Digital Boulevard, LLC (“Digital Boulevard,” “we,” “us” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information in connection with our website at digitalblvd.co, our Turnpike subscription growth marketing service, and our other marketing and professional services (collectively, the “Services”).

Digital Boulevard, LLC is a Texas limited liability company located at 12848 Queensbury Lane, Suite 208, Houston, Texas 77024.

Please read this Policy carefully. By using our website or the Services, you acknowledge that you have read and understood this Policy. If you do not agree with our practices, please do not use the Services.

1.  SUMMARY OF KEY POINTS

This summary highlights the points people ask about most. It is not a substitute for the full Policy, and each item links to the section that explains it in detail.

·  We act in two different roles. For our website and our own client relationships we decide how data is used. For data inside our clients’ advertising accounts we act on our client’s instructions only. See Sections 2 and 9.

·  We collect information you give us, information collected automatically when you visit our site, and information from advertising and analytics partners. See Sections 3 through 5.

·  We use advertising and retargeting technologies. Under some state laws this counts as “selling” or “sharing” your information, and you can opt out. See Sections 7 and 8.

·  We honor Global Privacy Control. If your browser sends a recognized opt-out signal, we treat it as an opt-out request. See Section 8.3.

·  We do not sell sensitive or biometric personal data. See Section 13.

·  We do not knowingly collect information from anyone under 18. Turnpike is a business service. See Section 17.

·  You have rights over your information, including access, correction and deletion, depending on where you live. See Sections 11 through 14.

·  You can reach us about privacy at [privacy@digitalblvd.co]. See Section 19.

2.  OUR TWO ROLES: CONTROLLER AND SERVICE PROVIDER

Understanding which role we are playing determines which parts of this Policy apply to you.

2.1  As a controller.  When we operate digitalblvd.co, market our services, respond to inquiries, onboard and bill subscribers, and manage our own business records, we determine the purposes and means of processing. We are a “controller” under the EU and UK General Data Protection Regulation and a “controller” or “business” under United States state privacy laws. Sections 3 through 8 and 11 through 18 describe this role.

2.2  As a service provider or processor.  When we manage advertising accounts for a Turnpike client, we handle personal information that belongs to that client — including customer lists, conversion data and audience data inside their advertising platforms. In that context our client is the controller or business, and we act as a “service provider” or “processor.” We process that information only on our client’s documented instructions. Section 9 describes this role.

2.3  If you are an individual whose data one of our clients advertises to.  We are not the right party to contact. Your relationship is with the business that collected your information. Please direct your request to that business. If you contact us and we can identify the relevant client, we will forward your request to them and let you know we have done so.

3.  INFORMATION WE COLLECT

3.1  Information you provide to us.  We collect information you submit directly, including:

(a)  Contact and identity information —  name, business email address, telephone number, company name, job title, and mailing address.

(b)  Account information —  the credentials and preferences associated with your Turnpike subscription, and the identity of the authorized representative you designate.

(c)  Billing information —  billing address, taxpayer or exemption status, and the last four digits and expiration date of your payment card. Full payment card numbers are collected and stored by our payment processor, not by us. See Section 6.2.

(d)  Commercial information —  subscription history, service records, and records of pauses, cancellations and support interactions.

(e)  Content you send us —  the substance of Requests, briefs, emails, messages in our intake channel, call notes, survey responses, and any files or materials you upload.

(f)  Recruiting information —  if you apply to work with us, your resume, work history and any information in your application.

3.2  Information collected automatically.  When you visit our website, our partners and we automatically collect:

(a)  Device and connection data —  IP address, browser type and version, operating system, device identifiers, screen resolution, language and time zone.

(b)  Usage data —  pages viewed, time on page, scroll depth, referring and exit pages, links and buttons clicked, form interactions, and the dates and times of your visits.

(c)  Advertising identifiers —  cookie identifiers and pixel data used to measure campaign performance and to deliver advertising to you on other websites and platforms.

Section 5 describes the technologies used to collect this information.

3.3  Information from third parties.  We may receive information about you from:

(a)  advertising and analytics providers, including Google, Microsoft, Meta, LinkedIn and Reddit, which provide us with campaign performance, audience and attribution data;

(b)  our customer relationship management, email and scheduling tools;

(c)  our payment processor, which confirms transaction status and provides limited card metadata;

(d)  publicly available sources and business data providers, which we use for prospecting and to verify business details; and

(e)  referral sources, partners and individuals who refer you to us.

3.4  Information we do not want.  Please do not send us government-issued identification numbers, financial account credentials, health information, biometric data, precise geolocation, or information about criminal history. We do not need this information to provide the Services and we ask that you not provide it. If you send it to us anyway, we will delete it when we identify it.

4.  HOW WE USE INFORMATION

We use the information described above for the following purposes:

(a)  To provide the Services —  to set up and administer your subscription, receive and work Requests, deliver work product, communicate with you, and provide support.

(b)  To bill and collect —  to process recurring payments, calculate and remit applicable taxes, issue receipts, and pursue overdue amounts.

(c)  To operate and improve —  to understand how our website and Services are used, diagnose technical problems, develop new offerings, and improve quality.

(d)  To market —  to send you information about our services, publish case studies and portfolio material subject to the Turnpike Master Services Agreement, run advertising campaigns, measure their performance, and build audiences for advertising.

(e)  To secure —  to protect against fraud, unauthorized access, abuse of the Services, and other security incidents.

(f)  To comply and enforce —  to meet our legal, tax and accounting obligations, respond to lawful requests, establish or defend legal claims, and enforce our agreements.

(g)  To create aggregated and de-identified data —  to produce benchmarks, industry insights and internal analytics. We do not attempt to re-identify de-identified data and will not present it in a manner that could reasonably identify any individual or client.

(h)  With your consent —  for any other purpose we describe to you at the time we ask.

5.  COOKIES AND SIMILAR TECHNOLOGIES

5.1  What we use.  We and our partners use cookies, pixels, tags, software development kits, local storage and server logs. These technologies fall into four categories:

(a)  Strictly necessary —  required to operate the site, maintain security, and remember your privacy choices. These cannot be disabled through our preference tool.

(b)  Functional —  remember your settings and preferences to improve your experience.

(c)  Analytics and performance —  help us understand traffic, engagement and site performance.

(d)  Advertising and targeting —  set by us or our advertising partners to measure campaigns and deliver relevant advertising to you on other sites and platforms. These are the technologies that may constitute a “sale” or “share” under state law.

5.2  Managing cookies.  You can manage non-essential cookies through the cookie preference tool available on our website, and through your browser settings. Blocking cookies may cause parts of the site to stop working as intended. Because these technologies are set on a per-browser and per-device basis, you will need to set your preferences on each browser and device you use.

5.3  Do Not Track.  Our website does not respond to browser “Do Not Track” signals, because no common standard for those signals has been adopted. We do respond to Global Privacy Control and other recognized universal opt-out signals as described in Section 8.3.

6.  HOW WE DISCLOSE INFORMATION

We do not sell personal information for money. We disclose personal information in the following circumstances:

6.1  Service providers.  We share information with vendors that perform functions on our behalf and are contractually restricted from using it for their own purposes, including hosting and cloud infrastructure, email and communications, project and task management, customer relationship management, analytics, accounting and bookkeeping, and professional advisors.

6.2  Payment processing.  Payments are processed by a third-party payment processor. We do not collect or store full payment card numbers. The processor handles your card data under its own privacy policy and applicable card network rules.

6.3  Advertising and analytics partners.  We share online identifiers and usage data with advertising and analytics platforms so that they can measure our campaigns and show you our advertising elsewhere. These partners may act as independent controllers of that data under their own policies. See Sections 7 and 8.

6.4  Design agents and contractors.  We may engage independent specialists to help deliver the Services. They are bound by confidentiality obligations and may access information only as needed to perform their work.

6.5  Business transfers.  If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business, personal information may be transferred as part of that transaction. We will notify you of any such transfer and of any material change to this Policy that results.

6.6  Legal and safety.  We may disclose information where we believe in good faith it is necessary to comply with law, a subpoena or other legal process; to respond to a lawful government request; to enforce our agreements; to investigate suspected fraud or abuse; or to protect the rights, property or safety of Digital Boulevard, our clients or the public.

6.7  With your direction.  We disclose information to any other party when you ask or authorize us to.

7.  ADVERTISING AND RETARGETING

7.1  What we do.  We advertise our services on Google, Microsoft, Meta, LinkedIn, Reddit and other platforms. We use pixels and tags on our website so that these platforms can measure which advertisements led to visits, form fills and subscriptions, and so that we can show advertising to people who have visited our site or who resemble our existing clients.

7.2  Why this matters legally.  Several United States state privacy laws define the disclosure of online identifiers to advertising platforms for cross-context behavioral advertising as a “sale” or “sharing” of personal information, even though no money changes hands. On that basis, we disclose that we “share” personal information — specifically, identifiers, internet activity data and inferences — with advertising partners for targeted advertising. Section 8 explains how to opt out.

7.3  Platform controls.  You can also limit advertising through controls each platform provides, including Google Ads Settings, Meta Ad Preferences, LinkedIn Ad Preferences, and the opt-out tools operated by the Digital Advertising Alliance at optout.aboutads.info and the Network Advertising Initiative at optout.networkadvertising.org.

8.  YOUR CHOICES AND OPT-OUTS

8.1  Opt out of targeted advertising, sale and sharing.  You may opt out of our use of your information for targeted advertising and of any disclosure that constitutes a sale or sharing by using the “Do Not Sell or Share My Personal Information” link on our website, by adjusting your cookie preferences through our preference tool, or by emailing us at [privacy@digitalblvd.co].

8.2  Marketing emails.  You may unsubscribe at any time using the link in any marketing email or by contacting us. We will still send you transactional and administrative messages about your subscription, billing and this Policy, and you cannot opt out of those while you remain a client.

8.3  Global Privacy Control and universal opt-out signals.  We recognize and honor the Global Privacy Control signal and other universal opt-out mechanisms recognized under applicable state law. If your browser or extension transmits a recognized signal, we treat it as a valid request to opt out of the sale and sharing of personal information and of targeted advertising for that browser and device. Where required, we will display a notice on our website confirming that we have honored the signal. Because the signal is browser- and device-specific, you will need to enable it on each browser and device you use.

8.4  Authorized agents.  You may use an authorized agent to submit an opt-out or rights request on your behalf. We may require proof of the agent’s authority and may require you to verify your own identity directly.

9.  CLIENT DATA: OUR ROLE AS A SERVICE PROVIDER

This Section applies to personal information that belongs to our clients and that we handle in the course of delivering Turnpike.

9.1  Our commitments.  When we process client data we will: process it only on the client’s documented instructions and as necessary to perform the Services; not sell it; not share it for cross-context behavioral advertising; not retain, use or disclose it for any purpose other than performing the Services, except as permitted by applicable law; and not combine it with personal information received from other sources, except to produce aggregated, de-identified benchmarks as described in Section 4(g).

9.2  The client’s responsibilities.  Our clients are responsible for the lawfulness of the data they provide and direct us to use. That includes providing required privacy notices, obtaining any required consent or legal basis, maintaining accurate opt-out and suppression lists, honoring universal opt-out signals on their own properties, and responding to requests from their own customers. This allocation is set out in Section 9 of the Turnpike Master Services Agreement.

9.3  Restricted data.  We do not accept protected health information, payment card data, financial account credentials, government-issued identifiers, biometric data, information about children, or other sensitive or special-category data. Our Services are not designed for and are not represented as compliant with HIPAA, PCI-DSS, GLBA or comparable regimes.

9.4  Onward transfers.  Where we engage a subprocessor to help deliver the Services, we impose obligations on that subprocessor that are at least as protective as those we owe our client, and we remain responsible for its performance.

9.5  Return and deletion.  On termination, we remove our access to client advertising accounts as described in the Turnpike Master Services Agreement, and we will return or delete client data on written request, except for copies retained in routine backups or as required by law.

9.6  Data Processing Addendum.  Clients that require a Data Processing Addendum, standard contractual clauses, or a security questionnaire may request one by contacting [privacy@digitalblvd.co]. Where a signed Data Processing Addendum is in place and its terms conflict with this Policy, the Addendum controls as to client data.

10.  DATA RETENTION

10.1  How long we keep information.  We retain personal information for as long as needed to fulfill the purposes described in this Policy, and afterward for the period required to satisfy our legal, tax, accounting and recordkeeping obligations, resolve disputes and enforce our agreements.

10.2  General periods.  As a general matter we retain account and billing records for seven (7) years after the end of the client relationship in order to meet tax and accounting requirements; work product and project communications for three (3) years after the end of the client relationship; marketing contact records until you unsubscribe or ask us to delete them, and then for a limited period to honor your suppression request; and website analytics and advertising data in accordance with the retention settings of the applicable platform.

10.3  Deletion.  When information is no longer needed, we delete it or de-identify it. Residual copies may persist in encrypted backups for a limited period before they are overwritten in the ordinary course.

11.  SECURITY

11.1  Our measures.  We maintain administrative, technical and physical safeguards appropriate to the nature of the information we handle, including access controls and least-privilege permissions, multi-factor authentication on business-critical systems, encryption in transit, vendor diligence, and confidentiality obligations for personnel and contractors.

11.2  Limits.  No method of transmission or storage is completely secure. We cannot guarantee absolute security, and you transmit information to us at your own risk. If you believe your interaction with us is no longer secure, contact us immediately at [privacy@digitalblvd.co].

11.3  Your role.  You are responsible for maintaining the confidentiality of any credentials you use to access the Services, for controlling who within your organization has access to your advertising accounts, and for notifying us promptly of any suspected unauthorized access.

12.  YOUR PRIVACY RIGHTS — UNITED STATES

12.1  Where these rights apply.  Comprehensive privacy laws are in effect in twenty states, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia. The rights available to you depend on your state of residence and on whether the applicable law covers our processing.

12.2  Your rights.  Subject to your state’s law and applicable exceptions, you may have the right to:

(a)  confirm whether we process your personal information and access it;

(b)  obtain a copy of your personal information in a portable format;

(c)  correct inaccuracies in your personal information;

(d)  delete personal information you provided or that we obtained about you;

(e)  opt out of targeted advertising, of the sale of personal information, and of certain profiling in furtherance of decisions producing legal or similarly significant effects;

(f)  limit the use and disclosure of sensitive personal information, where applicable;

(g)  obtain a list of the third parties to whom we have disclosed personal information, in states that provide this right; and

(h)  not be discriminated against or retaliated against for exercising any of these rights. We will not deny you services, charge you a different price, or provide a different level of quality because you exercised a privacy right.

12.3  How to submit a request.  Email [privacy@digitalblvd.co] with the subject line “Privacy Rights Request,” or write to us at the address in Section 19. Tell us which right you wish to exercise and the state in which you reside.

12.4  Verification.  We will take reasonable steps to verify your identity before acting on a request, typically by matching information you provide against our records or by confirming control of the email address associated with your information. We may decline to act on a request we cannot verify. We do not use verification information for any other purpose.

12.5  Timing.  We will respond within forty-five (45) days. Where permitted, we may extend that period by an additional forty-five (45) days and will tell you if we do. We may charge a reasonable fee or decline requests that are manifestly unfounded, excessive or repetitive, and will explain our reasons if we do.

12.6  Appeals.  If we decline your request, you may appeal by replying to our response or emailing [privacy@digitalblvd.co] with the subject line “Privacy Rights Appeal.” We will respond to your appeal within sixty (60) days with a written explanation of our decision. If we deny your appeal, you may contact your state attorney general to submit a complaint. We will provide the relevant contact method in our appeal response.

13.  ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

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13.1  Categories of personal information.  The following table describes the categories of personal information we have collected in the preceding twelve months, using the categories defined in the California Consumer Privacy Act as amended.

If you need this Policy in an alternative accessible format, contact us, and we will provide one.

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13.2  Sources and purposes.  We collect these categories from the sources described in Section 3 and use them for the business and commercial purposes described in Section 4. We disclose them to the categories of recipients described in Section 6.

13.3  Sensitive personal information.  We do not collect, use, sell or share sensitive personal information for purposes that would require us to offer a right to limit its use under the CCPA.

13.4  No sale for monetary consideration.  We do not sell personal information for money, and we do not sell or share the personal information of consumers we know to be under sixteen (16) years of age.

13.5  Shine the Light.  California Civil Code section 1798.83 permits California residents to request information about disclosure of personal information to third parties for their direct marketing purposes. We do not make such disclosures. You may confirm this by contacting us.

13.6  Notice at collection.  This Policy, together with the notice presented on our website at or before the point of collection, serves as our notice at collection.

14.  ADDITIONAL DISCLOSURES FOR TEXAS RESIDENTS

14.1  Targeted advertising and sale.  Under the Texas Data Privacy and Security Act, we disclose that we process personal data for targeted advertising and that our disclosure of identifiers to advertising platforms may constitute a sale of personal data. You may opt out as described in Section 8.

14.2  Sensitive and biometric data.  We do not sell sensitive personal data and we do not sell biometric personal data. If that ever changes, we will post the notices required by Texas law in the same location and manner as this Policy before doing so.

14.3  Exercising your rights.  Texas residents may exercise the rights described in Section 12 by the methods described in Section 12.3, and may appeal a denial as described in Section 12.6.

15.  ADDITIONAL INFORMATION FOR THE EEA, UK AND SWITZERLAND

15.1  Legal bases.  Where the EU or UK General Data Protection Regulation applies, we process personal data on the following legal bases: performance of a contract, for the information we need to provide the Services and administer your subscription; legitimate interests, for marketing to business contacts, securing our systems, improving the Services and pursuing claims, where those interests are not overridden by your rights; consent, for non-essential cookies, advertising technologies and marketing emails where consent is required, which you may withdraw at any time without affecting prior processing; and legal obligation, for tax, accounting and compliance recordkeeping.

15.2  Your rights.  Subject to applicable law, you have the right to access your personal data; to rectify inaccurate data; to erase data; to restrict processing; to data portability; to object to processing based on legitimate interests, including direct marketing; and to withdraw consent. You also have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. We do not make such decisions.

15.3  How to exercise.  Contact [privacy@digitalblvd.co]. We will respond within one (1) month, which we may extend by two (2) further months for complex requests, and will tell you if we do.

15.4  International transfers.  We are located in the United States and our service providers are primarily located in the United States. When we transfer personal data out of the EEA, the United Kingdom or Switzerland, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum, together with supplementary measures where appropriate. You may request a copy of the relevant safeguards by contacting us.

15.5  Complaints.  You have the right to lodge a complaint with your local supervisory authority, or with the UK Information Commissioner’s Office if you are in the United Kingdom. We would appreciate the opportunity to address your concern before you do.

15.6  Representative.  We have not appointed an EU or UK representative under Article 27 because we do not currently target the EEA or UK market. If that changes, we will update this Policy and provide the representative’s contact details.

16.  OTHER STATE AND REGIONAL DISCLOSURES

16.1  Nevada.  Nevada residents may submit a verified request directing us not to sell certain covered information. We do not sell covered information as defined by Nevada law, but you may submit a request to [privacy@digitalblvd.co].

16.2  Colorado, Connecticut and other opt-out states.  Residents of states requiring recognition of universal opt-out mechanisms may exercise their opt-out rights through the signal described in Section 8.3 or through the methods in Section 8.1.

16.3  Canada.  If you are in Canada, you may have rights under the Personal Information Protection and Electronic Documents Act and comparable provincial laws, including access and correction rights. Contact us to exercise them.

17.  CHILDREN’S PRIVACY

The Services are business-to-business services intended for organizations and the professionals who work for them. The Services are not directed to individuals under eighteen (18) years of age, and we do not knowingly collect personal information from anyone under 18. We do not knowingly sell or share the personal information of anyone under 18. If we learn that we have collected information from a person under 18, we will delete it promptly. If you believe a minor has provided us with information, contact [privacy@digitalblvd.co] and we will investigate.

18.  THIRD-PARTY WEBSITES AND ADDITIONAL TERMS

18.1  Third-party sites.  Our website and communications may link to sites we do not control. This Policy does not apply to those sites, and we are not responsible for their content or privacy practices. Review the privacy policy of any site you visit.

18.2  Relationship to the Master Services Agreement.  If you are a Turnpike client, this Policy supplements the Turnpike Master Services Agreement. Where this Policy conflicts with a signed Data Processing Addendum as to client data, the Addendum controls. Where it conflicts with the Master Services Agreement on any other matter, the Master Services Agreement controls.

18.3  Changes to this Policy.  We may update this Policy from time to time. We will revise the “Last Updated” date at the top and, where the change is material, provide additional notice by email or a prominent notice on our website before the change takes effect. Your continued use of the Services after the effective date constitutes acceptance of the updated Policy. Please review it periodically.

19.  HOW TO CONTACT US

For questions, requests, or complaints about this Policy or our privacy practices:

Digital Boulevard, LLC

Attn: Privacy

12848 Queensbury Lane, Suite 208

Houston, Texas 77024

Email: [hello@digitalblvd.co]

Web: digitalblvd.co

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If you need this Policy in an alternative accessible format, contact us, and we will provide one.

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