Austley Privacy Policy

General

We at Austley ("Austley," "we," "our," or "us") respect your privacy. This Privacy Policy ("Policy") explains how we collect, use, and disclose information from and about you ("your information") that we receive in the ways specified below.

Austley provides marketing and communications consulting services, including AI enablement, full-service marketing and communications support, and coaching for individual marketing professionals (the "Austley Services"). We work with business clients and individual clients ("Clients").

We collect information when individuals visit and interact with austley.com (the "Site") and when Clients engage with us or use the Austley Services. The Site and the Austley Services are collectively referred to as the "Services." How we collect your information and what information we collect depends on how you interact with the Services.

Austley is the controller of information collected from visitors to the Site and from Clients when they interact with Austley or Austley's Services.

By using or otherwise interacting with us, you acknowledge that we will collect, use, and disclose your information as described in this Policy.

Please read this Policy carefully. If you do not agree to this Policy, please do not use our Services.

Types of Information We Collect

We collect information that you provide to us, information that we collect automatically, and information from other sources.

Information You Provide to Us

We collect information you provide to us depending on how you use the Services — for example, when you fill out a contact form, book a discovery call, sign up for our newsletter, engage us for services, or contact us for support. This information may include:

• Contact information such as your name, company name and details, mailing address, email address, phone number, and country of residence.
• Commercial information, including billing and financial information necessary to process payments for engagements (such as billing address and payment details). Payment processing is handled by third-party payment processors; we do not store full credit card numbers on our systems.
• Engagement information including messages you send to us, materials you share with us as part of a consulting engagement, and recordings or notes from client calls (with your consent where required).
• Any other information you provide to us, such as survey responses, feedback, or content you submit to The MarComm Grind community.

You can choose not to provide us with certain information, but you may not be able to engage our Services or access all features of the Site.

Information We Collect Automatically

When you interact with the Services, we may automatically collect information about your browser, device, and use of the Services, including IP address, approximate location, information about your activity on the Services (such as page views and features you use), device type, browser type, operating system and version, the web page you were visiting before you came to the Site, information you search for on the Site, locale preferences, date and time stamps associated with visits, and metadata about your interactions.

Some of this data is collected using cookies and similar technologies. To learn more about these technologies and your choices regarding them, please see the section below titled "Your Choices and Rights."

Information From Other Sources

We may collect information about you from publicly and commercially available sources, as permitted by law, including publicly available directories, social media platforms (such as LinkedIn), referral partners, and business partners.

How We Use Your Information

We may use your information for the following purposes:

• To provide and improve the Services;
• To respond to your inquiries, schedule consultations, and provide client support;
• To communicate with you about the Services and to provide updates, offers, and other information related to our work (subject to your preferences and applicable law);
• To market our Services to you, including through email, social media, and other channels (subject to your preferences and applicable law);
• To analyze and research how the Services are used and to develop new offerings;
• To prevent fraud and protect the security and integrity of the Services, and to protect the rights, safety, and property of Austley, our Clients, and others;
• To enforce our policies, including this Policy and our engagement agreements;
• To comply with legal obligations, including applicable laws, regulations, and legal process (such as subpoenas, warrants, or preservation requests); and
• For any other purpose, with your consent.

We may aggregate, de-identify, or anonymize information collected through the Services so that it is no longer reasonably capable of being associated with you. We may use and share aggregated or anonymized information for any purpose, at our discretion.

Our legal bases for processing your information are as follows:

• Performance of contract — where use of your information is necessary to perform our obligations under an engagement agreement or other commitment to you.
• Legitimate interests — where use of your information furthers our legitimate interests or those of others, such as operating our business, marketing our services, securing our systems, and preventing fraud.
• Compliance with legal obligations — where we use your information to comply with applicable laws, such as tax and accounting requirements.
• Consent — where you have consented to our processing of your information for a particular purpose.

We may combine information collected through the Services with information from other sources and use the combined information in accordance with this Policy.

How We Share Your Information

We may share your information under the following circumstances:

• Internally — with personnel and contractors of Austley as necessary to operate our business and deliver the Services.
• Service providers — with third parties that work on our behalf to help us operate our business and deliver the Services, including, without limitation: payment processing, email and CRM platforms, website hosting and analytics, scheduling tools, document storage, legal or accounting services, and marketing platforms. Service providers must comply with this Policy and may only use your information to provide services to us.
• Affiliates and partners — with referral partners or collaborators where you have engaged with them in connection with our Services.
• As required or permitted by law — to comply with legal process or to protect the rights, safety, or property of Austley, our Clients, or others.
• Business transactions — if we sell, transfer, or merge some or all of our business or assets, your information may be transferred as part of that transaction.
• With your consent — when you have given us permission to share your information.

Please note that if you choose to share your information publicly (for example, in a post on The MarComm Grind community or in a public comment on our content), that information will be visible to others.

Your Choices and Rights

Marketing Emails

You may opt out of our marketing emails at any time by clicking the "unsubscribe" link in any marketing email. Even if you unsubscribe, we may still send you transactional or administrative messages related to your engagement with us, such as invoices, project updates, or responses to your inquiries.

Cookies and Similar Technologies

When you interact with the Services, we (and third parties acting on our behalf) automatically collect certain information through cookies, pixel tags, web beacons, local storage, and similar technologies. Cookies are small text files stored on your browser or device that allow us to provide certain features, personalize your experience, and understand how our Site is used.

Your web browser may allow you to manage cookies. Each browser is different, so please follow the instructions in your browser's help section. If you delete or disable cookies, some parts of the Services may not work properly.

"Do Not Track" Signals

"Do Not Track" ("DNT") is a setting offered by some browsers. DNT signals are not yet uniform across browsers, so we, like many website operators, do not currently respond to DNT signals.

Your Rights

Depending on your jurisdiction of residence, you may have the right to request:

• Access to, a copy of, and information about our processing of your information;
• Correction of inaccuracies in your information;
• Deletion of your information, subject to any legal or other obligations we have to retain certain information; and
• Restriction of or objection to our processing of your information in certain circumstances.

These rights are subject to applicable exceptions, and we will need to verify your identity before processing your request. To submit a request, please contact us using the methods in the "Contacting Us" section below.

If you are a resident of the European Economic Area ("EEA"), the United Kingdom, or California, please see the sections below for additional rights that may apply to you.

Third-Party Links and Content

The Services may contain links to third-party websites, content, or services (for example, links to scheduling tools, payment processors, or social media platforms). When you interact with third-party content or visit a third-party website, you are providing information directly to those third parties. Their use of your information is governed by their own privacy policies, not ours. We encourage you to read those policies before sharing information with any third party.

Retention

We retain your information for as long as necessary to provide our Services, comply with our legal obligations, resolve disputes, and enforce our agreements. Retention periods are determined based on the type of information collected and the purpose of collection. In general, personal information related to Clients will be retained for the duration of the engagement and for a period of up to seven (7) years following the end of the engagement, consistent with applicable tax and recordkeeping requirements.

Security

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your information. However, no security measures are perfect, and there is always some risk in transmitting information over the internet. We cannot guarantee the security of your information, and you transmit it to us at your own risk.

You can help prevent unauthorized access to your information by protecting your account credentials (where applicable) and limiting access to your devices.

Children's Privacy

The Services are not intended for children under the age of 18. We do not knowingly collect personal information from children under the age of 18. If we learn that a child has provided us with personal information, we will delete it in accordance with applicable law. If you believe a child has provided us with personal information without parental consent, please contact us at privacy@austley.com.

Notice to Non-U.S. Users and Consent to Transfers

Austley is based in the United States, and we process your information in the United States, where privacy laws may differ from those in your jurisdiction. By using the Services, you understand and agree to the transfer of your information to the United States and to the processing of that information as described in this Policy.

Where required by law, we will use appropriate safeguards for transferring data from the EEA or UK, including signing Standard Contractual Clauses ("SCCs") where applicable.

Notice to EEA and UK Residents

You have the right to lodge a complaint with a data protection supervisory authority in the EU Member State where you reside or work, or where you believe an infringement has occurred. We encourage you to contact us first so we can work to address your concern directly.

Notice to California Residents

If you are a California resident, the California Consumer Privacy Act ("CCPA") provides you with additional rights regarding our collection, use, and sharing of your personal information.

Categories of Personal Information We Collect

We collect the following categories of personal information, as described in the "Types of Information We Collect" section above:

• Identifiers (such as name, address, IP address, and email address);
• Commercial information (such as services purchased or considered);
• Payment information;
• Internet or other electronic network activity information (such as browsing history and interactions with our Services);
• Location data (approximate location based on IP address);
• Audio information (notes or recordings from client calls, where applicable and with consent); and
• Inferences drawn from the above.

How We Use and Share These Categories of Personal Information

We use the above categories of personal information for the purposes listed in "How We Use Your Information," and we disclose your information to third parties as described in "How We Share Your Information."

Your CCPA Rights

California residents (or their authorized representatives) have the right to request access to, correction of, or deletion of their personal information, subject to certain exceptions under California law. We will verify your identity before responding to a request. We will not discriminate against you for exercising your rights.

Shine the Light Disclosure

The California "Shine the Light" law gives California residents the right to request information about how we share certain categories of personal information with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

Changes to this Policy

We reserve the right to amend or update this Policy from time to time. If we make material changes, we will notify you as required by law. Please check this Policy periodically for updates. The most recent revision will be reflected in the "Last Modified" section below.

Contacting Us

If you have any questions or concerns about this Policy or your rights, please contact us:

By email: privacy@austley.com