Privacy Policy

Effective April 12, 2024

CTRL FREQ (“we,” “us,” “our”) works hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) describes how we collect, use and disclose your Personal Information and how to exercise any rights you might have with respect this information. It governs information we collect through our website(s) including www.ctrlfreq.com (collectively, “Sites”) and information we collect from you or third parties through any other means to provide our services or perform our other business activities (collectively, “Services”).

Please read this Privacy Policy carefully before using our Sites and/or Services. If you do not agree with this Privacy Policy, you must refrain from using our Sites and/or Services. By Accessing or using our Sites and/or Services you agree to our use of your information consistent with this Privacy Policy.

This Privacy Policy does not address our data collection, use, and disclosure practices when acting as a service provider on behalf of our business clients (“Clients”). If you are a Client for whom we act as a data processor, we recommend you review the terms of our agreement with you for additional information.

Information We Collect

Personal Information

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

• Personal identifiers and contact information such as name, mailing address (including zip code and country), email address, phone number, social media username, profile picture, and social security number;

• Commercial information such as payment card or bank account information;

• Internet & network information such as browsing/search history, IP address, data collected by cookies and similar technologies, device specifications such as device IDs, specifications, and operating system; and

• Professional/employment information such as business name, job title, EIN, and entity type.

The types of Personal Information we collect about you may vary based on how you use our Sites and/or Services and your relationship with us.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on our Sites (“Usage Data”). For example, each time you use our Sites, we may automatically collect the type of web browser you use, the type of device you use, your device ID, your operating system and version, your IP address, your internet service provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Sites. If the data we automatically collect is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as anonymous Usage Data.

Communication Recordings

We may record calls and retain the content of written and electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

How We Collect Information

Voluntary Disclosure

We may ask you to provide us with Personal Information when you communicate with us, including when you book an appointment with us, when you onboard with us, and when you make a payment. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of our Sites or Services or we may not be able to fulfill your requested interaction.

Third-Party Data Sources

We may collect Personal Information from third-party data sources such as marketing agencies or partners, analytics firms, and data providers.

Cookies and Interest-Based Advertising

Cookies and Automated Tools

We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as pixels to track your interaction with our Sites and to improve the experience of our Sites and Services, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of our Sites or Services may not work if you delete or disable cookies.

We use the following types of cookies and other automated tools:

• Strictly Necessary: These tools are essential to operate the Sites or Services and provide you with services you have requested including to identify and repair errors in the Sites or Services.

• Functional: These tools enable certain features or non-essential functionality on our Sites or Services. For example, we might use these tools to recognize you and remember your preferences or settings when you return to our Sites or Services.

• Advertising: These tools allow us and third parties to learn more about you, including your use of our Sites, Services, and other websites, and advertise products or services that might interest you including our products and services.

• Analytics: These tools help us and third parties understand how our Sites are working and who is visiting our Sites. 

User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.

If you arrive at our Sites by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you searched that led you to our Sites, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached our Sites to determine what information the operator collects and how it uses such information. We may retain information about you provided to us by other websites and will use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

Interest-Based Advertising

We may work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of our Sites or Services as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via our Sites or on third-party websites. If you do not want to receive interest-based advertising, please visit the Digital Advertising Alliance (DAA) Consumer Choice Page. The DAA website allows you to opt-out of one or more interest-based advertising networks. Opt-outs are device and browser specific; therefore, you must set your opt-out preferences for each device and browser. Deleting browser cookies can remove your opt-out preferences; however, the DAA offers browser extensions that help preserve the opt-out preferences you set on the DAA's Consumer Choice Page. Please note that opt-outs only apply to interest-based advertising from participating companies. You may still receive other types of online advertising.

Information from Advertisements

If you arrive at our Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).

Google Analytics

One tool we use is Google Analytics. For more information about Google Analytics, including how it collects and processes Personal Information and Usage Data, please review Google’s Safeguarding Your Data disclosure.

Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize our Website(s). Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like) and this enables us to build and maintain our Website(s) with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

How We Use and Share Information

Generally

We may use Personal Information for business purposes, such as to:

• Fulfilling customer requests and support: to provide goods or services, keep customers informed about the status of their services, respond to questions and address customers concerns, provide newsletters, announcements, service bulletins and other information;

• Marketing and market research: to send communications and offers for our or third parties’ products and services, including offers based on consumers’ interests, personal and business characteristics and location, perform analytics for market and consumer research, trend analysis, financial analysis, and anonymization of personal information;

• Website use and analytics: to provide you with access to and use of our Sites and Services, analyze consumers’ use of our websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data;

• Product research: to conduct research and analysis for maintaining, protecting, and developing services, increase and maintain the safety of our products and services, and prevent misuse;

• Business operations: to evaluate, develop, and improve business operations, products and services offered, perform business administration and other normal business activities; and

• Compliance: to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others.

Service Providers

We may provide your Personal Information to other businesses (“Service Providers”) to provide services to us or on our behalf. Categories of service providers we use include:

• Fulfillment and account servicing vendors, which help us provide products, services and information to you and service your account;

• Payment processors, which help us to accept and process the payments for our products/services to you;

• Marketing and communications vendors, which help us market our products/services to you, show you advertisements, and conduct other outreach campaigns, including vendors providing email, telephone, and text message services;

• Research and development vendors, which help us develop and improve our products and services;

• Data and business analytics vendors, which help us collect, analyze, and improve the accuracy of our data (including Personal Information);

• IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;

• Professional service firms, which provide accounting, legal and other professional services; and

• General service providers, which help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.

Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. 

California Shine the Light Disclosure – Your Privacy Rights

We do not sell Personal Information to third parties for their own direct marketing purposes.  

Personal Information We Collect As A Service Provider For Our Clients

When acting on behalf of our Clients as a service provider, we may collect, use, and disclose Personal Information for the purpose of servicing those Clients. The specific categories of Personal Information collected and how that Personal Information is used or disclosed is determined by our Clients and will vary.

The Personal Information collected, used, and disclosed on our Clients’ behalf is governed by their privacy policies and our contract with them. When acting on behalf of a Client, we supply that Client with all information requested by them or consistent with their contract. This information can vary depending on the Client. If you request information about the Personal Information we collect, use, and disclose on a Client’s behalf, we will direct you to contact the Client.

Other Important Privacy Provisions

Security

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.

Google API Policy Compliance

Our use and transfer to any other application of information received from Google APIs will adhere to Google API Services User Data Policy , including the Limited Use requirements, as applicable.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

Other Transfers

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.

Links and Other Websites

Our Sites may contain links to third party websites. Please be aware that if you access these links, you will be leaving our Site. We encourage users to read the privacy policies of those sites, as we are not responsible for their content, links, or privacy procedures.

Updates

We may update this Privacy Policy in the future and will post any updates on our Sites. Updates are effective immediately upon posting. If you use our Sites or Services after the update, you are agreeing to the updated Privacy Policy.

Children’s Privacy

Our Sites and Services are not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.

California “Do Not Track” Disclosure

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Sites and Services do not respond to “do not track” signals.

Contact Us

If you have any questions about this Privacy Policy, please email us at INFO@CTRLFREQ.COM.