Marketer’s Privacy Policy

Revised 05/19/2026

Introduction

Infusion Strategies respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit this website and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.
  • In email, text, and other electronic messages between you and us.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at the email address below.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone numbers or any other identifier by which you may be contacted online or offline (“personal information”);
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking technologies.
  • From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does not include personal information, but it helps us improve our Website and deliver a better and more personalized service. The technologies we use for this automatic data collection may include cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To notify you about changes to our Website or any products or services we offer or provide through it.

Disclosure of Your Information

We may disclose personal information that we collect, or you provide as described in this privacy policy:

  • To fulfill the purpose for which you provide it.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, and in accordance with applicable contractual obligations (including partner data processing agreements), legal requirements, and our internal records retention policy (BMG-RD-POL-2025, aligned to ISO 27001:2022 Control A.5.33).

Data Category Retention Period Basis / Notes
Partner Data (PII)
Lead data, consumer records, unsubscribe lists, knockouts
Per applicable DPA terms; delete when no longer required for processing CCPA; Partner DPAs; BMG-DPP-POL-2025; BMG-RD-POL-2025 §4.1. Disposal requires CEO/President approval.
Transaction and service records Per applicable legal and tax requirements Applicable legal and tax record-keeping obligations. Overlapping sensitive PI retained for minimum necessary purposes only.
General communications and correspondence As required for the stated purpose; no longer than applicable DPA term Deleted when no longer required for processing or upon expiry of applicable agreement.
Website analytics
Cookies, IP, browsing behavior
Up to 13 months From date of collection unless a shorter period is required by law.
Sensitive personal information
CPRA Categories A & B
No longer than required by the applicable DPA or 24 months, whichever is shorter — unless legally required Used only for the minimum necessary purpose. Where overlap with legal retention obligations exists, sensitive PI is isolated from further commercial use. BMG-RD-POL-2025 §4.1.

Data Disposal and Deletion

After the applicable retention period, we will securely delete personal information using an encrypted wipe process. Evidence of deletion is retained in accordance with our internal data governance procedures. Where deletion is not immediately possible (for example, because information is stored in backup archives), we will isolate the information from further processing until deletion is possible. Anonymization may be used as an alternative to deletion where the resulting data can no longer be linked to an identifiable individual.

Retention Triggers for Partner Data (PII)

For Partner Data (PII), the following events determine when data is no longer required for processing and should be flagged for deletion review:

Expiry or termination of the applicable partner data processing agreement. When a partner DPA expires or is terminated, the associated consumer records are no longer required for the contracted processing purpose and should be reviewed for deletion unless another lawful basis for retention applies.

Unsubscribe and opt-out events. When a consumer submits an unsubscribe request or exercises their right to opt out of marketing communications, all active marketing to that consumer ceases immediately upon processing of the request. The consumer’s record is retained on a suppression/unsubscribe list only for as long as required under the applicable DPA and applicable law, and solely for suppression, compliance, and legal purposes — not for marketing.

No longer required for processing. Where data is no longer required to fulfill the purpose for which it was collected and no contractual, legal, or regulatory retention obligation applies, it is scheduled for secure deletion in accordance with BMG-RD-POL-2025 §4.1, subject to CEO/President disposal approval.

Choices About How We Use and Disclose Your Information

Tracking Technologies, Advertising, and Global Privacy Control

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

In addition, Infusion Strategies honors opt-out preference signals transmitted through the Global Privacy Control (GPC). When we detect a GPC signal from your browser, we will treat it as a valid opt-out request for the sale and sharing of your personal information and will process it accordingly. You do not need to submit a separate opt-out request if your browser is configured to send a GPC signal.

California residents may have additional personal information rights and choices as described in the California Privacy Notice section below.

Your California Privacy Rights

If you are a California resident, California law provides you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, please visit the California Attorney General’s privacy resources at https://oag.ca.gov/privacy.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page.

Privacy Notice for California Residents

Amended to Incorporate Rights Under the California Privacy Rights Act (CPRA)

This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA).

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We have collected the following categories of personal information from consumers within the last twelve (12) months:

  • Category A: Identifiers (e.g., name, postal address, email address, IP address, social security number, driver’s license number, passport number).
  • Category B: California Customer Records personal information categories (e.g., financial account information, credit card numbers).
  • Category F: Internet or other electronic network activity information (e.g., browsing history, interaction with our website).

Sensitive Personal Information (CPRA)

Under the CPRA, certain categories of personal information are designated as “sensitive personal information.” Where we collect sensitive personal information, we only use it for the purposes for which it was collected or as otherwise permitted by law. Categories of sensitive personal information that we may collect include:

  • Social Security numbers, driver’s license numbers, and passport numbers (Category A above).
  • Financial account information including bank account numbers, credit card numbers, and debit card numbers (Category B above).
  • Medical information and health insurance information, where applicable.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided.
  • To provide you with information, products, or services that you request from us.
  • To provide you with email alerts and marketing communications (subject to your opt-out rights).
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
  • To improve our website and present its contents to you.
  • For testing, research, analysis, and product development.
  • As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
  • Third-party marketers who offer products or services that may be of interest to you, subject to your right to opt out of such sharing as described below.

Sale or Sharing of Personal Information

In the preceding twelve (12) months, we have sold or shared personal information as described above. Under the CPRA, consumers have the right to opt out of the sale or sharing of their personal information, including sharing for cross-context behavioral advertising purposes.

To exercise your right to opt out, please see the “Your Rights and Choices” section below and submit a request using our consumer rights request form and specifying your opt-out request type.

Your Rights and Choices

The CCPA, as amended by the CPRA, provides California consumers with the following rights:

1. Right to Know / Access and Data Portability

You have the right to request that we disclose information about our collection and use of your personal information over the past 12 months, including categories collected, sources, business purposes, third parties with whom it is shared, and the specific pieces of personal information we hold about you.

2. Right to Delete

You have the right to request that we delete personal information we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

3. Right to Correct Inaccurate Personal Information

Under the CPRA, you have the right to request that we correct inaccurate personal information that we maintain about you. Upon receipt of a verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate information as directed.

4. Right to Opt Out of Sale or Sharing

You have the right to direct us not to sell or share your personal information at any time, including sharing for cross-context behavioral advertising. To exercise this right, submit a request using the methods described below. Once you opt out, we will not sell or share your personal information unless you subsequently provide authorization.

5. Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to direct us to limit our use and disclosure of your sensitive personal information to only what is necessary to provide the services you requested. To exercise this right, submit a request using the contact methods described below.

6. Right of Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny goods or services, charge different prices, provide different quality of service, or suggest different treatment based on your exercise of privacy rights.

Exercising Your California Privacy Rights

To exercise any of the rights described above, please submit a verifiable consumer request using one of the following methods:

Authorized Agent Procedures

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. If you wish to designate an authorized agent, you must:

  1. Provide the authorized agent with written signed permission to submit the request on your behalf;
  2. Verify your own identity directly with us by providing the information described below; and
  3. Confirm with us that you have authorized the agent to act on your behalf.

For business agents, we may also require proof of registration with the California Secretary of State. We will process authorized agent requests within the same timeframe as direct consumer requests.

Verification and Response Timing

You may make a verifiable consumer request for access or data portability up to twice within a 12-month period. We will endeavor to respond within 45 days of receipt. If we require more time (up to 90 days total), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Contact Information

If you have questions about this privacy policy or wish to exercise your rights under California law, please contact us:

Effective as of May 19, 2026