for their own marketing purposes.

3. AI and Large Language Model (LLM) Disclosure

Kaiban uses artificial intelligence tools in its internal research, content development, and business operations workflows (“AI”).

In accordance with Connecticut Public Act 25-113 (amending the Connecticut Data Privacy Act, effective July 1, 2026) and consistent with best practices under applicable state privacy laws:

• Kaiban does not sell or provide your personal information to any AI or LLM provider for the purpose of training large language models.

• Kaiban uses AI as a research, analysis and content development tool. To Kaiban's knowledge as of this Policy's effective date, the AI’s enterprise terms do not use customer inputs submitted through the enterprise product to train underlying models. Kaiban contractually requires, and will require in its vendor agreements, that vendors not use Kaiban-submitted personal data to train LLMs without express prior written authorization.

• If Kaiban's use of AI tools that process personal data changes materially, this Policy will be updated and prior consent revoked or re-obtained as required by applicable law.

• Provider categories whose tools Kaiban uses in operations include: AI research and content tools; CRM and email marketing platforms; productivity and collaboration tools; design tools; website hosting and form platforms; and meeting scheduling tools. Each vendor's privacy and AI training practices are governed by their respective privacy policies and data processing agreements.

6. Data Retention

Kaiban retains personal information only for as long as reasonably necessary to fulfill the purpose for which it was collected, to comply with legal obligations, and to resolve disputes. The table below describes our general retention practice by data category.

When the applicable retention period expires, Kaiban will delete or anonymize the data unless a longer period is required by law or a pending legal matter.

4. Cookies and Tracking Technologies

The Site may use cookies, web beacons, and similar tracking technologies operated by Squarespace and any analytics services enabled on the Site.

• Essential cookies: Required for basic Site functionality and security. These cannot be disabled without impairing Site operation.

• Analytics cookies: Used to understand aggregate Site traffic patterns. No personally identifiable information is shared with analytics providers beyond what is described in this Policy.

• No behavioral advertising cookies: Kaiban does not use cross-context behavioral advertising cookies or tracking for retargeting purposes.

You may control cookies through your browser settings. Most browsers allow you to refuse cookies or delete existing cookies. Disabling cookies may affect your ability to use certain Site features.

Global Privacy Control (GPC): If your browser transmits a Global Privacy Control signal, Kaiban will treat it as a valid opt-out from any sharing of your personal information for cross-context behavioral advertising to the extent applicable under California law (Cal. Civ. Code § 1798.135) and any other state law requiring GPC compliance.

5. Sharing and Disclosure of Information

Kaiban does not sell your personal information. We may share information in the following limited circumstances:

Service providers: We share information with vendors who assist in operating the Site and Kaiban's business, including website hosting and form providers, CRM and email marketing providers, productivity and collaboration tool providers, scheduling tool providers, design tool providers, and AI research tool providers. Each acts as a service provider under applicable law. You may request a list of specific service providers by emailing support@kaibanconsulting.com.

Legal requirements: We may disclose information when required by law, court order, subpoena, regulatory inquiry, or to protect the rights, property, or safety of Kaiban, its team, or others.

Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of Kaiban's assets, information held by Kaiban may be transferred as part of that transaction, subject to the same privacy protections described here.

No third-party marketing: We do not share your information with third parties for their own marketing, advertising, or promotional purposes.

7. Security

Kaiban implements commercially reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. Our practices include access controls, encrypted transmission protocols (HTTPS), role-based access limitations, and vendor security requirements.

No transmission of data over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security. If you have reason to believe that your personal information has been compromised, please contact us at support@kaibanconsulting.com.

8. Data Breach Notification

In the event of a data breach affecting your personal information, Kaiban will notify affected individuals and applicable state attorneys general or regulators as required by applicable law. Notification timelines vary by state. Kaiban's general practice is to provide notice within 30 calendar days of discovering a breach, subject to law enforcement requests for delay. California residents: in addition to individual notice, Kaiban will notify the California Attorney General as required when a breach affects more than 500 California residents. Notification will be provided via email to the address on file, or by substitute notice if direct notification is not feasible.

9. Your Privacy Rights

Depending on your state of residence, you may have the following rights with respect to your personal information. We will not discriminate against you for exercising any of these rights.

How to submit a request: You may submit a privacy rights request using either of the following methods:

1. Email: Send your request to support@kaibanconsulting.com with the subject line "Privacy Rights Request — [Your State]"

2. Web form: Submit via the contact form at kaibanconsulting.com/contact with "Privacy Rights Request" in the subject field

We will acknowledge receipt of your request within 10 business days and respond within 45 calendar days. If we require additional time, we will notify you of the extension.

Do Not Sell or Share My Personal Information: Kaiban does not sell personal information. We do not share personal information for cross-context behavioral advertising. If this practice changes, Kaiban will update this Policy and provide a "Do Not Sell or Share My Personal Information" opt-out mechanism on the Site homepage before doing so.

California residents may also contact the California Privacy Protection Agency at cppa.ca.gov for information about your rights.

Authorized agents: California and other state residents may designate an authorized agent to submit rights requests on their behalf. We may require verification of your identity and your agent's authorization before processing the request.

10. Point-of-Collection Notice

When you submit a contact form or inquiry on this Site, you are providing personal information directly to Kaiban. By submitting a form on this Site, you acknowledge that your information will be collected and used as described in this Privacy Policy.

11. Children's Privacy

The Site is not directed to individuals under the age of 13, and Kaiban does not knowingly collect personal information from children under 13. If you believe we have inadvertently collected information from a child under 13, please contact us at support@kaibanconsulting.com and we will delete it promptly.

12. Third-Party Links

The Site may contain links to third-party websites, platforms, or services. Kaiban is not responsible for the privacy practices of those sites. We encourage you to review the privacy policies of any third-party site you visit.

13. Governing Law and California Statutory Rights

This Privacy Policy is governed by the laws of the Commonwealth of Virginia, without regard to its conflict-of-laws principles, except where preempted by applicable federal law.

California Residents — Unwaivable Statutory Rights: Notwithstanding the Virginia governing law election, if you are a California resident, your rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), Cal. Civ. Code § 1798.100 et seq., are fully preserved and cannot be waived, limited, or diminished by this Policy or by any contract. Nothing in this Policy is intended to waive any right that California law deems non-waivable. All CCPA/CPRA rights requests will be honored as described in Section 9, regardless of governing law. Per Cal. Civ. Code § 1798.192, any provision of this Policy that purports to waive a California resident's CCPA/CPRA rights is void and unenforceable.

Other State Residents: To the extent your state of residence grants you privacy rights under applicable law that cannot be waived by contract (including Virginia, Connecticut, Colorado, Texas, and other states with active privacy statutes), those rights are preserved and will be honored by Kaiban consistent with applicable law.

14. Changes to This Policy

Kaiban reviews and updates this Privacy Policy at least annually and whenever material changes occur in our data practices or applicable law. When we make material changes, we will update the "Last Reviewed" date at the top of this page and, where required by applicable law, provide notice to affected individuals. Your continued use of the Site after any modification constitutes acceptance of the updated Policy.

15. Contact Us

For privacy-related questions, rights requests, or concerns:

Kaiban Consulting LLC Midlothian, Virginia Email:support@kaibanconsulting.comSubject line for rights requests: "Privacy Rights Request — [Your State]"

Kaiban Consulting LLC — Confidential and Proprietary — Version 2.0 — July 8, 2026This document is prepared for internal use and attorney review before final publication. It is not legal advice.