Privacy Policy

1. Introduction and Scope

This Privacy Policy describes how CGM Equity Holdings, LLC, a Utah limited liability company doing business as CGM Equity, collects, uses, stores, shares, and protects personal information obtained through our website located at www.cgmequity.lol, through any related digital properties, through our professional services, and through any other interactions you may have with our organization. This policy applies to all visitors, users, clients, prospective clients, vendors, and job applicants who interact with CGM Equity.

CGM Equity is a computer systems design and related services firm specializing in enterprise systems architecture, cloud infrastructure engineering, systems integration, cybersecurity, and managed IT operations. Our headquarters is located at 2554 N Geranium Drive, Saratoga Springs, Utah 84045-6701, United States of America. Throughout this document, references to CGM Equity, we, us, and our refer to CGM Equity Holdings, LLC and its affiliated operating entities. The website was developed and is maintained by the CGM Equity engineering team.

By accessing our website or using our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any provision contained herein, you should discontinue use of our website and services immediately. We reserve the right to modify this policy at any time, and such modifications will be effective immediately upon posting to this page. Your continued use of our website or services after any changes constitutes your acceptance of the revised policy.

This Privacy Policy is designed to comply with applicable privacy laws in the jurisdictions where we operate, including but not limited to the California Consumer Privacy Act as amended by the California Privacy Rights Act, the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and applicable provisions of the General Data Protection Regulation to the extent they govern our processing activities. We are committed to the principles of transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality in all of our data handling practices.

2. Information We Collect

2.1 Information You Provide Directly

We collect information that you voluntarily provide when you interact with our website, communicate with our team, or engage our services. This includes information submitted through our contact forms, email correspondence, phone calls, service inquiry forms, and client onboarding documentation. The categories of information we may collect include your full name, business email address, personal email address if provided, telephone number, job title, organization name, physical business address, billing address, payment information including bank account details and credit card data where applicable for service engagement, tax identification numbers, and any other information you choose to include in messages, project descriptions, or service requests submitted to us.

When you engage CGM Equity for professional services, we may also collect additional information necessary for the performance of our contractual obligations. This can include system access credentials provided under strict security protocols, network configuration data, infrastructure documentation, architectural diagrams, and other technical information related to your existing systems environment that you authorize us to review and optimize as part of the services we provide.

2.2 Information Collected Automatically

When you visit our website, certain information is collected automatically through standard web technologies. This automatic collection includes your Internet Protocol address, browser type and version, operating system type and version, device type and manufacturer, screen resolution, referring and exit pages, date and time stamps of your visit, pages viewed and time spent on each page, clickstream data including the sequence of links and buttons you interact with, and form interaction behavior. We also collect information about your network including Internet Service Provider name, approximate geographic location derived from your IP address at the city or regional level, connection speed, and language preferences as indicated by your browser settings.

We use server logs, web beacons, tracking pixels, and similar technologies to collect this information. Our servers automatically record information that your browser sends whenever you visit a website. This data is used for system administration, security monitoring, traffic analysis, and to improve the functionality and content of our website. Server log data is typically retained for a period of thirty days before being archived and eventually purged, unless required for security investigations or legal compliance purposes.

2.3 Information from Third Parties

We may receive information about you from third-party sources to supplement our own records and to help us provide more relevant services. These sources may include business intelligence platforms, publicly available business registries, professional networking platforms, trade association directories, credit reporting agencies where applicable for business account verification, and referral partners who introduce you to our services. We treat all information received from third-party sources in accordance with this Privacy Policy and applicable law.

3. How We Use Your Information

We use the information we collect for specific business purposes that are necessary to provide our services, operate our business, and comply with legal obligations. Each category of use is described below with the corresponding lawful basis for processing.

We use your information to provide, maintain, and improve our services including the delivery of contracted computer systems design, architecture consulting, cloud infrastructure engineering, systems integration, cybersecurity assessment, and managed IT operations services. This includes using your contact information to communicate about project status, deliverables, milestones, and service-related notifications.

We use your information to respond to inquiries submitted through our website, by email, or by telephone. When you request information about our services, pricing, or availability, we process your contact details and the content of your inquiry to provide a responsive and personalized reply. We may follow up on inquiries that do not result in an immediate engagement to determine whether your needs have changed or whether additional information would be helpful to your decision-making process.

We use your information to process payments, manage billing and invoicing, maintain financial records, and fulfill our accounting obligations. This includes the use of payment information for transaction processing, invoice generation, payment reconciliation, collection activities where necessary, and financial reporting and auditing purposes required by applicable law.

We use your information to send marketing communications about our services, industry insights, technical white papers, event invitations, and company updates where you have provided consent or where otherwise permitted by applicable law. You may opt out of marketing communications at any time by using the unsubscribe link included in every marketing email or by contacting us directly at our privacy contact address.

We use your information to analyze website usage patterns, improve user experience, optimize website performance, conduct testing of content and layout variations, and develop aggregate statistical insights about our audience. This analysis is performed using both first-party data collected directly and aggregated analytics services, and results are used to inform website design decisions and content strategy.

We use your information to protect the security and integrity of our systems, networks, and data. This includes monitoring for unauthorized access attempts, investigating security incidents, detecting and preventing fraud, enforcing our Terms of Service, and complying with legal obligations including responding to lawful requests from law enforcement and regulatory authorities.

4. Legal Bases for Processing

For individuals located in jurisdictions that require a specified legal basis for the processing of personal data, we rely on the following legal grounds. Contractual Necessity means processing your information is necessary for the performance of a contract with you, such as delivering services you have engaged us to provide, or to take steps at your request prior to entering into a contract. Legitimate Interests means we process information where it is necessary for our legitimate business interests or those of a third party, provided those interests are not overridden by your data protection rights. Our legitimate interests include operating and improving our business, providing customer support, protecting against fraud and security threats, conducting business analytics, and marketing our services to existing and prospective clients in a business-to-business context.

Consent means that where required by applicable law, we obtain your consent before processing your personal data for specific purposes, such as sending direct marketing communications or placing non-essential cookies on your device. You have the right to withdraw consent at any time, though such withdrawal will not affect the lawfulness of processing performed prior to withdrawal. Legal Obligation means we process information where necessary to comply with applicable laws, regulations, court orders, government requests, or other legal processes to which we are subject. Vital Interests means that in rare circumstances, we may process information where necessary to protect your vital interests or those of another natural person.

5. Disclosure of Your Information

We do not sell your personal information. We do not rent, trade, or otherwise disclose your personal information to third parties for their independent commercial use. We may share your information only in the limited circumstances described below and always subject to appropriate confidentiality and data protection obligations.

We may share information with service providers and subcontractors who perform functions on our behalf. These include cloud hosting providers, payment processors, customer relationship management platform operators, email service providers, analytics services, professional advisors including legal counsel and accountants, auditors, and insurance providers. Each service provider is bound by contractual obligations that limit their use of your information to the specific purpose for which it was disclosed and require them to implement appropriate technical and organizational security measures.

We may disclose information as required by law, regulation, legal process, or governmental request. This includes responding to subpoenas, court orders, search warrants, national security letters, or other lawful requests from public authorities. We will make reasonable efforts to notify you of such disclosure unless prohibited by law or where notification would compromise an ongoing investigation or pose a risk of harm to any person.

We may disclose information in connection with a corporate transaction, including a merger, acquisition, consolidation, restructuring, sale of all or a substantial portion of our assets, financing, or similar transaction. In such an event, we will require the acquiring entity to honor the commitments set forth in this Privacy Policy or provide you with notice and an opportunity to exercise your rights regarding your information before material changes take effect.

We may disclose aggregated, de-identified, or anonymized information that cannot reasonably be used to identify you. Such data is not considered personal information and may be used for any lawful purpose including industry analysis, benchmarking, and publication of technical insights.

6. Data Retention

We retain personal information for no longer than is necessary to fulfill the purposes for which it was collected, or as required by applicable law, regulation, or contractual obligation. The specific retention period for each category of information is determined by reference to the nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information, whether those purposes can be achieved through alternative means, and applicable legal and regulatory requirements.

Contact form submissions and inquiry correspondence are retained for a period of two years from the date of last communication, after which they are securely deleted unless a client relationship has been established, in which case the information is retained in accordance with our client records retention policy. Client engagement records, including contracts, project documentation, system architecture documents, and communications, are retained for the duration of the client relationship plus seven years following termination of the engagement to comply with professional standards, tax obligations, and statutes of limitations for potential legal claims. Financial records, including invoices, payment records, and accounting documentation, are retained for a period of seven years in accordance with applicable tax laws and financial regulations. Website server logs and automatically collected technical data are retained for thirty days of rolling retention before being purged from active systems. Anonymized aggregate analytics data may be retained indefinitely for trend analysis and business planning.

7. Data Security

We implement and maintain comprehensive administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of your personal information. Our security program is aligned with industry standards and is regularly reviewed and updated to address evolving threats and vulnerabilities.

Our technical safeguards include encryption of data in transit using TLS 1.3, encryption of data at rest using AES-256, multi-factor authentication for all administrative access, role-based access controls with the principle of least privilege, automated vulnerability scanning and penetration testing, intrusion detection and prevention systems, endpoint detection and response capabilities across all managed devices, security information and event management with real-time alerting, and regular third-party security assessments and audits of our infrastructure.

Our administrative safeguards include a documented information security policy reviewed annually, mandatory security awareness training for all personnel, background checks for employees and contractors with access to sensitive systems, formal incident response procedures with defined escalation paths, vendor risk management program with security assessments for all third-party service providers, business continuity and disaster recovery plans tested at least annually, and data classification and handling procedures that define protection requirements based on information sensitivity levels.

While we implement robust security measures, no method of electronic transmission or storage is perfectly secure. We cannot guarantee that your information will never be accessed, disclosed, altered, or destroyed as a result of a breach of our safeguards. In the event of a data breach that affects your personal information, we will notify you and relevant authorities in accordance with applicable legal requirements and within the timeframes mandated by those requirements.

8. Your Privacy Rights

Depending on your jurisdiction of residence, you may have certain rights regarding your personal information. We honor all applicable privacy rights and will respond to verified requests in accordance with the timelines and requirements set forth by governing law. The rights described below may be subject to certain exceptions and limitations as provided by applicable statutes.

Right to Access and Data Portability: You have the right to request confirmation of whether we process your personal information and, if so, to obtain access to that information in a structured, commonly used, and machine-readable format. You may request copies of the specific personal information we hold about you, along with details about the categories of information, purposes of processing, and categories of third parties with whom the information has been shared.

Right to Correction: You have the right to request correction of inaccurate or incomplete personal information that we hold about you. We will make commercially reasonable efforts to correct such information upon verification of your request and the accuracy of the corrected data you provide.

Right to Deletion: You have the right to request deletion of your personal information under certain circumstances, such as when the information is no longer necessary for the purpose for which it was collected, when you withdraw consent on which processing is based, or when the information has been unlawfully processed. We may decline a deletion request where retention is necessary for compliance with a legal obligation, establishment or defense of legal claims, or completion of a transaction for which the information was collected.

Right to Restrict Processing: You have the right to request restriction of the processing of your personal information in certain circumstances, including when you contest the accuracy of the information, when the processing is unlawful and you oppose deletion, or when we no longer need the information but you require it for legal claims.

Right to Opt Out of Sale or Sharing: CGM Equity does not sell personal information to third parties and has not done so in the preceding twelve months. We do not share personal information for cross-context behavioral advertising purposes. To the extent our use of analytics or advertising technologies could be construed as a sale or sharing under applicable law, you may exercise opt-out preference signals through your browser settings or by contacting us directly.

Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights. This means we will not deny you goods or services, charge different prices or rates, provide a different level or quality of services, or suggest that you will receive a different price or level of service based on your exercise of privacy rights.

To exercise any of these rights, please submit a verifiable request using the contact information provided in Section 16 below. We will acknowledge receipt of your request within ten business days and provide a substantive response within the time period required by applicable law, typically forty-five calendar days. We may extend the response period by an additional forty-five days when reasonably necessary, and we will notify you of any such extension. Before fulfilling your request, we will verify your identity by matching information you provide against our existing records. We may require additional verification for sensitive requests involving particularly sensitive categories of information.

9. Cookies and Tracking Technologies

Our website uses cookies, web beacons, tracking pixels, local storage, and similar technologies to enhance your browsing experience, analyze website traffic, and understand where our visitors originate. A cookie is a small text file that a website stores on your device through your web browser. Cookies may be session-based, meaning they expire when you close your browser, or persistent, meaning they remain on your device until they expire or are manually deleted.

We use essential cookies that are strictly necessary for the operation of our website. These cookies enable core functionality such as security, network management, and accessibility. Essential cookies do not require your consent under most privacy regulations. We also use analytics cookies that help us understand how visitors interact with our website by collecting and reporting information anonymously. These cookies allow us to measure page visits, traffic sources, time spent on pages, and user navigation patterns so we can improve our content and user experience.

You may configure your browser settings to block, delete, or alert you about cookies. Most browsers provide controls that allow you to manage cookie preferences on a site-by-site basis. Please note that disabling essential cookies may affect the functionality of our website and limit your ability to use certain features. You may also install browser extensions that block tracking scripts and analytics services. For more information about managing cookies, consult your browser help documentation or visit the privacy settings page of your browser.

We do not currently respond to browser-based Do Not Track signals in a standardized manner, as there is no universally adopted standard for how such signals should be interpreted. However, you may exercise control over tracking through the cookie management mechanisms described in this section and through the privacy preference signals built into certain browsers that are recognized under applicable state privacy laws.

10. Children's Privacy

Our website and services are directed at business professionals and are not intended for use by individuals under the age of eighteen. We do not knowingly collect, solicit, maintain, or process personal information from children under the age of thirteen, or under the age of sixteen where applicable law sets a higher threshold. If we become aware that we have inadvertently collected personal information from a child without verified parental consent, we will take immediate steps to delete such information from our records. If you believe that a child under the applicable age threshold has provided personal information to us, please contact our privacy team immediately using the contact information provided in this policy so that we can investigate and take appropriate remedial action without delay.

11. International Data Transfers

CGM Equity is headquartered in the United States of America, and our primary data processing activities occur within the United States. If you are visiting our website or using our services from outside the United States, please be aware that your information will be transferred to, stored in, and processed within the United States, which may have data protection laws that differ from the laws of your country of residence.

When we transfer personal information across international borders, we implement appropriate safeguards to ensure that your information receives an adequate level of protection as required by applicable data protection laws. These safeguards may include reliance on adequacy decisions issued by relevant regulatory authorities, execution of standard contractual clauses approved by applicable regulatory bodies, implementation of binding corporate rules where applicable, and assessment of the legal framework in the destination jurisdiction to ensure enforceability of individual rights and availability of effective remedies.

By using our website or services, you acknowledge that your information will be subject to the laws of the United States, and you consent to the transfer of your information to the United States for processing in accordance with this Privacy Policy. If you do not consent to such transfer and processing, you should not use our website or services.

12. Third-Party Services and Links

Our website may contain links to third-party websites, services, and resources that are not owned, operated, or controlled by CGM Equity. These links are provided for your convenience and informational purposes only. We are not responsible for and make no representations regarding the privacy practices, content, security, or reliability of any third-party websites. We encourage you to review the privacy policies of every third-party website you visit before providing any personal information.

We may use third-party service providers to facilitate various aspects of our website and business operations. When we engage such providers, we conduct due diligence to assess their data protection practices and enter into written agreements that impose data protection obligations consistent with the commitments set forth in this Privacy Policy. However, the data handling practices of these providers are ultimately governed by their own privacy policies and terms of service. We are not liable for the acts or omissions of third-party service providers beyond the remedies available to us under our agreements with them, except to the extent required by applicable law.

13. Do Not Track Signals

Certain web browsers and browser extensions offer a Do Not Track feature that sends a signal to websites requesting that they refrain from tracking the users browsing activities. At present, there is no consensus among industry participants, standards bodies, or regulatory authorities regarding the meaning of Do Not Track signals or how websites should respond to them. As a result, our website does not currently take action to respond to Do Not Track signals transmitted by web browsers. We continue to monitor developments in this area and will adjust our practices as industry standards and legal requirements evolve. In the meantime, you may manage your tracking preferences through the cookie controls described in Section 9 of this Privacy Policy.

14. Data Breach Notification

In the event of a security incident that results in unauthorized access to, disclosure of, or loss of personal information under our control, we will execute our incident response procedures to contain the incident, assess the scope and impact, and notify affected individuals and relevant regulatory authorities in accordance with applicable legal requirements and contractual obligations. Notifications will include a description of the incident, the categories and approximate number of individuals affected, the categories and approximate volume of personal information involved, the likely consequences of the breach, a description of the measures we have taken or will take to address the breach and mitigate its effects, and contact information for individuals to obtain additional information about the incident.

We will provide notification without unreasonable delay and, where feasible, within the timeframes mandated by applicable law. We may delay notification where a law enforcement agency determines that notification would impede a criminal investigation or where necessary to determine the scope of the breach and restore the reasonable integrity of the affected systems before disclosure.

15. Changes to This Privacy Policy

We reserve the right to update, modify, or replace this Privacy Policy at any time and from time to time in our sole discretion. When we make material changes, we will post the updated policy on this page with a new Last Updated date and, where required by applicable law, we will provide additional notice such as a prominent banner on our website homepage or a direct email notification to individuals with whom we have an established relationship. Changes that are purely administrative, technical, or editorial in nature may be made without prior notice.

We encourage you to review this Privacy Policy periodically to stay informed about our information practices and the choices available to you. Your continued use of our website or services following the posting of any changes to this Privacy Policy constitutes your acceptance of those changes. If you do not agree with the modified policy, you should discontinue use of our website and services.

16. Contact Us About Privacy

If you have questions, concerns, requests, or complaints regarding this Privacy Policy or our data handling practices, if you wish to exercise your privacy rights as described in Section 8, or if you believe that we have not adhered to the terms of this Privacy Policy, please contact us using the information below. We take all privacy inquiries seriously and will investigate and respond to your communication promptly and thoroughly.

CGM Equity Holdings, LLC
Attn: Privacy Office
2554 N Geranium Drive
Saratoga Springs, UT 84045-6701
United States of America

Email: talk@cgmequity.lol
Phone: +1 (707) 705-1682
Website: www.cgmequity.lol

If you are located in a jurisdiction that provides for a right to lodge a complaint with a data protection supervisory authority, you have the right to do so. We encourage you to contact us first so that we have the opportunity to address your concerns directly. We are committed to resolving privacy complaints in a fair and timely manner.

The CGM Equity development team built and maintains this website with data privacy and security as foundational design principles. Our commitment to protecting your information extends from our client engagements to every digital property we operate.