Privacy Policy

1. Categories of Personal Information We Collect

The type of information we collect depends on your interaction with us. In the 12 months preceding the Last Updated date above, we have collected the following categories of personal information:

Contact Information

Full name, email address, mailing address, and telephone number.

Identifiers

Internet Protocol (IP) address, account usernames and passwords (where applicable), and electronic signatures.

Commercial Information

Records of Services purchased, requested, or considered, and your service history with us.

Internet or Electronic Usage Data

Website browsing and interaction history, IP address, cookie data, browser type and version, device identifiers, and interaction with our content or advertisements.

Geolocation Data

General geographic location derived from your IP address when you visit our Site.

Inferences

Information derived from the above categories to understand your service preferences and marketing needs.

We do not knowingly collect sensitive personal information (such as social security numbers, financial account numbers, precise geolocation, or health information) except where strictly necessary and only with your consent.

2. Sources of Personal Information

We collect personal information in the following ways:

Directly from You

When you fill out a contact or intake form, schedule a consultation, send an email, subscribe to our newsletter, or otherwise communicate with us.

Through Cookies and Similar Technologies

When you visit our Site, we and our third-party partners may automatically collect information about your browser, device, and how you interact with our Site using cookies, pixels, and similar tracking technologies. See Section 6 for more detail.

From Service Providers

We may receive personal information from third-party vendors who support our operations, including email delivery and newsletter vendors (Brevo) and customer relationship management platforms.

From Ad and Analytics Providers

We may receive information about you from third parties that provide us with advertising, data analytics, or site measurement services, including Google Analytics and similar platforms.

3. Purposes for Collecting Personal Information

In the 12 months preceding the Last Updated date above, we have used personal information for the following purposes:

• To process and respond to your service inquiries, schedule consultations, and provide you with the digital marketing services you have requested.
• To communicate with you about your project, appointments, and follow-ups.
• To send you receipts, proposals, reports, and other transactional communications.
• For marketing and promotional purposes — to send you updates, insights, and information about our Services. You may opt out at any time (see Section 8).
• To analyze Site usage and statistics in order to improve our Site, marketing, and Services.
• To detect and prevent fraud, unauthorized access, and other illegal activity.
• To maintain and improve our Site, IT systems, and security infrastructure.
• To comply with our legal obligations and applicable regulations.
• To assert or defend legal claims.
• For other purposes we may describe to you at the time of collection.

4. How We Disclose Personal Information

We do not sell your personal information for monetary consideration. In the 12 months preceding the Last Updated date above, we have disclosed personal information in the following circumstances:

Service Providers

We share personal information with third-party companies that perform services on our behalf, such as email delivery and newsletter management (Brevo), IT support, and marketing analytics. Our service providers are contractually required to use your information only as directed by us and to maintain appropriate security measures.

Ad and Analytics Providers

We may share or make available certain categories of personal information (identifiers, commercial information, geolocation data, internet or electronic usage data, and inferences) through cookies and online tracking technologies with advertising and analytics providers for measurement purposes. This may constitute a "sale" or "sharing" of personal information under California law. See Section 7 for your opt-out rights. These practices do not apply to Google user data received through Machina Lumina. See Section 13.

Government and Law Enforcement

We may disclose personal information to government agencies, regulatory bodies, law enforcement, or courts when required by law, subpoena, court order, or when we reasonably believe disclosure is necessary to comply with applicable law, protect our rights, or protect the safety of others.

Business Transfers

If Anchor Type LLC is involved in a merger, acquisition, asset sale, or other corporate transaction, your personal information may be transferred as part of that transaction. We will notify you of any such change as required by law.

With Your Consent

We may disclose your personal information for any other purpose with your explicit consent.

5. How Long We Keep Personal Information

We retain your personal information for as long as necessary to provide our Services, maintain our business records, and comply with our legal obligations. We use the following criteria to determine retention periods:

• How long the information is needed to provide our Services and operate our business;
• Whether contractual or legal obligations require us to retain the information for a specific period;
• Whether any law, statute, or regulation specifies a retention period;
• Whether you have agreed to a longer retention period;
• The sensitivity of the data; and
• The reasonable expectation for retention at the time the data was collected.

Where we process personal information for marketing purposes, we process it until you ask us to stop (and for a short administrative period after that). We maintain a record of your opt-out preference so we can honor it in the future.

6. Cookies, Analytics, and Similar Tracking Technology

Cookies and Tracking Technology

When you access our Site, we and third-party companies we work with may collect and store information using technologies such as server logs, cookies, web beacons, pixels, tags, and similar technologies (collectively, "Cookies"). The information collected may include your activities on our Site, IP address, browser and operating system type and version, device identifiers, and demographic or interest information.

We use this information to understand how users navigate to and around our Site, which content or services are accessed, and to keep track of your preferences. We also use these technologies to allow third parties to provide analytics and advertising services on our behalf.

Global Privacy Control

If you have enabled the Global Privacy Control ("GPC") or another opt-out preference signal on your browser, we will honor such signals by disabling targeted advertising and cross-context behavioral advertising cookies. Please note that a GPC signal applies only to the browser on which it is enabled.

Google Analytics

We use Google Analytics to understand how visitors use our Site. Google Analytics collects information such as how often users visit our Site, which pages they visit, and what prior sites they used before coming to our Site. To learn more about how Google uses data, please visit google.com/policies/privacy/partners. To opt out of Google Analytics, you may install the Google Analytics Opt-out Browser Add-on.

Do Not Track Signals

Some browsers have a "Do Not Track" feature. Our Site is not currently configured to respond to such signals, but we do honor the Global Privacy Control as described above.

7. California Privacy Rights (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA") provides you with specific rights regarding your personal information. This section describes those rights and how to exercise them.

Your Rights

• Right to Know and Access: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, our business purpose for collecting it, and the categories of third parties to whom we disclosed it.
• Right to Correction: You have the right to request that we correct inaccurate personal information we hold about you.
• Right to Deletion: You have the right to request that we delete personal information we have collected from or about you, subject to certain exceptions.
• Right to Opt Out of Sale or Sharing: We do not sell personal information for money. However, we do use cookies and online tracking technologies that may constitute a "sale" or "sharing" of personal information for targeted advertising under California law. You have the right to opt out of such sale or sharing by contacting us as described below. These practices do not apply to Google user data received through Machina Lumina. See Section 13.
• Right to Limit Use of Sensitive Personal Information: To the extent we collect sensitive personal information, you have the right to direct us to limit its use and disclosure to the purposes specified under California law.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

Sale and Sharing of Personal Information

In the 12 months preceding the Last Updated date above, we may have "shared" the following categories of personal information with advertising and analytics providers for measurement purposes: identifiers, commercial information, internet or electronic usage data, geolocation data, and inferences. We do not knowingly sell or share the personal information of consumers under the age of 16. Google user data received through Machina Lumina is never included in this and is never sold or shared. See Section 13.

How to Exercise Your Rights

To submit a rights request, please contact us by:

• Email: contact@wearemachina.com

For requests other than opt-out requests, we will verify your identity by matching the information you provide against the information we hold. We will respond to verifiable consumer requests within 45 days of receipt. If we require more time (up to 90 days total), we will inform you of the reason and extension in writing.

You may designate an authorized agent to submit a request on your behalf by providing us with a signed, written authorization. We may require you to verify your identity directly with us even when using an authorized agent.

California Shine the Light

California Civil Code § 1798.83 permits California residents to request information about how their personal information is shared with third parties for those third parties' own direct marketing purposes. To make such a request, please email us at contact@wearemachina.com.

8. Your Choices Regarding Marketing Communications

Marketing Emails

You may opt out of receiving marketing emails from us at any time by clicking the "Unsubscribe" link in any marketing email we send or by contacting us at contact@wearemachina.com. After we process your opt-out, we will stop sending you marketing emails. You will continue to receive transactional communications (such as consultation confirmations and service updates).

9. Links to Third-Party Websites

Our Site may contain links to third-party websites or services whose privacy practices may differ from ours. If you submit personal information to any of those sites, your information is governed by their privacy policies, not ours. We encourage you to review the privacy policy of any website or application you visit.

10. Security

We implement reasonable technical, organizational, administrative, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee the absolute security of your information and encourage you to take steps to protect your own data. In the event of a data breach that affects your rights and freedoms, we will notify affected individuals and relevant authorities as required by applicable law.

11. Children's Privacy

Our Site and Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe we have inadvertently collected personal information from your child, please contact us immediately at contact@wearemachina.com. We will delete such information from our records promptly upon verification. We do not knowingly sell or share the personal information of consumers under the age of 16 without affirmative authorization.

12. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated Privacy Policy on this page with a revised "Last Updated" date. If we make material changes, we will provide notice as required by applicable law. Your continued use of our Site or Services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

13. Google Account Data Used by Machina Lumina

This section applies only to Machina Lumina, our search performance product for businesses. It does not apply to visitors of this website. Where this section and any other part of this Policy disagree about Google user data, this section governs.

What We Access

When you connect a Google account to Machina Lumina, you choose which of your own Google services to connect, and Google shows you the exact permissions before you grant them. With your permission we read:

• Google Search Console. The searches your pages show up for, the position they show up in, how often people see them, how often people click, and which of your pages Google has indexed.
• Google Analytics. Sessions, users, traffic sources, landing page performance, and the conversion events you have already set up in your property.

We ask for read-only permission on both. We do not write to either one, and we connect to no other Google service.

How We Use It

We use this data to run the features you signed up for, and for nothing else. It becomes the dashboard you log into, the charts you read there, the list of page fixes we propose, and the reports we email you. A member of our team may look at your data when you ask us for support, when we need to fix a fault in the product, when security or the law requires it, or when we look at figures that have been combined across accounts and no longer identify you.

We do not sell your Google user data. We do not disclose it to advertisers, data brokers, credit reference services, or anyone else for their own purposes. We do not use it for advertising or ad targeting, ours or anyone else's. We do not use it to train models. The sale and sharing practices described in Sections 4 and 7 of this Policy cover website and marketing data. They do not cover Google user data, and Google user data is never included in them.

How We Store and Protect It

Your Google access and refresh tokens are encrypted with AES-256-GCM before they are written to our database. The encryption key is held in our hosting platform's secret store, separate from the database. The tokens cannot be read through our administration interface. The data we read from Google is stored in our own database, on servers we control, and is transmitted over TLS.

Who Else Sees It

Google user data stays with us and our hosting provider. We do not pass it to the vendors we use for email delivery or for anything else. Those vendors receive the search terms and business details you enter yourself, never data read from your Google account.

How Long We Keep It

We keep your Google user data for as long as your account keeps the connection open. When you disconnect a Google service, we delete the stored tokens for it. When you close your account, we delete your Google user data along with the rest of your account data, other than records we are required by law to keep. Reports and charts already delivered to you are yours to keep.

How to Withdraw Access

You can disconnect any Google service from the connections page inside Machina Lumina at any time, and you do not need to ask us first. You can also revoke our access directly from your Google Account at myaccount.google.com/permissions. Either route ends our permission to read your account, and we stop. To have your stored data deleted as well, email us at contact@wearemachina.com.

Limited Use

Machina Lumina's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us: