July 18, 2024

Privacy Statement

Protecting your personal data is our priority. This Privacy Statement applies to NOW CFO, LLC and each of its subsidiaries and affiliates (“NOW CFO”, “we”, “us”, or “our”) and our websites and online services and describes how we handle personal data and the choices available to you regarding collection and use of personal data.  This Privacy Statement is not a contract and does not create any legal rights or obligations.

We may update this Privacy Statement from time to time.  The date of the current Privacy Statement is listed at the top of the Privacy Statement.

Collection of Personal Data

NOW CFO’s customers are generally businesses.  As a result, we largely collect non-personal, business data.  Still there is personal data related to the individual that is acting for the business.  There is also personal data related to individuals that are acting for themselves, as individuals.  This Privacy Statement applies to this personal data.

We collect personal data from you and about you in various contexts.  These contexts may be categorized in terms of engaging in a services agreement (the “Services”), marketing and sales activities (“Marketing”), and your interactions with our online services, including our website (the “Online Activities”), which are described, in turn, below.

Services

In connection with the signing of a services agreement, we may collect personal data about you, including name, title, company, address, email address, phone number, and in some cases other categories of personal data such as payment card information.

Marketing

We may ask you for and collect personal data in connection with our marking activities, including when you enter personal data into an intake form, survey, or other questionnaire (including intake call, chat, or other communication).  We may collect personal data (such as name, title, company, address, email address, phone number, and services/products of interest) you provide to us during these marketing activities.

In some cases, we may monitor or record certain communications (including through the use of automated tools by us or our third-party providers).  We (and our third-party providers) may also collect information made publicly available through third-party platforms such as social media platforms, websites, online databases, or online directories.

Online Activities

When you interact with us online, including through our websites, we and our third-party providers may automatically collect certain information from your device and your browsing activities.  For example, we may collect IP addresses and other unique identifiers as well as certain device characteristics and metrics relating to your visit including operating system, device type and version, browser type and version, the URL entered and the referring page/campaign, date/time of visit, and other data including the time spent browsing.

We and our third-parties may also collect information automatically about the electronic path you take to our websites, through our websites, and when exiting the websites, as well as your usage and activity on our websites, such as the links an objects you view, click, or otherwise interact with (known as “clickstream data”).

We collect this personal data directly from you, from your browser or device when you interact with our website or our other online services, from third-parties, including our service providers, business partners, channel partners, and from public third-party platforms such as social media websites, online databases or online directories.

With regard to the categorization of personal data, we collect the following categories of personal data:

• Identifiers, such as first and last name, IP address and other unique identifiers;
• Customer Records, such as address, telephone number, email address, and payment card information;
• Commercial Information, such as product or service interests and orders;
• Internet/Network Information, such as log file data (including IP address, browser type) and clickstream data (including your usage and activity on our online website platforms);
• Geolocation Data, such as general geographic location based on IP address;
• Sensory Information, such as audio recordings, photograph, and video recordings you choose to provide, or we otherwise record as permitted by law;
• Professional/Employment Information, such as job title, company and industry;
• Other Personal Data, such as entries to promotions, comments in response to surveys or other inquiries, and requests or comments an individual chooses to send us; and
• Inferences, such as deriving sales recommendations from other personal data we have collected.

 

Use of Your Personal Information

We use personal data from you for a variety of purposes.  For example, we use personal data to communicate with you, to facilitate the provision of services to you, to facilitate the billing and payment for services rendered to you, to analyze and improve your experience with us, to analyze and improve the use of our website and other online services, and to deliver marketing communications and personalized and non-personalized advertising.

NOW CFO’s primary goal in collecting personal data is to facilitate an engagement for providing services to you, provide services to you within an engagement, to communicate with you regarding business matters associated with the engagement, to provide you with a better customer experience during the engagement, to enable us to contact you if a problem arises with an engagement, and to contact you if there is some other need to reach you.  Similarly, we use personal data necessary to complete payment transactions related to the services provided in an engagement.  In addition, we use the information you provide to help us improve the customer experience through an engagement and to improve the services provided in an engagement.  We may also match personal data with third-party data to help us better understand our clients.

We and our third-party providers use log data and clickstream data to measure the use of our websites and online services, as well as to improve the content of our sites. We and our third-party providers may also use this data for purposes of determining which products and services may be of interest to you, and to market to you based on those interests.

In order to collect log data and clickstream data, we and our third-party providers may use cookies (small data files that are stored on an individual’s computer or device) and other related technologies such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).  We may use third-party analytics tools such as Google Analytics to help us measure traffic, usage and activity trends for our websites and online services, and to better understand our user base and clients.

Regarding our legal basis for processing personal data, we process personal data:

• When it is necessary for the performance of any contractual relationship we may have with you, such as payment information where it is necessary to process a payment transaction with you;
• When it is necessary for us to comply with our legal obligations, such as tax reporting; or
• Where it is necessary for the purposes of the legitimate interests pursued by us, which are identified above, where those interests are not overridden by the interests or fundamental rights and freedoms of the data subject.

 

Sharing of Personal Data

We share personal data with our subsidiaries and related companies.  For example, in the context of a services engagement, personal data is shared with the relevant service partner that will be providing the services along with the accounting team that will be handling the billing and payments.

We may share your personal data with third-party service providers so that they may provide services to us that are consistent with the terms of this Privacy Statement (e.g., email services, time and project management, database management, communications monitoring, lead generation, and other services on our behalf).  We may also, on occasion, provide personal data to third-party businesses as part of a specific product, service, or promotion.

We share website usage information about visitors to our websites with third-party advertising companies for the purpose of personalizing future advertising campaigns and improving reporting statistics.

We may share your information with third-parties, such as legal advisors and law enforcement, in connection with the establishment, exercise, or defense of legal claims; to comply with laws and regulations or to respond to lawful requests and legal process; to protect our rights and property and the rights and property of our agents, clients, and others, including to enforce our agreement, policies, and Terms of Service; to detect, suppress, or prevent fraud; to reduce credit risk and collect debts owed to us; to protect the health and safety of us, our customers, or any person; as otherwise required by applicable law, court order, subpoena, or other legal process; or as requested by a governmental or law enforcement authority.  We may also disclose information about you to third parties with your consent.

We may also disclose or use personal data in connection with certain corporate business transactions, such as mergers and acquisitions.

We do not share or sell SMS opt-in, or phone numbers for the purpose of SMS.

Your Privacy Choices

• Right to Know: The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you, including:
  • The categories of personal data collected;
  • The categories of sources of the personal data;
  • The purposes for which the personal data were collected;
  • The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed;
  • The categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes; and
  • The categories of personal data sold (if any) and the categories of third parties to whom the personal data were sold.
• The Right to Access & Portability: The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• The Right to Correction: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
• The Right to Request Deletion: The right to have us delete the personal data we maintain about you.

Submitting Privacy Rights Requests

To exercise the Right to Know, Access, Correction, or Deletion, please submit a request indicating the right you wish to exercise by:

• Emailing your request to us at legal@nowcfo.com
• Calling us at (385) 377-4500

Before processing your request, we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s).  In order to verify your identity, we generally require matching of sufficient information you provide us to information we maintain about you in our systems.  As a result, we require request to include first and last name, email address, state of residency, and the data request.  At times, we may need to request additional personal data from you, taking into consideration our relationship with you and the sensitivity of your request.

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request or by calling (385) 377-4500.

How to Contact Us

If you have other questions, comments, or concerns about our privacy practices please contact us at legal@nowcfo.com or at the address below.

Legal -Data Protection Office
NOW CFO, LLC
210 North 2100 West,
Salt Lake City,
UT 84116

Email: legal@nowcfo.com