Part 1: 15-Day Limited Warranty

1. Overview

JCC Business Solutions ("JCC," "we," "us") provides a 15-calendar-day limited warranty on each one-time purchase of its digital tools (the "App"). Under this warranty, JCC's first commitment is to fix confirmed software defects ("Bugs") free of charge. If, after a genuine good-faith attempt, a confirmed Bug cannot reasonably be fixed, the Buyer becomes eligible for a full refund of the purchase price for that App, subject to the exceptions in Section 5(c) below, which mainly cover situations where the issue was caused by the Buyer's own changes to the Google Sheet or the App itself.

2. Warranty Period

The warranty period begins on the date the App (or access to it) is delivered to the Buyer, whether by file transfer, shared link, or successful first setup, and ends fifteen (15) calendar days after that date. The Buyer must report the issue within this 15-day period for it to be covered. Once a report is timely received, JCC will continue working toward a resolution (fix, or refund if unfixable) even if that process extends a few days beyond the 15-day window. Requests first reported after the 15-day period are not covered, though JCC may, at its sole discretion, still choose to assist.

3. What Is Covered

During the warranty period, JCC will investigate and, where confirmed, correct at no cost any Bug that:

1. Causes a core, advertised feature of the App to fail to work as demonstrated or described at the time of purchase;
2. Is reproducible by JCC using the App in its standard, supported configuration (hosted on GitHub Pages or an equivalent static host, connected to a correctly configured Google Sheets + Apps Script backend matching the setup guide provided); and
3. Is reported by the Buyer with enough detail (see Section 6) for JCC to identify and reproduce the issue.

4. What Is Not Covered

This warranty does not cover the items below, and they are not eligible for either a free fix or a refund:

5. Remedy

(a) Primary Remedy: Repair. JCC's first obligation under this warranty is to use commercially reasonable, good-faith efforts to fix confirmed Bugs (as defined in Section 3) and deliver a corrected version of the App to the Buyer within a reasonable time, generally within five (5) to seven (7) business days of confirming the defect, depending on complexity.

(b) Fallback Remedy: Refund for Unfixable Defects. If, after a genuine good-faith effort, JCC determines that a confirmed Bug cannot reasonably be resolved, the Buyer is entitled to a full refund of the purchase price paid for that App, provided none of the exceptions in Section 5(c) apply.

(c) Exceptions: When the Refund in Section 5(b) Does Not Apply. The Buyer is not entitled to a refund under Section 5(b) if the unresolved issue is caused by, or traceable to, any of the following:

In these cases, JCC may still choose, at its sole discretion, to assist the Buyer. For example, JCC may offer guidance on restoring the original Sheet structure, but is under no obligation to do so.

(d) How a Refund Is Processed. Where a refund applies under Section 5(b), JCC will process it to the original payment method or channel used by the Buyer within a reasonable time after confirming the defect is unfixable. JCC reserves the right to request that the Buyer confirm removal or discontinued use of the App as a condition of the refund.

6. How to Request Warranty Support

To request a warranty fix (and, if applicable, a refund under Section 5(b)), the Buyer must, within the 15-day period:

1. Contact JCC through jccbusinesssolutions@gmail.com;
2. Provide proof of purchase (invoice number, receipt, or payment confirmation);
3. Describe the issue in detail, including the steps to reproduce it; and
4. If possible, provide a screenshot or screen recording of the issue.

7. Limitation of Liability

To the fullest extent permitted by law, JCC's total liability for any claim relating to the App, whether under this warranty, contract, or otherwise, is limited to the purchase price actually paid by the Buyer for that App. JCC is not liable for indirect, incidental, consequential, or special damages, including lost income, lost data, or business interruption.

8. Single License, No Resale

The App is licensed for use by the individual or business that purchased it. This warranty is personal to the original Buyer and does not transfer if the App is resold, shared, or distributed to a third party.

9. Changes to This Policy

JCC may update this warranty policy for future purchases. Changes will not apply retroactively to purchases already made before the update.

10. Governing Law

This warranty is governed by the laws of the Republic of the Philippines. Nothing in this policy is intended to waive any right that cannot be waived under Philippine law, including applicable provisions of the Civil Code and the Consumer Act of the Philippines (Republic Act No. 7394), to the extent such laws apply to the transaction.

Part 2: Data Privacy Policy

1. Who This Policy Is For

Client Pulse is a software application developed and licensed by JCC Business Solutions ("JCC," "we," "us") for financial advisors ("Advisor," "you") to help manage client premium due reminders, birthday greetings, and related client-servicing activities. This policy applies to Advisors who use Client Pulse and explains how personal information may be handled in connection with the application. For purposes of this policy, "Client Data" means personal information relating to the Advisor's own clients that the Advisor chooses to enter into or use with Client Pulse.

2. Roles and Responsibilities Under the Data Privacy Act

The Advisor generally determines which clients are entered into Client Pulse, what information is used, why the information is processed, and how the Advisor communicates with those clients. Accordingly, the Advisor is generally responsible for determining and maintaining the appropriate lawful basis for processing Client Data and for complying with applicable privacy laws, company policies, contractual obligations, and client-facing requirements.

JCC is primarily a software provider. Client Pulse is designed so that JCC does not ordinarily receive, store, or directly access the Advisor's Client Data during normal operation. However, the legal classification of a party under the Data Privacy Act depends on the actual nature of the processing activity. If JCC actually receives or processes personal information in a particular circumstance, JCC will handle that information only for the legitimate purpose for which it was provided and in accordance with applicable data privacy requirements.

3. How Client Pulse Actually Handles Data

This is the part most Advisors want to understand clearly, so here it is in plain terms:

1. Client Pulse runs as a web application inside the Advisor's own browser.
2. The Advisor creates and controls their own Google Sheet, using their own Google account, as the application's client database.
3. The Advisor deploys their own Google Apps Script (a small backend program) under their own Google account. This is what actually stores and retrieves Client Data such as names, policy numbers, premium amounts, due dates, contact numbers, and birthdays.
4. The Client Pulse frontend communicates directly with the Advisor's own Apps Script deployment and Google Sheet, rather than routing the Advisor's Client Data through a JCC-operated central database.
5. JCC does not maintain a central database containing the Advisor's Client Data as part of normal operation, does not require the Advisor to upload their complete client database to JCC, and does not require the Advisor's Google password.

4. What JCC Does Not Ordinarily Collect or Access

During normal operation, JCC does not ordinarily receive or maintain a copy of the Advisor's:

• Client names
• Policy numbers
• Premium or amount due information
• Client contact numbers, email addresses, or home addresses
• Birthdates or other Client Data entered into the Advisor's own Google Sheet

These types of Client Data are not ordinarily collected or stored by JCC as part of the normal operation of Client Pulse. This section describes how the app ordinarily operates; Section 6 explains the limited circumstances in which incidental access may occur.

5. What JCC May Collect

JCC may collect limited information about the Advisor as a customer or user of the software, such as:

• Advisor name, email address, and contact details;
• Purchase or subscription information and payment confirmation or transaction reference details, which the Advisor provides directly;
• Information voluntarily provided in customer support communications;
• Information reasonably necessary to provide technical support or administer the software license.

JCC will not intentionally use Advisor information or Client Data for unrelated purposes, including selling personal information, profiling clients, or marketing to the Advisor's clients.

6. Data Minimization

Client Pulse is designed around data minimization. Advisors should only enter information reasonably necessary for the intended client-servicing functions of the application, and should avoid entering unnecessary sensitive or unrelated information.

7. Technical Support and Incidental Access

JCC does not ordinarily require access to an Advisor's Client Data in order to provide Client Pulse. If an Advisor voluntarily provides a screenshot, screen recording, sample export, error message, log, or other material for technical support, that material may incidentally contain limited Client Data. Advisors are strongly encouraged to remove client names, mask policy numbers and contact numbers, remove unnecessary financial information, redact sensitive personal information, and use test or anonymized data whenever reasonably practicable when sharing material for support.

JCC will use any Client Data voluntarily provided during technical support only for the specific support, troubleshooting, security, or maintenance purpose for which it was provided. JCC will not:

• sell the information;
• use it for advertising or profiling;
• use it to build a separate client database;
• disclose it to unrelated third parties; or
• use it for a purpose unrelated to the support request.

JCC will restrict access to voluntarily provided support information to persons who reasonably need it for the relevant support or security purpose, and will retain it only for as long as reasonably necessary, subject to legitimate legal, contractual, or recordkeeping requirements.

8. Data Security

Client Pulse is designed to minimize JCC's direct exposure to Client Data. JCC maintains reasonable and appropriate technical and organizational safeguards for the systems and information under JCC's control, which may include HTTPS/TLS connections, controlled access to JCC systems, reasonable source-code access controls, secure coding practices, minimizing unnecessary collection of personal information, avoiding intentional storage of Client Data on JCC-controlled infrastructure, avoiding unnecessary inclusion of personal information in application logs, and reasonable vulnerability identification, remediation, and incident response procedures.

The Advisor is responsible for securing the Google environment used for their Client Data, including their Google account, passwords, multi-factor authentication, device security, and Google Sheet sharing permissions. JCC cannot guarantee the security of third-party infrastructure, or of the Advisor's own devices, networks, Google account, or third-party services.

9. Security Incidents and Personal Data Breaches

JCC maintains reasonable procedures for identifying, assessing, containing, investigating, documenting, and mitigating security incidents involving systems or information under JCC's control. If JCC becomes aware of an actual or reasonably suspected security incident involving Client Data that JCC has received or processed, JCC will assess the nature and scope of the incident, take reasonable steps to contain and mitigate it, investigate relevant technical circumstances, document material facts and remedial actions, notify the affected Advisor as appropriate, and reasonably cooperate with the Advisor where required by applicable law or contractual obligations. Any notification, reporting, or cooperation obligations will be determined based on the nature and circumstances of the incident and applicable Philippine privacy laws and regulations.

10. Rights of the Advisor's Clients

The Advisor is generally responsible for managing requests and obligations relating to their client relationships and Client Data, because the Advisor determines the purposes and means of the relevant client processing. The Advisor is responsible for ensuring there is an appropriate lawful basis for processing Client Data, and for satisfying applicable transparency, notice, access, correction, objection, erasure/blocking, and other data-subject requirements.

If JCC receives a privacy request relating to Client Data that JCC actually holds or processes, JCC will reasonably cooperate with the Advisor as required by applicable law.

11. Data Retention

JCC does not ordinarily retain the Advisor's Client Data, because Client Data is designed to remain in the Advisor's own Google environment. The Advisor is responsible for establishing appropriate retention and deletion practices for Client Data in accordance with applicable law, company policy, contractual requirements, and legitimate business purposes.

JCC may retain limited Advisor/customer information necessary for purchase records, billing, subscription administration, customer support, contractual records, security purposes, or legal and regulatory obligations. If Client Data is voluntarily provided to JCC during support, it will be retained only for as long as reasonably necessary for the stated purpose, subject to legitimate legal or recordkeeping requirements.

12. Third-Party Services Involved

Client Pulse may rely on third-party services selected or configured by the Advisor, or used to deliver the application, including:

• Google Sheets, Google Apps Script, and Google Drive, under the Advisor's own Google account, which may process Client Data;
• GitHub Pages or another static hosting provider, used primarily to deliver the Client Pulse application itself, and not intended to serve as JCC's central Client Data database;
• Email or messaging services the Advisor configures, which may process limited information such as email addresses, telephone numbers, or message content as necessary to deliver the communication.

Third-party services are governed by their own terms, privacy policies, security practices, and infrastructure. JCC does not control the infrastructure or privacy practices of third-party providers, and their use by such providers does not by itself guarantee compliance with any particular law or standard.

13. Organizational and Company Policy Compliance

The Advisor is responsible for ensuring that their use of Client Pulse is permitted under all applicable company, employer, insurance company, agency, contractual, regulatory, and data privacy requirements that apply to the Advisor. For Advisors affiliated with a financial institution, insurance company, agency, or other organization, the Advisor should obtain any required internal approval before using Client Pulse with organizational or client information.

Client Pulse is an independent software product developed by JCC Business Solutions. This policy does not state or imply that any insurance company, agency, or other organization has approved, endorsed, or authorized Client Pulse, or that Client Pulse is compliant with any particular organization's internal requirements, unless actual written authorization exists.

14. Children's Data

Client Pulse is not specifically designed for the collection or management of children's personal data. Advisors should avoid entering information relating to minors unless such processing is necessary, lawful, and permitted under applicable organizational policies.

15. Changes to This Policy

JCC may update this policy to reflect changes in Client Pulse, in applicable law, in National Privacy Commission guidance, in security practices, or in third-party services. Material changes will be reflected by an updated effective date and, where applicable, an updated agreement version number. Changes will not be represented as retroactively removing any right or obligation that cannot legally be waived.

16. Governing Law

This policy is governed by the laws of the Republic of the Philippines, including Republic Act No. 10173 (Data Privacy Act of 2012), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission. Nothing in this policy is intended to waive any right, remedy, or obligation that cannot lawfully be waived under Philippine law.

17. Contact

Questions about Client Pulse as software, privacy questions concerning JCC-controlled information, security concerns, technical support, and privacy-related communications concerning information actually received by JCC may be sent to jccbusinesssolutions@gmail.com. Questions about how a specific Advisor is handling a particular client's personal data should generally be directed to that Advisor, since the Advisor is responsible for that client's information under the Data Privacy Act.