PRIVACY POLICY

Flywheel Strategy, LLC ("Company," "we," "us," or "our"), values our customers and respects your privacy. This privacy policy (“Policy”) describes the personal information we collect about you, why we collect it, how we use and protect it, when we share it with third parties, and how third parties may use that information. Our Policy also describes the choices you can make about how we collect and use your information. By providing your personal information to us while using our website (“Site”), you are consenting to the manner in which we collect, use, disclose, protect and otherwise manage that information.
If our information practices change, we will post an updated version of the Policy on our Site. You can tell if the Policy has changed by checking the “Last Updated” date that appears above and that will be the date on which the new Policy becomes effective. You may exercise your choices about how we collect and use your information consistent with this Policy at any time. If you have any questions about our Policy, please contact us as described in the section below titled, "Contact Us".

1. WHAT INFORMATION DO WE COLLECT?
The personal information that we collect depends on the context of your interactions with us and the Site, the choices you make and the products and features you use. 
 
We collect personal information that you voluntarily provide to us, such as when we make a business proposal to you, when you express an interest in obtaining information about us or our Services, and when you participate in business meetings, phone calls, emails or discussions with us. The personal information we collect may include the following:

• Names
• Business addresses
• Phone numbers
• Email addresses

We do not collect or process sensitive information such as credit card or debit card numbers in combination with any required security or access credentials, drivers license numbers, state identification cards, passport numbers, social security numbers, biometric information, genetic data, information concerning health, racial or ethnic origin, religious or philosophical beliefs, union membership, sexual orientation, and/or the contents of any consumer’s mail, email or text messages unless we are the intended recipient of the communication.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such Personal Information.

Cookies and Similar Technologies

We collect Device Information using cookies. “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. When you first visit our Site, you will be notified that we use first and third party cookies to help the Site function efficiently, to give you a smooth customer experience and to deliver our ads. Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser settings to disable cookies on our site, but you will need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Please visit http://www.allaboutcookies.org/.

Cookies, pixel tags and/or other similar technologies are used to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies, pixel tags and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalized content. cookies, pixel tags and similar technologies to distinguish you from other users of our Site. This helps us to provide you with an enhanced personalised experience when you browse our Site and also allows us to improve our Site and track how it is performing.  
A number of cookies and similar technologies we use last only for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to the Site and will last for longer. Some cookies will also record from where you came to our Site and where you visit once you have left our Site.
When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and other information we have described above.

2. HOW DO WE PROCESS YOUR INFORMATION?
We process your Personal Information solely as necessary to provide our Services to you, to respond to your inquiries, and as otherwise expressly permitted by you or under applicable law.
Additionally, we use your Personal Information:

• For billing purposes;
• To communicate with you and to send you information by email, postal mail, telephone, text message, or other means about our Services and promotions, unless you direct us not to contact you with promotional communications;
• To respond to your inquiries and solve potential issues you might have with our Services;
• To request feedback about our Services;
• To send administrative information to you such as to update you on changes to our terms, conditions and policies;
• To link or combine with information we get from others to help understand your needs and provide you with better service;
• To protect the security or integrity of our Site and our business; 
• To enforce our terms and conditions and policies for business purposes;
• To comply with legal and regulatory requirements;
• To respond to legal requests and prevent harm; and/or
• To contact you if necessary.

3. DO WE SHARE YOUR PERSONAL INFORMATION?
We share your Personal Information with third parties to help us run our business. For example, we use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy. You can also opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

We may need to share your Personal Information in the following situations:

• Business Partners. We may share with our associates, contractors, agents and business partners solely as necessary to provide the Services to you.
• Visitor Information. We may use third parties to improve our ability to identify visitors to the Website. We, and third parties, use this information to obtain more information about our visitors and reach out to them through other channels, such as email and/or direct mail. To learn more or opt out from these companies you can visit http://www.networkadvertising.org/choices and https://www.aboutads.info. 
• Interested Mailings. We may share, exchange and/or cross-reference our postal mailing list with selected providers of goods and services that may be of interest to you.
• Legal Obligations. We may share your information to comply with laws or regulations or in response to a valid subpoena, order, or government request, or to protect your rights, the rights of Company, and others.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. HOW DO YOU GET MY CONSENT?
When you provide us with Personal Information through our Site, during in-person or remote discussions, complete a transaction, verify your credit card, sign an agreement to engage us to provide services, your consent is implied as granted to our collecting it and using it for the purposes set forth in this privacy policy.

If we ask for your Personal Information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

5. HOW DO I WITHDRAW MY CONSENT?
You can unsubscribe from our marketing email list at any time by clicking on an unsubscribe link in the emails, following other directions to unsubscribe that we may include in our emails, or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary in connection with our provision of services to you, to respond to your communications, or for other non-marketing purposes.  

If after you opt in to receive emails, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at newsletter@flywheelstrategy.co or mailing us at: 242 W 61st St Apt 3A New York, NY 10023.

6. HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your Personal Information only for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?
We take appropriate and reasonable security measures to protect your Personal Information. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. 

8. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 16 years of age. You represent that you are at least 16 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that Personal Information from users less than 16 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 16, please contact us at newsletter@flywheelstrategy.co or mail us at: 242 W 61st St Apt 3A New York, NY 10023.

9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.

10. DO WE SELL YOUR INFORMATION?
No. We only use your Personal Information for the purpose of providing our services to you and as otherwise set forth in this Privacy Policy. If at any time you wish (i) to know or obtain a copy of the Personal Information we have regarding you and how we have obtained it, (ii) to correct or change any Personal Information you have previously provided, (iii) for us to confirm we have not “sold” you Personal Information (as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), (iv) for us to delete your Personal Information, please contact us at newsletter@flywheelstrategy.co or mail us at: 242 W 61st St Apt 3A New York, NY 10023.

11. CONTACT US
If you have questions or comments about this notice, you may email us at hello@flywheelstrategy.co or by post to:

Flywheel Strategy, LLC
242 W 61st St
Apt 3A
New York, NY 10023
United States