PRIVACY POLICY

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Last Updated: September 5th, 2025

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This Privacy Policy ("Policy") describes how Valiant Business Services LLC ("Valiant," "Company," "we," "us," or "our"), a Florida limited liability company with principal offices at 16192 Coastal Highway, Lewes, Delaware 19958, and our parent company Juiced IO Inc, collect, use, disclose, and protect personal information in connection with our marketing services, digital platforms, websites, client portals, and business operations.

This Policy applies to all individuals who interact with Valiant, including current and prospective clients, website visitors, service users, business partners, vendors, employees, and other stakeholders. By engaging with Valiant's services or platforms, you acknowledge that you have read, understood, and consent to the practices described in this Policy.

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1. INFORMATION COLLECTION AND DATA SOURCES

1.1 Direct Information Collection

We collect personal information directly from individuals through various channels:

Website and Digital Platforms:

Contact forms and inquiry submissions
Account registration and profile creation
Newsletter subscriptions and content downloads
Event registrations and webinar attendance
Survey responses and feedback submissions
Client portal usage and project collaboration

Business Operations:

Service consultations and proposal processes
Contract negotiations and agreement execution
Project communications and deliverable reviews
Performance meetings and strategic planning sessions
Training programs and capability assessments
Invoice processing and payment transactions

Marketing and Sales Activities:

Trade show interactions and business card exchanges
Networking events and professional conferences
Referral programs and partnership introductions
Sales presentations and capability demonstrations
Request for proposal (RFP) responses and evaluations

1.2 Automatic Information Collection

Our digital platforms automatically collect certain information:

Technical Data:

IP addresses and geographic location information
Browser types, versions, and operating systems
Device identifiers and hardware specifications
Connection information and internet service providers
Referring websites and navigation patterns
Session duration and page interaction metrics

Usage Analytics:

Page views, clicks, and content engagement
Search queries and filter preferences
Feature usage and platform interactions
Download activities and resource access
Error logs and technical performance data
A/B testing participation and results

Communication Metadata:

Email delivery and engagement metrics
Communication timing and frequency patterns
Platform usage and login activities
Document access and collaboration metrics

1.3 Third-Party Information Sources

We may receive personal information from external sources:

Business Partners and Referrals:

Client referrals and professional introductions
Partner company shared contacts and prospects
Industry associations and membership organizations
Professional networking platforms and databases

Public and Commercial Sources:

Publicly available business directories and databases
Social media platforms and professional networks
Industry publications and news sources
Government databases and regulatory filings
Credit reporting agencies and financial information services

Service Providers and Vendors:

Marketing automation and CRM platforms
Event management and registration services
Data enrichment and validation services
Research and analytics providers

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2. CATEGORIES OF PERSONAL INFORMATION

2.1 Identity and Contact Information

Basic Identifiers:

Full names and professional titles
Email addresses and phone numbers
Physical addresses and mailing information
Company names and organizational affiliations
Professional credentials and certifications

Professional Information:

Job titles and responsibilities
Department and reporting structures
Industry experience and expertise areas
Career history and professional achievements
Education and qualification details

2.2 Business and Commercial Information

Financial Information:

Payment details and billing information
Credit card numbers and banking information (encrypted)
Purchase history and transaction records
Budget information and spending patterns
Invoice processing and payment terms

Commercial Relationships:

Service agreements and contract details
Project scope and deliverable requirements
Performance metrics and success criteria
Vendor relationships and supplier information
Partnership agreements and collaboration terms

2.3 Technical and Usage Data

Device and Network Information:

IP addresses and geographic locations
Browser fingerprints and device identifiers
Operating systems and software versions
Network connection details and speeds
Hardware specifications and capabilities

Platform Usage Analytics:

Login frequencies and session durations
Feature usage patterns and preferences
Content consumption and engagement metrics
Search behavior and navigation patterns
Performance optimization and error reporting

2.4 Communication and Interaction Data

Correspondence Records:

Email communications and attachments
Meeting notes and discussion summaries
Phone call logs and conversation records
Project collaboration and feedback
Support requests and resolution details

Marketing and Engagement Data:

Campaign interaction and response rates
Content preferences and consumption patterns
Event attendance and participation levels
Survey responses and feedback submissions
Social media engagement and interactions

2.5 Sensitive Personal Information

Protected Categories (where applicable and consented):

Professional certifications requiring background verification
Government identification for international compliance
Health information for employee benefits and accommodation
Diversity and inclusion voluntary self-identification
Financial information for creditworthiness assessment

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3. PURPOSES AND LEGAL BASIS FOR PROCESSING

3.1 Service Delivery and Contract Performance

We process personal information to fulfill our contractual obligations and deliver professional services:

Primary Service Functions:

Executing marketing services and creative development
Managing projects and coordinating deliverables
Providing strategic consulting and business advisory services
Delivering training programs and capability building
Maintaining client relationships and account management

Operational Support:

Processing payments and managing financial transactions
Coordinating with subcontractors and vendor partners
Managing intellectual property and deliverable ownership
Ensuring quality control and performance standards
Providing customer support and technical assistance

Legal Basis: Contractual necessity for service delivery and performance of agreed obligations.

3.2 Legitimate Business Interests

We process information to support essential business operations:

Business Development:

Identifying potential clients and business opportunities
Developing proposals and capability presentations
Building strategic partnerships and alliances
Conducting market research and competitive analysis
Managing sales pipelines and prospect relationships

Operational Excellence:

Improving service quality and delivery processes
Optimizing technology platforms and user experiences
Conducting performance analysis and benchmarking
Managing risk and ensuring compliance obligations
Protecting intellectual property and trade secrets

Legal Basis: Legitimate interests in conducting business operations, balanced against individual privacy rights.

3.3 Legal and Regulatory Compliance

We process information to meet various legal obligations:

Regulatory Requirements:

Anti-money laundering (AML) and know-your-customer (KYC) compliance
Tax reporting and financial record keeping
Employment law compliance and workplace regulations
Industry-specific regulations and licensing requirements
International trade compliance and sanctions screening

Legal Proceedings:

Responding to lawful government requests and subpoenas
Defending legal claims and protecting business interests
Enforcing contracts and collecting outstanding payments
Investigating fraud and protecting against security threats
Maintaining records for audit and examination purposes

Legal Basis: Legal obligation and vital interests for regulatory compliance and legal protection.

3.4 Consent-Based Processing

We obtain explicit consent for certain processing activities:

Marketing Communications:

Sending promotional emails and newsletters
Sharing industry insights and thought leadership content
Inviting to events and educational programs
Conducting market research surveys and studies
Personalizing marketing messages and content

Enhanced Services:

Accessing social media profiles for business development
Using location data for event and meeting coordination
Collecting biometric data for security purposes (where applicable)
Processing sensitive personal information beyond business necessity
Sharing information with third parties for non-essential purposes

Legal Basis: Explicit consent, with the right to withdraw at any time.

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4. DATA SHARING AND THIRD-PARTY DISCLOSURE

4.1 Internal Sharing Within Corporate Structure

Personal information may be shared within our corporate family:

Parent Company Integration:

Juiced IO Inc receives consolidated reporting and strategic oversight data
Shared technology platforms and administrative systems
Coordinated business development and client relationship management
Consolidated financial reporting and regulatory compliance
Strategic planning and resource allocation decisions

Affiliated Entities:

Subsidiary companies providing specialized services
Joint venture partners for specific client engagements
Affiliated marketing agencies and creative studios
International operations and regional service delivery
Shared service centers for operational efficiency

4.2 Service Providers and Vendors

We engage qualified third-party service providers under strict data protection obligations:

Technology and Infrastructure:

Cloud hosting and data storage providers
Software platforms and application vendors
Cybersecurity and monitoring services
Backup and disaster recovery providers
Network and telecommunications services

Professional Services:

Legal counsel and advisory services
Accounting and financial audit firms
Management consulting and strategy advisors
Marketing research and analytics providers
Training and professional development services

Operational Support:

Payment processing and merchant services
Document management and storage providers
Event planning and logistics coordination
Travel agencies and expense management systems
Facility management and security services

4.3 Client-Directed Sharing

We share information as directed by our clients for service delivery:

Campaign Execution:

Social media platforms and advertising networks
Email marketing and automation platforms
Analytics and measurement services
Creative production and media suppliers
Influencer networks and partnership platforms

Project Collaboration:

Client-designated team members and stakeholders
Approved subcontractors and specialized vendors
Research participants and survey respondents
Event attendees and program participants
Regulatory authorities as required for compliance

4.4 Legal and Regulatory Disclosure

Information may be disclosed to meet legal obligations:

Government Authorities:

Law enforcement agencies with valid legal process
Regulatory bodies conducting investigations or audits
Tax authorities for compliance and reporting purposes
Court orders and legal proceedings requiring disclosure
National security and anti-terrorism investigations

Legal Protection:

Attorneys and legal advisors for counsel and representation
Insurance companies for claims processing and risk management
Debt collection agencies for outstanding payment recovery
Forensic investigators for fraud or security incident response
Expert witnesses and consultants for legal proceedings

4.5 Business Transactions

Personal information may be transferred in connection with business changes:

Mergers and Acquisitions:

Due diligence processes with appropriate confidentiality protections
Asset transfers and business combination transactions
Successor companies assuming service obligations
Integration planning and transition management
Regulatory approval and compliance requirements

Corporate Restructuring:

Spin-offs and divestiture transactions
Bankruptcy or insolvency proceedings
Partnership formations and joint ventures
Licensing agreements and franchise arrangements
Investment transactions and capital raising activities

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5. INTERNATIONAL DATA TRANSFERS AND SAFEGUARDS

5.1 Cross-Border Transfer Framework

As a global marketing services provider, we transfer personal information internationally:

Transfer Destinations:

United States operations and data processing centers
European Union member states for GDPR compliance
Canada for North American operational efficiency
Other jurisdictions where clients or partners operate
Cloud service provider data centers worldwide

Transfer Mechanisms:

European Commission adequacy decisions where available
Standard Contractual Clauses (SCCs) for non-adequate countries
Binding Corporate Rules (BCRs) for intra-group transfers
Certification schemes and codes of conduct
Explicit consent for specific transfer purposes

5.2 Adequacy Decisions and Safe Harbor Frameworks

We rely on adequacy determinations and safe harbor programs:

Recognized Adequate Jurisdictions:

Canada under PIPEDA framework
United Kingdom under UK GDPR
Switzerland under Federal Data Protection Act
Israel under Privacy Protection Law
Other jurisdictions with European Commission adequacy decisions

Safe Harbor and Framework Programs:

EU-US Data Privacy Framework compliance
Swiss-US Data Privacy Framework participation
Asia-Pacific Economic Cooperation (APEC) Cross-Border Privacy Rules
International Organization for Standardization (ISO) certifications
Industry-specific privacy certification programs

5.3 Standard Contractual Clauses and Binding Agreements

For transfers to non-adequate countries, we implement appropriate safeguards:

European Commission SCCs:

Controller-to-controller transfer agreements
Controller-to-processor service agreements
Processor-to-processor subcontracting arrangements
Updated SCCs incorporating Schrems II requirements
Additional safeguards and risk assessments

Customized Data Transfer Agreements:

Enhanced security measures and technical safeguards
Data localization requirements where legally mandated
Incident notification and breach response procedures
Regular compliance monitoring and audit requirements
Termination and data return obligations

5.4 Data Localization and Residency Requirements

We comply with local data residency requirements:

Regulated Industries:

Healthcare data under HIPAA and similar regulations
Financial services data under banking and securities laws
Government contract data under national security requirements
Educational data under FERPA and student privacy laws
Telecommunications data under local carrier regulations

Operational Considerations:

Performance optimization through regional data centers
Disaster recovery and business continuity planning
Legal access and law enforcement cooperation
Technical integration with local systems and platforms
Cost optimization and operational efficiency

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6. DATA RETENTION AND LIFECYCLE MANAGEMENT

6.1 Retention Principles and Framework

Our data retention practices balance business needs with privacy requirements:

Core Principles:

Data minimization and purpose limitation
Regular review and assessment of retention needs
Secure deletion and disposal procedures
Legal hold and litigation preservation requirements
Cost-effective storage and archival strategies

Retention Categories:

Active operational data for current business needs
Archived historical data for reference and compliance
Backup copies for disaster recovery and business continuity
Legal hold data for litigation and regulatory proceedings
Anonymized data for research and analytics purposes

6.2 Specific Retention Periods

Different categories of information have varying retention requirements:

Client Relationship Data:

Active client records: Duration of relationship plus 7 years
Contract and agreement documents: 10 years post-expiration
Project deliverables and work product: 7 years post-completion
Financial records and invoicing: 7 years per tax requirements
Communication records: 5 years unless legal hold applies

Website and Marketing Data:

Website analytics and usage data: 26 months (Google Analytics standard)
Marketing campaign performance data: 3 years
Email marketing engagement data: 3 years or until unsubscribe
Lead generation and prospect data: 5 years unless converted to client
Event attendance and registration data: 3 years

Employee and Personnel Data:

Current employee records: Duration of employment plus 7 years
Payroll and benefits information: 7 years post-termination
Performance reviews and development records: 5 years
Training and certification records: Duration plus 3 years
Background check and hiring records: 3 years per EEOC requirements

Vendor and Partner Data:

Active vendor records: Duration of relationship plus 5 years
Contract and procurement documents: 7 years post-expiration
Payment and invoice records: 7 years per accounting standards
Performance and evaluation records: 3 years post-relationship
Due diligence and onboarding records: 5 years

6.3 Automated Retention Management

We employ automated systems for efficient retention management:

Data Classification:

Automated tagging and categorization systems
Sensitivity level assignment and protection measures
Retention period calculation and scheduling
Legal hold identification and preservation
Archive and disposal trigger mechanisms

Lifecycle Management:

Regular data inventory and assessment procedures
Automated deletion and purging processes
Backup verification and restoration testing
Compliance monitoring and audit trail maintenance
Exception handling and manual review procedures

6.4 Legal Hold and Preservation Procedures

When legal proceedings or investigations arise:

Hold Identification:

Legal counsel consultation and scope determination
Affected data identification and preservation mapping
Custodian notification and compliance procedures
Technology system configuration for hold implementation
Documentation and audit trail maintenance

Hold Management:

Regular hold review and scope adjustment
Technology updates and system migration procedures
Employee training and compliance monitoring
Third-party vendor hold coordination
Hold release and normal retention resumption

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7. INDIVIDUAL RIGHTS AND PRIVACY CONTROLS

7.1 Universal Privacy Rights

All individuals have certain fundamental privacy rights:

Access and Transparency:

Right to know what personal information we collect and process
Right to access copies of personal information we maintain
Right to understand the sources of information and sharing practices
Right to receive clear and understandable privacy notices
Right to contact us with questions and concerns

Control and Correction:

Right to correct inaccurate or incomplete personal information
Right to update contact preferences and communication settings
Right to withdraw consent for consent-based processing
Right to object to processing for direct marketing purposes
Right to request restrictions on certain processing activities

Deletion and Portability:

Right to request deletion of personal information under certain circumstances
Right to receive personal information in a portable format
Right to transmit information to other service providers
Right to have information removed from public access
Right to anonymization or pseudonymization where appropriate

7.2 Enhanced Rights Under Specific Laws

Additional rights may apply based on jurisdiction and applicable laws:

California Rights (CCPA/CPRA):

Right to know specific pieces and categories of information collected
Right to delete personal information (subject to exceptions)
Right to correct inaccurate personal information
Right to opt-out of sale or sharing for targeted advertising
Right to limit use of sensitive personal information
Right to non-discrimination for exercising privacy rights

European Rights (GDPR):

Right of access to personal data and processing information
Right to rectification of inaccurate or incomplete data
Right to erasure ("right to be forgotten") under specific circumstances
Right to restrict processing in certain situations
Right to data portability for structured data
Right to object to processing based on legitimate interests
Rights related to automated decision-making and profiling

7.3 Rights Exercise Procedures

We provide multiple channels for exercising privacy rights:

Online Submission:

Privacy request forms on our website
Client portal privacy settings and controls
Email submission to privacy@valiant.biz
Automated processing for standard requests
Status tracking and response communication

Direct Contact:

Phone inquiries during business hours: (302) 212-4282
Written requests to our Delaware office address
In-person meetings for complex requests (by appointment)
Third-party representative authorization procedures
Legal guardian or power of attorney requests

7.4 Response Procedures and Timelines

We respond to privacy rights requests promptly and efficiently:

Standard Response Times:

Acknowledgment within 2 business days of receipt
Substantive response within 30 days (45 days for complex requests)
California requests: 45 days (with possible 45-day extension)
GDPR requests: 30 days (with possible 60-day extension for complex requests)
Urgent requests processed on expedited basis

Verification and Authentication:

Identity verification procedures to prevent fraud
Account authentication for existing clients and users
Additional verification for sensitive requests
Third-party representative authorization requirements
Record keeping and audit trail maintenance

Response Content:

Clear explanation of actions taken or reasons for denial
Information about appeal and complaint procedures
Contact information for follow-up questions
Educational resources about privacy rights and controls
Referral to relevant supervisory authorities where appropriate

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8. SECURITY MEASURES AND DATA PROTECTION

8.1 Comprehensive Security Framework

We implement enterprise-grade security measures to protect personal information:

Technical Safeguards:

Advanced encryption for data at rest and in transit
Multi-factor authentication and strong password requirements
Network segmentation and access control systems
Regular security patches and software updates
Intrusion detection and prevention systems
Endpoint protection and device management

Administrative Safeguards:

Comprehensive employee security training programs
Background checks and security clearance procedures
Regular security awareness and phishing simulation
Incident response and breach notification procedures
Third-party security assessment and due diligence
Compliance monitoring and audit programs

Physical Safeguards:

Secured office facilities with access control systems
Visitor management and escort procedures
Locked storage for sensitive documents and media
Clean desk policies and secure disposal procedures
Video surveillance and security monitoring
Environmental controls and disaster protection

8.2 Encryption and Technical Protection

Personal information receives multiple layers of technical protection:

Encryption Standards:

AES-256 encryption for data at rest
TLS 1.3 for data transmission and communication
End-to-end encryption for sensitive communications
Database encryption and key management systems
File-level encryption for portable storage devices
Email encryption for confidential communications

Access Controls:

Role-based access control (RBAC) systems
Principle of least privilege implementation
Regular access reviews and privilege recertification
Privileged account management and monitoring
Single sign-on (SSO) integration and management
Session management and automatic timeout procedures

Network Security:

Firewall protection and network segmentation
Virtual private network (VPN) for remote access
Intrusion detection and prevention systems (IDS/IPS)
Security information and event management (SIEM)
Regular vulnerability scanning and penetration testing
Distributed denial of service (DDoS) protection

8.3 Security Monitoring and Incident Response

We maintain 24/7 security monitoring and rapid incident response capabilities:

Continuous Monitoring:

Real-time security event monitoring and alerting
Automated threat detection and response systems
User behavior analytics and anomaly detection
Regular security assessments and vulnerability scanning
Third-party security monitoring and managed services
Compliance monitoring and regulatory reporting

Incident Response:

Dedicated incident response team and procedures
Rapid containment and damage assessment protocols
Forensic investigation and root cause analysis
Law enforcement coordination where appropriate
Client and regulatory notification procedures
Recovery and business continuity planning

8.4 Third-Party Security and Vendor Management

We extend security requirements to all third-party relationships:

Vendor Assessment:

Comprehensive security questionnaires and assessments
On-site security audits and facility reviews
Certification verification and compliance validation
Contract security requirements and service level agreements
Regular monitoring and performance reviews
Incident reporting and response coordination

Data Processing Agreements:

Detailed security specifications and requirements
Encryption and technical safeguard mandates
Access control and authentication requirements
Incident notification and breach response procedures
Audit rights and compliance verification processes
Data return and secure deletion obligations

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9. COOKIES AND TRACKING TECHNOLOGIES

9.1 Types of Cookies and Technologies

We use various tracking technologies to enhance user experience and provide services:

Essential Cookies:

Session management and user authentication
Security features and fraud prevention
Load balancing and performance optimization
Shopping cart and form completion functionality
Accessibility features and user preference settings

Analytics and Performance:

Website usage statistics and performance metrics
User behavior analysis and navigation patterns
A/B testing and feature optimization
Error tracking and technical troubleshooting
Conversion tracking and goal completion measurement

Marketing and Advertising:

Interest-based advertising and retargeting
Campaign effectiveness and attribution measurement
Social media integration and sharing functionality
Lead generation and conversion optimization
Cross-device tracking and user recognition

Functionality and Personalization:

Content personalization and recommendation engines
Language and region preferences
Customized user interface and experience settings
Remember login credentials and form data
Chat and communication platform integration

9.2 Cookie Consent and Management

We provide comprehensive cookie control and consent management:

Consent Banner and Preferences:

Clear information about cookie types and purposes
Granular consent options for different cookie categories
Easy acceptance or rejection of non-essential cookies
Preference center access and ongoing management
Withdrawal of consent and cookie deletion options

Cookie Policy and Transparency:

Detailed cookie policy with specific information about each cookie
Regular updates and notifications of policy changes
Clear explanation of cookie duration and expiration
Information about third-party cookies and partners
Contact information for cookie-related questions

9.3 Third-Party Tracking and Social Media

Our websites may include third-party tracking and social media integrations:

Analytics Platforms:

Google Analytics and Google Tag Manager
Adobe Analytics and marketing automation platforms
Heatmapping and user session recording tools
Performance monitoring and optimization services
Custom analytics and reporting solutions

Social Media and Sharing:

Facebook, Twitter, LinkedIn social media plugins
YouTube and Vimeo video embedding
Social sharing buttons and engagement features
Social login and authentication options
Social media advertising pixel tracking

Marketing and Advertising Networks:

Google Ads and Microsoft Advertising platforms
Facebook and Instagram advertising networks
LinkedIn and professional networking platforms
Programmatic advertising and retargeting networks
Email marketing and automation platform tracking

9.4 Cookie Control and Opt-Out Options

Users have multiple options for controlling cookies and tracking:

Browser Settings:

Native browser cookie controls and blocking options
Private browsing and incognito mode usage
Third-party cookie blocking and tracking protection
JavaScript disabling for enhanced privacy
Regular cookie deletion and clearing procedures

Industry Opt-Out Programs:

Digital Advertising Alliance (DAA) opt-out tools
Network Advertising Initiative (NAI) consumer choice
European Digital Advertising Alliance (EDAA) options
Google Ads Settings and personalization controls
Facebook Off-Facebook Activity management

Platform-Specific Controls:

Google Analytics opt-out browser extension
Social media privacy settings and ad preferences
Email marketing unsubscribe and preference management
Mobile device advertising identifier controls
Location services and tracking permissions

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10. MARKETING COMMUNICATIONS AND CONSENT

10.1 Marketing Communication Types

We engage in various marketing communications based on appropriate legal bases:

Business-to-Business Communications:

Industry newsletters and thought leadership content
Event invitations and educational webinar announcements
Service updates and new capability introductions
Case study sharing and success story highlights
Research reports and market analysis distribution

Relationship-Based Marketing:

Account-specific updates and strategic recommendations
Project completion notifications and success celebrations
Renewal discussions and contract amendment communications
Training opportunities and professional development programs
Industry award notifications and recognition announcements

Lead Nurturing and Development:

Prospect education and capability demonstration content
RFP opportunity notifications and qualification assistance
Partnership introductions and collaboration opportunities
Market intelligence and competitive analysis sharing
Speaking engagement and conference participation invitations

10.2 Consent Management and Preferences

We provide comprehensive consent management for marketing communications:

Opt-In Procedures:

Clear and specific consent requests for marketing emails
Separate consent for different types of communications
Double opt-in confirmation for newsletter subscriptions
Explicit consent for sensitive or promotional content
Easy subscription management and preference updates

Preference Centers:

Granular control over communication types and frequency
Topic and industry-specific subscription options
Format preferences (HTML, text, digest, real-time)
Delivery timing and frequency controls
Language and localization preferences

Unsubscribe and Opt-Out:

One-click unsubscribe links in all marketing emails
Global opt-out options for all marketing communications
Partial unsubscribe options for specific communication types
Confirmation of unsubscribe requests and status
Suppression list management and honor procedures

10.3 Legal Basis and Compliance

Our marketing communications comply with applicable laws and regulations:

CAN-SPAM Act Compliance:

Clear sender identification and contact information
Truthful and accurate subject lines and content
Prominent unsubscribe mechanisms and honor procedures
Physical address inclusion in commercial messages
Prompt processing of opt-out requests (within 10 business days)

GDPR Marketing Requirements:

Lawful basis establishment for marketing processing
Explicit consent for electronic marketing to individuals
Legitimate interest balancing for business-to-business marketing
Right to object to direct marketing activities
Clear information about profiling and automated decision-making

Other International Requirements:

Canada's Anti-Spam Legislation (CASL) compliance
Australia's Spam Act requirements
Local marketing and advertising regulations
Industry-specific communication restrictions
Cross-border marketing law coordination

10.4 Marketing Data and Analytics

We use personal information for marketing optimization and analysis:

Campaign Performance:

Open rates, click-through rates, and engagement metrics
Conversion tracking and lead qualification analysis
A/B testing for subject lines, content, and timing
Segmentation analysis and audience development
Attribution modeling and multi-touch analysis

Customer Journey Mapping:

Touchpoint analysis and interaction tracking
Lead scoring and qualification processes
Sales funnel optimization and conversion improvement
Customer lifetime value modeling and prediction
Churn prediction and retention strategy development

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11. CLIENT DATA AND CAMPAIGN MANAGEMENT

11.1 Client Data Processing Framework

As a marketing services provider, we process significant amounts of client data:

Campaign Execution Data:

Customer databases and contact information
Purchase history and transaction records
Website analytics and user behavior data
Email marketing lists and engagement metrics
Social media followers and interaction data
Survey responses and feedback information

Performance and Analytics Data:

Campaign performance metrics and KPIs
Conversion rates and attribution analysis
Customer segmentation and persona development
Market research and competitive intelligence
Return on investment (ROI) and effectiveness measurement
Predictive modeling and forecasting data

11.2 Data Controller vs. Processor Relationships

Our role varies depending on the specific service and data type:

Data Controller Activities:

Lead generation and prospect development
Industry research and market analysis
Internal business development and client relationship management
Performance benchmarking and service improvement
Training and knowledge development programs

Data Processor Activities:

Email marketing campaign execution on behalf of clients
Social media management and content publishing
Website analytics implementation and reporting
Customer survey deployment and analysis
Database management and segmentation services

Joint Controller Arrangements:

Collaborative research and industry studies
Co-marketing campaigns and partnership activities
Event planning and attendee management
Referral programs and business development initiatives
Strategic consulting with shared analytics and insights

11.3 Client Data Protection Obligations

We implement robust protections for client-entrusted data:

Contractual Safeguards:

Comprehensive data processing agreements (DPAs)
Detailed security specifications and requirements
Breach notification and incident response procedures
Data return and secure deletion obligations
Regular compliance audits and assessments

Technical and Administrative Controls:

Segregated data storage and access controls
Client-specific encryption keys and security measures
Role-based access with client approval requirements
Regular backup and disaster recovery procedures
Detailed logging and audit trail maintenance

11.4 Cross-Client Data Isolation

We maintain strict separation between client data sets:

Data Segregation:

Logical and physical separation of client databases
Client-specific access controls and authentication
Dedicated processing environments where required
Clear data classification and handling procedures
Regular access reviews and permission audits

Aggregation and Benchmarking:

Anonymous aggregation for industry benchmarking
De-identification procedures for comparative analysis
Opt-out options for benchmarking participation
Clear disclosure of aggregation practices
Client approval for specific research and analysis projects

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12. EMPLOYEE AND PERSONNEL DATA

12.1 Employee Data Collection and Processing

We collect and process personal information about our employees and personnel:

Recruitment and Hiring:

Job application information and resumes
Interview notes and assessment records
Background check and reference verification
Drug testing and health screening results (where permitted)
Diversity and inclusion voluntary self-identification

Employment Records:

Personnel files and employment history
Compensation and benefits information
Performance reviews and development plans
Training records and certification tracking
Disciplinary actions and corrective measures
Attendance and leave tracking

Workplace Operations:

Office access and security badge information
IT equipment assignment and usage monitoring
Email and communication system usage
Expense reports and travel arrangements
Health and safety incident reporting

12.2 Employee Privacy Rights and Protections

Our employees have specific privacy rights and protections:

Transparency and Access:

Clear privacy notices about data collection and use
Access to personal information in personnel files
Right to correct inaccurate information
Regular updates about policy changes
Clear complaint and grievance procedures

Consent and Choice:

Opt-in consent for non-mandatory programs and benefits
Choice in emergency contact and beneficiary information
Voluntary participation in wellness and health programs
Consent for photo/video usage in marketing materials
Privacy settings for internal directory and communication tools

Retention and Deletion:

Clear retention periods for different types of records
Secure deletion procedures upon employment termination
Legal hold procedures for litigation and investigations
Archive and retrieval procedures for historical records
Regular review and purging of outdated information

12.3 Workplace Monitoring and Communications

We maintain appropriate workplace monitoring while respecting privacy:

IT Systems and Communications:

Email and internet usage monitoring for security and compliance
Network access logging and security monitoring
Software usage and license compliance tracking
Mobile device management for company-provided devices
Remote work monitoring and productivity tools

Physical Workplace:

Security camera systems in common areas
Access control and visitor management systems
Health and safety monitoring and reporting
Parking and facility usage tracking
Environmental monitoring and controls

Limitations and Protections:

No monitoring of personal communications on personal devices
Limited monitoring scope focused on business purposes
Clear policies and employee notification procedures
Regular review and assessment of monitoring practices
Compliance with labor laws and collective bargaining agreements

12.4 International Employee Privacy

For employees in different jurisdictions, we comply with local employment laws:

European Union (GDPR):

Enhanced consent requirements for employee data processing
Data protection impact assessments for employee monitoring
Works council consultation and employee representative involvement
Specific protections for sensitive personal data
Right to portability for employee data

Other Jurisdictions:

Compliance with local employment and labor laws
Specific privacy rights and protections under local law
Cultural considerations and workplace privacy expectations
Language requirements for privacy notices and policies
Local data residency and transfer restrictions

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13. VENDOR AND PARTNER DATA MANAGEMENT

13.1 Vendor Data Collection and Processing

We collect personal information from vendors, partners, and business associates:

Vendor Management:

Contact information for key personnel and decision-makers
Financial information for payment processing and credit evaluation
Performance metrics and evaluation records
Contract negotiations and agreement documentation
Insurance and certification verification

Due Diligence and Onboarding:

Background checks and financial stability assessment
Regulatory compliance and licensing verification
References and past performance evaluation
Security assessment and risk evaluation
Quality assurance and capability verification

Ongoing Relationship Management:

Performance monitoring and evaluation records
Communication logs and interaction history
Invoice processing and payment records
Training and certification tracking
Incident reporting and resolution documentation

13.2 Partner and Alliance Data

We process information related to strategic partnerships and business alliances:

Partnership Development:

Strategic planning and opportunity assessment
Joint marketing and business development activities
Revenue sharing and performance tracking
Competitive intelligence and market analysis
Relationship management and communication coordination

Collaboration and Integration:

Technical integration and data sharing agreements
Joint project management and deliverable coordination
Shared client relationship management
Co-marketing campaign execution and measurement
Knowledge sharing and best practice development

13.3 Third-Party Data Protection Requirements

We extend our privacy and security requirements to all business partners:

Contractual Obligations:

Comprehensive data processing agreements and privacy terms
Security specifications and technical safeguard requirements
Incident notification and breach response procedures
Audit rights and compliance verification processes
Data return and secure deletion obligations

Ongoing Monitoring:

Regular security assessments and compliance reviews
Performance monitoring and quality assurance procedures
Training and awareness programs for partner personnel
Incident reporting and investigation coordination
Continuous improvement and best practice sharing

13.4 Vendor Data Retention and Lifecycle Management

We manage vendor and partner data throughout the relationship lifecycle:

Active Relationship Phase:

Regular data updates and accuracy verification
Performance tracking and evaluation documentation
Communication and interaction logging
Contract and agreement maintenance
Training and certification tracking

Relationship Termination:

Final performance evaluation and documentation
Contract closeout and final payment processing
Data retention for legal and business reference purposes
Transition planning and knowledge transfer
Reference and recommendation procedures

Post-Relationship Management:

Archived relationship data for reference and compliance
Regulatory reporting and audit trail maintenance
Legal hold and litigation support procedures
Historical performance analysis and benchmarking
Alumni and relationship maintenance programs

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14. CHILDREN'S PRIVACY PROTECTION

14.1 Children's Online Privacy Protection Act (COPPA) Compliance

We are committed to protecting children's privacy and comply with COPPA requirements:

Age Verification and Restrictions:

Our services are not directed to children under 13 years of age
Age verification procedures for account creation and service access
Parental consent mechanisms where children's data may be involved
Special protections for educational and family-oriented campaigns
Clear privacy notices for services that may reach children

Prohibited Collection:

No intentional collection of personal information from children under 13
Immediate deletion procedures if child information is discovered
Parental notification and consent procedures for inadvertent collection
Special handling for contest, survey, and promotional activities
Enhanced security and access controls for any child-related data

14.2 Educational and Family Marketing Services

When providing services that may involve children's data:

Educational Institution Services:

Compliance with Family Educational Rights and Privacy Act (FERPA)
Student privacy protections and parental rights recognition
Limited collection and use for educational purposes only
Enhanced security and confidentiality measures
Regular compliance audits and assessment procedures

Family-Oriented Marketing:

Special consent procedures for family-targeted campaigns
Parental oversight and control mechanisms
Limited data collection focused on family unit rather than individual children
Clear opt-out procedures for parents and guardians
Regular review and assessment of family data practices

14.3 International Children's Privacy Compliance

We comply with children's privacy laws in all jurisdictions where we operate:

European Union (GDPR Article 8):

Enhanced consent requirements for children under 16 (or lower national age)
Parental consent verification and ongoing management
Special protections for children's personal data processing
Age-appropriate privacy notices and communication
Regular assessment of processing legitimacy and necessity

Other International Requirements:

Canada's Personal Information Protection and Electronic Documents Act (PIPEDA)
Australia's Privacy Act and children's privacy protections
Local age verification and parental consent requirements
Cultural considerations for family privacy expectations
Coordination with local child protection and safety authorities

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15. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

15.1 California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) Compliance

California residents have specific privacy rights under state law:

Information Collection Disclosure:

Categories of personal information collected over the past 12 months
Sources from which personal information is collected
Business or commercial purposes for collection and use
Categories of third parties with whom information is shared
Specific pieces of personal information collected about the consumer

Consumer Rights:

Right to know what personal information is collected and how it's used
Right to delete personal information (subject to exceptions)
Right to correct inaccurate personal information
Right to opt-out of the sale or sharing of personal information
Right to limit the use and disclosure of sensitive personal information
Right to non-discrimination for exercising privacy rights

15.2 Categories of Personal Information Under CCPA/CPRA

We collect and process the following categories as defined by California law:

Identifiers:

Names, aliases, postal addresses, email addresses
Phone numbers and other contact information
Online identifiers and IP addresses
Account names and social media handles
Government identification numbers (where necessary)

Commercial Information:

Records of services purchased or considered
Purchasing or consuming histories or tendencies
Payment information and transaction records
Customer service interactions and support requests
Contract and agreement terms and performance

Internet or Electronic Network Activity:

Browsing history and search history on our websites
Information on interaction with websites, applications, or advertisements
Platform usage patterns and feature utilization
Email engagement and communication preferences
Social media interactions and engagement metrics

Geolocation Data:

Approximate location derived from IP addresses
Location information for event and service coordination
Regional preferences and localization settings
Timezone and language preferences
Travel and meeting coordination information

Professional or Employment-Related Information:

Job titles, roles, and responsibilities
Company affiliations and organizational structure
Professional credentials and certifications
Industry experience and expertise areas
Career history and professional achievements

Sensitive Personal Information:

Account login credentials and authentication information
Financial account numbers and payment information
Precise geolocation data (with explicit consent)
Government identification numbers (where legally required)
Professional licensing and certification information

15.3 Sale and Sharing Disclosure

We do not sell personal information in the traditional sense, but may share information that constitutes "sale" or "sharing" under California law:

Cross-Context Behavioral Advertising:

Website analytics and performance measurement
Interest-based advertising and retargeting campaigns
Social media advertising and lookalike audience development
Third-party advertising network participation
Cross-device tracking and user recognition

Business Partner Sharing:

Joint marketing campaigns and partnership activities
Referral programs and lead sharing arrangements
Industry research and benchmarking studies
Event co-sponsorship and attendee sharing
Strategic alliance and collaboration activities

Opt-Out Rights and Procedures:

"Do Not Sell or Share My Personal Information" link on our website
Online form submission for opt-out requests
Email requests to privacy@valiant.biz
Phone requests during business hours
Verification procedures to prevent fraudulent requests

15.4 CPRA Enhanced Rights and Protections

The California Privacy Rights Act provides additional rights and protections:

Sensitive Personal Information Limitations:

Right to limit use and disclosure of sensitive personal information
Opt-out options for sensitive data processing beyond business necessity
Enhanced notice requirements for sensitive data collection
Special protections for financial, health, and government identification data
Regular assessment and minimization of sensitive data processing

Automated Decision-Making and Profiling:

Right to know about automated decision-making processes
Right to request human review of automated decisions
Opt-out rights for certain automated processing activities
Transparency about profiling and algorithmic decision-making
Appeal processes for automated decision outcomes

Third-Party Risk Assessment:

Enhanced due diligence for service providers and vendors
Contractual requirements for data protection and privacy compliance
Regular auditing and assessment of third-party data practices
Incident notification and breach response coordination
Termination rights for non-compliant third parties

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16. EUROPEAN PRIVACY RIGHTS (GDPR)

16.1 General Data Protection Regulation (GDPR) Compliance Framework

We comply with GDPR requirements for all European Economic Area (EEA) data subjects:

Legal Bases for Processing:

Consent: Explicit, informed, and freely given agreement for specific processing activities
Contract: Processing necessary for contract performance or pre-contractual measures
Legal Obligation: Processing required to comply with legal or regulatory requirements
Legitimate Interests: Processing necessary for legitimate business interests, balanced against individual rights
Vital Interests: Processing necessary to protect someone's life or physical safety
Public Task: Processing necessary for public interest or official authority tasks

Data Subject Rights:

Right of Access (Article 15): Confirmation of processing and access to personal data
Right to Rectification (Article 16): Correction of inaccurate or incomplete data
Right to Erasure (Article 17): "Right to be forgotten" under specific circumstances
Right to Restrict Processing (Article 18): Limitation of processing in certain situations
Right to Data Portability (Article 20): Receive data in structured, machine-readable format
Right to Object (Article 21): Object to processing based on legitimate interests or direct marketing
Rights Related to Automated Decision-Making (Article 22): Protection against solely automated decisions with legal effects

16.2 Lawful Basis Assessment and Documentation

We maintain detailed documentation of our legal bases for processing:

Consent Management:

Clear and specific consent requests with granular options
Easy withdrawal mechanisms and ongoing consent management
Regular consent refresh and reconfirmation procedures
Documentation of consent date, scope, and withdrawal
Child consent and parental verification procedures where applicable

Legitimate Interests Assessment:

Balancing test documentation for legitimate interest processing
Purpose limitation and data minimization analysis
Individual rights and freedom impact assessment
Alternative processing method evaluation
Regular review and reassessment procedures

Contract and Legal Obligation Processing:

Clear documentation of contract performance necessity
Legal obligation identification and compliance mapping
Third-country adequacy and safeguard assessment
Regular legal basis review and update procedures
Data subject notification and transparency measures

16.3 International Data Transfers from Europe

We implement appropriate safeguards for transfers outside the EEA:

Adequacy Decisions:

Reliance on European Commission adequacy decisions where available
Regular monitoring of adequacy status and withdrawal procedures
Alternative safeguard preparation for potential adequacy changes
Documentation of adequacy reliance and transfer records
Data subject notification about transfer destinations

Standard Contractual Clauses (SCCs):

Implementation of European Commission approved SCCs
Additional safeguards and transfer impact assessments
Regular review of transfer necessity and alternatives
Suspension procedures for problematic transfers
Documentation and record-keeping requirements

Binding Corporate Rules (BCRs) and Certification:

Internal data transfer policies and procedures
Regular compliance audits and assessment procedures
Employee training and awareness programs
Data subject complaint and redress mechanisms
Supervisory authority cooperation and coordination

16.4 GDPR Compliance Monitoring and Governance

We maintain comprehensive GDPR compliance programs:

Data Protection Impact Assessments (DPIAs):

Risk assessment for high-risk processing activities
Privacy by design and default implementation
Regular DPIA review and update procedures
Consultation with supervisory authorities where required
Documentation and record-keeping for compliance demonstration

Records of Processing Activities (Article 30):

Comprehensive processing activity documentation
Regular review and update of processing records
Data controller and processor activity mapping
Legal basis documentation and assessment
International transfer and safeguard documentation

Data Protection Officer (DPO) and Governance:

Designated data protection officer contact and responsibilities
Regular compliance monitoring and assessment procedures
Employee training and awareness programs
Incident response and breach notification procedures
Supervisory authority cooperation and communication

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17. OTHER STATE PRIVACY LAWS

17.1 Virginia Consumer Data Protection Act (VCDPA)

Virginia residents have specific privacy rights under state law effective January 1, 2023:

Consumer Rights:

Right to access personal data and processing information
Right to correct inaccurate personal data
Right to delete personal data under certain circumstances
Right to opt-out of targeted advertising and sale of personal data
Right to data portability for consumer-provided information

Processing Requirements:

Data minimization and purpose limitation principles
Consent requirements for sensitive data processing
Opt-out mechanisms for targeted advertising and profiling
Data protection assessments for high-risk processing
Privacy notice and transparency requirements

17.2 Colorado Privacy Act (CPA)

Colorado residents have privacy rights under state law effective July 1, 2023:

Enhanced Protections:

Biometric data protection and consent requirements
Universal opt-out signal recognition and honor procedures
Data protection assessment requirements for high-risk processing
Appeal process for denied consumer rights requests
Non-discrimination provisions for rights exercise

Processing Obligations:

Purpose specification and data minimization requirements
Consent for sensitive data processing activities
Regular data protection impact assessments
Third-party processor oversight and management
Breach notification and response procedures

17.3 Connecticut Data Privacy Act (CTDPA)

Connecticut residents have privacy rights under state law effective July 1, 2023:

Consumer Rights Framework:

Access, correction, and deletion rights for personal data
Data portability rights for consumer-provided information
Opt-out rights for targeted advertising and sale
Appeal process for denied or incomplete responses
Non-retaliation protection for rights exercise

Business Obligations:

Privacy notice and transparency requirements
Consent mechanisms for sensitive data processing
Data protection assessments for high-risk activities
Third-party oversight and contractual requirements
Regular compliance monitoring and assessment

17.4 Additional State Privacy Legislation

We monitor and comply with emerging state privacy laws:

Pending and Proposed Legislation:

Regular monitoring of state legislative developments
Compliance preparation for new law effective dates
Legal analysis and requirement assessment procedures
System and process adaptation for new requirements
Training and awareness programs for new obligations

Multi-State Compliance Framework:

Harmonized privacy practices across jurisdictions
Centralized rights request processing and response
Consistent privacy notice and transparency information
Coordinated breach notification and response procedures
Regular compliance auditing and assessment programs

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18. DATA BREACH RESPONSE AND NOTIFICATION

18.1 Comprehensive Breach Response Framework

We maintain detailed incident response procedures for data security events:

Incident Detection and Classification:

24/7 security monitoring and alerting systems
Automated threat detection and anomaly identification
Employee reporting procedures and escalation protocols
Third-party notification and coordination procedures
Initial risk assessment and impact evaluation

Immediate Response and Containment:

Incident response team activation and coordination
Immediate containment and threat neutralization procedures
System isolation and evidence preservation protocols
Forensic investigation and root cause analysis
Recovery and restoration planning and execution

18.2 Legal and Regulatory Notification Requirements

We comply with all applicable breach notification laws and regulations:

Timeline Requirements:

GDPR: 72 hours to supervisory authority, without undue delay to data subjects
California: Without unreasonable delay, typically within specified timeframes
Other States: Varies by jurisdiction, generally within 30-60 days
Federal Laws: HIPAA, GLBA, and other sector-specific requirements
Client Contracts: Notification timelines specified in service agreements

Notification Content:

Nature and scope of the security incident
Categories and approximate number of affected individuals
Description of likely consequences and potential harm
Measures taken to address the breach and mitigate harm
Contact information for questions and additional information
Recommendations for individual protective measures

18.3 Individual and Stakeholder Communication

We provide clear and timely communication to all affected parties:

Data Subject Notification:

Clear, plain language description of the incident
Specific information about personal data involved
Likely consequences and potential risks
Measures taken and recommended individual actions
Contact information for questions and support
Free identity protection services where appropriate

Client and Partner Communication:

Immediate notification to affected clients and business partners
Detailed briefings on incident scope and potential impact
Coordination on client-specific notification requirements
Ongoing updates throughout investigation and remediation
Lessons learned and prevention measure implementation

18.4 Post-Incident Analysis and Improvement

Every security incident provides opportunities for improvement:

Root Cause Analysis:

Detailed forensic investigation and evidence analysis
Process and system vulnerability identification
Human factor and training need assessment
Third-party and vendor contribution evaluation
Regulatory and compliance gap identification

Remediation and Prevention:

Security control enhancement and implementation
Process improvement and training program updates
Technology upgrade and system hardening procedures
Third-party risk assessment and management enhancement
Regular testing and validation of improvements

Documentation and Reporting:

Comprehensive incident documentation and lessons learned
Regulatory reporting and supervisory authority coordination
Client and stakeholder impact assessment and communication
Insurance claim preparation and coordination
Legal and compliance documentation and record-keeping

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19. PRIVACY GOVERNANCE AND COMPLIANCE

19.1 Privacy Program Governance Structure

We maintain comprehensive privacy governance with clear accountability:

Privacy Leadership:

Chief Privacy Officer or designated privacy lead
Privacy steering committee with cross-functional representation
Regular board and executive leadership privacy briefings
Privacy champion network throughout the organization
External privacy counsel and advisory relationships

Privacy by Design and Default:

Privacy considerations integrated into all business processes
Regular privacy impact assessments for new products and services
Default privacy settings and user control implementation
Data minimization and purpose limitation principles
Regular privacy training and awareness programs

19.2 Compliance Monitoring and Assessment

We regularly assess and monitor our privacy practices:

Internal Auditing:

Regular privacy compliance audits and assessments
Process review and gap analysis procedures
Employee compliance monitoring and training verification
Third-party risk assessment and management oversight
Corrective action planning and implementation tracking

External Validation:

Third-party privacy audits and certifications
Regulatory examination and assessment cooperation
Industry best practice benchmarking and comparison
Legal compliance verification and validation
Insurance and risk management assessment coordination

19.3 Employee Training and Awareness

All employees receive comprehensive privacy training:

Onboarding Training:

Privacy law and regulation overview
Company privacy policies and procedures
Role-specific privacy responsibilities and obligations
Incident reporting and escalation procedures
Ongoing training requirements and expectations

Ongoing Education:

Annual privacy training and certification requirements
Regular updates on privacy law changes and developments
Specialized training for high-risk roles and responsibilities
Privacy incident simulation and response training
Industry best practice sharing and discussion

19.4 Vendor and Third-Party Management

We extend privacy requirements throughout our vendor ecosystem:

Due Diligence and Onboarding:

Comprehensive privacy and security assessments
Data processing agreement negotiation and execution
Regular compliance verification and monitoring
Performance evaluation and improvement planning
Incident response and breach notification coordination

Ongoing Management:

Regular vendor privacy compliance audits and reviews
Contract compliance monitoring and enforcement
Performance measurement and improvement tracking
Relationship review and optimization procedures
Termination and transition planning for non-compliance

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20. POLICY UPDATES AND COMMUNICATION

20.1 Policy Maintenance and Updates

We regularly review and update this Privacy Policy:

Regular Review Schedule:

Annual comprehensive policy review and assessment
Quarterly updates for regulatory and law changes
Monthly monitoring of privacy developments and trends
Immediate updates for material business or system changes
Emergency updates for security incidents or regulatory requirements

Update Process:

Legal and compliance review of all changes
Business impact assessment and stakeholder consultation
Executive approval for material policy modifications
Effective date coordination and implementation planning
Communication and training program updates

20.2 Communication and Notification Procedures

We provide appropriate notice of policy changes:

Material Changes:

Email notification to active clients and users
Prominent website posting and banner notifications
In-platform notifications and alerts where applicable
Direct mail for significant changes affecting consumer rights
Press release and public announcement for major updates

Minor Updates:

Website posting with effective date notation
Regular newsletter inclusion and update summaries
Annual policy review and acknowledgment procedures
Training program updates and employee communication
Stakeholder briefings and discussion sessions

20.3 Stakeholder Engagement and Feedback

We welcome feedback and questions about our privacy practices:

Public Comment and Input:

Open comment periods for major policy changes
Stakeholder consultation and feedback incorporation
Industry association and peer collaboration
Academic research and best practice development
Consumer advocacy group engagement and dialogue

Continuous Improvement:

Regular feedback collection and analysis
Best practice research and implementation
Technology advancement and privacy enhancement evaluation
Regulatory guidance and enforcement action analysis
Customer satisfaction and trust measurement programs

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CONTACT INFORMATION AND PRIVACY INQUIRIES

For all privacy-related questions, requests, or concerns, please contact us:

Valiant Business Services LLC
Privacy and Data Protection Office
16192 Coastal Highway
Lewes, DE 19958
United States of America

Parent Company:
Juiced IO Inc

Privacy Contact Information:

Privacy Inquiries: privacy@valiant.biz
Data Subject Rights Requests: privacy@valiant.biz
General Privacy Questions: (302) 212-4282
Data Protection Officer: Benjamin Hall - admin@valiant.biz
Legal and Compliance: legal@valiant.biz

Privacy Rights Request Portal:Visit our website at [website URL] to access our privacy rights request portal for:

California Consumer Privacy Act (CCPA/CPRA) requests
European General Data Protection Regulation (GDPR) requests
Other state privacy law requests
General privacy inquiries and questions
Marketing communication preferences and opt-out requests

Response Commitment:

Initial acknowledgment within 2 business days
Substantive response within 30-45 days (depending on jurisdiction)
Expedited processing for urgent requests
Clear explanation of actions taken or reasons for any limitations
Follow-up support and additional assistance as needed

Business Hours:Monday through Friday, 9:00 AM to 6:00 PM Eastern Standard Time, excluding federal holidays recognized in the United States.

Supervisory Authority Contact Information:For European data subjects, you may contact your local supervisory authority or the lead supervisory authority for cross-border processing. For California residents, you may contact the California Privacy Protection Agency. For other jurisdictions, please contact your local data protection or privacy authority.

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ACKNOWLEDGMENT AND EFFECTIVE DATE

This Privacy Policy is effective as of September 3, 2025, and supersedes all previous versions. By continuing to use our services or engage with our platforms after this date, you acknowledge that you have read, understood, and consent to the practices described in this Policy.

We reserve the right to modify this Policy at any time in accordance with applicable laws and our commitment to transparency and user control. Material changes will be communicated through appropriate channels as described in this Policy.

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This Privacy Policy contains confidential and proprietary information about Valiant Business Services LLC and Juiced IO Inc privacy practices and procedures. This document is provided for transparency and compliance purposes and may not be reproduced or distributed without authorization.

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