Privacy Policy
This Privacy Policy explains how Integrity Agency (“Integrity Agency,” “we,” “us,” or “our”) collects, uses, discloses, stores, and otherwise processes personal information in connection with integrityagency.io and related properties (the “Site”), and in connection with private inquiries submitted through the Site. Integrity Agency operates as a private advisory and growth-infrastructure practice. Engagements are accepted by referral and invitation only. This Policy constitutes our notice at or before the point of collection for purposes of applicable U.S. state privacy laws.
1. Scope and Application
This Policy governs personal information collected through integrityagency.io, any subdomain, landing page, or hosted content operated by Integrity Agency, and through private inquiries, referrals, correspondence, or preliminary communications with our principals. It does not govern confidential information exchanged within an executed engagement, which is addressed by the engagement letter and associated confidentiality instruments.
2. Who We Are
Integrity Agency is a private advisory and growth-infrastructure practice. The controller responsible for personal information collected through the Site is Integrity Agency. Privacy questions may be directed to [email protected]. General correspondence may be directed to [email protected].
3. Information We Collect
We collect only what is necessary to evaluate an inquiry, conduct diligence on prospective counterparties, communicate with you, operate and secure the Site, and comply with our legal and professional obligations. Categories are set out below.
3.1 Information You Provide
When you submit a private inquiry or otherwise correspond with us, we may collect your name, title, company, entity of record, email address, phone number (if provided), referral source, and any additional context you or the referring party shares. Where you are referred by a third party, we may also receive information about the referral, the relationship, and the nature of the introduction.
3.2 Information Collected Automatically
We collect standard server logs, including IP address, user agent, referring URL, and device and session information, for security, diagnostic, and integrity purposes. These logs are not used for behavioral advertising or cross-context profiling.
3.3 Information from Third Parties
Where appropriate, we may collect publicly available information about you or your entity — including regulatory filings, press coverage, and professional biographical information — as part of our diligence in evaluating an inquiry.
4. Sources of Information
- directly from you or your representatives
- from a referring principal, investor, advisor, or counterparty
- automatically from your browser or device
- from publicly available and commercial sources used for diligence
5. How We Use Information
- to evaluate inquiries and determine whether to proceed to a preliminary conversation
- to conduct diligence on prospective counterparties, referrers, and principals
- to communicate with you in connection with an inquiry, referral, or engagement
- to administer, secure, and operate the Site
- to protect our rights, our principals, our clients, and our operations
- to comply with legal, regulatory, tax, and professional obligations
- to establish, exercise, or defend legal claims
We do not use inquiry submissions to populate marketing lists, behavioral advertising segments, lookalike audiences, or third-party retargeting campaigns.
6. Legal Bases (EEA / UK Visitors)
Where the General Data Protection Regulation or the UK GDPR applies, we process personal information on one or more of the following legal bases: (i) our legitimate interests in evaluating inquiries, conducting diligence, operating our practice, protecting our reputation and intellectual property, and securing the Site; (ii) the performance of, or steps preparatory to, an engagement; (iii) compliance with legal obligations; and (iv) your consent, where we ask for and obtain it, which you may withdraw at any time.
7. Automated Processing and AI
Submissions are reviewed personally by a senior principal. We do not make decisions about whether to accept or decline an inquiry through solely automated means that produce legal or similarly significant effects. Where we use software-assisted tools to route, tag, or organize correspondence, those tools support human decision-making. We do not use inquiry content, referral information, or any Client Confidential Information to train, fine-tune, evaluate, benchmark, or develop third-party artificial intelligence models, machine-learning systems, or competing advisory products.
8. Confidentiality of Inquiries
All inquiries, referrals, and preliminary communications are treated as confidential and are reviewed only by principals and designated staff. Submission of an inquiry does not create an advisory, contractual, or fiduciary relationship; a relationship is formed only upon execution of a written engagement letter. Where an engagement proceeds, the relationship is governed by a separately executed engagement letter and, where appropriate, mutual non-disclosure.
9. Cookies, Tracking, and Signals
The Site uses minimal, first-party technologies strictly necessary to render the Site, maintain session state, and preserve operational security. We do not deploy third-party advertising trackers, cross-site identifiers, behavioral profiling pixels, or lookalike-audience instruments. You may manage or disable cookies through your browser.
9.1 Do Not Track
Because no uniform standard has emerged, we do not currently respond differently to browser “Do Not Track” (DNT) signals. We do not engage in the cross-context behavioral advertising or tracking practices that DNT is intended to address.
9.2 Global Privacy Control
Where required by applicable law, we honor the Global Privacy Control (GPC) signal. When we detect a valid GPC signal from your browser, we treat it as an opt-out of any arrangement that could be characterized as a “sale” or “share” of personal information under U.S. state privacy law associated with that browser.
10. Sharing and Disclosure
We do not sell personal information for money, and we do not share personal information for cross-context behavioral advertising. We may disclose personal information in the following limited circumstances:
- to hosting, security, email, and operational service providers engaged under confidentiality obligations
- to professional advisers such as legal, tax, and financial counsel
- to regulators, courts, law enforcement, or governmental authorities where required by law, subpoena, or court order
- to a successor entity or counterparty in connection with a merger, acquisition, restructuring, financing, or sale of assets
- to a referring principal for purposes of confirming receipt and status of a referred inquiry
- where we reasonably believe disclosure is necessary to protect any person, prevent fraud, enforce our terms, or defend our rights
11. Unsolicited Communications
Integrity Agency does not receive services, vendor, or solicitation inquiries through the private inquiry form. Unsolicited commercial outreach directed to our personal or team inboxes is not invited and does not constitute a business relationship, and no conduct of Integrity Agency (including the display of email addresses on the Site) should be construed as consent to receive commercial, marketing, or recruiting communications. Information provided in unsolicited outreach may be retained or shared for security, fraud-prevention, and enforcement purposes.
12. Retention
Inquiry records are retained for up to twelve months unless a longer period is warranted by an active, concluded, or prospective engagement, by a legal hold, by a regulatory or professional obligation, or by the establishment, exercise, or defense of legal claims. You may request deletion of an inquiry record at any time by writing to [email protected], subject to our right to retain information we are legally required or permitted to retain.
13. Security and Breach Notification
Submissions are transmitted over HTTPS and stored on infrastructure operated by Cloudflare, Inc. Access is restricted to principals and designated staff under confidentiality obligations. We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a confirmed security incident affecting your personal information, we will notify affected individuals and applicable authorities as required by law.
14. International Transfers
Integrity Agency operates globally. If you access the Site or submit an inquiry from outside the United States, you understand that your personal information may be transferred to, stored in, and processed in the United States or other jurisdictions where we or our service providers operate. Data-protection laws in those jurisdictions may differ from those in your jurisdiction. Where required, we rely on appropriate transfer mechanisms, including the Standard Contractual Clauses and, as applicable, the UK International Data Transfer Addendum, together with supplementary technical, organizational, or contractual measures reasonably necessary to address identified risks. By using the Site or submitting an inquiry, you consent to such transfers.
15. Your Privacy Rights
Depending on your jurisdiction, you may have rights to:
- confirm whether we process your personal information
- access personal information we hold about you
- correct inaccurate personal information
- request deletion of personal information
- obtain a portable copy of certain personal information
- opt out of any arrangement that could be characterized as a sale or share
- opt out of targeted advertising (which we do not engage in)
- limit use of sensitive personal information
- withdraw consent where processing is based on consent
- appeal a denial of a rights request
15.1 How to Exercise Rights
To exercise any right, email [email protected] with the subject line “Privacy Request.” We respond within 45 days of a verifiable request, with one additional 45-day extension where reasonably necessary. We may need to verify your identity or your authority before responding. We will not discriminate against you for exercising a privacy right.
15.2 Authorized Agents
You may designate an authorized agent to submit a privacy request on your behalf. We may require the agent to provide signed written permission from you, and we may require you to verify your identity directly with us or confirm that you provided the agent with permission.
16. U.S. State Privacy Disclosures
Residents of U.S. states with comprehensive consumer privacy laws — including California (CCPA/CPRA), Colorado, Connecticut, Utah, Virginia, Oregon, Texas, Montana, Delaware, Iowa, Indiana, Tennessee, New Jersey, and others as enacted — may have rights to access, correct, delete, port, limit the processing of sensitive personal information, and opt out of targeted advertising, sale, or sharing. In the preceding twelve months, we have collected the categories of identifiers, professional or employment-related information, commercial information, and internet or network activity described in this Policy, for the business purposes stated here. We have not sold personal information for money and we have not shared personal information for cross-context behavioral advertising. We do not knowingly sell or share the personal information of consumers under sixteen years of age. California residents may request the categories and specific pieces of personal information we collected about them in the preceding twelve months by contacting [email protected].
17. California “Shine the Light”
California Civil Code § 1798.83 permits California residents to request information regarding the disclosure of personal information to third parties for their direct marketing purposes. Integrity Agency does not disclose personal information to third parties for their direct marketing purposes. California residents with questions may contact [email protected].
18. Sensitive Personal Information
Do not submit through the Site or ordinary email: government identification numbers (Social Security, passport, driver’s license), full financial account numbers, medical records, protected health information, precise geolocation, biometric or genetic data, racial or ethnic origin, religious beliefs, union affiliation, sexual orientation, or other categories classified as sensitive under applicable law. If a prospective engagement requires the handling of sensitive or regulated information, a separate written instrument will govern that handling.
19. Children’s Privacy
The Site is not directed to children under sixteen, and we do not knowingly collect personal information from children under sixteen. If we learn that we have collected such information without appropriate authorization, we will take reasonable steps to delete it.
20. Third-Party Links
The Site may reference or link to third-party publications, organizations, or platforms. Their privacy practices are governed by their own policies, which we do not control. Inclusion of such references does not imply endorsement or partnership unless expressly stated.
21. Changes to This Policy
We may update this Policy from time to time. The most current version is posted on this page and takes effect upon posting. Continued use of the Site or submission of an inquiry after an updated Policy is posted constitutes acceptance of the revised Policy.
22. Contact
For privacy matters: [email protected]. For general correspondence: [email protected]. Residents of jurisdictions with specific statutory rights (including the GDPR, UK GDPR, CCPA, and comparable state laws) may exercise those rights by writing to the privacy address.
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