Privacy Policy
TOM Enterprise is committed to Transparent Impact — one of our six core values — and that commitment extends fully to how we handle your personal information. This policy explains what we collect, why we collect it, how it lives in our systems, and the rights you hold over your own data.
We do not sell your data. We do not share it for marketing. And you always have the right to request a human review of any AI-assisted decision.
Who We Are
Organization identity, legal standing, and governing law
TOM Enterprise is an Arizona-based nonprofit creative incubator operating under the mission Legacy Starts Now. We equip creative entrepreneurs with branding, strategy, and financial literacy, removing the financial and structural barriers that historically prevent underestimated founders from launching legacy-grade businesses.
TOM Enterprise is headquartered in Tempe, Arizona and incorporated under Arizona state law. Our 501(c)(3) application is currently pending with the IRS under EIN 42-1915663. Governance is provided by our April 2026 Bylaws and the Revamped Strategic Plan 2026–2029, approved by the Board of Directors.
The Founder and Executive Director is Tralynn Obryan McCullar. All final decisions regarding data, enrollment, scholarships, and program changes are made by the Founder — not by automated systems. For any privacy-related inquiries, our legal and compliance function is supported by Linda, our AI Legal Associate, under direct founder oversight.
TOM Enterprise · Tempe, Arizona · tralynnm@tomenterprise.org · (623) 269-8232 · tomenterprise.org
This Privacy Policy applies to all personal data collected through our website at tomenterprise.org, through our program application and intake forms, through our HubSpot CRM (Portal ID 246222094), through our Legacy Hub member portal, through email and social media communications, and through any in-person events or workshops hosted by TOM Enterprise.
What We Collect
Categories of personal information gathered across all touchpoints
We collect personal information only when it is necessary to serve you, evaluate your fit for our programs, administer your enrollment, or track your outcomes over time. We do not collect data speculatively. The following table describes the categories of personal information we may collect and the context in which each is gathered.
| Category | Examples | Collected When |
|---|---|---|
| Identity & Contact | Full name, email address, phone number, city/state | Web forms, application forms, event registrations, email sign-up |
| Business Information | Business name, industry, stage of business, business description | Program application form, Surgical Logic intake rubric |
| Program Responses | Application essay answers, discovery-call notes, intake assessment scores | Intake form submissions and the 30-minute structured discovery call |
| Financial Context | Self-reported pricing tier preference (Standard, Sliding Scale, or Scholarship) | Discovery call and enrollment process; never verified by third-party systems |
| Engagement Data | Email open rates, link clicks, event attendance, workshop check-ins | HubSpot CRM automatically via email workflows and event registrations |
| Progress & Milestone Data | Weekly cohort check-ins, deliverable submissions, mentor session notes, goal tracking | During active program or service engagement; stored in HubSpot Contact timeline |
| Outcome Survey Data | Business launch status, revenue self-report, credit improvement, confidence ratings | 90-day post-completion survey, 6-month alumni follow-up, 12-month and annual alumni interviews |
| Website Usage Data | IP address, browser type, pages visited, session duration | Automatically via cookies and analytics tools when you visit tomenterprise.org |
| Social Media Data | DM content, comments, public profile information | When you interact with TOM Enterprise on Instagram, LinkedIn, or Facebook |
| AI Disclaimer Acknowledgment | Timestamp and confirmation that the AI Disclaimer Addendum was acknowledged | Required at every manual intake before enrollment can proceed |
We do not collect government ID numbers, social security numbers, bank account details, credit reports, or payment card data directly. Payment processing, if applicable, is handled by a third-party payment processor subject to their own privacy and security policies. We do not collect race, ethnicity, or national origin — though we do track the aggregate percentage of clients from underserved or first-generation entrepreneur backgrounds at the program level for impact reporting purposes, using only self-reported, voluntarily provided information.
How We Use It
The specific, lawful purposes for which your information is processed
TOM Enterprise processes personal information for specific, legitimate, and clearly defined purposes. We do not use personal data for purposes beyond those described here without first notifying you and, where required, obtaining your consent.
Program Admissions & Enrollment
Your application data — including your business description, stage of business, availability, coachability signals, and stated financial context — is used to evaluate your fit for TOM Enterprise programs using our Surgical Logic 8-category rubric. Scores are calculated on a 1–5 scale across eight categories, and results determine your pipeline stage (Priority Outreach ≥32, Standard Outreach 24–31, Waitlist 16–23, Decline 0–15). All scoring is AI-assisted via Stan (our Sales Associate AI agent) and reviewed by the Founder before any final enrollment or decline decision is communicated.
- Process your program application and admission decision
- Schedule your 30-minute structured discovery call via Eva (our Executive Assistant AI agent)
- Confirm your pricing tier selection (Standard $1,500 · Sliding Scale $750 · Scholarship $0 for the Legacy Builder Cohort)
- Execute your service agreement and retain enrollment documentation in HubSpot
Program Delivery & Client Service
Once enrolled, your information is used to deliver the specific service or program you have engaged. This includes scheduling cohort sessions, pairing you with a mentor, tracking your weekly milestones and deliverables, facilitating peer cohort connection, and ensuring your Demo Day preparation is on schedule.
- Deliver 12-week Legacy Builder Cohort sessions (10–15 participants, twice per year)
- Facilitate 1-on-1 mentorship (bi-weekly 60-minute sessions, 6-month commitment, goal tracking)
- Administer Financial Literacy Workshops (monthly, 20–30 attendees per session)
- Deliver Brand Identity, Strategic Business Planning, and Creative Direction services
- Log all session notes, deliverable milestones, and progress check-ins to your HubSpot Contact timeline
Outcome Tracking & Impact Reporting
TOM Enterprise tracks client outcomes longitudinally — at intake, 90 days post-completion, 6 months, 12 months, and annually — as part of our Transparent Impact core value. Outcome data contributes to our Annual Impact Report, published every Q1, and to grant reporting for foundation and government funders. All aggregate data published externally is anonymized; no individual is identified without explicit written consent.
- Administer post-program surveys and alumni follow-up interviews at defined milestones
- Track program-level metrics: 85% cohort completion rate, 75% business launch within 12 months, 90% improved business confidence
- Compile data for the Annual Impact Report and grant applications
- Calculate Social Return on Investment (SROI) — Year 1 target: $3.50 per $1 invested
Communications & Community
We use your contact information to communicate with you about your program enrollment, upcoming events, new resources, the bi-weekly email newsletter, and community updates from TOM Enterprise. You can unsubscribe from non-essential communications at any time. Essential communications related to your active enrollment or ongoing service agreement cannot be opted out of for the duration of your engagement.
- Send program updates, session reminders, and enrollment communications
- Distribute the bi-weekly TOM Enterprise email newsletter (opt-out available at any time)
- Notify you of new resources, workshop events, and cohort application windows
- Publish alumni spotlight stories and case studies — only with your explicit written consent
AI Disclosure
How our five-agent AI workforce touches your data — and where the human stays in the loop
TOM Enterprise's intake and operational stack is partially AI-operated. Every manual intake requires acknowledgment of the AI Disclaimer Addendum before enrollment proceeds. This section of our Privacy Policy fulfills and expands on the disclosures contained in that Addendum. You have the right to request human-only review of any decision at any time.
TOM Enterprise operates a five-agent AI workforce. Each agent has a discrete domain and defined authority boundary. No AI agent is authorized to make final enrollment, scholarship, or program change decisions. Those decisions are reserved exclusively for the Founder.
| AI Agent | Role | Touches Your Data? | Decision Authority |
|---|---|---|---|
| Eva | Executive Assistant · Central Command | Yes — inbox triage, calendar scheduling, cross-agent routing | No final decisions — schedules and routes only; escalates to Founder |
| Stan | Sales Associate · Pipeline Vetting | Yes — scores all 91+ active leads using the 8-category Surgical Logic rubric | No final decisions — scores and recommends; Founder approves enrollment/decline |
| Linda | Legal Associate · Compliance | Yes — reviews externally-facing content and compliance documentation | No binding legal decisions — reviews and flags; Founder holds final authority |
| Penny | Blog Writer · Content & Onboarding | Limited — drafts onboarding materials and blog content; does not access individual applicant records | No decisions — content only; Linda audits before publication |
| Sonny | Social Media Manager · Campaign Execution | Limited — manages social content and community DMs; routes sales-intent DMs to Stan | No decisions — community management only; sales-intent escalated to Stan/Eva |
The Human-in-the-Loop Guarantee
You have an unconditional right to request that any decision affecting your enrollment, pricing tier, or scholarship status be reviewed by a human — specifically, by the Founder, Tralynn Obryan McCullar. To exercise this right, email tralynnm@tomenterprise.org with the subject line "Human Review Request" and describe the decision you'd like reviewed. We will acknowledge your request within 48 hours and complete the review within 5 business days.
All AI Disclaimer Addendum acknowledgments — including the timestamp and the identity of the applicant — are permanently retained as a Note on your HubSpot Contact record. This record serves as the documented evidence of informed consent to AI-assisted intake. You may request a copy of this record at any time.
HubSpot & CRM
How your data is stored, structured, and managed in our CRM platform
TOM Enterprise's primary CRM is HubSpot (Portal ID: 246222094). HubSpot is the system of record for all applicant, client, and alumni data from first contact through longitudinal outcome tracking. All pipeline stages, session notes, Surgical Logic scores, AI Disclaimer Addendum acknowledgments, and milestone check-ins are stored in HubSpot.
Your data in HubSpot moves through six defined pipeline stages, each with an owner and clear exit criteria:
| Stage | Owner | What Happens to Your Data |
|---|---|---|
| 1 · Inbound | Eva (AI) | Contact record created in HubSpot. Web form, referral, or social media source logged. |
| 2 · Vetted | Stan (AI) | Surgical Logic 8-category rubric applied. Score (24–40 qualifies) saved as custom property on your Contact record. |
| 3 · Outreach | Stan (AI) | Personalized outreach sent. Discovery call scheduled. Outreach sequence logged in Contact timeline. |
| 4 · Discovery | Founder (Human) | 30-minute call notes logged directly to your HubSpot Contact timeline by the Founder. AI Disclaimer Addendum acknowledged and attached as Note. |
| 5 · Enrollment | Eva (AI) + Founder | Tier selection, signed service agreement, and payment confirmation stored. Active client record created. |
| 6 · Waitlist/Decline | Linda (AI) + Founder | Standardized communication sent within 72 hours. Record closed with reason code. Data retained per our retention schedule (Section 07). |
HubSpot is a third-party service provider subject to HubSpot's own Privacy Policy and Terms of Service, available at legal.hubspot.com/privacy-policy. TOM Enterprise has a data processing agreement with HubSpot consistent with applicable data protection law. HubSpot does not have independent permission to use your data for its own marketing purposes.
A weekly pipeline report is generated by Stan and summarized for the Founder by Eva. This report covers lead volume, conversion rates at each pipeline stage, and channel performance. It does not contain full personal data — it contains aggregate metrics and flagged individual records requiring Founder action.
Sharing Your Information
Who we share data with, why, and what we will never do
Applicant data is not sold or shared for marketing purposes. Ever. This is a foundational operating principle at TOM Enterprise, not just a legal compliance position. It is reflected in our Operations Manual, our April 2026 Bylaws, and our service agreements.
We may share your information only in the following limited and specific circumstances:
- Service Delivery Partners: If your program engagement involves a matched mentor from our mentor roster (including volunteer mentors from corporate partner organizations such as Avnet, Republic Services, Microchip Technology, ON Semiconductor, or Insight Enterprises), your name, business description, and stated goals will be shared with your mentor for the purpose of your engagement only. Mentors operate under a confidentiality agreement with TOM Enterprise.
- Technology Service Providers: HubSpot (CRM, Portal 246222094), our email platform, our video conferencing tool, and our design tools may receive your contact and engagement data as part of service delivery. All are subject to data processing agreements and are not authorized to use your data for independent marketing purposes.
- Community Partners for Referrals: If you were referred to TOM Enterprise by a community partner organization (such as Tempe Community Action Agency or Chicanos Por La Causa), we may confirm your enrollment status with the referring organization for the purpose of referral tracking. No program content, financial data, or personal essay responses are shared.
- Grant Funders and Foundation Partners: Aggregate, anonymized outcome data is shared with foundation funders (such as the Arizona Community Foundation, National Endowment for the Arts, or Kresge Foundation) as part of grant reporting. No individual is identifiable in these reports without explicit written consent.
- Legal Requirements: We may disclose personal information if required to do so by applicable law, court order, or government authority — or to protect the rights, property, or safety of TOM Enterprise, our clients, or the public.
- Alumni Spotlights and Case Studies: We may feature your story, business transformation, or outcome in marketing materials, on our website, in our Annual Impact Report, or on social media — but only with your explicit, separate, written consent. You may withdraw consent for future use at any time; previously published content is not retroactively removed.
We will never: sell your personal data to any third party · share your data with advertising networks · disclose your pricing tier selection publicly · share your discovery-call notes or application essay responses with any party other than the Founder · use your data for automated decision-making that produces legal or similarly significant effects without your explicit consent and the ability to request human review.
Data Retention
How long we keep your information and when it is deleted
TOM Enterprise retains personal data for as long as is necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. The following schedule governs our retention practices.
| Data Type | Retention Period | Basis |
|---|---|---|
| Active client records — all program data, session notes, deliverables, and milestone tracking | Duration of engagement + 5 years | Nonprofit accounting and grant compliance obligations under Arizona law |
| Alumni longitudinal outcome data — 90-day, 6-month, 12-month, and annual survey responses | Indefinitely (anonymized for aggregate impact reporting after Year 5) | Impact measurement, SROI calculation, and Annual Impact Report publication |
| Discovery-call notes — saved to HubSpot Contact timeline | Duration of record + 3 years post-close | Operations Manual: all discovery notes retained in HubSpot |
| AI Disclaimer Addendum acknowledgments | Permanent — retained as Note on HubSpot Contact record | AI compliance documentation; legal evidence of informed consent |
| Declined and waitlisted applicant records — standardized communication sent within 72 hours, record closed with reason code | 2 years post-close | Potential reapplication, waitlist priority tracking, and referral pipeline |
| Email newsletter subscriber data | Until unsubscribe + 1 year | CAN-SPAM compliance; unsubscribe requests honored within 10 business days |
| Service agreements and signed documents | 7 years post-execution | Arizona nonprofit record-keeping requirements and IRS documentation standards |
| Website analytics and usage data | 26 months (standard analytics retention) | Performance monitoring; anonymized and aggregated after initial period |
When personal data is no longer required under this schedule, we delete it from HubSpot and any other systems where it is stored. Deletion is triggered by Eva (our AI Executive Assistant) on an annual review cycle, subject to Founder approval. Data subject to active legal hold or open dispute is exempt from standard deletion schedules.
Your Rights
Your rights over your personal information and how to exercise them
You have meaningful rights over your personal information at TOM Enterprise. We honor these rights fully and without unnecessary friction. To exercise any right listed below, email tralynnm@tomenterprise.org with the subject line identifying the right you wish to exercise. We will respond within 5 business days and fulfill your request within 30 days (or notify you if a longer period is required).
We will never discriminate against you, deny you program access, or reduce the quality of services you receive because you exercised any privacy right. If you believe your rights have not been honored, you may contact the Founder directly at tralynnm@tomenterprise.org or by phone at (623) 269-8232.
Cookies & Analytics
How our website uses cookies and what tracking tools we employ
The TOM Enterprise website at tomenterprise.org uses cookies and similar tracking technologies to understand how visitors interact with our site and to improve performance. We do not use cookies for cross-site advertising, behavioral tracking on third-party platforms, or the sale of visitor data.
- Strictly Necessary Cookies: Required for the website to function — session management, form security tokens, and login state for the Legacy Hub member portal. Cannot be disabled without affecting site functionality.
- Analytics Cookies: Used to collect aggregate data on page visits, session duration, traffic sources, and user flows. This data is anonymized and used solely to improve the website and content strategy. Retained for up to 26 months.
- HubSpot Tracking: HubSpot places a tracking cookie on your browser when you visit our site or click a link in a TOM Enterprise email. This allows HubSpot to connect your website activity to your Contact record, enabling our team to understand which resources and pages are most relevant to you. You can opt out of HubSpot tracking via the cookie consent banner or by disabling cookies in your browser settings.
- No Third-Party Advertising Cookies: TOM Enterprise does not use Google Ads, Meta Pixel for retargeting, or any other advertising network cookies on our website.
You can control cookie settings through your browser preferences. Disabling cookies may affect some website functionality, including the Legacy Hub member portal. A cookie consent banner is displayed to new visitors and can be revisited via the "Cookie Preferences" link in the website footer.
Minors & Age Policy
Our services are designed for adults; this section explains our position on minors' data
TOM Enterprise programs and services are designed for adults aged 18 and older. Our target segments include creative solopreneurs, first-generation entrepreneurs, career transitioners, and college students and recent graduates — all individuals who are of legal age to enter into service agreements and who have the legal capacity to operate a business entity.
We do not knowingly collect personal information from individuals under the age of 18. If you are under 18, please do not submit an application, create an account, or provide any personal information through our website or programs. If we discover that we have inadvertently collected personal information from a minor, we will delete that information promptly from all our systems, including HubSpot.
If you are a parent or guardian and believe your child has submitted personal information to TOM Enterprise, please contact us immediately at tralynnm@tomenterprise.org with the subject line "Minor Data Deletion Request" and we will take prompt action.
Policy Updates
How and when this Privacy Policy may change
TOM Enterprise may update this Privacy Policy from time to time as our programs, technology stack, or legal obligations evolve. All material changes to this policy will be communicated to active clients and newsletter subscribers via email at least 14 days before the changes take effect. Non-material changes (such as clarifications of existing language or corrections of typographical errors) may be made without advance notice.
Policy updates are subject to approval by the Founder and are logged against the April 2026 Bylaws in the manner described in our Operations Manual. Linda, our AI Legal Associate, audits the updated policy text before publication, and the Founder retains final approval authority on all policy changes.
The current version of this Privacy Policy is always accessible at tomenterprise.org/privacy-policy. The "Last Updated" date at the bottom of this page reflects the date of the most recent revision. Continued use of TOM Enterprise's website or services after a policy update constitutes acceptance of the revised terms.
May 2026 — Version 1.0: Initial Privacy Policy published. Incorporates AI Disclaimer Addendum disclosures, HubSpot CRM data practices, five-agent AI workforce disclosure, Surgical Logic intake rubric data flows, and longitudinal alumni outcome tracking practices. Governed by April 2026 Bylaws and TOM Enterprise Operations Manual v1.0.
Questions? Contact Us.
How to reach TOM Enterprise with any privacy concern, request, or question
If you have questions about this Privacy Policy, want to exercise any of your data rights, or need to request a human review of any AI-assisted decision, please reach out. We are a small, founder-led team committed to direct and honest communication — your question will not disappear into a ticketing system.
We're here. Ask us anything.
This Privacy Policy was prepared by TOM Enterprise with support from Linda, our AI Legal Associate, and approved by Founder Tralynn Obryan McCullar. It is governed by the April 2026 TOM Enterprise Bylaws and the Revamped Strategic Business Plan 2026–2029. For binding legal commitments, please contact the Founder directly. This policy does not constitute legal advice. TOM Enterprise recommends that applicants and clients seek independent legal counsel regarding their own business and data practices.