Effective Date: 01/01/2026
Company: 88ninety LLC
Jurisdiction: State of Maryland, United States

88ninety LLC (“88ninety,” “Company,” “we,” “our,” or “us”) is committed to protecting your privacy while maintaining appropriate legal safeguards for our business operations.

This Privacy Policy describes how we collect, use, disclose, transfer, retain, and protect personal information in connection with:

• www.88ninety.com (the “Website”)
• Client service engagements
• Internship and educational programs
• Electronic communications
• Electronic payments

By accessing the Website or submitting personal information, you acknowledge and agree to this Privacy Policy.

Scope of Policy

This Privacy Policy applies to:

• Website visitors
• Internship applicants
• Job applicants
• Business clients and prospects
• Vendors and contractors

This Policy does not apply to information governed by separate written agreements (e.g., client contracts or NDAs).

Categories of Information Collected

We may collect the following categories of personal data:

A. Identifiers

• Name
• Email address
• Phone number
• IP address
• Mailing address

B. Professional & Educational Information

• Resume/CV
• Education history
• Employment history
• Skills and certifications

C. Commercial Information

• Payment information
• Transaction records
• Engagement details

D. Technical Information

• Browser type
• Device identifiers
• Website usage data
• Cookies and analytics information

E. Communications

• Emails
• Messages submitted via forms

We collect information directly from you and automatically through Website technologies.

Legal Bases for Processing (GDPR Compliance)

If you are located in the European Economic Area (EEA), United Kingdom, or other jurisdictions recognizing similar rights, we process personal data based on:

• Consent
• Performance of a contract
• Legitimate business interests
• Legal obligations
• Protection of legal claims

By submitting information, you consent to its processing in the United States.

How We Use Information

We use personal information to:

• Evaluate internship and employment applications
• Provide contracted services
• Process electronic payments
• Communicate with clients and applicants
• Improve Website functionality
• Prevent fraud and maintain security
• Enforce legal rights
• Comply with laws and regulatory requirements

We do not sell personal information.

Electronic Payments & Financial Data

Payments are processed through third-party secure payment processors.

We:

• Do not store full credit card numbers
• Do not directly process raw card data
• Rely on PCI-compliant providers

We disclaim liability for security failures attributable to third-party processors beyond our reasonable control.

Data Sharing & Disclosure

We may disclose personal information:

• To service providers (hosting, analytics, payment processors)
• To professional advisors (lawyers, accountants)
• In response to subpoenas or legal processes
• To protect our legal rights
• In connection with mergers, acquisitions, or asset transfers

We require service providers to implement reasonable safeguards but do not guarantee their independent security practices.

International Data Transfers

Personal information may be transferred to and processed in the United States.

If you are located outside the U.S., you acknowledge:

• U.S. data protection laws may differ from your jurisdiction
• You voluntarily consent to international transfer
• We rely on standard contractual protections where required

Data Retention

We retain personal information only for as long as reasonably necessary to:

• Fulfill business purposes
• Comply with legal obligations
• Defend against legal claims
• Maintain business records

We may retain limited data after deletion requests if required by law or necessary for legitimate business purposes.

Data Security

We implement commercially reasonable administrative, technical, and physical safeguards.

HOWEVER:

• No system is 100% secure
• We do not guarantee absolute security
• You submit data at your own risk

To the fullest extent permitted by law, we disclaim liability for unauthorized access caused by factors beyond our reasonable control.

Your Rights – GDPR

If you are in the EEA or similar jurisdiction, you may have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion
• Restrict processing
• Object to processing
• Data portability
• Withdraw consent

Requests may be submitted to: info@88ninety.com

We may:

• Verify identity before fulfilling requests
• Deny requests where legally permitted
• Charge reasonable administrative fees for excessive requests

California Privacy Rights (CCPA/CPRA)

If you are a California resident, you may have the right to:

• Know what personal information we collect
• Request deletion
• Request correction
• Opt out of “sale” or “sharing” (we do not sell personal data)
• Non-discrimination for exercising rights

To exercise your rights, email: info@88ninety.com
Subject Line: “California Privacy Request”

We will respond within legally required timelines.

We may require identity verification before processing requests.

Data Deletion Request Workflow

To request deletion:

1. Submit a written request to info@88ninety.com
2. Include full name and email used on the Website
3. Provide proof of identity (if requested)

We will:

• Confirm receipt within 10 business days
• Verify identity
• Process the request within 45 days (or as required by law)

We may deny deletion if:

• Required for legal compliance
• Necessary for contractual obligations
• Required to defend legal claims
• Needed for fraud prevention

Children’s Privacy

Our Website and services are intended for individuals 18 years or older.

We do not knowingly collect data from minors. If discovered, such data will be deleted promptly.

Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW:

88ninety LLC shall not be liable for:

• Indirect damages
• Consequential damages
• Data loss
• Unauthorized access
• Cyber incidents
• Third-party breaches

Total liability shall not exceed the amount paid to us (if any) in the twelve (12) months preceding the claim.

Maryland Governing Law

This Privacy Policy shall be governed by the laws of the State of Maryland, without regard to conflict of law principles.

Any disputes shall be brought exclusively in the state or federal courts located in Maryland.

You consent to jurisdiction in Maryland courts.

Changes to This Policy

We reserve the right to modify this Privacy Policy at any time.

Changes will be posted with a revised effective date.

Continued use of the Website constitutes acceptance of updates.

Contact Information

88ninety LLC
State of Maryland
United States

Email: info@88ninety.com
Website: www.88ninety.com