TRMS360 Privacy Policy
- Effective Date
- September 29, 2026
- Last Updated
- September 29, 2026
TRMS360 respects your privacy and is committed to protecting the personal information and business information entrusted to us.
This Privacy Policy explains how Lucchesi & Associates, LLC, doing business as TRMS360 ("TRMS360," "we," "us," or "our"), collects, uses, stores, discloses, and protects information when you visit our websites, complete a TRMS360 Business Growth Checkup, create an account, purchase or use a TRMS360 membership, interact with an AI Mentor, participate in a Momentum Engine, communicate with us, or otherwise use the TRMS360 System and related services.
By using TRMS360, you acknowledge the practices described in this Privacy Policy.
1. Information We Collect
The information we collect depends on how you interact with TRMS360.
Information You Provide Directly
We may collect information such as:
- Name
- Email address
- Telephone number
- Company or business name
- Job title or role
- Account and profile information
- Membership level
- Communication preferences
- Information submitted through forms, surveys, questionnaires, support requests, or scheduling tools
Business Information
TRMS360 is designed to help business owners understand, strengthen, and grow their businesses. As a result, you may choose to provide business information including:
- Business goals and priorities
- Revenue or financial information
- Business metrics
- Sales and marketing information
- Customer and market information
- Operational information
- Team and leadership information
- Systems and technology information
- Business processes
- Owner involvement or dependency
- Intellectual property or business assets
- Growth challenges and opportunities
- Business evidence, progress, and outcomes
You should not submit information to TRMS360 that you are not authorized to provide.
Business Growth Checkup and Assessment Information
When you complete the TRMS360 Business Growth Checkup, B.U.I.L.D. Assessment, or another TRMS360 assessment, we may collect:
- Your answers
- Scores
- B.U.I.L.D. pillar results
- Identified strengths and opportunities
- Recommendations
- Next Best Moves or Next Best Actions
- Assessment history
- Changes in results over time
Information provided through a public Business Growth Checkup may be retained and associated with your TRMS360 account if you later become a member so that we can continue your experience without unnecessarily asking you to provide the same information again.
Momentum Engine and Progress Information
When you use Momentum Engines or other implementation tools, we may collect information concerning:
- Engines you start or complete
- Steps and milestones
- Actions completed
- Progress
- Resources used
- Business evidence created
- Outcomes reported
- Recommendations generated from your progress
AI Mentor Information
When you interact with a TRMS360 AI Mentor, we may process:
- Messages and prompts you submit
- Information generated during the interaction
- Relevant TRMS360 profile, business, assessment, recommendation, or progress context provided to the AI Mentor
- Mentor usage or engagement information
TRMS360 AI Mentors are intended to provide contextual business guidance. Information from your TRMS360 account may therefore be used to make an AI Mentor interaction more relevant to your business and current priorities.
Do not submit highly sensitive personal information, confidential information belonging to another person, passwords, Social Security numbers, full payment-card numbers, medical information, or other information that is unnecessary for receiving TRMS360 services through an AI Mentor.
Purchase and Transaction Information
When you purchase a TRMS360 membership or related service, we may receive transaction-related information such as:
- Product or membership purchased
- Transaction status
- Purchase date
- Billing status
- Limited payment-related information supplied by the payment provider
Payment-card information may be processed directly by a third-party payment processor. TRMS360 does not need your full payment-card number to provide the TRMS360 System.
Communications
If you contact us by email, telephone, text message, support request, social media, scheduling system, or another communication channel, we may retain the communication and related contact information.
Information Collected Automatically
When you use our websites or applications, certain technical information may be collected automatically, including:
- IP address
- Browser and device information
- Operating system
- Pages or features visited
- Dates and times of access
- Referring pages
- Session and authentication information
- Application activity
- Error, security, and diagnostic information
We may use cookies, local storage, session technologies, or similar technologies to operate, secure, remember preferences for, and improve our services.
2. How We Use Information
We may use information to:
- Create and maintain your TRMS360 account
- Authenticate users and protect accounts
- Provide the TRMS360 System
- Administer memberships
- Create and maintain business profiles
- Deliver the Business Growth Checkup and B.U.I.L.D. Assessment
- Calculate and display assessment results
- Generate recommendations and Next Best Actions
- Recommend Momentum Engines, AI Mentors, resources, tools, and support
- Personalize your TRMS360 experience
- Provide AI-assisted business guidance
- Track progress and completed activities
- Measure changes in your business over time
- Maintain historical assessment and progress information
- Provide GoHighLevel-related implementation and account support where included with your membership
- Provide coaching, implementation, or other human support where applicable
- Process transactions and administer purchases
- Schedule appointments
- Send account, transactional, service, and support communications
- Send marketing communications where permitted by law and your preferences
- Respond to questions and support requests
- Improve TRMS360 products, services, content, and user experience
- Maintain security and prevent fraud, abuse, or unauthorized access
- Diagnose technical problems
- Maintain records
- Enforce our agreements
- Comply with legal obligations
- Protect our rights and the rights and safety of our users and others
3. AI and Automated Recommendations
TRMS360 uses technology and artificial intelligence to help analyze information, identify priorities, generate recommendations, and provide guidance.
AI-generated content and recommendations may be based on information you provide to TRMS360, including business profile information, assessment results, current priorities, Momentum Engine activity, and other relevant business context.
AI output may be incomplete, inaccurate, or inappropriate for a particular situation. AI-generated information is intended to support—not replace—your own judgment or qualified professional advice.
TRMS360 may also allow authorized members of our team to review, modify, or override certain recommendations where human judgment or support is appropriate.
We do not represent AI-generated guidance as legal, tax, accounting, investment, medical, or other regulated professional advice.
4. How We Disclose Information
We may disclose information to third parties when reasonably necessary to operate TRMS360 and provide our services.
These may include providers supporting:
- Cloud databases and authentication
- Website and application hosting
- CRM and customer relationship management
- Email and SMS communications
- Transactional email
- Scheduling
- Payment processing
- Analytics and application monitoring
- Customer support
- AI and AI Mentor functionality
- Automation and workflow services
- Community or member services
TRMS360 currently uses technology and service providers in areas that include Supabase, Vercel, GoHighLevel, and Resend, as well as AI infrastructure and other providers required to operate the TRMS360 System.
These providers may process information on our behalf according to their services and contractual obligations.
We may also disclose information:
- With your direction or consent
- To professional advisers such as attorneys, accountants, or consultants
- To comply with applicable law, legal process, court order, or governmental request
- To investigate fraud, security incidents, abuse, or violations of our agreements
- To protect the rights, property, or safety of TRMS360, our users, or others
- In connection with a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction
5. We Do Not Sell Personal Information
TRMS360 does not sell personal information for money.
We do not sell your confidential business information, assessment answers, B.U.I.L.D. results, AI Mentor conversations, or member progress information to data brokers.
If our practices change in a way that constitutes a "sale" or "sharing" under an applicable privacy law, we will update this Privacy Policy and provide any notices or choices required by law.
6. Marketing Communications
If you choose to receive marketing communications, we may use your contact information to send information about TRMS360, programs, events, resources, membership opportunities, or related offerings.
You may unsubscribe from marketing emails by using the unsubscribe link provided in the message.
You may also request that we stop sending marketing communications by contacting us.
Opting out of marketing communications does not prevent us from sending transactional or service-related messages necessary to administer your account, membership, purchase, security, or requested services.
8. Data Retention
We retain information for as long as reasonably necessary to:
- Provide TRMS360 services
- Maintain your account and membership
- Preserve assessment and progress history
- Maintain legitimate business and transaction records
- Resolve disputes
- Prevent fraud and abuse
- Enforce agreements
- Comply with legal, accounting, tax, and regulatory obligations
Different categories of information may be retained for different periods.
If you request deletion, we will delete or de-identify eligible information as required by applicable law, subject to legitimate retention requirements and legal exceptions.
Backups and archival systems may retain information for a limited period after information is removed from active systems.
9. Data Security
We use reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, loss, or misuse.
These safeguards may include authentication, access controls, encrypted connections, database security controls, role-based permissions, monitoring, and other security measures appropriate to the nature of the information processed.
No website, application, database, transmission, or storage system can be guaranteed to be completely secure. You are responsible for protecting your account credentials and for notifying us if you believe your account has been compromised.
10. Your Privacy Choices and Rights
Depending on where you live and applicable law, you may have rights concerning your personal information.
These may include the right to:
- Confirm whether we process your personal information
- Request access to personal information we maintain about you
- Request correction of inaccurate information
- Request deletion of eligible personal information
- Request a portable copy of certain information
- Withdraw consent where processing is based on consent
- Opt out of certain marketing communications
- Opt out of certain targeted advertising, sales, sharing, or profiling where applicable
- Limit certain uses of sensitive personal information where applicable
- Appeal certain decisions concerning a privacy request where required by law
- Exercise applicable privacy rights without unlawful discrimination
These rights are not absolute. Applicable law may permit or require us to retain or continue processing certain information.
To make a privacy request, contact us using the information in the Contact Us section below.
We may need to verify your identity before fulfilling a request. Authorized agents may submit requests where permitted by applicable law and subject to appropriate verification.
If applicable law provides a right to appeal our response to your privacy request, you may submit an appeal using the same contact information and clearly identify your request as a Privacy Appeal.
11. California Privacy Rights
California residents may have additional rights under California privacy laws, depending on whether those laws apply to TRMS360.
These may include rights to know, access, correct, or delete certain personal information and rights concerning the sale or sharing of personal information, sensitive personal information, and certain forms of targeted advertising.
TRMS360 does not sell personal information for money.
If TRMS360 becomes subject to additional California-specific disclosure or opt-out requirements, we will provide the notices and mechanisms required by applicable law.
12. Florida Privacy Rights
Florida residents may have privacy rights under Florida law where the applicable statutory requirements are met.
These may include rights concerning access, correction, deletion, portability, certain targeted advertising, sale of personal data, profiling, and certain sensitive data processing.
Requests may be submitted using the contact information provided below.
13. Children's Privacy
TRMS360 is designed for business owners, entrepreneurs, professionals, and other adult users. It is not intended for children under 18.
We do not knowingly solicit or collect personal information from children for the purpose of providing TRMS360 memberships or business-growth services.
If you believe a child has provided personal information to TRMS360 without appropriate authorization, please contact us so that we can review the situation and take appropriate action.
14. Third-Party Websites and Services
TRMS360 may contain links to or integrate with third-party websites, applications, platforms, or services.
Their privacy practices are governed by their own policies and agreements. TRMS360 is not responsible for the privacy practices of third parties that independently control information collected through their services.
We encourage you to review their privacy policies before providing information.
15. Business Information and Confidentiality
TRMS360 recognizes that members may provide information about their businesses that they consider confidential or commercially sensitive.
We use business information to provide and improve TRMS360 services, personalize guidance, generate recommendations, track progress, and provide support as described in this Privacy Policy.
We do not sell members' confidential business information to data brokers.
You remain responsible for determining what information is appropriate to submit to TRMS360 and for ensuring that you have authority to provide information concerning employees, customers, vendors, partners, or other third parties.
16. Aggregated and De-Identified Information
We may create aggregated or de-identified information that is not reasonably capable of identifying you.
We may use such information for purposes such as:
- Understanding how TRMS360 is used
- Improving assessments and recommendations
- Improving products and services
- Measuring platform performance
- Developing features
- Research and analysis
- Understanding general business-growth patterns
We will not attempt to re-identify information that we maintain as de-identified except as permitted by law, including where necessary to test whether our de-identification methods are effective.
17. International Users
TRMS360 is operated from the United States.
If you access TRMS360 from outside the United States, your information may be transferred to, processed in, or stored in the United States or other countries where our service providers operate.
Privacy and data-protection laws in those jurisdictions may differ from the laws where you live.
If TRMS360 expands its services into jurisdictions requiring additional privacy notices, contractual protections, or transfer mechanisms, we will implement those measures as appropriate.
18. Changes to This Privacy Policy
We may update this Privacy Policy as TRMS360 evolves, our technology or services change, or legal requirements change.
When we make changes, we will update the "Last Updated" date above.
If a change materially affects how we use personal information, we will provide additional notice when required by applicable law.
We encourage you to review this Privacy Policy periodically.
19. Contact Us
Questions, concerns, or requests concerning this Privacy Policy or your personal information may be directed to:
TRMS360
Operated by Lucchesi & Associates, LLC
Email: nancy@trms360.com
When submitting a privacy request, please include enough information for us to identify your account or records and understand your request.
Please do not send sensitive personal information by ordinary email.
