Privacy Policy

This Privacy Policy describes the types of information gathered by JMH Consulting Services LLC, trading as MyLA28 ("MyLA28", "we" or "us") in providing our website at www.myla28.com (the "Site"), and also in providing a scheduling tool and itinerary builder for events and locations of the 2028 Summer Olympics, including both free and paid tiers of service, all as made available through the Site (collectively, the "Service"), how we use information, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information, and our efforts to protect the information you provide to us through the Site.

By using the Service, you hereby consent to allow us to process information in accordance with this Privacy Policy. Please also refer to our Terms of Service, which are incorporated into this document as if repeated in full. Capitalized terms found here which are not defined in this Privacy Policy shall have the same definition as in the Terms of Service.

Territoriality

Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY VISITING THE SITE AND USING THE SERVICE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND, TO THE EXTENT POSSIBLE, THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

Who Collects Your Information On Our Service?

We do. JMH Consulting Services LLC collects information from you, and we are responsible for the protection of your information.

What Information Do We Collect?

Personal Information

We collect certain personal information about you, which may be supplied when you register or sign up for the Service, when you create or update your account, when you purchase access to the paid tier of the Service, when you use the Site, when you build an itinerary, and also when any other information about you is submitted to us, directly or indirectly. The types of personal information we collect and save include:

• Contact and account information such as name, email address, and (if you choose to provide it) accommodation address(es) where you will be staying during the Olympics.
• Google Login information: If you choose "Login with Google," we collect your name and email address from your Google account. We do not receive your Google password. Google's own privacy policy (available at https://policies.google.com/privacy) governs their collection and handling of your information during the login process.
• Facebook Login information: If you choose "Login with Facebook," we collect your name and email address from your Facebook account. We do not receive your Facebook password. Facebook's own privacy policy (available at https://www.facebook.com/privacy/policy/) governs their collection and handling of your information during the login process. You also agree to Facebook's Login Terms.
• Payment information: Although it may appear that we collect financial information, it is actually collected and processed through our third-party payment processor ("Payment Processor"). Our Payment Processor collects information such as credit card number, name, billing address, CVV code, and expiration date from you at the time of purchase. We do not hold your financial information. We receive only a confirmation of payment, the amount paid, and the date of transaction.
• Technical information collected in our logs. Such information may include standard web log entries that contain your IP address, first-party cookies (for the session only), page URL, timestamp, browser type, and operating system.
• Itinerary data: Event selections, saved schedules, notes, and travel preferences you create within the Service.

You may also provide us information when you interact with us through email or online chat. We may retain such information in order to provide you with Services.

The Service does not currently request permission to access your photo gallery, camera roll, or other device storage.

Non-personal Information

Non-personal information is anonymous or non-personally identifiable information about you, including but not limited to which events are added to itineraries most frequently, how pages are used, search terms entered, and similar non-personal data.

Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online. An IP address is a number assigned to your device whenever you surf the internet, and may make it possible to identify your approximate location (e.g., city or region). Further, the Service may utilize web beacons, pixel tags, cookies, embedded links, and other commonly used information-gathering tools. If non-personal information is paired or linked to any of your personally identifiable information ("PII"), we will treat that non-personal information as if it were also PII.

Aggregate Information

We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, location (city/region from IP address), device information, session information, page views, operating system, referral sites, and time spent on the page.

Why Is My Information Being Collected?

We collect information to provide the Service to you, including both free and paid features. We need to collect your personal information to, among other things: create and manage your account, process payments for paid access, build and save your itineraries, calculate estimated travel times between your saved accommodation address and event locations, and enable navigation features. We also collect aggregate information to help us improve the Service and diagnose technical problems. We collect log information for monitoring purposes to help us administer the Service, calculate usage levels, and maintain security.

How Do We Use the Information We Collect?

We use the personal information you provide for the purposes for which you have submitted it including:

Internal Uses. We may use your PII to respond to your inquiries, track usage trends, prevent fraud or abuse, develop and improve the Service, and perform research and analytics.

Creating and Maintaining Your Account. We use your name and email to create and manage your account. If you register with a username/password, we store those credentials securely.

Processing Payments. Our Payment Processor uses your financial information to charge you $10 (plus applicable tax) for access to the paid advanced scheduler tool. We do not see or store your full payment card details. We are PCI DSS compliant as a merchant (SAQ A).

Providing Itinerary & Travel Features. We use your saved accommodation address(es) to calculate estimated travel times to Olympic events. When you click the "navigate" button, we pass your chosen address (or future real-time location, with your permission) to Google Maps or Apple Maps. We do not control those third-party services.

Communicating With You About Our Services. We may use your email to contact you in the event certain information is missing or incorrect, to send service-related announcements (e.g., scheduled maintenance, feature updates), or to send receipts and payment confirmations.

Sending Administrative Emails. We may use your email to: (a) confirm your account creation; (b) confirm your payment and upgrade to paid access; (c) provide you with information regarding the Service; (d) inform you of changes to this Privacy Policy, our Terms of Service, or other policies.

Sending Marketing and Promotional Emails. We may use your email to send you newsletters, tips, or information about new features. You may opt out at any time using the unsubscribe link in any such email. Opting out of marketing emails will not affect administrative or transactional emails (e.g., payment receipts).

Future Location Features (with consent). If and when we implement real-time location tracking via a progressive web app, we will first obtain your explicit permission. You may revoke that permission at any time via your browser or device settings. Note: You will receive a separate privacy policy update before this feature launches.

We may use anonymous information to improve the design and content of our Service, and to personalize your experience.

Do We Share Your Personal Information?

We will not share your personal information except: (a) for the purposes for which you provided it; (b) with your consent; (c) as may be required by law or as we think necessary to protect our organization (including the defense of legal claims) or others from injury (e.g., in response to a court order or subpoena, or a law enforcement agency request); or (d) with persons or organizations with whom we contract to carry out internal operations or business activities (e.g., hosting provider, payment processor, email service provider) subject to confidentiality obligations.

We do not sell your personal information to anyone.

We may also share aggregate, de-identified information with others, including affiliated and non-affiliated organizations.

Finally, we may transfer or disclose your personal information to a third party, or our successor in interest, in connection with, or as the result of, an acquisition, sale, merger or bankruptcy involving our company.

How Can You Access And Control Your Information?

After becoming a user of the Service, you may revise or edit your information through your account settings, or by sending an email to info@myla28.com. You may request access to your personal information that we have collected, or request correction of errors, by emailing legal@myla28.com. You may request deletion of your account and all associated personal information by emailing legal@myla28.com with "Delete My Account" in the subject line. Note: Deleting your account will terminate your access to the paid advanced scheduler tool, and under our no-refunds policy, we will not issue refunds for unused portions of paid access.

You may opt out of receiving promotional and marketing emails by using the unsubscribe feature in the email or by emailing info@myla28.com with "Opt-Out" in the subject line.

How Do We Store and Protect Your Information?

After receiving your personal information, we will store it for as long as your account is active or as needed to provide the Service (including to maintain records of paid transactions for tax and legal compliance). We have physical, electronic, contractual, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Our hosting platform uses industry-standard encryption (e.g., TLS for data in transit, AES for data at rest). Our Payment Processor is PCI-DSS compliant. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers' systems.

If you are visiting the Site from outside the USA, your connection will be through and to servers located in the USA, and your information will be stored in servers located within the USA.

We store your personal information until you request us to delete it, or after a period of prolonged account inactivity (e.g., 12 months), except for transaction records which we may retain for up to 7 years for tax and accounting purposes. We may store logs and other technical records for a shorter period (e.g., 90 days) for security and troubleshooting purposes.

How Do We Use Cookies And Other Network Technologies?

To enhance your online experience with us, our web pages may use "cookies." Cookies are text files that our web server may place on your computer's hard drive to store your preferences (e.g., keeping you logged in during a session). Cookies, by themselves, do not tell us your email address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. You may disable cookies through your browser settings, but certain features of the Service may not function properly (e.g., you may have to log in repeatedly).

Cookie Consent: Upon your first visit, we will display a cookie banner asking for your consent to set non-essential cookies (including Google Analytics). Essential cookies (e.g., session login) do not require consent. You may change your preferences at any time.

Our Service uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 ("Google"). Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Service and report on activities and trends. This service may collect information regarding the use of other websites, apps and online resources. For more information on how Google uses data when you use our Site, please visit: https://policies.google.com/technologies/partner-sites . You may opt out of Google Analytics by downloading the browser add-on available at https://tools.google.com/dlpage/gaoptout .

We do not currently use Facebook pixels, custom audience pixels, or similar ad retargeting tools. If we add them in the future, we will update this policy.

Do Not Track. At present, the Site does not specifically respond to browser do-not-track signals. Some state laws, including California, require this disclosure, and we provide it here.

Collection of Information by Others.

Our Service includes links to third-party websites and apps, specifically Google Maps and Apple Maps, which you access when you click the "navigate" button. Please check the privacy policies of Google and Apple to learn how they collect, use, store and share information that you may submit to them or that they collect (including your location and address information).

Children and Young People's Information - COPPA Compliance

We comply with the Children's Online Privacy Protection Act ("COPPA"). The Service is not intended for children under 13 years of age. We do not knowingly collect personal information from anyone under 13. If you are between the ages of 13 and 18, you may only use the Service with the permission and supervision of a parent or legal guardian. By registering for an account, you confirm that you meet these age requirements.

During account creation, we require all users to confirm their date of birth. If we discover that a user under 13 has provided personal information to us, we will immediately delete their account and all associated data. If you believe your child under 13 has used our Service without your permission, please contact us at legal@myla28.com.

Information for European Users (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, the following additional terms apply to you under the General Data Protection Regulation (GDPR).

Legal Bases for Processing

We process your personal information only when we have a legal basis to do so. The legal bases we rely on include:

• Contract performance: To provide the Service you have requested, including account creation, itinerary building, and paid access.
• Legitimate interests: To improve our Service, prevent fraud, and communicate administrative updates.
• Consent: For marketing emails, Google Analytics cookies, and (in the future) real-time location tracking. You may withdraw consent at any time.
• Legal obligation: To retain transaction records for tax purposes.

Your GDPR Rights

You have the following rights, which you may exercise by emailing legal@myla28.com:

• Right to access: Request a copy of your personal data.
• Right to rectification: Correct inaccurate or incomplete data.
• Right to erasure ("right to be forgotten"): Request deletion of your data, subject to legal retention obligations (e.g., tax records).
• Right to restriction: Limit how we use your data while a complaint is investigated.
• Right to data portability: Receive your data in a structured, machine-readable format.
• Right to object: Object to processing based on legitimate interests (e.g., marketing).
• Right to withdraw consent: Withdraw any consent you have given (e.g., for marketing emails or cookies).

International Transfers

Your personal data is transferred to and processed in the United States. The United States has not received an adequacy decision from the European Commission. We rely on Standard Contractual Clauses (SCCs) with our hosting provider and payment processor to ensure an adequate level of data protection. By using the Service, you acknowledge this transfer.

Right to Lodge a Complaint

You have the right to lodge a complaint with your local supervisory authority (e.g., the ICO in the UK or your national Data Protection Authority).

Data Protection Officer (DPO)

We do not have a statutory DPO because we are not a large-scale processor. For GDPR inquiries, contact us at legal@myla28.com.

California Privacy Rights

California law allows California residents to request information regarding our disclosures to third parties in the prior calendar year, if any, of their personally identifiable information. We do not sell your personal information. To make a request regarding our disclosures, please contact us at legal@myla28.com with "Request for Privacy Information" in the subject line. Please include your name, email, and username (if any). We will respond within 30 days.

Limit the Use of My Sensitive Personal Information: If we enable real-time location tracking, California residents may limit use of that sensitive personal information by disabling location services in their browser/device settings or by emailing legal@myla28.com with "Limit Location Use" in the subject line.

Do Not Sell or Share My Personal Information: If we later enable advertising or analytics that share your information for cross-context behavioral advertising, we will update this policy and provide a "Do Not Sell or Share My Personal Information" link as required by California law. You may also opt out of any future "sale" of your information by emailing legal@myla28.com with "Opt-Out of Sale" in the subject line.

CAN-SPAM

In accordance with the CAN-SPAM Act, you may opt out or unsubscribe from future promotional emails by following the prompts in our emails, or by emailing us at info@myla28.com with "Opt-Out" in the subject line.

Changes to this Policy

Because our business needs may change over time, we reserve the right to modify this Privacy Policy. If at any time in the future we plan to use your PII in a way that differs from this Privacy Policy, we will revise this Privacy Policy as appropriate. In the event of a change, we will post the updated policy to the Site, email it to the email address you provided, or otherwise notify you. Your continued use of the Service following notice of changes means you accept such changes. Please refer to the "Effective Date" above to see when this Policy was last updated.

Our Contact Information

If you have any questions or concerns about this Privacy Policy you may e-mail us at: legal@myla28.com or info@myla28.com

Copyright © JMH Consulting Services LLC. All rights reserved. The Service is the property of JMH Consulting Services LLC and is protected by national and international copyright, trademark, and other applicable laws. All Olympic-related names and marks are property of their respective owners.