OVERVIEW

This Privacy Policy describes the data practices of Concinnity Limited (“we,” “our,” or “us”) regarding the personal information we gather, utilize, store, and share when you engage with our digital marketing platforms, campaign management tools, and marketing analytics services (“Platform”). This document also outlines your data protection rights and provides guidance on contacting us with privacy-related inquiries.

This Policy applies to interactions with our websites featuring this Privacy Policy, account creation and usage of our Marketing Platform, Dashboard, Consulting Services and Campaign Management Tools, participation in our branded social media presence, attendance at our marketing webinars or training events, and various forms of direct communication with our organization.

This Policy does not govern our data handling when we act as a data processor for our business clients. Such processing is controlled by our service agreements with clients and their respective privacy policies.

Please review this Privacy Policy thoroughly. If you disagree with these terms, please refrain from using our Platform or sharing your personal information with us. By accessing our Platform or providing us with your personal data, you confirm your understanding and acceptance of this Privacy Policy. Your Platform usage is additionally governed by our Terms of Service.

This Privacy Policy takes effect from the date indicated above. We may periodically update this Policy, and changes will be posted on this page with an updated effective date. We recommend reviewing this date regularly to stay informed of any modifications. Material changes affecting our use or disclosure of your personal information will be communicated through our website or other appropriate methods as required by law. Continued use of our Platform following such updates constitutes your acceptance of the revised terms.

TERMINOLOGY

“Associated Companies” refers to entities within our corporate family as identified in this Privacy Policy.

“International Data Protection Regulations” encompasses the General Data Protection Regulation (EU) 2016/679 (GDPR), relevant national implementing legislation, and where applicable, the UK Data Protection Act 2018 and UK GDPR.

“Privacy Policy” means this document.

“Concinnity,” “we,” “us,” and “our” refer to Concinnity Digital Marketing and its Associated Companies, unless otherwise specified.

“Platform” encompasses the Marketing Platform, Analytics Dashboard, and Campaign Management Tools accessible through our websites and tracking technologies.

“You” and “your” refer to individuals whose personal data is covered by this Privacy Policy.

“Client Website Visitors” refers to users of websites operated by our clients who have implemented our marketing tracking and analytics solutions.

DATA WE GATHER

Certain Platform features are accessible without providing personal information, though full functionality requires personal data sharing. We process personal information from three primary sources: data you provide directly, information from external sources, and automatically collected data.

Direct Information Provision

Account Creation. When establishing an account through our Platform or entering into a service agreement, we request specific personal details including your full name, organization name, email address, and account password. Third-party authentication through services like Google, Facebook, or LinkedIn provides us with your name and email address according to your profile permissions on those platforms. The data we receive depends on the privacy settings and policies of these external services, which you should review carefully.

Direct Communications. We collect personal information when you voluntarily contact us through inquiry forms, engage with our website chatbot, participate in our surveys, reach out to customer support about Platform issues, or otherwise communicate regarding our services.

Transaction Processing. We gather transaction details for Platform purchases, including information necessary for order fulfillment and financial data such as credit card information. For paying customers, we receive payment transaction details including your name, payment amount, and transaction dates.

Billing Information. We collect billing and payment details when you sign up for trials, purchase services, or upgrade your account, including payment method information such as credit card numbers.

Supplementary Billing Details. You may optionally provide additional information such as VAT numbers, alternative billing addresses, or your organization’s legal name.

Identity Confirmation. In certain circumstances (such as refund requests or fraud reports), we may request verification information including billing details, email addresses, login credentials, and identity verification documents as permitted by law.

Content Engagement and Event Participation. When accessing our marketing blog, downloading resources, or participating in marketing webinars or training events, we may collect information such as your name, professional title, company name, email address, phone number, or other relevant details.

Customer Testimonials. We collect and display testimonials from satisfied customers on our Platform. With your consent, we may publish your testimonial along with your name. You may request updates or removal of your testimonial by contacting [email protected].

Marketing Platform Integration. When you implement our Analytics Dashboard on your website, we collect information about your domain, campaign tracking configuration, and implementation details necessary for Platform functionality.

Third-Party Information Sources

We may combine your directly provided information with data obtained from external sources, including:

Our authorized partners and distributors may provide business contact information, including addresses, job titles, email addresses, and phone numbers, when you purchase Platform access through these channels.

External sources such as marketing campaigns, business partners, public databases, and data providers. This information may include company details, location data, demographic information, and professional contact information. We use this data to enhance our existing records and improve accuracy for purposes described throughout this Privacy Policy.

Automatically Collected Information

Like many commercial websites and tracking services, we employ various technologies, including usage data collection tools, cookies, web beacons, pixels, and similar technologies, to automatically gather information that may include personal data as you navigate our websites, use our Platform, or interact with our communications, subject to applicable legal consent requirements.

Device and Usage Information. When users visit our websites, we may monitor, collect, and aggregate information, including visited pages, page visit sequences and timing, clicked hyperlinks or elements, and referral URLs. This process may involve logging IP addresses, operating systems, and browser software used by website visitors. IP addresses may enable us to determine Internet Service Providers and approximate geographic locations.

Cookies and Related Technologies. We and our partners may use cookies and similar technologies to gather information about Platform usage for various business purposes detailed in our Cookie Policy. For comprehensive information about our cookie usage and your related choices, please refer to our Cookie Policy.

Analytics Services. Our Platform utilizes digital marketing analytics services, including Google Analytics and Google Search Console, for web analysis. This may include operating modes that enable linking data, sessions, and interactions across multiple devices to pseudonymous user identifiers for cross-device activity analysis.

Marketing Platform Integrations. Our Platform may integrate with external platforms and services including:

Advertising platforms (Google Ads, Facebook Ads, LinkedIn Ads, etc.)
E-commerce platforms and payment processing services
Content management systems
Email marketing services
Marketing automation tools
Custom marketing tools and calculators

When you connect these integrations, we may receive and process data in accordance with your configuration settings and the terms of the external services. These services maintain their own privacy policies governing their data collection and usage practices.

INFORMATION UTILIZATION

We utilize the personal information described above for the following purposes:

To deliver Platform services and related support, process transactions, manage user accounts, and respond to your requests. This processing is necessary to perform our contractual obligations with you.

To the extent permitted by applicable law and for legitimate business interests, including:

Operating and maintaining our websites, providing requested content (such as marketing resources and technical documentation), and responding to Platform

service requests, including sharing your information with our partners as necessary for efficient service delivery and Platform sales facilitation.

Managing our relationship with you through administrative communications including Platform information, policy updates, product information that may

interest you, and responding to your requests or communications.

Analyzing your preferences, interests, and behavior patterns (including Platform usage and website interactions) to identify insights, trends, and correlations. This enables us to enhance your Platform experience with more relevant content and

service offerings while improving Platform functionality, features, user experience, and developing new products and services.

Supporting internal business operations including data analysis, benchmarking, audits, research, studies, surveys, and usage trend identification.
Preventing fraud, criminal activities, and service misuse while ensuring the security of our IT infrastructure, architecture, and networks.
Complying with legal obligations and processes, responding to governmental authority requests, enforcing our Terms of Service, protecting our operations and rights, safeguarding privacy and safety, and pursuing available remedies or limiting damages.
Maintaining basic identification data to prevent unwanted processing when you request data deletion or marketing list removal.

For marketing and promotional activities, including updates about new products and services, upcoming marketing events, or other promotions and news through email or push notifications, as permitted by law.

Where legally required, we will only send marketing information with your consent. Otherwise, we rely on legitimate business interests for such communications. You may opt out of marketing communications as described in the “Marketing Communication Opt-out” section below.

We engage advertising partners, including third-party advertising companies and social media platforms, to display advertisements across the web. These companies may use cookies and similar technologies to collect information about your interactions across our Platform, communications, and other online services to serve targeted advertisements. Where legally required, we conduct such advertising activities based on your consent; otherwise, we rely on legitimate business interests. Please refer to our Cookie Policy for additional information.

Our clients are responsible for obtaining necessary Client Website Visitor consents and complying with applicable privacy laws. We process Client Website Visitor data according to our client agreements and applicable data protection regulations.

PERSONAL DATA SHARING

We do not sell, rent, lease, or otherwise transfer your personal information to others, except to provide requested products and services as described below, with your permission, or as required by applicable law.

Service Providers

We may engage external companies and individuals to perform services on our behalf to help deliver our Platform services. We specifically utilize third-party providers for payment processing, fraud prevention, risk assessment, hosting and information technology services, email communications, customer support, analytics and data services, marketing, advertising, and customer relationship management. These parties may process your personal information under our instructions while providing relevant services to us.

Associated Companies

We may share your data with our Associated Companies for administrative purposes, Platform service delivery (including engineering services, infrastructure support, or data processing), related customer support, or sales and marketing activities on our behalf. For example, when you request service information, we may transfer relevant personal data to another Associated Company to enable appropriate responses to your request.

Partners, Distributors, and Third Parties

When you request Platform services or inquire about our offerings, we may share personal information such as your name, company name, and email address with our authorized partners, distributors, and other third parties as necessary for efficient service delivery and Platform sales facilitation, and for those parties’ own marketing services. These third parties process your personal information as independent data controllers according to their privacy policies. Please review the applicable partner privacy policy for information about their data practices.

Client Control of Website Visitor Data

Our clients control Client Website Visitor data collected through our Analytics Dashboard code. Clients may export, share, or transfer Client Website Visitor data to third parties including:

Analytics and business intelligence platforms
Marketing automation and CRM systems
Advertising networks and demand-side platforms
Data warehouses and storage solutions
Third-party service providers and consultants

We enable these data transfers through integrations, APIs, and export functionality. Clients are responsible for ensuring lawful data-sharing practices and for obtaining the necessary Client Website Visitor consents.

Social Media Platforms

Where legally permissible or with your consent, where required, we may use limited personal information, such as your email address, in hashed form to share with social media platforms for lead generation, website traffic driving, or product and service promotion. These social media platforms are not controlled or supervised by us. Questions regarding how these platforms process your personal information should be directed to the respective platform providers.

Business Transactions

If we become involved in mergers, acquisitions, financing due diligence, reorganizations, bankruptcies, receiverships, asset sales, or service transitions to other providers, your personal information may be transferred to successors or affiliates as part of such transactions.

Legal Obligations

We may share your personal information to comply with legal obligations, protect and defend our rights or property, act urgently to protect personal safety or public safety, or protect against legal liability. Examples include sharing with regulatory bodies governing our work and services, government departments such as law enforcement, courts, financial institutions, external auditors, etc.

DATA RETENTION PERIODS

We retain your personal information for as long as reasonably necessary to provide Platform services and fulfill requested transactions, comply with legal obligations, or serve other legitimate business purposes such as maintaining business and financial.

records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.

Client Data: We retain client account information for as long as your account remains active or as needed to provide Platform services. Following account termination, we may retain certain information as required by law or for legitimate business purposes including billing records, transaction history, and communications for up to seven years.

Client Website Visitor Data: Client Website Visitor data retention periods are configurable by clients and depend on client settings and applicable legal requirements. Default retention periods include:

Raw event data: 26 months from collection
Aggregated analytics data: 50 months from creation
Cookie data: 24 months from last activity (client configurable)
Campaign tracking data: 30 days (if feature is enabled)

Clients can configure shorter retention periods or request earlier deletion of Client Website Visitor data through our Platform dashboard or by contacting support. After applicable retention periods elapse, your personal information will be anonymized or deleted.

PERSONAL DATA PROTECTION

We have implemented physical, technical, and administrative security measures designed to protect the confidentiality of personal information we process, including:

Data encryption in transit
Encryption at rest for sensitive information stored in our systems
Access controls requirements
Regular security audits and vulnerability assessments
Intrusion detection and prevention systems
Security monitoring and incident response procedures
Employee training on data security and privacy practices
Secure software development lifecycle practices
Regular backup and disaster recovery procedures

However, the Internet cannot be guaranteed to be completely secure, and we cannot ensure or warrant the security of any personal information you provide to us. You are

responsible for protecting the security of your login information.

If you know or suspect that your personal information has been lost, stolen, misappropriated, or otherwise compromised, or in case of any actual or suspected unauthorized account use, please immediately contact us at [email protected] .

INTERNATIONAL DATA TRANSFERS

Concinnity Digital Marketing is based in the United States, and other members of our group may be located in countries outside the EEA or UK. If you are accessing our websites and Platform from the EEA, UK, or other regions with data protection laws, please note that, for business, administrative, management, and legal purposes, we may transfer your personal information from your country of residence to our facilities and service providers in various jurisdictions. These countries may have data protection laws that are less stringent than or otherwise different from the laws in your location.

Where we transfer your personal information as described above, we will take steps to ensure that your personal information receives adequate security protection where it is processed and your rights continue to be protected pursuant to applicable data protection law, including through the use of:

Standard Contractual Clauses approved by the European Commission
Adequacy decisions where applicable
Other lawful transfer mechanisms as permitted under applicable law

In some cases, transfers of your personal information to us are necessary to perform our agreement with you. If you would like more information about the safeguards we implement as described above, please contact us as indicated below.

PRIVACY RIGHTS AND OPTIONS

Marketing Communication Opt-out

You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in communications you receive from us or by contacting us as provided in the “Contact Information” section below. You may continue to receive Platform-related and other non-marketing emails.

Online Tracking Opt-out

You can opt out of third-party cookies as described in our Cookie Policy. Most web browsers accept cookies by default. If you prefer, you can usually set your browser to remove or reject browser cookies. Please note that removing or rejecting cookies may affect the availability and functionality of our Platform services.

Personal Data Requests

We offer you choices affecting how we handle personal information under our control. Depending on your location and the nature of your Platform interactions, you may request the following regarding personal information:

Information about how we have collected and used personal information. We have made this information available to you without requiring a request by including it in this Privacy Policy.

Access to a copy of the personal information we have collected about you. Where applicable, we will provide information in a portable, machine-readable, readily usable format.

Correction of personal information that is inaccurate or outdated.

Deletion of personal information we no longer need to provide Platform services or for other lawful purposes.

Opt out of having your personal information shared or processed for targeted advertising. To exercise this right, visit the “Do Not Sell or Share My Personal Information” link in our website footer.

Additional rights, such as objecting to and requesting that we restrict our use of personal information, and, where applicable, you may withdraw your consent.

To make a request, please email or write to us using the contact information provided in the “Contact Information” section below. We may ask for specific information to help confirm your identity. Depending on your residence, you may be entitled to authorize an agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority in accordance with applicable laws. You are entitled to exercise these rights free from discrimination.

You may also access, review, modify, and delete your account profile information by logging into your account and editing information through your account settings.

Client Website Visitor Rights

If you are a Client Website Visitor whose data is collected through our Analytics Dashboard code on a client’s website, you should contact the website owner (our client) directly to exercise your privacy rights regarding that data. However, you may also

CHILDREN’S PRIVACY

Our Platform services are not directed to children under the age of 16. We do not knowingly collect personal information from children under 16. If you have reason to believe that a child under 16 has provided personal information to us through the Platform, please contact us at [email protected], and we will endeavor to delete that information from our databases.

Clients who implement our Analytics Dashboard code are responsible for ensuring compliance with children’s privacy laws, including obtaining necessary parental consent if their websites are directed at children.

CONTACT INFORMATION

Concinnity Digital Marketing is the entity responsible for personal data processing under this Privacy Policy.

If you have questions or concerns regarding our Privacy Policy or use of personal information, or if you want to exercise your rights regarding your personal information, please contact us by email at our designated request address at [email protected].