Pilot Program
Last updated: 1 August 2026
This Privacy Policy explains what personal data Pebbles LLC collects, uses, shares and retains via the app during the pilot phase for a closed group of invited participants.
Pebbles LLC is granting you access to a relationship intelligence application called “Pebbles” during the specified pilot period in accordance with the Terms of Use.
We collect via the app the following categories of personal data:
If you submit any personal data relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
We may use your personal data to:
We do not use your personal data for advertising, profiling, or any purpose beyond those stated herein. We also do not sell your data to third parties.
The categories of third parties with whom we may share your personal data include:
Subject to certain exceptions and depending on where you live, you may have the right to:
You may also have the right to object at any time, in accordance with law, to our processing of your personal data where such processing is based on our or a third party’s legitimate interest.
You have the right to be free from unlawful discrimination for exercising your rights under applicable law.
Some states (including but not limited to California, Texas and Virginia) have specific rights for their residents. For information about those rights, see the Supplemental US Privacy Rights section below.
To exercise your rights under applicable law, contact us by email at anneka@withpebbles.com.
We retain your personal data only as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted under applicable law.
Pebbles LLC uses technical and organisational measures designed to guard against unauthorised access or other use of your personal data. While we take reasonable precautions, no system is completely secure.
Pebbles is not intended for use by anyone under the age of 18. We do not knowingly collect data from minors. If we become aware that a minor has provided us with personal data, we will delete it promptly.
Residents of Alabama, California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah or Virginia may be entitled to further information about our practices and have additional privacy rights, which are described in this section.
The following chart details which categories of personal data we collect and process, as well as which categories of personal data we disclose for our operational business purposes, including within the 12 months preceding the date this Privacy Policy was last updated. We have not “shared” your personal data for purposes of cross-context behavioural or targeted advertising, including within the 12 months preceding the date this Privacy Policy was last updated. We do not “sell” your personal data as defined under applicable law, including for payment or similar consideration, and we have not “sold” your personal information within the 12 months preceding the date of this Privacy Policy.
| Categories of Personal Information | Disclosed to which categories of third parties |
|---|---|
| Identifiers, such as name, email address, IP address, and online and device identifiers | Service providers, regulatory or government agencies, others as may be required by law |
| Cal. Civ. Code §1798.80(e) records — name, email address, employment information, education information | Service providers, regulatory or government agencies, others as may be required by law |
| Professional or employment-related information — participant’s school, cohort, graduation year, networking goals; and the employer, job title, and meeting context recorded about their contacts | Service providers, regulatory or government agencies, others as may be required by law |
| Internet or other electronic network activity information | Service providers, data analytics providers, regulatory or government agencies, others as may be required by law |
As described in the Personal Data We Collect section above, we may collect your personal data directly from you, automatically through your use of the app, and from other categories of sources such as social media platforms.
As described in the How We Use Personal Data section above, we may use your personal data to provide the app and associated services to you, to authenticate your ability to access and/or use the app, to provide and improve products and services, to operate, manage, and maintain our business, to respond to your inquiries and fulfil your requests, and to send administrative information to you. We may also use your personal data for our business purposes and objectives, including data analysis, developing new products, improving existing products, identifying usage trends, troubleshooting issues and expanding our business activities. Additionally, we may use your personal data to comply with applicable law, legal process, respond to requests from public and government authorities and to protect our rights, operations, and enforce our terms of use.
As described in the Data Retention section above, we may retain your personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Policy, depending on the length of our relationship with you, whether there is a legal obligation to which we are subject or retention is advisable in light of our legal position.
The Terms of Use governing your use of the app do not permit you to upload any sensitive personal data as that term is defined under applicable law. As such, Pebbles LLC does not process sensitive personal data.
Pebbles LLC has no actual knowledge that it sells or shares personal data of consumers under 16 years old.
Subject to certain exceptions and depending on where you live, you may have the right to make the following requests, at no charge:
You have the right to be free from unlawful discrimination for exercising your rights under applicable state law.
If you wish to exercise a right, you may email us at anneka@withpebbles.com. We will verify and respond to your request in accordance with applicable law, taking into account the type and sensitivity of the personal data subject to the request. In some instances, we may decline to honour your request where the law or right you are invoking does not apply or where an exception applies. If we refuse to take action on your request, you may have the right under applicable law to appeal the refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by emailing us at anneka@withpebbles.com. If you want to make a request as an authorised agent on behalf of an individual under applicable law, you may use the contact methods noted above. As part of our verification process, we may request that you provide us with proof that you have been authorised by the individual on whose behalf you are making the request under applicable law, which may include signed permission provided by such individual.
If you have any questions or concerns about this Privacy Policy, you may email us at anneka@withpebbles.com.
Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify it.
We may update this Privacy Policy from time to time and therefore we invite you to keep checking this Policy periodically. The date on which this Policy was last modified will be updated at the top of this Policy.
Questions about this Privacy Policy? Contact us at anneka@withpebbles.com.