Last Updated: April 10, 2026

1. WELCOME

JailGeek, Inc. (“JailGeek,” “we,” “us,” or “our”) operates the website located at www.jailgeek.com (the “Website”) and portal located at app.jailgeek.com (the “Portal,” and together with the Website, the “Sites”). JailGeek provides cloud-based software that assists state and local governments with complex federal cost accounting processes related to federal detention reimbursement, federal jail space management, and related operational support for state and local detention facilities and their government operators (collectively, the “Services”).

This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you visit our Sites, use our Services, or otherwise interact with us, in compliance with the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”), and other applicable U.S. privacy laws.

By accessing the Sites on any computer, mobile phone, tablet, or other device (collectively, a “Device”) or otherwise interacting with JailGeek, you agree to the terms of this Privacy Policy. If you do not agree, please do not use the Sites or Services.

In the course of providing our Services, JailGeek may process data that our clients submit or make available through the Portal (“Customer Data”). Our use and processing of Customer Data is governed by the applicable service agreement and any data processing terms between JailGeek and the client, not this Privacy Policy. This Privacy Policy applies to personal information we collect from visitors to our Website; prospective, current, and former clients; newsletter subscribers; Portal account holders (with respect to their account and usage information); and individuals who otherwise contact us.

2. INFORMATION WE COLLECT

2.1 Information Collected Directly From You

We collect personal information that you voluntarily provide when you interact with us through the Sites, including when you submit inquiries, request a consultation or demo, subscribe to our communications, create a Portal account, or otherwise contact us.

A. Inquiry, Consultation, and Demo Requests.

When you submit a contact, consultation, or demo request form on our Website, we may collect:

• • • first and last name
    • email address
    • phone number
    • state or local detention center
    • position or title
    • average daily population held in the detention center
    • average number of federal detainees
    • details regarding federal detention funding

B. Newsletter and Marketing Subscription Information.

If you subscribe to our newsletter or product updates, we collect your email address and any other information you provide in connection with your subscription.

C. Account and Portal Information.

If you are a client or authorized user of the Portal, we collect information necessary to create and manage your account, including your name, email address, username, password, state or local detention center affiliation, and role or title.

D. Payment and Billing Information.

In connection with paid Services, we collect payment and billing information, such as billing name, billing address, and payment method details. Payment card information is generally processed by our third-party payment processors, and we may receive only limited transaction data (such as payment status and partial card metadata).

E. Communications, Support Inquiries, and Feedback.

We collect the content of your communications when you contact us by email, phone, or through the Sites, including support requests, feedback, and any other correspondence.

2.2 Information Collected Automatically

When you use our Sites, we may automatically collect certain technical and usage information, including:

• IP address
• browser and device characteristics
• operating system
• language preferences
• referring URLs
• device type and device name
• approximate location based on IP address
• date and time of access
• pages visited and interactions with the Sites
• server log information

When you access our Sites through a mobile device, we may also automatically collect certain mobile device information, including device type, mobile operating system, and mobile browser type.

2.3 Information Received From Third Parties

We may receive information about you from third-party sources, such as business partners, analytics providers, or publicly available sources, and combine it with other information we collect about you. We use this information in accordance with this Privacy Policy.

3. HOW WE USE INFORMATION

We use the information we collect for the purposes described in this Privacy Policy, including to:

• provide, operate, and maintain our Sites and Services
• process transactions and manage client accounts
• respond to inquiries, demo requests, consultation requests, and customer support communications
• send administrative communications, including confirmations, updates, policy notices, and security alerts
• improve, personalize, and enhance our Sites and Services
• analyze usage patterns, trends, and analytics of our Sites and Services
• prevent, investigate, and respond to fraud, unauthorized access, and other unlawful activity
• enforce our Terms of Service and policies and protect the rights, property, and safety of JailGeek, our clients, and the public
• comply with legal obligations
• establish, exercise, or defend legal claims

You may opt-out of marketing communications at any time by following the unsubscribe instructions in our emails or by contacting us using the information provided below.

4. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies to operate our Sites, remember your preferences, enhance functionality, analyze how visitors use our Sites, and support our communications and marketing efforts.

For more detailed information regarding the types of cookies and similar technologies we use, how you can manage your cookie preferences, and your rights and choices, please review our Cookie Policy.

5. HOW WE DISCLOSE INFORMATION

as defined under applicable state laws, including the CCPA. We may disclose personal information in the following circumstances:

5.1 Service Providers

We may share personal information with service providers and contractors that help us operate our Sites and business, such as:

• website hosting and infrastructure providers
• IT and cybersecurity vendors
• email and communications vendors
• payment processors
• analytics and performance tools
• customer support tools
• legal, accounting, and professional advisors

These service providers are contractually required to use your information solely to provide services to us and for no other purpose.

5.2 Internal Business Operations

Where necessary, personal information may be shared internally within JailGeek with management, operations, client support, and other personnel for legitimate business purposes.

5.3 Analytics Services

We use third-party web analytics services, including Google Analytics, to help us understand how visitors use our Sites. Information collected through these analytics services is automatically sent to the analytics provider, which may use cookies to assist with the analysis. Google Analytics may also provide demographic, interest-related, geographic, and referral data that JailGeek may use to better understand our user base.

5.4 Advertising and Targeted Content

JailGeek may work with advertising partners to deliver relevant content or advertisements based on your interactions with our Sites. Depending on the tools and technologies used, certain disclosures of information to advertising partners could be considered “sharing” for cross-context behavioral advertising under applicable state privacy laws.

5.5 Legal Requirements

We may disclose personal information if required to do so by law (including in response to a subpoena, court order, or request from law enforcement or another government authority) or in the good faith belief that such disclosure is necessary to (i) comply with a legal obligation, (ii) protect or defend our rights, interests, or property, (iii) act in urgent circumstances to protect the personal safety of users or the public, or (iv) protect against legal liability or potential fraud.

5.6 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, personal information may be transferred as part of that transaction, subject to continued protection consistent with this Privacy Policy.

5.7 With Your Consent

We may disclose your information for other purposes with your explicit consent.

6. DATA RETENTION

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including:

• responding to inquiries and managing client relationships
• providing and supporting the Services
• maintaining business and financial records
• complying with legal, regulatory, and accounting obligations
• resolving disputes and enforcing our agreements

Retention periods may be extended where required or permitted by applicable law.

7. SECURITY

We implement appropriate technical, administrative, and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity conducted under your Portal account.

8. YOUR PRIVACY RIGHTS AND U.S. STATE DISCLOSURES

8.1 Rights for All Users

Depending on your state of residence and subject to applicable law, you may have the following rights with respect to your personal information:

1. 1. Access. Request confirmation of whether we process your personal information and access to such information.
   2. Correction. Request correction of inaccurate personal information.
   3. Deletion. Request deletion of your personal information, subject to legal exceptions.
   4. Opt-Out of Marketing. Unsubscribe from marketing communications by using the unsubscribe link in our emails or by contacting us directly.
   5. Non-Discrimination. We will not discriminate against you for exercising your privacy rights.

8.2 United States State Privacy Rights

If you are located in the United States, this Privacy Policy explains how we collect, use, and disclose your personal information under applicable state privacy laws. While we disclose personal information to service providers for the business purposes described in Section 5, we do not “sell” your personal information. We do not collect “sensitive” personal information for purposes that would trigger additional consent requirements or a “Right to Limit” under applicable state laws, as our collection is limited to necessary business purposes.

8.3 California-Specific Notice (CCPA/CPRA)

California residents have the following additional rights:

1. 1. Right to Know. Request disclosure of:
      • categories of personal information collected
      • categories of sources from which personal information is collected
      • business or commercial purposes for collecting personal information
      • categories of third parties to whom we disclose personal information
      • specific pieces of personal information we have collected about you

3. 2. Right to Delete. Request deletion of personal information we have collected from you, subject to certain exceptions (e.g., completing transactions, detecting security incidents, complying with legal obligations, internal uses reasonably aligned with your expectations).
   3. Right to Correct. Request correction of inaccurate personal information we maintain about you.
   4. Right to Opt-Out. Opt out of the sale or sharing of personal information. As stated above, we do not sell personal information.
   5. Right to Limit Use of Sensitive Personal Information. Limit our use and disclosure of sensitive personal information to permitted purposes.
   6. Right to Non-Discrimination. We will not discriminate against you for exercising your CCPA/CPRA rights.

8.4 Authorized Agents

California residents may designate an authorized agent to submit privacy rights requests on their behalf by providing written authorization to privacy@jailgeek.com. We may require you to verify your identity directly with us and confirm that you authorized the agent to submit the request.

8.5 Response Time and Verification

We will confirm receipt of your request within 10 business days and respond within 45 days (extendable by an additional 45 days with notice). We will verify your identity before fulfilling your request by comparing the information you provide with our records.

8.6 Categories of Personal Information Collected (Last 12 Months)