Privacy Policy

Privacy Policy

Last updated: [current date]

1. Introduction

This Privacy Policy explains how Chofski Consulting ("we," "us," or "our") collects, uses, shares, and protects your personal information when you visit our website, use our services, or otherwise interact with us. Tabitha Winter is the primary contact for privacy matters and can be reached at tabithawinter@chofskiconsulting.com or 07545566949.

This policy applies to all personal data we collect through our website, email communications, SMS messages, forms, client interactions, and any other touchpoints related to our Business Consulting services. By using our services or providing us with your information, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

We collect several types of personal information to deliver our services, communicate with you, and improve your experience:

Information You Provide Directly:

• Identity and contact data: your name, email address, phone number, company name, job title, and any other information you submit through contact forms, consultation requests, service inquiries, or client onboarding processes
• Payment information: billing details necessary to process transactions, though full payment card numbers are collected and processed directly by our third-party payment processor and are not stored on our systems
• Communications and content: messages, questions, feedback, testimonials, or other content you submit to us via email, forms, SMS, or during consultations
• Professional information: details about your business, industry, challenges, goals, and other information relevant to the consulting services you request

Information Collected Automatically:

• Technical and usage data: IP address, browser type and version, device type, operating system, referring URLs, pages viewed, time spent on pages, links clicked, and other usage patterns when you visit our website
• Location data: approximate geographic location derived from your IP address
• Cookies and similar technologies: we use cookies, web beacons, and similar tracking technologies to collect information about your browsing behavior and preferences (see Section 7 and our separate Cookie Policy for details)

Information from Third Parties:

• Analytics providers: we receive aggregated and individual-level data from analytics services such as Google Analytics about how visitors use our website
• Marketing and communication platforms: data about email opens, clicks, and SMS delivery and engagement from our email and SMS service providers

3. How We Use Your Information

We use the personal information we collect for the following purposes:

Service Delivery and Performance:

• Provide, deliver, and manage our Business Consulting services, including scheduling consultations, delivering advice and recommendations, and fulfilling contractual obligations
• Process payments and maintain transaction records through our third-party payment processor
• Communicate with you about your services, appointments, deliverables, and account matters
• Respond to your inquiries, requests, and support needs

Marketing and Communications:

• Send you marketing emails about our services, resources, events, and offers (you can unsubscribe at any time as described in Section 6)
• Send you marketing SMS messages where you have provided prior express written consent (you can opt out by replying STOP as described in Section 6)
• Personalize our communications and offers based on your interests and interactions with us

Business Operations and Improvement:

• Analyze website usage, user behavior, and service performance to improve our offerings, user experience, and business operations
• Conduct research, testing, and analytics to develop new services and enhance existing ones
• Maintain records for business administration, accounting, and legal compliance

Security, Fraud Prevention, and Legal Compliance:

• Detect, prevent, and address fraud, security incidents, and other harmful or illegal activity
• Comply with applicable laws, regulations, legal processes, and enforceable governmental requests
• Enforce our Terms of Service and other agreements
• Protect the rights, property, and safety of Chofski Consulting, our clients, and others

4. Legal Bases for Processing

For visitors and clients located in the European Union or United Kingdom, we process your personal data based on the following lawful bases under the General Data Protection Regulation (GDPR) and UK GDPR:

Consent: When you provide explicit consent, such as opting in to receive marketing emails or SMS messages, subscribing to our communications, or submitting information through forms with clear consent language.

Performance of a Contract: When processing is necessary to fulfill our contractual obligations to you, such as delivering consulting services you have purchased, processing payments, and providing client support.

Legitimate Interests: When we have a legitimate business interest that is not overridden by your privacy rights, such as analyzing website usage to improve our services, preventing fraud and security threats, maintaining business records, and sending relevant information to existing clients about similar services.

Legal Obligation: When we must process your data to comply with legal requirements, such as tax reporting, responding to lawful requests from authorities, or maintaining records required by law.

You have the right to withdraw consent at any time where we rely on consent as the legal basis, without affecting the lawfulness of processing based on consent before withdrawal.

5. How We Share Your Information

We share your personal information only in the following circumstances:

Service Providers and Processors: We engage trusted third-party service providers to perform functions on our behalf. These processors have access to personal information only as needed to perform their functions and are contractually obligated to protect your data and use it only for the purposes we specify. Categories of processors include:

• Payment processors: to securely process transactions and handle billing (these providers collect and process payment card information directly and maintain PCI DSS compliance)
• Email service providers: to send transactional and marketing emails and track engagement
• SMS service providers: to send text messages and manage opt-ins and opt-outs
• Website hosting and infrastructure providers: to host our website and store data
• Analytics providers: to analyze website traffic, user behavior, and service performance
• Customer relationship management (CRM) platforms: to manage client relationships and communications
• Cloud storage providers: to securely store business records and client files

Legal and Safety Disclosures: We may disclose your information if required by law, legal process, or governmental request, or when we believe in good faith that disclosure is necessary to:

• Comply with legal obligations, court orders, subpoenas, or regulatory requirements
• Protect the rights, property, or safety of Chofski Consulting, our clients, or the public
• Detect, prevent, or address fraud, security issues, or technical problems
• Enforce our Terms of Service or other agreements

Business Transfers: If Chofski Consulting is involved in a merger, acquisition, sale of assets, bankruptcy, or other business transaction, your personal information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on our website of any such change in ownership or control of your personal information.

With Your Consent: We may share your information for other purposes with your explicit consent or at your direction.

Sale of Personal Information: We do not sell your personal information to third parties for monetary or other valuable consideration. For California residents, this means we do not engage in "sales" or "sharing" of personal information as defined under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). You have the right to opt out of any future sale or sharing, should our practices change, by contacting us as described in Section 10.

6. Marketing Communications and Your Choices

Email Marketing: If you receive marketing emails from us, each message includes an unsubscribe link that allows you to opt out of future marketing emails. You can also unsubscribe by contacting us at tabithawinter@chofskiconsulting.com. Even if you opt out of marketing emails, we may still send you transactional or service-related messages about your account, services, or requests.

Our email marketing practices comply with the CAN-SPAM Act. All marketing emails clearly identify Chofski Consulting as the sender, include our contact information, provide a clear and conspicuous unsubscribe mechanism, and honor opt-out requests promptly (within 10 business days).

SMS Marketing: We send marketing text messages only to individuals who have provided prior express written consent to receive such messages, as required by the Telephone Consumer Protection Act (TCPA). By opting in to SMS marketing, you consent to receive automated marketing messages at the phone number you provided, and you understand that consent is not a condition of purchase.

You can opt out of SMS marketing at any time by replying STOP to any message. You can also reply HELP for assistance or contact us at tabithawinter@chofskiconsulting.com. Message and data rates may apply. Message frequency varies based on your interactions and our marketing schedule.

7. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activity, remember your preferences, analyze website performance, and deliver relevant content and advertisements.

Cookies are small text files stored on your device that help us recognize you on return visits and understand how you use our website. We use both first-party cookies (set by Chofski Consulting) and third-party cookies (set by service providers like analytics platforms).

For detailed information about the specific cookies we use, their purposes, duration, and how to manage your cookie preferences, please see our separate Cookie Policy. You can control cookies through your browser settings, but disabling certain cookies may limit your ability to use some features of our website.

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Client and Service Data: We retain information related to consulting services and client relationships for the duration of the engagement and for a reasonable period afterward to maintain business records, provide ongoing support, comply with legal and tax obligations, and resolve disputes. This is typically [6-7 years] from the end of the client relationship, in line with standard business record retention practices.

Marketing Data: We retain contact information and marketing preferences for individuals who have opted in to our communications until they unsubscribe or request deletion, or until the data becomes outdated or inactive (typically after [2-3 years] of no engagement).

Website Usage Data: Analytics and usage data is typically retained for [12-24 months] to identify trends and improve our services, after which it may be aggregated or deleted.

Legal and Compliance Records: We may retain certain information longer when required by law, to comply with regulatory obligations, resolve disputes, enforce agreements, or defend legal claims.

When personal information is no longer needed, we securely delete or anonymize it in accordance with our data retention and deletion procedures.

9. Data Security

We implement reasonable technical, administrative, and physical safeguards designed to protect your personal information from unauthorized access, use, disclosure, alteration, and destruction. These measures include:

• Encryption of data in transit using SSL/TLS protocols
• Secure storage of data with access controls and authentication requirements
• Regular security assessments and updates to our systems and practices
• Contractual obligations requiring our service providers to maintain appropriate security measures
• Employee training on data protection and privacy practices

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information using commercially reasonable means, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of any passwords or account credentials and for notifying us immediately of any unauthorized access to your account.

10. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

Rights for EU and UK Residents (GDPR/UK GDPR):

• Right of Access: You can request confirmation of whether we process your personal data and obtain a copy of that data
• Right to Rectification: You can request correction of inaccurate or incomplete personal data
• Right to Erasure (Right to be Forgotten): You can request deletion of your personal data in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected or when you withdraw consent
• Right to Restriction of Processing: You can request that we limit how we use your data in certain situations
• Right to Data Portability: You can request a copy of your data in a structured, commonly used, machine-readable format and have it transmitted to another controller
• Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw that consent at any time
• Right to Lodge a Complaint: You can file a complaint with your local data protection authority if you believe we have violated your privacy rights

Rights for California Residents (CCPA/CPRA):

• Right to Know: You can request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collection, and the categories of third parties with whom we share personal information
• Right to Delete: You can request deletion of your personal information, subject to certain exceptions
• Right to Correct: You can request correction of inaccurate personal information we maintain about you
• Right to Opt Out of Sale or Sharing: You can opt out of the sale or sharing of your personal information (we do not currently sell or share personal information as defined by CCPA/CPRA)
• Right to Limit Use of Sensitive Personal Information: You can limit our use of sensitive personal information to purposes necessary to perform services or provide goods reasonably expected by an average consumer (we do not use sensitive personal information beyond these purposes)
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA/CPRA rights

How to Exercise Your Rights: To submit a request to access, correct, delete, or otherwise exercise your privacy rights, please contact us at:

• Email: tabithawinter@chofskiconsulting.com
• Phone: 07545566949

We will verify your identity before processing your request to protect your personal information from unauthorized access. Verification may require you to provide information that matches data we have on file or to confirm details about your interactions with us. For California requests, you may designate an authorized agent to submit requests on your behalf by providing written authorization.

We will respond to verified requests within the timeframes required by applicable law (typically 30 days for GDPR requests and 45 days for CCPA requests, with possible extensions). We do not charge a fee for processing requests unless they are manifestly unfounded, excessive, or repetitive.

11. International Data Transfers

Chofski Consulting operates primarily in [the United Kingdom / the jurisdiction where the business is based]. If you are located outside this jurisdiction, please be aware that your personal information may be transferred to, stored, and processed in countries that may have different data protection laws than your country of residence.

For transfers of personal data from the European Economic Area (EEA) or United Kingdom to countries that do not provide an adequate level of data protection as determined by the European Commission or UK authorities, we rely on appropriate safeguards such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission or UK authorities
• Adequacy decisions recognizing certain countries as providing adequate protection
• Processor agreements requiring service providers to implement appropriate technical and organizational measures

By using our services and providing your information, you consent to such transfers. If you have questions about international transfers of your data, please contact us at tabithawinter@chofskiconsulting.com.

12. Children's Privacy

Our services are not directed to, and we do not knowingly collect personal information from, children under the age of 13 (or under 16 for individuals in the European Economic Area or United Kingdom). If we become aware that we have collected personal information from a child under these ages without valid parental consent, we will take steps to delete that information promptly.

If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us at tabithawinter@chofskiconsulting.com so we can take appropriate action.

13. Third-Party Links and Services

Our website and communications may contain links to third-party websites, services, or resources that are not owned or controlled by Chofski Consulting. This Privacy Policy applies only to information collected by us. We are not responsible for the privacy practices, content, or policies of third-party sites or services.

When you click on a third-party link or interact with a third-party service, you are subject to that party's privacy policy and terms. We encourage you to review the privacy policies of any third-party sites or services you visit or use.

Some third-party services we use, such as payment processors and analytics providers, may collect information directly from you or your device. Their collection and use of information is governed by their own privacy policies.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, legal requirements, or for other operational, legal, or regulatory reasons. When we make material changes, we will notify you by:

• Updating the "Last updated" date at the top of this policy
• Sending an email to the address associated with your account (if applicable)
• Posting a notice on our website or through other appropriate communication channels

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information. Your continued use of our services after changes become effective constitutes your acceptance of the updated Privacy Policy.

If changes materially affect your rights or how we handle personal information collected before the change, we will obtain your consent where required by applicable law.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Chofski Consulting Tabitha Winter Email: tabithawinter@chofskiconsulting.com Phone: 07545566949

For privacy-related inquiries, compliance questions, or to exercise your privacy rights, please use the contact information above. We will respond to your inquiry as promptly as possible, typically within [5-10 business days] for general questions and within the timeframes required by law for formal rights requests.