PRIVACY POLICY
Altair Partners LLC
Effective Date: January 11, 2025 (Updated July 31, 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, with its principal place of business located at [Insert Physical Address], hereby establishes this comprehensive Privacy Policy ("Policy") to delineate with utmost specificity the manner in which we collect, process, store, utilize, disclose, and protect the personal information of all individuals ("you," "your," or "user") who interact with our organization through any means whatsoever, including but not limited to:

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

1.2 Our officially designated and verified social media accounts, specifically limited to @paris_altair, @altair_partners, and @client.altairpartners on all 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, including all future modifications that may be implemented at our sole discretion. Should you disagree with any provision of this Policy, your sole and exclusive remedy is to immediately cease all interaction with our services and terminate any existing business relationship with the Company.

2. Detailed Catalog of Collected Information

We systematically collect, process, and maintain an extensive array of personal and non-personal information through various methodologies and technological means, as exhaustively enumerated below:

2.1 Personal Identifiable Information (PII)

2.1.1 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)

2.1.2 Professional and Employment-Related Data

• Detailed employment history (including positions held, dates of employment, responsibilities)
• Educational background (degrees earned, institutions attended, dates of attendance)
• Professional qualifications, licenses, and certifications
• References and recommendations

2.1.3 Financial and Transactional Information

• Complete payment card details (credit/debit card numbers, expiration dates, CVV codes, cardholder names)
• Bank account information for electronic funds transfers (account numbers, routing numbers, account types)
• Comprehensive billing histories (invoices issued, payments received, outstanding balances)
• Tax identification numbers where required by applicable law

2.1.4 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

2.2 Non-Personal Information

2.2.1 Technical System Information

• Complete Internet Protocol (IP) address information, including both IPv4 and IPv6 addresses
• Precise browser specifications (vendor, version, installed plugins, language settings, cookie preferences)
• Exhaustive device characteristics (manufacturer, model, hardware specifications, operating system version)
• Network connection details (internet service provider, connection type, bandwidth)

2.2.2 User Interaction Data

• Minute-by-minute records of all website interactions
• Comprehensive clickstream data documenting every user action
• Precise timestamps for all system interactions
• Detailed form interaction histories (field entries, changes, submission attempts)

2.2.3 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

3. Social Media Content and Testimonial Disclosure

All content published on our officially designated and verified social media accounts (@paris_altair, @altair_partners, @client.altairpartners) 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:

3.1 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

3.2 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

4. 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:

4.1 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

4.2 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

4.3 Ethical Safeguards

• Quarterly audits of algorithmic decision-making processes
• Continuous monitoring for inappropriate or biased outputs
• Human oversight of all critical business communications

5. Comprehensive Data Security Framework

We implement a robust, multi-layered security architecture incorporating the following protective measures:

5.1 Technical Security Controls

• 256-bit SSL/TLS encryption for all data transmissions
• Advanced network firewall protection with stateful packet inspection
• Intrusion detection and prevention systems (IDPS)
• Regular vulnerability scanning and penetration testing

5.2 Administrative Security Measures

• Role-based access control (RBAC) with least privilege principles
• Mandatory security awareness training for all personnel
• Comprehensive incident response plan with defined escalation paths

5.3 Physical Security Protections

• Secure data center facilities with biometric access controls
• 24/7/365 monitoring with CCTV surveillance
• Environmental controls including fire suppression systems

7. Your Rights & Choices

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

7.1 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

7.2 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.

7.3 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

7.4 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

7.5 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

7.6 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

7.7 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

7.8 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)

To exercise these rights, submit a verifiable request to:
Data Protection Officer
Altair Partners LLC
Email: matthew.yanovych@altairpartners.com
Phone: 503-544-2571

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

8. International Data Transfers

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

8.1 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

8.2 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

By using our services, you explicitly consent to these transfers and understand that:

• Other countries may have different data protection standards
• Your data may be subject to foreign government access requests

9. Children's Privacy

9.1 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

9.2 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

9.3 Parental Rights

Legal guardians may:

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

10. AI Transparency

10.1 System Specifications

Our AI implementations:

• Utilize GPT-4 and similar large language models
• Are trained on datasets last updated on [Date]
• Have an accuracy rate of [X]% as of last audit

10.2 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

10.3 Audit Procedures

We conduct quarterly audits that:

• Evaluate for racial, gender, and other biases
• Test response accuracy against known standards
• Document all system limitations

11. Policy Updates

11.1 Modification Procedures

We may update this policy to reflect:

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

11.2 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

11.3 Historical Versions

Archived versions are available upon request for:

• Compliance verification
• Dispute resolution
• Historical reference

12. Contact Us

12.1 Data Protection Officer

Matthew Yanovych
Email: matthew.yanovych@altairpartners.com
Phone: 503-544-2571

12.2 Mailing Address

Altair Partners LLC
Attn: Legal Department
6520 se 81st ave apt D
Portland, OR 97206

12.3 Response Times

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

13. Governing Law

13.1 Jurisdictional Provisions

All disputes shall be:

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

13.2 Arbitration Terms

• Conducted under AAA Commercial Rules
• Held in Portland, OR
• No class action participation permitted

13.3 Severability Clause

If any provision is found invalid:

• Remaining provisions remain in full force
• The invalid provision shall be reformed to minimum validity

14. 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.

14.1 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)

14.2 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

14.3 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

14.4 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 7 years to comply with financial and tax auditing requirements.
• We do not sell or rent affiliate information to third parties for marketing purposes.

14.5 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.

14.6 Affiliate Rights

Affiliates may exercise the same privacy rights as clients under Section 7 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: matthew.yanovych@altairpartners.com
Phone: 503-544-2571

15. 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:

15.1 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

15.2 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

15.3 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

15.4 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

15.5 Data Retention

Package Service data is retained for:

• Completed projects: 2 years from delivery date
• Unclaimed deliverables: 90 days from completion notice
• Financial records: 7 years for tax compliance

15.6 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

15.7 Limitations of Service

The Package Service does not include:

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