Privacy Policy

PRIVACY POLICY

1. INTRODUCTION AND SCOPE

Last Updated: May 20, 2025

This Privacy Policy describes how Clark Gentry Advisors, LLC ("we," "us," or "our") collects, uses, and shares information about you when you visit our website [insert website URL] (the "Site"), interact with our content, or use our services.

Who We Are: Clark Gentry Advisors, LLC is a business consulting firm specializing in AI strategy. We help organizations navigate the complexities of artificial intelligence implementation, governance, and optimization.

What This Policy Covers: This Privacy Policy applies to information we collect when you use our Site, request information about our services, sign up for newsletters or communications, or otherwise interact with us online. It does not apply to information collected by third parties, even if linked from our Site.

Your Consent: By using our Site, you consent to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree with our policies and practices, please do not use our Site.

Applicable Privacy Laws: This Privacy Policy is designed to comply with applicable U.S. privacy laws, including:

• California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• Virginia Consumer Data Protection Act (VCDPA)
• Colorado Privacy Act (CPA)
• Connecticut Data Privacy Act (CTDPA)
• Utah Consumer Privacy Act (UCPA)
• Relevant provisions of the General Data Protection Regulation (GDPR) that may impact U.S. operations

Changes to This Policy: We may update this Privacy Policy periodically. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes.

Questions or Concerns: If you have any questions about this Privacy Policy or our data practices, please contact us using the information provided in the "Contact Information" section below.

2. INFORMATION WE COLLECT

We collect several types of information from and about users of our Site. This information may be categorized as follows:

Personal Information: Information that identifies, relates to, describes, or can reasonably be linked to a particular individual. This includes:

• Identifiers, such as:
  • Name
  • Email address
  • IP address
  • Device identifiers
  • Cookie IDs

How We Collect Information:

1. Information You Provide to Us Directly:
   • When you fill out forms on our Site
   • When you request information about our services
   • When you subscribe to our newsletter or communications
   • When you contact us via email or through our contact forms
   • When you provide feedback or respond to surveys

1. Information Collected Automatically:
   • Usage Data: We automatically collect certain information about your equipment, browsing actions, and patterns when you visit our Site, including:
     • Pages you visit
     • Time spent on those pages
     • Referring websites
     • Click-through patterns
     • Date and time of your visit
   • Device Information: We collect information about the device you use to access our Site, including:
     • Device type
     • Operating system
     • Browser type
     • Internet connection

1. Cookies and Tracking Technologies: We use cookies and similar tracking technologies to track activity on our Site and to hold certain information. Cookies are small data files placed on your device that help us improve our Site and your experience, see which areas and features of our Site are popular, and count visits.

Types of Cookies We Use:

• Essential Cookies: Necessary for the Site to function properly
• Analytical/Performance Cookies: Allow us to recognize and count visitors and see how they move around our Site
• Functionality Cookies: Enable us to personalize content
• Targeting Cookies: Record your visit to our Site, the pages you visit, and the links you follow

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, some portions of our Site may not function properly.

1. Information from Third Parties: We may receive information about you from third parties, such as business partners, service providers, and analytics providers.

Categories of Personal Information We Have Collected in the Last 12 Months:

• Identifiers (such as name, email address, IP address)
• Internet or other electronic network activity information (such as browsing history, search history, and information regarding interaction with our Site)

We Do Not Collect:

• Sensitive personal information (such as precise geolocation, racial or ethnic origin, religious beliefs, or health information)
• Information from children under the age of 13

3. HOW WE USE YOUR INFORMATION

We use the information we collect about you for various business and commercial purposes. This section describes how and why we use your information.

Business Purposes for Using Your Information:

1. To Provide and Maintain Our Services:
   • Deliver the consulting services and information you request
   • Process and complete transactions
   • Send administrative information, such as updates, security alerts, and support messages
   • Respond to your comments, questions, and requests
   • Provide customer service and support

1. To Improve Our Site and Services:
   • Understand how visitors use our Site
   • Monitor and analyze usage patterns and trends
   • Test, research, analyze, and develop new features and services
   • Enhance user experience and improve Site functionality

1. To Communicate with You:
   • Send you marketing communications about our services, events, and promotions (with your consent where required by law)
   • Respond to your inquiries and provide information about our AI consulting services
   • Send you technical notices, updates, security alerts, and administrative messages

1. For Security and Legal Purposes:
   • Detect, prevent, and address technical issues, fraud, or illegal activity
   • Protect the rights, property, or safety of our company, our users, or others
   • Comply with applicable laws, regulations, legal processes, or governmental requests
   • Enforce our Terms of Service and other agreements

Retention of Your Information:

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you
• Whether there is a legal obligation to which we are subject
• Whether retention is advisable in light of our legal position (such as for statutes of limitations, litigation, or regulatory investigations)

Legal Bases for Processing (Relevant for GDPR Considerations):

While we primarily operate in the US, we recognize that some privacy principles from the GDPR may be relevant. Where applicable, we process your personal information on the following legal bases:

• With your consent
• To perform a contract with you
• For our legitimate interests
• To comply with our legal obligations

We Do Not:

• Sell your personal information to third parties
• Use your personal information for automated decision-making or profiling that produces legal or similarly significant effects
• Process sensitive personal information for purposes other than those permitted by applicable laws

Opting Out:

You can opt out of receiving marketing communications from us at any time by following the unsubscribe instructions included in our marketing communications or by contacting us directly.

4. HOW WE SHARE YOUR INFORMATION

We may share your personal information with certain third parties in limited circumstances. This section explains when and why we share your information.

Categories of Third Parties We Share With:

1. Service Providers and Contractors: We share information with third-party vendors, consultants, and other service providers who perform services on our behalf, such as:
   • IT and system administration service providers
   • Data analytics providers
   • Email delivery services
   • Customer relationship management platforms
   • Cloud storage providers

These service providers are contractually bound to use personal information only for the purposes of providing services to us and in accordance with our instructions.

1. Professional Advisors: We may share information with professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they provide to us.
2. Business Partners: We may share information with business partners who help us provide our AI consulting services or with whom we jointly offer products or services.
3. Legal and Regulatory Authorities: We may disclose your information when required by law, regulation, or legal process, such as:
   • In response to a court order, subpoena, or similar legal process
   • To comply with laws, regulations, or governmental requests
   • To protect our rights, property, or safety
   • To investigate, prevent, or take action regarding illegal activities, suspected fraud, or violations of our Terms of Service

Important Clarifications About Sharing:

• We Do Not Sell Your Personal Information: We do not sell your personal information to third parties for monetary or other valuable consideration as defined under applicable state privacy laws.
• We Do Not Share Your Personal Information for Cross-Context Behavioral Advertising: We do not share your personal information with third parties for cross-context behavioral advertising purposes (targeted advertising based on your activities across different websites, applications, or services).
• Data Processing Agreements: We enter into data processing agreements with our service providers and contractors that require them to:
  • Process personal information only for specified purposes
  • Maintain appropriate security measures
  • Assist us in responding to consumer rights requests
  • Return or delete personal information when our relationship ends

International Data Transfers:

We primarily operate in the United States and process data within the US. We do not transfer personal information to countries outside the United States.

Corporate Transactions:

In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your information may be transferred to a successor entity or to a third party involved in the transaction, provided that the receiving entity agrees to respect your personal information in a manner consistent with our Privacy Policy.

5. YOUR PRIVACY RIGHTS

Depending on your state of residence, you may have certain rights regarding your personal information. This section describes these rights and how to exercise them.

Privacy Rights for Residents of California, Virginia, Colorado, Connecticut, and Utah:

If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, you may have the following rights with respect to your personal information:

1. Right to Know/Access: You have the right to know what personal information we have collected about you, including the categories of personal information, the sources from which we collected it, the purposes for which we collected or processed it, and the categories of third parties with whom we shared it.
2. Right to Delete: You have the right to request deletion of personal information that we have collected from you, subject to certain exceptions.
3. Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you.
4. Right to Opt-Out: You have the right to opt out of:
   • The "sale" of your personal information (though we do not sell personal information)
   • The sharing of your personal information for cross-context behavioral advertising (though we do not share for this purpose)
   • Certain profiling and automated decision-making (though we do not engage in these practices)

1. Right to Data Portability: You have the right to receive your personal information in a portable and, to the extent technically feasible, readily usable format.
2. Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

How to Exercise Your Rights:

To exercise your privacy rights, you may:

• Email us at admin@clarkgentry.com

Verification Process:

To protect your privacy and security, we may need to verify your identity before processing your request. We will only use the information you provide for verification purposes. You may need to provide:

• Name
• Email address
• Additional information depending on the nature of your request

Authorized Agents:

You may designate an authorized agent to make a request on your behalf. Authorized agents must provide proof of your written permission and may be required to verify their own identity.

Response Timing:

We will acknowledge receipt of your request within 10 business days and provide a substantive response within 45 calendar days (or as otherwise required by applicable law). If we need more time, we will inform you of the reason and extension period.

Appeals Process:

If we decline to take action on your request, we will inform you of our decision and reasoning. If you wish to appeal our decision, you may submit an appeal to the contact information provided in the "Contact Information" section below.

6. DATA SECURITY

We implement reasonable security measures to protect your personal information from accidental loss and unauthorized access, use, alteration, and disclosure.

Our Security Measures:

• Encryption of sensitive information
• Secure networks and systems
• Access controls and authentication procedures
• Regular security assessments
• Employee training on data protection

Data Breach Notification:

In the event of a data breach that compromises your personal information, we will notify you and relevant authorities as required by applicable law. Our notification will include:

• A description of the incident
• The types of information affected
• Steps we are taking to investigate and mitigate the breach
• Measures you can take to protect yourself
• Contact information for questions

Your Role in Security:

While we implement security measures, no method of transmission over the Internet or electronic storage is 100% secure. We encourage you to:

• Use strong, unique passwords for your accounts
• Be cautious about what information you share online
• Keep your devices and software updated
• Report any suspicious activities related to your interactions with us

7. CHILDREN'S PRIVACY

Our Site is not directed to children under 13 years of age, and we do not knowingly collect personal information from children under 13.

COPPA Compliance:

We comply with the Children's Online Privacy Protection Act (COPPA). If we learn we have collected personal information from a child under 13 without verification of parental consent, we will take steps to delete that information as quickly as possible.

Parental Rights:

If you believe we might have any information from or about a child under 13, please contact us using the information provided in the "Contact Information" section below.

8. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this Privacy Policy.

Material Changes:

If we make material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by placing a prominent notice on our Site. We will provide this notice before the change becomes effective.

Review of Changes:

We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

9. CONTACT INFORMATION

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Clark Gentry Advisors, LLC

Email: admin@clarkgentry.com

For California Residents:If you are a California resident, you may contact us to exercise your CCPA/CPRA rights or request more information about our compliance with California privacy law.

For Virginia, Colorado, Connecticut, and Utah Residents:If you are a resident of Virginia, Colorado, Connecticut, or Utah, you may contact us to exercise your rights under your state's privacy law or to appeal a decision we made regarding your request.

Response Time:We strive to respond to all legitimate inquiries within 45 days. In some cases, we may require additional time or information, and we will notify you if this is the case.

BY USING OUR SITE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY.