Privacy Policy

Effective date: {EFFECTIVE_DATE} · Last updated: {EFFECTIVE_DATE}

1. Who we are

This Privacy Policy explains how {LEGAL_ENTITY_NAME}, doing business as Penguin Agents, a Grow Higher Media company ("Penguin Agents," "we," "us," or "our"), handles personal information collected through this website and our related marketing and booking activities. We are a United States done-for-you marketing agency and we serve a national audience. Our principal place of business is {BUSINESS_ADDRESS}.

This policy applies to information we collect on this website. It does not cover the separate privacy practices of our clients or of third-party services we link to.

2. Information we collect

We collect the following categories of personal information:

• Contact and identity information you give us, such as your name, work email address, and mobile phone number.
• Business information you give us, such as your business or practice name, industry or niche, approximate monthly advertising spend range, and your goals or the issue you want to fix. This is collected through our "Book a Leak-Check" form and our newsletter opt-in.
• Communications you send us, including form submissions, chat messages, replies to our texts or emails, and notes from calls.
• Device and usage information collected automatically, such as IP address, browser type, device type, pages viewed, referring pages, and general location inferred from IP.
• Cookie and tracking data as described in the Cookies and tracking section and in our Cookie Policy.

We do not intentionally collect sensitive personal information (such as Social Security number, financial account numbers, health diagnoses, or precise geolocation) through this website. Please do not submit sensitive information through our forms or chat.

3. Sources of information

We collect personal information directly from you (through forms, the chat concierge, email, text, and calls), automatically from your device (through cookies and similar technologies), and from service providers who help us run our advertising, analytics, and customer-relationship tools, such as advertising platforms and our booking and CRM provider.

4. How we use information

We use personal information to:

• respond to your request, schedule and confirm your Leak-Check consultation, and provide our services;
• send you reminders and follow-ups about a booked call by SMS text and email;
• send marketing communications, including our newsletter, where you have opted in or as otherwise permitted by law;
• measure, operate, and improve our website, advertising, and offers;
• create and manage records in our customer-relationship system;
• protect against fraud and misuse and maintain the security of our systems; and
• comply with legal obligations and enforce our Terms of Service.

5. Cookies and tracking technologies

We and our providers use cookies, pixels, tags, and similar technologies to run the site, understand traffic, and deliver and measure advertising. These include:

• Meta Pixel (Meta Platforms, Inc.) for advertising measurement and audience building on Facebook and Instagram;
• Google Analytics and Google Ads (Google LLC) for website analytics and advertising measurement and remarketing; and
• GoHighLevel / LeadConnector (our CRM, booking, and messaging provider) for forms, scheduling, chat, and communications.

Non-essential cookies (analytics and advertising) load only after you accept them through our cookie banner. You can change your choice at any time, and you can also control cookies through your browser settings. For full details and opt-out links, see our Cookie Policy.

6. How we share information

We do not sell your personal information for money. We share personal information in these situations:

• Service providers. With vendors that process information on our behalf, such as our CRM, booking, and messaging provider (GoHighLevel / LeadConnector), our email and SMS delivery tools, our advertising and analytics providers (Meta, Google), and hosting providers. They are permitted to use the information only to provide services to us.
• Advertising partners. With advertising platforms through cookies and pixels for measurement and audience purposes. Depending on your state, some of this activity may be considered "sharing" for targeted advertising or a "sale" under certain state laws, even when no money changes hands. See your rights below.
• Legal and safety. When required by law, subpoena, or legal process, or to protect our rights, users, or the public.
• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, subject to this policy.
• With your direction. When you ask us to share information, for example with a Penguin Agents client you have engaged.

7. Your California privacy rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, gives you the following rights, subject to exceptions:

• Right to know the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of third parties with whom we share it.
• Right to delete personal information we collected from you.
• Right to correct inaccurate personal information.
• Right to opt out of the "sale" or "sharing" of your personal information, including for cross-context behavioral advertising.
• Right to limit the use of sensitive personal information (we do not use sensitive personal information for purposes that require this right, but we honor requests).
• Right to non-discrimination for exercising your rights. We will not deny you services, charge a different price, or provide a different level of service because you exercised a privacy right.

How to exercise these rights. Submit a request by email to {PRIVACY_EMAIL} or by phone at {SUPPORT_PHONE}. We will verify your request using the information we have on file and respond within the timeframes required by law. You may use an authorized agent to submit a request on your behalf with proof of authorization. If we decline a request, you may appeal by replying to our decision or contacting us at {PRIVACY_EMAIL}.

8. Do Not Sell or Share My Personal Information

We do not sell your personal information for money. However, our use of advertising cookies and pixels (such as the Meta Pixel and Google Ads) may be considered a "sale" or "sharing" of personal information for targeted or cross-context behavioral advertising under California and certain other state laws.

You can opt out of this activity in these ways:

• Select Decline non-essential in our cookie banner, which keeps advertising and analytics cookies off on this browser.
• Enable a browser or extension that sends the Global Privacy Control (GPC) signal. We treat a valid GPC signal as a request to opt out of sale and sharing for that browser.
• Email us at {PRIVACY_EMAIL} with the subject line "Do Not Sell or Share."

Because these opt-outs are tied to cookies and your browser, you may need to opt out again if you clear cookies, use another browser, or use another device.

9. California "Shine the Light"

California Civil Code Section 1798.83 lets California residents request information once per year about personal information we disclosed to third parties for their own direct marketing. We do not disclose personal information to third parties for their own direct marketing. To make a request, email {PRIVACY_EMAIL}.

10. Other US state privacy rights

Residents of states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, and Utah, among others, may have rights to access, correct, delete, and obtain a portable copy of their personal information, and to opt out of targeted advertising and the sale of personal information. Where those laws provide an appeal process, we will honor it. To exercise any of these rights, contact us at {PRIVACY_EMAIL}. We will verify and respond as required by the applicable law.

11. SMS and email communications

SMS text messages. When you book a Leak-Check and provide your mobile number with consent, we send you appointment reminders and related messages, and, where you agree, marketing messages. Message frequency varies. Message and data rates may apply. Consent to receive texts is not a condition of any purchase. You can opt out at any time by replying STOP to any message, and you can get help by replying HELP or emailing {PRIVACY_EMAIL}. Mobile opt-in data and consent are not shared with third parties for their own marketing.

Email. We send transactional emails about your booking and, where you opt in, our newsletter and marketing emails. You can unsubscribe from marketing email at any time using the link in any message or by emailing {PRIVACY_EMAIL}. We may still send you non-marketing messages about a booked call.

12. Data retention

We keep personal information for as long as needed to provide our services, communicate with you, comply with our legal obligations, resolve disputes, and enforce our agreements. Our general retention period is {DATA_RETENTION_PERIOD}, after which we delete or de-identify the information unless a longer period is required by law.

13. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Please do not send sensitive information through our forms or chat.

14. Children's privacy

This website is intended for business owners and is not directed to children. We do not knowingly collect personal information from anyone under 16, and no part of the site is directed to children under 13. If you believe a child has provided us personal information, contact us at {PRIVACY_EMAIL} and we will delete it.

15. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, where appropriate, provide additional notice. Your continued use of the site after an update means you accept the revised policy.

16. Contact us

Questions or requests about privacy can be sent to:

{LEGAL_ENTITY_NAME} (Penguin Agents, a Grow Higher Media company)
{BUSINESS_ADDRESS}
Email: {PRIVACY_EMAIL}
Phone: {SUPPORT_PHONE}