PRIVACY POLICY
Altair Partners LLC
Effective Date: January 11, 2025 (Updated December 28, 2025)

1. Introduction and Scope of Application

Altair Partners LLC ("the Company," "we," "us," or "our"), a digital marketing agency duly registered and operating under the laws of the State of Oregon, United States, currently in the process of relocating to a new business address. For all communications, please use email: support@altairpartner.com. If you need to send physical mail for important legal matters that require a postal address, please contact us via email and we will provide a temporary mailing address.

1.1 Our primary corporate website (www.altairpartner.com) and all associated subdomains (including without limitation altairpartners.co);

1.2 Our officially designated and verified social media accounts, specifically limited to @altair_partners on Instagram.com / LinkedIn.com / x.com platforms where these accounts are registered;

1.3 All electronic communication channels including email correspondence, SMS messaging, and any other digital communication platforms;

1.4 Telephone communications, both inbound and outbound;

1.5 In-person interactions at corporate events, meetings, or conferences;

1.6 Any other conceivable method of data collection that may be developed during the effective period of this Policy.

This Policy constitutes an integral part of our Terms of Service and shall be interpreted in conjunction with all other governing documents of the Company. By accessing, utilizing, or otherwise interacting with any aspect of our services, you hereby acknowledge, understand, and irrevocably consent to all provisions contained herein. We will provide 30 days' notice for material changes to this Policy, during which time you may choose to continue using our services under the existing terms or terminate your relationship with us.

2. Legal Bases for Processing Personal Data

We process your personal information based on one or more of the following legal grounds under applicable data protection laws:

2.1 Contractual Necessity

Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, including:

• Providing our digital marketing services as requested
• Processing payments and issuing invoices
• Managing client accounts and delivering purchased services
• Providing customer support and service communications

2.2 Legal Obligation

Processing is necessary for compliance with our legal obligations, including:

• Tax reporting and accounting requirements
• Responding to lawful government requests and court orders
• Maintaining business records as required by law
• Complying with anti-money laundering regulations

2.3 Legitimate Interests

Processing is necessary for the purposes of our legitimate business interests, including:

• Marketing and business development activities
• Improving our services and user experience
• Preventing fraud and ensuring network security
• Administrative and operational purposes

2.4 Consent

Where required by law, we obtain your explicit consent for specific processing activities, including:

• Marketing communications and newsletters
• Certain types of cookies and tracking technologies
• Processing of sensitive personal data

3. Detailed Catalog of Collected Information

We systematically collect, process, and maintain personal and non-personal information necessary for providing our digital marketing services, as enumerated below:

3.1 Personal Identifiable Information (PII)

3.1.1 Biographical and Contact Information

• Complete legal name (including first, middle, last, and any suffixes)
• All professional titles, designations, and certifications
• Current and historical business affiliation information (company name, department, job title, reporting structure)
• Comprehensive contact details (primary and secondary email addresses, mobile telephone numbers, landline telephone numbers, fax numbers, physical mailing addresses)

3.1.2 Professional and Employment-Related Data

• Professional qualifications, licenses, and certifications relevant to our services

3.1.3 Financial and Transactional Information

• Payment information processed through secure third-party payment processors
• Billing histories (invoices issued, payments received, outstanding balances)
• Tax identification numbers where required by applicable law for business transactions

3.1.4 Marketing and Communication Preferences

• Explicit opt-in and opt-out selections for each distinct communication channel
• Granular subscription preferences for various newsletter categories
• Detailed records of marketing communications sent, delivered, opened, and clicked
• Comprehensive survey responses and feedback mechanisms

3.2 Non-Personal Information

3.2.1 Technical System Information

• Internet Protocol (IP) address information
• Browser specifications (vendor, version, language settings, cookie preferences)
• Device characteristics (operating system version, device type)

3.2.2 User Interaction Data

• Records of website interactions
• Clickstream data documenting user actions
• Timestamps for system interactions
• Form interaction histories (field entries, changes, submission attempts)

3.2.3 Tracking Technologies Implementation

We employ an extensive suite of tracking technologies including but not limited to:

• Persistent cookies with configurable lifespans
• Session cookies for temporary data retention
• Local Storage Objects (LSOs) including HTML5 Web Storage
• Web beacons (also known as clear GIFs or pixel tags)
• Embedded scripts from third-party analytics providers

4. Data Retention and Deletion Policies

4.1 Retention Periods

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

• Client contract data: 3 years from contract termination for business operations
• Financial and tax records: 5 years from transaction date as required by law
• Marketing consent records: 3 years from last interaction
• Website analytics data: 26 months from collection
• Legal dispute records: Until resolution plus 3 years

4.2 Deletion Procedures

Upon expiration of applicable retention periods, we implement secure deletion procedures including:

• Physical destruction of paper records
• Secure erasure of electronic files
• Database record anonymization
• Verification of complete data removal

5. Social Media Content and Testimonial Disclosure

All content published on our officially designated and verified social media accounts (@altair_partners) represents the official communications of Altair Partners LLC. With respect to testimonials, case studies, or success stories featured on these platforms or our corporate website, please note the following critical disclosures:

5.1 Nature of Published Content

Content may include, without limitation:

• Authentic client experiences and verifiable feedback
• Simulated scenarios developed for illustrative and educational purposes
• Volunteer participants engaged in marketing research initiatives
• Hypothetical examples demonstrating service capabilities and potential outcomes

5.2 Representation and Liability

• No representation or warranty is made that all published content reflects actual client engagements unless explicitly stated as such with verifiable documentation
• We accept legal responsibility only for content published on our officially designated accounts enumerated in Section 1.2
• Any content appearing on social media profiles or platforms not explicitly listed in Section 1.2 shall not be considered representative of the Company's official position unless independently verified through our corporate communication channels

6. Artificial Intelligence Implementation Framework

As an integral component of our service delivery model, certain user interactions may be facilitated through artificial intelligence systems. These implementations are subject to the following material disclosures and limitations:

6.1 System Characteristics and Capabilities

• All AI-generated communications are produced by sophisticated machine learning algorithms
• These systems utilize statistical modeling techniques to generate responses
• AI outputs are derived from analysis of extensive training datasets

6.2 Operational Limitations

• AI systems cannot form legally binding agreements or representations
• Output may contain inaccuracies or reflect biases present in training data
• Complex inquiries may require escalation to human personnel

6.3 Ethical Safeguards

• We periodically review AI systems for quality and fairness
• Continuous monitoring for inappropriate outputs
• Human oversight of all critical business communications

7. Comprehensive Data Security Framework

We implement industry-standard security measures provided by our hosting and technology partners (such as AWS, Google Cloud, and Shopify) including:

7.1 Technical Security Controls

• 256-bit SSL/TLS encryption for all data transmissions
• Network firewall protection
• Regular security updates and patches

7.2 Administrative Security Measures

• Access control with least privilege principles
• Security awareness training for personnel
• Incident response planning

7.3 Infrastructure Security

• Secure data centers managed by our cloud providers
• Environmental controls and monitoring
• Regular backup procedures

8. Third-Party Data Sharing and Disclosure

8.1 Categories of Third-Party Recipients

We may share your personal information with the following categories of third parties:

• Service Providers: Cloud hosting, payment processing, email marketing, analytics
• Business Partners: Co-marketing partners, technology integrations
• Professional Advisors: Lawyers, accountants, consultants
• Government Authorities: As required by law or legal process
• Business Transferees: In connection with mergers, acquisitions, or asset sales

8.2 Data Processing Agreements

All third-party service providers are subject to comprehensive Data Processing Agreements that:

• Limit processing to specified purposes
• Require appropriate security measures
• Prohibit secondary use of data
• Mandate data breach notification

8.3 No Sale of Personal Information

We do not sell, rent, or trade your personal information to third parties for monetary or other valuable consideration as defined under applicable privacy laws.

9. Your Rights & Choices

Depending on your geographical location and applicable data protection regulations, you may exercise the following rights regarding your personal information:

9.1 Right of Access

You may submit a formal written request to obtain:

• Confirmation as to whether or not we are processing your personal data
• A copy of all personal data we maintain about you in a structured, commonly used, and machine-readable format
• Information about the purposes of processing, categories of data, and recipients of such data

9.2 Right to Rectification

You may demand correction of any inaccurate personal data and completion of incomplete personal data, including by means of providing a supplementary statement.

9.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal data when:

• The data is no longer necessary for its original purpose
• You withdraw consent and no other legal basis exists
• The data has been unlawfully processed
• Erasure is required to comply with legal obligations

9.4 Right to Restriction of Processing

You may request limitation of processing when:

• Contesting the accuracy of personal data
• Processing is unlawful but you oppose erasure
• We no longer need the data but you require it for legal claims

9.5 Right to Data Portability

You may receive your personal data in a structured, commonly used format and transmit it to another controller where processing is:

• Based on consent or contract
• Carried out by automated means

9.6 Right to Object

You may object at any time to processing of personal data concerning you when processing is:

• Based on legitimate interests
• For direct marketing purposes
• For scientific/historical research or statistics

9.7 Right to Withdraw Consent

Where processing is based on consent, you may withdraw consent at any time without affecting:

• Lawfulness of processing before withdrawal
• Processing conducted under other legal bases

9.8 Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights, including:

• Denying goods or services
• Charging different prices or rates
• Providing a different level or quality of services
• Suggesting any of the above

9.9 Right to Lodge Complaints

You have the right to file a complaint with:

• The Oregon Attorney General's Office (for US residents)
• Your local Data Protection Authority (for EU/UK residents)
• California Privacy Protection Agency (for California residents)

To exercise these rights, submit a verifiable request to:
Data Protection Officer
Altair Partners LLC
Email: support@altairpartner.com

We will respond within 30 days of receipt and may request additional information to verify your identity.

10. International Data Transfers

Your personal data may be transferred to, stored, and processed in:

10.1 Transfer Mechanisms

• United States: Our primary servers are located in Oregon, USA
• Third Countries: May include service providers in Canada, UK, EU, and other jurisdictions

10.2 Safeguards Implemented

For transfers outside your jurisdiction, we implement:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data Processing Agreements with all third-party vendors
• Regular audits of foreign data processors
• Adequacy determinations where applicable

These transfer mechanisms ensure that your data receives adequate protection in accordance with applicable data protection laws.

11. Children's Privacy

11.1 Age Restrictions

We do not knowingly:

• Collect personal data from individuals under 18 years of age
• Market any services to minors
• Process children's data without parental consent

11.2 Verification Procedures

If we become aware of underage data collection, we will:

• Immediately delete all related records
• Terminate the associated account
• Document the incident in our compliance logs

11.3 Parental Rights

Legal guardians may:

• Review data collected about their child
• Request deletion of such data
• Revoke previously given consents

12. AI Transparency

12.1 System Specifications

Our AI implementations:

• Utilize advanced language models for content generation and customer service
• Are continuously updated to improve accuracy and relevance
• Undergo regular performance evaluations and quality assessments

12.2 Limitations of Use

AI-generated content:

• Cannot provide legal, financial, or medical advice
• May contain factual inaccuracies
• Should be verified by human experts for critical decisions

12.3 Review Procedures

We periodically review AI systems for quality and fairness to ensure appropriate performance standards.

13. Policy Updates

13.1 Modification Procedures

We may update this policy to reflect:

• Changes in our data practices
• New legal requirements
• Technological developments

13.2 Notification Protocol

For material changes, we will:

• Post notices on our website for 30 days prior
• Send email alerts to registered users
• Update the Effective Date prominently

13.3 Historical Versions

Archived versions are available upon request for:

• Compliance verification
• Dispute resolution
• Historical reference

14. Contact Us

14.1 Data Protection Officer

Email: support@altairpartner.com

14.2 Mailing Address

Altair Partners LLC is currently relocating to a new business address. For all communications, please use email: support@altairpartner.com. If you need to send physical mail for important legal matters that require a postal address, please contact us via email and we will provide a temporary mailing address.

14.3 Response Times

• Data access requests: 30 days
• Deletion requests: 45 days
• Complaints: 15 business days

15. Governing Law

15.1 Jurisdictional Provisions

All disputes shall be:

• Governed by Oregon state law
• Subject to jurisdiction in Multnomah County courts

16. Affiliate Program Data Processing Notice

As part of our manual referral-based affiliate program, Altair Partners LLC collects, stores, and processes specific categories of personal data from individuals ("Affiliates") who participate in said program by referring prospective clients to our business. This section outlines the categories of data collected, the purpose of collection, and the legal bases for processing such information in accordance with applicable privacy regulations.

16.1 Categories of Affiliate Data Collected

We may collect the following types of data from or about our Affiliates:

• Full legal name and contact information (email address, mailing address, phone number)
• Taxpayer identification numbers (e.g., SSN, EIN, or ITIN)
• Payment account details (e.g., PayPal, bank routing and account numbers)
• Timestamped records of referral submissions and conversations
• Communication logs and documentation related to referral tracking or dispute resolution
• Affiliate agreement signature and acceptance history
• Payout records, commission structures, and tax form submissions (e.g., W-9 or W-8BEN)

16.2 Purpose of Data Processing

Affiliate data is processed for the following purposes:

• Verifying referral authenticity and assigning commissions
• Communicating program terms, updates, and policy changes
• Issuing commission payments
• Complying with federal and state tax obligations (including IRS Form 1099-NEC filing)
• Resolving referral disputes or misconduct cases
• Preventing fraudulent activities or misrepresentation

16.3 Legal Basis for Processing

Our processing of affiliate information is based on the following legal grounds:

• Contractual necessity: To fulfill our obligations under the affiliate agreement
• Legal obligation: To comply with U.S. tax law, anti-fraud requirements, and regulatory reporting
• Legitimate interest: To manage and improve the program, detect misuse, and protect client relationships

16.4 Data Sharing and Retention

• Affiliate-related tax data may be shared with the Internal Revenue Service (IRS) or other lawful authorities.
• Referral and payout history may be retained for a period of up to 5 years to comply with financial and tax auditing requirements.
• We do not sell or rent affiliate information to third parties for marketing purposes.

16.5 Consent and Participation

By participating in our affiliate program and submitting any referral information to Altair Partners LLC, you explicitly acknowledge and consent to:

• The collection and processing of your personal and referral-related data
• The potential issuance of IRS Forms (e.g., 1099-NEC)
• The application of all terms described in this Privacy Policy

Failure to comply with the referral verification requirements outlined in the Affiliate Agreement may result in ineligibility for commissions and removal from the program.

16.6 Affiliate Rights

Affiliates may exercise the same privacy rights as clients under Section 9 of this Policy, including:

• Requesting access to or correction of their data
• Requesting deletion or restriction of data under specific conditions
• Objecting to certain types of processing
• Lodging complaints with relevant data protection authorities

All such requests may be submitted in writing to:
Email: support@altairpartner.com

17. Digital Product Packages Privacy Notice

This section applies specifically to our "No-Call Digital Packages" service ("Package Service"), where customers can purchase predefined digital marketing packages without consultation calls. By using this service, you agree to the following additional terms:

17.1 Service Description

The Package Service allows customers to:

• Purchase predefined digital marketing packages through our website
• Submit required materials via secure upload portals
• Receive completed deliverables without consultation calls
• Request one (1) free revision per package purchased

17.2 Data Collection for Package Service

When using the Package Service, we collect:

• Package selection and purchase details
• Uploaded creative assets and brand materials
• Project briefs and specifications forms
• Revision requests and feedback
• Delivery confirmations and acceptance records

17.3 No-Call Policy

The Package Service operates under strict no-call principles:

• We will not initiate phone calls for package clarification
• All communication occurs via email or project management system
• Customers must provide complete information upfront
• Incomplete submissions may result in delayed delivery

17.4 Revision Policy

Each package includes:

• One (1) complimentary revision request
• Revision must be requested within 7 days of delivery
• Must specify required changes in writing
• No refunds or additional revisions beyond this allowance

17.5 Data Retention

Package Service data is retained for:

• Completed projects: 2 years from delivery date
• Unclaimed deliverables: 90 days from completion notice
• Financial records: 5 years for tax compliance

17.6 Intellectual Property

All final deliverables:

• Become customer property upon full payment
• May include our standard attribution unless paid for removal
• Are provided with standard usage rights

17.7 Limitations of Service

The Package Service does not include:

• Custom strategy development
• Ongoing account management
• Performance guarantees
• Multiple revision rounds

18. California-Specific Privacy Rights

18.1 California Consumer Privacy Act (CCPA/CPRA)

If you are a California resident, you have the following additional rights:

• Right to Know: You may request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information.
• Right to Delete: You may request deletion of your personal information that we have collected, subject to certain exceptions.
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Opt-Out: You may opt-out of the "sale" or "sharing" of your personal information.
• Right to Limit Use and Disclosure: You may limit the use and disclosure of sensitive personal information.

18.2 Financial Incentives

We may offer financial incentives for the collection, retention, or sale of personal information. Material terms will be presented when you opt-in. You may withdraw at any time.

18.3 Metrics Reporting

We will compile and disclose metrics regarding consumer rights requests as required by CPRA regulations.

19. Data Breach Notification Protocol

19.1 Incident Response

In the event of a data breach, we will:

• Immediately investigate and contain the breach
• Assess the scope and impact of compromised data
• Notify affected individuals and regulatory authorities as required by law
• Implement remediation measures to prevent recurrence

19.2 Notification Timeline

We will provide breach notifications within:

• 72 hours to regulatory authorities (where required by law)
• Without undue delay to affected individuals
• As required by specific state breach notification laws