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.
TABLE OF CONTENTS
- Information Collection and Data Sources
- Categories of Personal Information
- Purposes and Legal Basis for Processing
- Data Sharing and Third-Party Disclosure
- International Data Transfers and Safeguards
- Data Retention and Lifecycle Management
- Individual Rights and Privacy Controls
- Security Measures and Data Protection
- Cookies and Tracking Technologies
- Marketing Communications and Consent
- Client Data and Campaign Management
- Employee and Personnel Data
- Vendor and Partner Data Management
- Children's Privacy Protection
- California Privacy Rights (CCPA/CPRA)
- European Privacy Rights (GDPR)
- Other State Privacy Laws
- Data Breach Response and Notification
- Privacy Governance and Compliance
- Policy Updates and Communication
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
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
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.
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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.
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.
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.
