Privacy Policy

Section 01

Scope and Applicability

This Privacy Policy applies to:

• Visitors to our website(s) and any associated landing pages
• Prospective clients who submit inquiries, request proposals, or contact us through any channel
• Current and former clients whose information we process in connection with the delivery of services
• Individuals whose personal data we may access on behalf of our clients (e.g., website analytics data, ad account data)

This Policy does not apply to third-party websites, platforms, or services that we may link to or use as part of service delivery. Those services are governed by their own privacy policies.

Section 02

Information We Collect

We collect personal information in the following categories:

A. Information You Provide Directly

• Contact information: name, email address, phone number, company name, and mailing address
• Inquiry and project details submitted through contact forms, email, or phone
• Billing and payment information (processed through secure third-party payment processors)
• Communications and correspondence you send to us

B. Information Collected Automatically

• IP address, browser type, device type, and operating system
• Pages visited, time spent on pages, referring URLs, and click behavior
• Cookie identifiers and similar tracking technologies (see Section 6)

C. Information Collected on Behalf of Clients

In the course of providing services, Atholm may access and process data contained in client-owned platforms including Google Ads accounts, Google Analytics (GA4), website CMS platforms, email marketing tools, and social media accounts. This data is processed solely to deliver the agreed-upon services and is governed by the client's own privacy obligations to their end users.

Section 03

How We Use Your Information

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

• To respond to inquiries and communicate about proposed or active service engagements
• To deliver, manage, and improve our digital marketing services
• To process payments and maintain accurate billing records
• To send service-related communications including project updates, invoices, and performance reports
• To send marketing communications about our services, where you have opted in or where permitted by applicable law
• To analyze website usage and improve our own digital presence
• To comply with legal obligations and enforce our Terms of Service
• To protect the security and integrity of our systems and client data

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes.

Section 04

Legal Basis for Processing

Atholm processes personal information on the following legal bases:

• Contract performance: Processing necessary to fulfill our obligations under a service agreement or SOW
• Legitimate interests: Processing necessary for our legitimate business interests, including marketing, security, and service improvement, where such interests are not overridden by your rights
• Legal obligation: Processing required to comply with applicable federal, state, or local law
• Consent: Where you have provided explicit consent, such as subscribing to marketing communications

Section 05

Disclosure of Personal Information

Atholm does not sell personal information. We may share information in the following limited circumstances:

A. Service Providers

We engage trusted third-party vendors to assist in delivering our services, including payment processors, cloud hosting providers, project management tools, analytics platforms, and AI tool providers (such as OpenAI, Anthropic, and Google). These vendors are contractually obligated to use personal information only as necessary to perform services on our behalf and to maintain appropriate security standards.

B. Client Platforms

When providing services, we access platforms owned by and on behalf of clients. Data within those platforms remains subject to the client's own privacy policies and end-user agreements.

C. Legal Requirements

We may disclose personal information if required to do so by law, regulation, court order, or governmental authority, or if we believe in good faith that such disclosure is necessary to protect our rights, your safety, or the safety of others.

D. Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of Atholm's assets, personal information may be transferred as part of that transaction. We will notify affected individuals prior to any such transfer where required by law.

Section 06

Cookies and Tracking Technologies

Our website may use cookies, web beacons, pixels, and similar technologies to collect information about your browsing behavior and improve your experience. Types of cookies we may use include:

• Essential cookies: Required for the website to function properly
• Analytics cookies: Help us understand how visitors interact with our site (e.g., Google Analytics)
• Marketing cookies: Used to deliver relevant content and track the effectiveness of our marketing efforts

You may control cookie preferences through your browser settings. Disabling certain cookies may affect website functionality. For opt-out options related to Google Analytics, visit: tools.google.com/dlpage/gaoptout.

Section 07

Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, to maintain accurate business records, and to comply with applicable legal obligations. Specific retention periods include:

• Client contact and project records: retained for a minimum of five (5) years following the conclusion of an engagement
• Billing and financial records: retained for a minimum of seven (7) years in accordance with applicable tax and accounting requirements
• Marketing communications opt-in records: retained for the duration of the relationship plus three (3) years
• Website analytics data: retained in accordance with the settings configured in our analytics platform

When personal information is no longer required, we take reasonable steps to securely delete or anonymize it.

Section 08

Data Security

Atholm implements reasonable and appropriate technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Use of secure, encrypted connections (HTTPS/TLS) for data transmission
• Access controls limiting personal data access to authorized personnel only
• Use of reputable, security-compliant third-party platforms for data storage and processing
• Regular review of security practices and vendor security standards

No method of electronic transmission or storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security. In the event of a data breach that affects your personal information, we will notify you as required by applicable law.

Section 09

Your Privacy Rights Under New Jersey Law

Atholm operates under the laws of the State of New Jersey. Residents of New Jersey may have the following rights regarding their personal information:

To exercise any of these rights, please contact us using the information in Section 15. We will respond to verifiable requests within forty-five (45) days. We may need to verify your identity before processing your request.

Section 10

Children's Privacy

Atholm's services are intended for business clients and are not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a minor, we will take steps to delete such information promptly. If you believe we have collected information from a minor, please contact us immediately.

Section 11

Third-Party Links and Platforms

Our website and service deliverables may contain links to third-party websites, platforms, and tools including Google, Meta, SEMrush, OpenAI, Anthropic, and others. Atholm is not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access through or in connection with our services.

Section 12

Use of Artificial Intelligence Tools

In delivering certain services, Atholm may utilize AI-powered tools and large language model platforms including OpenAI's ChatGPT, Anthropic's Claude, and Google Gemini. Our commitments when using these tools:

We are committed to using AI tools responsibly and in a manner consistent with our confidentiality obligations to clients.

Section 13

Governing Law and Jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of the State of New Jersey, without regard to conflict of law principles. Any disputes arising out of or related to this Privacy Policy shall be subject to the exclusive jurisdiction of the state and federal courts located in New Jersey. Both parties consent to personal jurisdiction in such courts.

Section 14

Changes to This Privacy Policy

Atholm reserves the right to update this Privacy Policy at any time to reflect changes in our practices, services, or applicable law. When we make material changes, we will update the Effective Date at the top of this Policy and, where appropriate, notify clients by email. Your continued use of our services following notice of changes constitutes your acceptance of the updated Policy.

Section 15

Contact Us

If you have questions, concerns, or requests related to this Privacy Policy or the handling of your personal information, please contact us. We take all privacy inquiries seriously and will respond within forty-five (45) days of receipt.