Introduction

Welcome to our Privacy Policy. We are a Wyoming, USA-registered company providing online managed lead generation and appointment-setting services to business clients. We value your privacy and are committed to protecting your personal data in compliance with applicable data protection laws in all regions where we operate. This Policy explains what personal information we collect, how we use and share it, and your rights concerning that information.

Scope: This Privacy Policy applies to personal data we process in the course of our B2B lead generation services across the United States, European Union (EU), United Kingdom (UK), Canada, Australia, New Zealand, and other English-speaking countries. We adhere to the requirements of major privacy laws, including the EU’s General Data Protection Regulation (GDPR), the UK Data Protection Act/UK GDPR, Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), Australia’s Privacy Act 1988, New Zealand’s Privacy Act 2020, and relevant U.S. state laws (such as the California Consumer Privacy Rights Act). We maintain a Privacy Policy because global privacy laws require businesses to inform individuals how their data is collected and used. By using our services or providing personal information to us, you agree to the practices described in this Policy.

B2B Focus: Our services are business-to-business (B2B) in nature, meaning we generally collect and use information in a professional context (e.g. details of business contacts, not private consumers). However, any information about an identifiable individual is treated as “personal data” and protected under this Policy, even if obtained from public business sources This Policy does not apply to information about companies or other legal entities, but only to personal information about individuals (such as employees or representatives of our client companies or prospective client companies).

Not for Minors: Our services and website are intended for adults in a business/professional capacity. We do not target or knowingly collect any personal data from children or minors (for example, anyone under 16 years old). If you are a child, please do not use our services or provide any personal information. If we discover we have inadvertently collected personal data from a minor, we will delete it promptly.

What Personal Data We Collect

We limit our collection to information that is relevant for our lead generation and appointment-setting services. “Personal data” (or “personal information”) means any information about an individual from which that person can be identified, directly or indirectly. The types of personal data we may collect and process include:

• Contact Information: Full name, professional email address, phone number, and business mailing address of potential leads or client contacts.

• Professional Profile Data: Job title, employer/company name, company website, department or role, LinkedIn profile URL, and other details from professional social networking profiles or business directories that relate to an individual’s professional identity.

• Publicly Available Business Information: Information obtained from public sources about a company or individual’s professional activities. For example, this might include details from a company’s website, business forum posts, or job postings (which may contain a hiring manager’s name or contact information). We only collect such data where it is lawfully made public and relevant to our services.

• Client-Provided Data: If you are a client, we may collect contact details of your authorized personnel (such as the name, work email, and phone of your company’s point of contact) and any information you provide to us about your target leads or prospects.

• Website Usage Data: If you visit our website, we may collect limited technical data such as your IP address, browser type, and cookies (see Cookies and Tracking below). We generally restrict this to what is necessary for security or to respond to your inquiries. We do not use this information to identify individual visitors unless required for fraud prevention or legal compliance.

• Communication Content: Copies of correspondence or scheduling information related to our interactions with leads or clients. For example, if we email a potential lead or schedule a call, we will retain relevant email content, calendar invites, or notes necessary to carry out our service.

No Sensitive Personal Data: We do not intentionally collect any sensitive or special categories of personal data. This means we do not seek to collect information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health information, or information about a person’s sex life or sexual orientation. We also do not collect information about criminal convictions or offenses. Please refrain from providing us with sensitive personal data. If such information is inadvertently obtained (for instance, if a lead volunteers it), we will not use it and will take steps to secure or delete it.

How We Collect Personal Data

We collect personal data in several ways, always by lawful and fair means. The main collection methods are:

• Directly from You: You may provide us information directly, for example when you contact us via email, phone, or our website (e.g. sending an inquiry or requesting information about our services). If you become a client, you will provide business contact details and other information necessary to work with you. We will use any data you choose to give us only for the purposes for which you provided it.

• From Clients (B2B Context): In some cases, our business clients provide us with personal data about third parties as part of our service delivery. For instance, a client might give us a list of prospective customer contacts for us to approach on their behalf, or they might direct us to engage specific leads. When we process personal data under the instructions of a client, we act as a data processor handling the data on behalf of that client (who is the data controller. In such cases, we will process the data solely for the client’s purposes and as permitted by our contract with that client.

• Public Sources and Professional Platforms: We often collect lead information from publicly available sources. This includes professional social networks like LinkedIn, company websites, industry directories, or public postings (e.g. press releases or job advertisements). For example, we might find a prospect’s work contact details on their employer’s website or gather the name and email of a hiring manager from a job posting. We only gather data that has been made public or published for professional purposes, and we verify its relevance to our B2B outreach. When collecting data from public sources, we rely on legitimate interest and ensure that such collection is done in a manner consistent with individuals’ reasonable expectations.

• Third-Party Data Providers: We currently do not purchase bulk lead lists from data brokers. However, if we ever receive personal data from third-party lead generation tools or partner companies, we will ensure those third parties lawfully obtained the data and have the right to share it. In all cases, we would inform you (either directly or via our client) that we have your information, as required by law.

• Automated Means on Our Website: As a primarily B2B service, our website’s data collection is limited. We may use cookies or server logs to collect Technical Data like IP addresses and browser type when you visit our site. These technologies help us ensure the website’s security and functionality. Any non-essential cookies (for analytics or preferences) would be used only with your consent, in accordance with applicable laws (e.g. EU ePrivacy rules). Please see Cookies and Tracking below for more detail.

If you refuse to provide personal data that we need to collect by law or under a contract (for example, a contact email to deliver our service), we may not be able to fulfill our obligations or provide you with the requested service.

How We Use Personal Data

We use the collected personal data strictly for specified, legitimate business purposes in connection with our lead generation and appointment-setting services. We do not use personal information in ways that are incompatible with these purposes. Specifically, we may use your personal data to:

• Provide and Improve Our Services: We process lead and contact information to perform our core services – for instance, to reach out to potential leads (via email, phone, or LinkedIn messaging) and arrange sales appointments or introductions on behalf of our clients. This involves using personal data to personalize communications, identify the correct point of contact at a target company, and coordinate meeting schedules. We may also use data (in aggregated or anonymized form) to analyze and enhance our lead generation strategies, ensuring our services remain effective and relevant. We do not use personal data for any automated decision-making that produces legal effects or similarly significant effects on individuals.

• Communicate with You: If you contact us (e.g. as a potential client requesting information, or as a lead responding to our outreach), we will use your contact details to respond and communicate. We also use client contact information to manage our business relationship, send service updates, invoices, and administrative information. For example, we may notify clients about changes to our services or this Privacy Policy.

• Marketing (B2B Outreach): We may use business contact information to send you marketing or promotional communications about our services if you are a business or professional who is likely interested in our offerings. We do this in a responsible manner and in accordance with applicable laws on direct marketing. In jurisdictions where consent is required for B2B communications (e.g., certain email marketing under anti-spam or ePrivacy laws), we will obtain your consent before sending such messages. In other cases, we may rely on our legitimate interest in reaching out to relevant business prospects with information about our services, as GDPR Recital 47 explicitly recognizes direct marketing as a legitimate use of personal data. Important: Every marketing email or message we send will include a clear option to opt out or unsubscribe, honoring your right to object to further communications. If you opt out, we will cease further marketing to you. We do not engage in random mass emailing — our outreach is targeted to professional contexts where we believe our services could genuinely assist your business

• Operate Our Website and IT Systems: We may use personal data to administer our website and internal systems. This includes ensuring IT security, debugging and troubleshooting, and performing usage analytics (if applicable). For example, we might review IP addresses in server logs to detect fraudulent access or attacks. Any analytics are typically done on anonymized data or with consent via cookies, and we do not profile individual website visitors.

• Legal Compliance and Protection: We will process personal data as needed to comply with legal obligations, such as maintaining business records for tax and accounting purposes, or responding to lawful requests by authorities. We may also use and retain data to establish or defend legal claims. For instance, if a recipient of our outreach requests to know where we obtained their data or alleges improper contact, we may use our records to demonstrate compliance (e.g. showing that data came from a public source and that an opt-out was honored). Additionally, we may use personal data to enforce our contracts and protect the rights, property, or safety of our company, our clients, or others (e.g. to prevent misuse of our services).

We will not use your personal data for any new purposes that are not described in this Policy without prior notice to you and obtaining consent where required. We do not use personal data for any kind of automated decision-making or profiling that has legal or significant effects on individuals (such as credit scoring, etc.), and we do not sell or rent personal information for monetary gain or for others’ independent use.

Legal Bases for Processing (GDPR/UK GDPR)

For individuals in the European Economic Area (EEA) or UK, we process personal data only when we have a valid lawful basis under GDPR/UK GDPR Article 6. The main legal grounds we rely on are:

• Legitimate Interests (Art. 6(1)(f) GDPR): In most cases, our processing is based on our legitimate business interests or those of our clients, balanced against your rights and expectations. We have a legitimate interest in connecting businesses with potential customers and in promoting our B2B services. For example, when we collect professional contact information from public sources and reach out to you regarding a relevant business opportunity, we do so on the basis of legitimate interest in direct marketing. We carefully consider the potential impact on your privacy and ensure that your interests do not override our legitimate interests. Note: You have the right to object to processing based on legitimate interests (see Your Rights below), and if you object, we will review and honor that objection where required by law.

• Consent (Art. 6(1)(a) GDPR): We will ask for your consent in situations where consent is the appropriate or legally required basis. For instance, if you are not already our client or prospect and we want to send you marketing emails in a jurisdiction or context that requires opt-in (such as certain email newsletter subscriptions), we will only do so with your explicit consent. You can withdraw your consent at any time, and we will cease the related processing. Additionally, our website will only use non-essential cookies or tracking with consent (where applicable).

• Contractual Necessity (Art. 6(1)(b) GDPR): If you are a client (or acting on behalf of one) and engage our services, we process your personal data as necessary to perform our contract with you. For example, we use your contact details to communicate and deliver the agreed services, and process payment information to bill for our services. Similarly, if a prospective client asks us for a quote or proposal, we process any data provided in that request as needed to take steps at the request of the data subject prior to entering into a contract.

• Legal Obligation (Art. 6(1)(c) GDPR): Some processing is necessary for us to comply with our legal obligations. This includes retaining certain transaction records for tax/audit purposes, or disclosing information when lawfully required by government authorities or court order. In such cases, we only process the data needed to fulfill those obligations.

• Public Interest / Vital Interest: These bases are generally not applicable to our activities. We do not perform tasks in the public interest, and we would only process data to protect someone’s vital interests (life or health) in an emergency situation.

Where we act as a processor on behalf of a client (handling data they control), our legal basis is aligned with that of our client, and our contract (Data Processing Agreement) with the client ensures processing is done lawfully (e.g. under the client’s legitimate interests or consent from their data subjects, as applicable).

Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies sparingly. Cookies are small text files placed on your device to store preferences and other information. We may use:

• Essential Cookies: to ensure the website functions correctly and securely (for example, session cookies to keep you logged in or remember your form inputs). These are necessary for our site to operate and do not require consent.

• Analytics or Performance Cookies: to collect anonymous usage data about how visitors navigate our site (e.g. page views, time on site). We currently do not use any third-party analytics scripts like Google Analytics. If we introduce analytics, we will do so in compliance with applicable laws (e.g., by showing a cookie consent banner in the EU/UK and only dropping analytics cookies if you opt-in).

• No Targeted Advertising Cookies: We do not use advertising cookies or engage in behavioral ad targeting on our site. As a B2B service provider, our site’s goal is to inform visitors about our services, not to serve ads.

You can control or delete cookies using your browser settings. Most browsers allow you to block cookies or alert you when cookies are being set. However, blocking certain essential cookies may impact the functionality of our site. For more information on cookies and how to manage them, you may refer to our Cookies Policy (if available) or contact us with any questions.

How We Share Personal Data

We treat personal data as confidential and do not sell or rent it to third parties for their own marketing use. However, in the course of running our business and delivering our services, we may need to share personal data with the following categories of recipients, under strict conditions:

• Client Companies: Our service by nature involves sharing lead information with the specific client on whose behalf we obtained or contacted that lead. If you are a business lead whose information we collected and you subsequently express interest or agree to a meeting, we will provide your relevant contact details and discussion notes to our client (the company that offers the product or service you are interested in). We only share with the particular client(s) that are relevant to your situation, not with arbitrary third parties. For example, if we arranged a sales appointment between you and Client X, we give Client X your name, role, and contact info to carry out that meeting – we will not share your data with other clients without your permission.

• Service Providers (Processors): We use trusted third-party companies to help us operate our business and support our services. These service providers process personal data on our behalf and under our instructions (as “processors” or equivalent under applicable law). They include, for example:

  • Hosting and IT Infrastructure: We may store data on cloud servers or use email/CRM systems provided by third parties. (We currently do not use AWS or GCP, but we may use other hosting services – the exact server locations may vary, see International Transfers below.)

  • Communication Tools: We might use an email delivery service or a VoIP phone provider to contact leads, or scheduling software to arrange meetings. These tools might process contact information to send out our communications on our behalf.

  • Analytics or Utility Tools: If we employ any analytics or logging services, those providers might process limited personal data (like IP addresses) for our internal use.

  In all cases, we ensure these vendors are bound by confidentiality and data protection obligations. They are not allowed to use your data for their own purposes and can only process it for the specific purposes we dictate. We perform due diligence on our providers to ensure they have appropriate data protection measures.

• Business Transfers: If we undergo a business transaction, such as a merger, acquisition by another company, or sale of all or part of our assets, personal data may be transferred to the acquiring entity or its advisors as part of due diligence and ultimately to the new owner. In such events, we will ensure the recipient agrees to handle personal data in a manner consistent with this Policy and applicable law. We will notify you of any change in ownership that affects your personal data, so you can exercise your rights if desired.

• Legal and Safety Disclosures: We may disclose personal data to third parties when required to do so by law or if we have a good-faith belief that such action is necessary to: (i) comply with a legal obligation (e.g., responding to subpoenas, court orders, or regulatory requests); (ii) protect and defend our rights or property, or the rights and safety of others; or (iii) investigate and prevent fraud or security issues. For example, we might share information with law enforcement if mandated, or report information to authorities to meet regulatory requirements.

• Professional Advisors: We may share data with our auditors, attorneys, insurers, or other professional consultants if necessary for obtaining advice or protecting our business interests, but only under duties of confidentiality.

No Unauthorized Third-Party Marketing: We do not share your personal information with unrelated third parties for their own marketing or advertising purposes. You will not receive communications from any third party as a result of information you have shared with us, unless you explicitly consent to such sharing.

If we ever need to share your personal data in a manner not covered above, we will explain it to you at the time and, if legally required, obtain your consent.

International Data Transfers

Given the international nature of our business, your personal data may be transferred to, and processed in, countries other than your country of residence. For example:

• We are based in the United States (Wyoming), and our primary operational data (client records, lead databases) are likely stored on servers in the U.S.

• We serve clients and handle data of individuals in the EU/EEA, UK, Canada, Australia, New Zealand, etc. If you are located in one of these regions, your personal data will likely be transferred to the United States for processing (since our team and main systems are in the U.S.). It may also transit through or be stored in other countries where our service providers maintain facilities. Note: We currently do not precisely know all server locations (as we are not using major cloud providers like AWS/GCP, servers might be managed by smaller hosting firms). However, we assume data could be stored in the U.S. and possibly in other jurisdictions depending on our IT solutions.

• If we or our sub-processors use cloud services or communication tools, there may be backups or routing of data through various countries. For instance, an email sent to an EU lead might pass through servers in different regions as part of internet infrastructure.

Our Commitment to Lawful Transfers: When we transfer personal data internationally, especially from the EU/UK or other regions with data transfer restrictions, we take steps to ensure appropriate safeguards are in place. These measures may include:

• Standard Contractual Clauses (SCCs): We have standard data protection clauses in our contracts between our US entity and any non-US affiliates or processors, as approved by the European Commission. This means that we contractually commit to protect EU personal data to GDPR standards even when it is transferred to a country (like the U.S.) that may not have an EU-equivalent privacy law.

• Data Privacy Framework: We are monitoring developments like the EU-U.S. Data Privacy Framework (DPF). If applicable and feasible, we may certify under such frameworks to facilitate compliant data transfers. (As of the latest update of this Policy, we have not yet self-certified under the DPF.)

• Adequacy Decisions: Where we transfer data to a country that the EU (or UK, or other relevant authority) has deemed to have an “adequate” level of data protection, we rely on that adequacy decision.

• Additional Safeguards: We implement technical and organizational measures such as encryption in transit and at rest, access controls, and data minimization to further protect personal data in cross-border scenarios. We also assess, on a case-by-case basis, whether any supplementary measures are needed to ensure transferred data remains protected (in light of legal requirements like the Schrems II ruling).

By using our services or providing us information, you understand that your personal data may be transferred to our facilities and those third parties with whom we share it (as described above), which may be located in jurisdictions different from your own. We will strive to ensure all transfers comply with applicable legal requirements.

If you have questions about our international data transfer practices or need more information about specific transfer safeguards (such as a copy of the SCCs we use), please contact us using the information in the Contact Us section.

Data Security and Storage

We take data security seriously and have implemented appropriate measures to protect personal data from unauthorized access, alteration, disclosure, or destruction. While no method of transmission over the Internet or electronic storage is 100% secure, we follow industry best practices to safeguard your information. Our security measures include:

• Technical Measures: We use up-to-date security technologies, such as firewalls, encryption, and secure protocols (HTTPS) for data in transit. Stored data is protected by access controls; for example, personal data we hold in databases or spreadsheets is accessible only with authenticated credentials by authorized personnel. Where possible, we encrypt personal data at rest or use secure cloud storage solutions with strong security track records. Regular backups are maintained securely to prevent data loss.

• Organizational Measures: We restrict access to personal data strictly to employees and contractors who need it to perform their job duties (“need-to-know” basis). All team members are trained on confidentiality and the importance of privacy and security. We have internal policies in place for handling personal data safely and responding to any potential security incidents.

• Vendor Due Diligence: Any service providers who handle personal data on our behalf are vetted for strong security practices. We enter into Data Processing Agreements requiring them to maintain adequate safeguards and notify us promptly in case of any data breach or security issue.

• Monitoring and Testing: We monitor our systems for possible vulnerabilities and attacks, and we periodically assess our security measures. Software and systems are kept updated with security patches. We also have an incident response plan – if a security breach were to occur, we will act quickly to contain it, mitigate any harm, and notify affected parties and regulators as required by law.

If you have reason to believe that your interaction with us or your data may no longer be secure (for example, if you suspect a vulnerability in our system or you received suspicious communication claiming to be from us), please notify us immediately so we can take action.

Data Retention

We will retain personal data only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In determining data retention periods, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure if retained longer than necessary, the purposes for which we process the data and whether we can achieve those purposes through other means, and applicable legal requirements.

Here are some general retention guidelines:

• Leads/Prospect Data: If we collect your information as a prospective business lead (and not on behalf of a specific client), we will retain it for a limited period relevant to our marketing and sales cycles. For example, we may keep your contact details and notes of interactions for a certain number of months or a couple of years to try to establish a business relationship. If you inform us that you are not interested or you object to further contact, we will either delete your data or at minimum suppress it in our systems to ensure we honor your no-contact request in the future. We won't keep prospect data indefinitely without activity. We periodically review our lead database and remove or anonymize data that is outdated or no longer needed.

• Client-Related Data: For individuals connected to our clients (either as client contacts or leads engaged on a client’s behalf), we retain personal data for as long as necessary to provide services to that client. This often means we keep data for the duration of the client contract and for a reasonable period thereafter. For instance, if we set an appointment between a lead and our client, we might retain the lead’s information until the deal progresses or for follow-up, but if it becomes clear no further action will occur, we would remove that data. We may also retain certain information to provide our client with reports or evidence of work done (e.g., a list of leads contacted) – in such cases, we act under our contract with the client regarding retention.

• Legal and Backup Retention: We may retain information as needed to comply with legal obligations or for legitimate business purposes such as dispute resolution or enforcement of agreements. For example, we may keep basic contact or transaction information in our accounting records for the legally required retention period (e.g., seven years for financial records under some laws). If any personal data is contained in routine backups, those backups might be retained for some additional time (with secure protection) until they cycle out, even after active records are deleted; we will continue to protect any such data.

• Website Visitor Data: Any technical logs or analytics data are generally retained for a short duration (often automatically overwritten or anonymized after a few weeks or months), except where needed for security analysis.

After the applicable retention period ends, we will either delete the personal data securely or anonymize it (so it can no longer be associated with an identifiable individual) if we still need the data for statistical purposes. For example, we might anonymize leads data to analyze conversion rates or industry trends without identifying individuals.

If you have specific questions about our data retention for a certain category of data, you can contact us for more details.

Your Rights and Choices

Privacy laws in various jurisdictions grant individuals certain rights regarding their personal data. We are committed to honoring those rights. The availability of rights and how to exercise them can depend on where you live and the applicable law, but we will make our best effort to accommodate any legitimate request regardless of origin. Here is an overview of your rights:

• Right to Be Informed: You have the right to be informed about how we collect and use your personal data. This Privacy Policy is one of the ways we provide you with that information. We aim to be transparent about our data practices.

• Right of Access: You can request confirmation of whether we hold personal data about you, and if so, request access to a copy of that data (commonly known as a “data subject access request”). This allows you to know what information we have about you. We will provide the data, along with details on how we use it and who we share it with, subject to some legal exceptions.

• Right to Rectification: If you believe that any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it. For example, if we have your wrong job title or a misspelled name, please let us know and we will fix it.

• Right to Erasure: You can request that we delete or remove your personal data, often referred to as the “right to be forgotten.” You may exercise this right, for instance, if the data is no longer necessary for the purposes we collected it, or if you have withdrawn consent (where consent was the basis) or objected to processing and we have no overriding grounds to continue. We will honor valid deletion requests and also direct any applicable service providers or third parties to delete your data, unless retention is required by law or other exemptions apply (for example, we may retain minimal information to record your opt-out or to fulfill legal obligations).

• Right to Restrict Processing: You have the right to request that we limit the processing of your personal data in certain circumstances – for example, while we verify the accuracy of data you contest or pending the resolution of an objection you raised. When processing is restricted, we will still store your data but not use it further until the restriction is lifted.

• Right to Data Portability: For data you provided to us and which we process by automated means on the basis of consent or contract, you may request to receive that data in a structured, commonly used, machine-readable format, and you have the right to transmit it to another entity. This right is most relevant if you were to ask us to transfer your information to a new service provider. Given our B2B service context, this right might seldom apply, but we will assist as required.

• Right to Object: You have the right to object to our processing of your personal data when we are relying on legitimate interests as the legal basis. If you object, we will reconsider the processing and will stop processing your data unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or if we need to continue processing for the establishment or defense of legal claims. Importantly, you have an unconditional right to object to processing of your personal data for direct marketing purposes at any time. If you object to marketing (or opt out of communications), we will cease using your data for that purpose immediately.

• Right to Withdraw Consent: If we process any of your data based on your consent, you have the right to withdraw that consent at any time. For example, if you signed up for a newsletter, you can unsubscribe (withdrawing consent for marketing emails). Withdrawing consent will not affect the lawfulness of any processing we did prior to your withdrawal. If you withdraw consent, we will stop the processing that was based on consent.

• Additional U.S. State Rights (California and others): If you are a resident of certain U.S. states, you may have additional rights under state laws:

  • California: Under the California Consumer Privacy Act (CCPA) as amended by the CPRA, California residents have the right to know what personal information is collected about them, to access that information, to request deletion of it (with similar exceptions as GDPR), to correct inaccurate personal information, to opt out of the “sale” or “sharing” of personal information, and to not be discriminated against for exercising their privacy rights. Please note, we do not sell personal information as defined by the CCPA (we do not exchange personal data for money or other valuable consideration apart from providing our services to our clients) and we do not share it for targeted advertising. If that ever changes, we will implement a “Do Not Sell or Share” mechanism on our website. If you are a California resident and send us a request to exercise your rights (access, deletion, etc.), we will process it in accordance with California law. We may need to verify your identity and request, which might involve asking you for additional information. You may also designate an authorized agent to make a request on your behalf, provided the agent’s request is accompanied by proof of authorization.

  • Other States (e.g. Virginia, Colorado, Connecticut, Utah): These states’ privacy laws (effective 2023) provide rights similar to the above, though they often exclude B2B contact data from their scope. If you are a resident of one of these states and believe our processing falls under that law, you can still contact us to exercise rights like access, correction, deletion, or to appeal a decision we make on your privacy request.

• Right to Lodge a Complaint: If you have concerns about our privacy practices, you have the right to complain to a supervisory authority.

  • For EU residents, this would be the data protection authority in your country (for example, the ICO in the UK, the CNIL in France, etc.). You can find the contact details of EU Data Protection Authorities online.

  • For Canadian residents, you can contact the Office of the Privacy Commissioner of Canada (OPC) or relevant provincial Privacy Commissioners.

  • For Australian residents, you can contact the Office of the Australian Information Commissioner (OAIC).

  • We encourage you to first reach out to us so we can try to address your concerns directly. But if you are not satisfied with our response, you can seek help from the authorities.

Exercising Your Rights: To exercise any of your rights, please contact us at the contact details provided below (see Contact Us). We will respond to your request as soon as possible and within any timeframe required by law (GDPR requires within one month, CCPA within 45 days, etc., with extensions if necessary which we will inform you of). There is generally no fee for exercising your rights, but if a request is manifestly unfounded or excessive (e.g., repetitive), we may charge a reasonable fee or refuse to act on it, as permitted by law. We may need to verify your identity to ensure that personal data is not disclosed to an unauthorized person – for example, we might ask you to confirm some details we have on file or to use a particular email address that we have associated with you.

We are committed to honoring your rights and ensuring you have control over your personal information.

Updates to This Privacy Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make changes, we will update the “Last Updated” date at the top of the Policy. If the changes are significant, we may also provide a more prominent notice (such as by email to our clients or a notice on our website’s homepage) that our privacy practices have changed.

We encourage you to review this Policy periodically to stay informed about how we are protecting your information. Your continued use of our services or website after any modifications to this Policy will constitute your acknowledgment of the changes and agreement to be bound by the updated Policy.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, please do not hesitate to contact us:

• Email: privacy@[ourdomain].com

• Postal Mail: [Company Name], Attn: Privacy Officer, [Street Address], [City], Wyoming, USA

• Contact Form: You may also reach us through the contact form on our website.

We will address your inquiry as promptly as possible. If you are contacting us to exercise a privacy right, please state clearly what you are requesting (e.g., “I am requesting a copy of my personal data” or “Please delete my information”) and provide enough information for us to verify your identity (if applicable).

Thank you for reading our Privacy Policy. We value the trust you place in us to handle your personal data responsibly.