Privacy Policy

1. Introduction

This Privacy Policy explains how MCI USA Operating Co. ("MCI," "we," "us," or "our") collects, uses, discloses, and protects personal information in connection with Jade (the "Platform" or "Services"), including registration, housing, sourcing, mobile app, exhibitor, lead, onsite, support, reporting, API, webhook, and AI-assisted workflows.

2. Scope and Roles (Organizer vs. End User)

Jade supports events operated by Organizers. In many cases:

• The Organizer determines why and how personal data is processed for an event (the "controller" or equivalent role).
• MCI processes personal data on behalf of the Organizer to provide the Services (the "processor" or equivalent role).

For enterprise customers, processing terms may be governed by a Data Processing Addendum (DPA). If you have questions about an event's data practices (such as how to exercise rights), you may also need to contact the Organizer directly.

3. Personal Information We Collect

We collect information from Organizers, Attendees, Exhibitors, and other Users.

3.1 Information You Provide

Depending on the event and configuration, we may collect:

• Identifiers and contact details (e.g., name, email, phone number, mailing address);
• Account credentials (username, password, authentication tokens);
• Registration and profile details (e.g., employer/organization, job title, attendance preferences);
• Housing and accommodation details (e.g., check-in/out dates, rooming preferences, rooming lists, and hotel confirmation details);
• Event participation details (e.g., session selections, speaker submissions, survey responses, CE credits, badge or wallet pass details, mobile app activity, appointments, and attendance/check-in records);
• Exhibitor and lead details (e.g., company profiles, booth information, staff, lead scans, lead qualifiers, collateral selections, and prospect invitations);
• Sourcing and contract details provided by suppliers, venues, or event teams where those workflows are enabled;
• Communications (support requests, chat messages, emails sent through the Platform);
• Accessibility, dietary, or other special assistance information (which may be considered sensitive under certain laws);
• Government ID or travel documentation information if required by the event (processed on Organizer instructions);
• Event-related content you upload (documents, images, notes).

3.2 Payment Information

Jade supports payment processing via third-party Payment Processors such as Stripe. Where an event uses credit-card guarantees rather than immediate charges, card details may be tokenized through a third-party vault such as Basis Theory. Payment card information is provided directly to Payment Processors and handled under their security standards and terms. MCI does not store full payment card numbers.

3.3 Automatically Collected Information

When you use the Services, we may automatically collect:

• device and browser information;
• IP address and approximate location derived from IP;
• log data (access times, pages/actions, error reports);
• identifiers needed for authentication and security;
• usage analytics and performance data.

3.4 Cookies and Similar Technologies

We use cookies and similar technologies for authentication, security, preferences, and analytics. See the Cookie Policy for details.

4. How We Use Personal Information

We use personal information to:

• provide, operate, and maintain the Services;
• process registrations, housing, and event-related workflows;
• process payments and manage refunds/chargebacks with Payment Processors and Organizers;
• support approvals, pricing rules, discounts, sourcing, lead retrieval, mobile app, onsite, and recommendation workflows (including via AI Features where configured);
• send transactional and event-related communications (confirmations, updates, receipts);
• provide customer support and respond to requests;
• monitor, prevent, and investigate fraud, abuse, and security incidents;
• improve, debug, and enhance the Services;
• comply with legal obligations and enforce our Terms and Policies.

5. AI Processing and Automated Decision-Making

Jade uses AI Features for tasks such as data validation, normalization, event setup assistance, support, analytics, recommendations, report drafting, document analysis, and suggested actions (depending on configuration).

• Automated workflows: Some features may involve automated or rule-based processing that affects Users (for example, eligibility routing, approvals, pricing tiers, discounts, fraud signals, or recommendations). Where applicable, Organizers may configure workflows and controls.
• No training on personal data: MCI does not use Customer Data or Attendee/Exhibitor personal data to train general-purpose AI models.
• Human oversight: Human review and override may be available depending on configuration and operational processes.

For more, see the AI Use & Transparency Policy.

6. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients:

6.1 Service Providers and Subprocessors

We use service providers ("subprocessors") to operate the Services, including:

• Microsoft Azure — Cloud hosting and infrastructure
• Amazon Web Services (AWS) — Cloud hosting and infrastructure (as applicable)
• MongoDB Atlas — Database hosting
• Stripe — Payment processing
• Basis Theory — Card vaulting for guarantee-only payment instruments where configured
• Mailjet / Mailgun — Email delivery and messaging
• OpenAI — AI-assisted platform features where configured
• Apple Wallet / Google Wallet providers — Wallet pass issuance where configured

6.2 Organizers and Event Stakeholders

Information may be shared with the Organizer operating the event and authorized event stakeholders (e.g., housing teams, exhibitors management, on-site check-in) consistent with the event configuration.

6.3 Legal, Safety, and Compliance

We may disclose information if we believe in good faith that disclosure is necessary to:

• comply with law or legal process;
• protect rights, safety, and security of MCI, Users, or the public;
• investigate and prevent fraud, abuse, or security incidents; or
• enforce our agreements and policies.

6.4 Business Transfers

If MCI is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, personal information may be transferred as part of that transaction subject to appropriate safeguards.

7. Data Retention

We retain personal information for as long as necessary to:

• provide the Services and operate events;
• comply with legal and accounting obligations;
• resolve disputes; and
• enforce agreements.

Retention periods may vary by event and contract. Organizers may control retention for event data under their agreements with MCI. We may retain de-identified or aggregated data that no longer identifies an individual.

8. Security

We implement administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, access controls, and monitoring. No method of transmission or storage is 100% secure; we cannot guarantee absolute security.

9. Children's Privacy

The Services are not directed to children under 13. If an event involves minors, Organizers are responsible for obtaining any required parental or guardian consent and providing appropriate notices. If we learn we collected personal information from a child under 13 without appropriate authorization, we will take steps to delete it.

10. US State Privacy Rights

Depending on your state of residence, you may have rights regarding your personal information, such as the right to access, correct, delete, or obtain a copy of your data, and to opt out of certain processing.

Because many events are operated by Organizers (who may be the controller), we may direct certain requests to the Organizer or assist them as required under our DPA. To submit a request, contact legal@wearemci.com and identify the event and your role (Attendee/Exhibitor/Organizer).

Non-discrimination: We will not discriminate against you for exercising applicable privacy rights.

11. Do Not Track

Some browsers offer "Do Not Track" signals. The Services do not respond to Do Not Track signals in a uniform manner because standards are not finalized.

12. International Data Transfers; Future Expansion

At launch, the Services are hosted in the United States. If we expand hosting to additional regions (including the EU), we will implement appropriate safeguards as required by applicable laws (such as contractual protections and transfer mechanisms).

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated policy and update the "Last Updated" date. Material changes may be accompanied by additional notice as required by law.

14. Contact

For questions or requests, contact: legal@wearemci.com.