Privacy Policy

Effective Date: July 19, 2026
Last Updated: July 19, 2026

Commva Inc (“Commva,” “we,” “us,” or “our”) respects your privacy and is committed to transparency regarding how we collect, use, disclose, retain, and protect personal information.

This Privacy Policy applies when you:

  • Visit or interact with https://www.commva.com/ and its related pages, forms, online-store features, and services, collectively, the “Website”;

  • Contact us or request information;

  • Submit a Website form;

  • Submit a Facebook or Instagram Instant Form;

  • Request or schedule a consultation;

  • Purchase or inquire about our services;

  • Subscribe to or interact with our email communications;

  • Interact with our advertisements or social-media content;

  • Communicate with us through a chat feature; or

  • Otherwise engage with Commva online or offline.

By using the Website or submitting information to us, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

The information we collect depends on how you interact with Commva and the services or features you use.

Information You Provide Directly

We may collect information you provide to us, including:

  • Your name;

  • Email address;

  • Telephone number;

  • Business or company name;

  • Job title or professional role;

  • Website address;

  • Social-media account or profile information;

  • Billing information;

  • Information about your business, project, marketing needs, objectives, budget, timeline, or requested services;

  • Messages, files, questionnaire responses, consultation details, and other information submitted through Website forms;

  • Information submitted through Facebook or Instagram Instant Forms;

  • Information provided when scheduling an appointment or consultation;

  • Information submitted when purchasing services;

  • Communication and marketing preferences;

  • Testimonials, reviews, survey responses, and feedback;

  • Information submitted through a chat feature; and

  • Any other information you choose to provide.

Please do not provide sensitive personal information unless it is reasonably necessary for us to respond to your request or provide the services you requested.

Facebook and Instagram Instant Form Information

We may use Facebook or Instagram Instant Forms provided by Meta Platforms, Inc. to collect information from individuals who interact with our advertisements.

Depending on the form, this information may include:

  • Your name;

  • Email address;

  • Telephone number;

  • Business name;

  • Website address;

  • Answers to questions about your business, marketing needs, or service interests; and

  • Any other information you choose to submit.

Information submitted through an Instant Form is processed by Meta before being provided to Commva.

When you submit a Facebook or Instagram Instant Form, the information you provide may be transferred to Klaviyo and added to our customer-relationship and email-marketing systems, subject to the consent language displayed on the form.

Meta’s independent handling of your information is governed by Meta’s own privacy policy, terms, and account settings.

Appointment and Consultation Information

If you schedule a consultation through Calendly or another scheduling feature, we may collect:

  • Your name;

  • Email address;

  • Telephone number;

  • Appointment date and time;

  • Time zone;

  • Business or project information;

  • Answers to scheduling questions; and

  • Information you include in appointment notes.

Calendly may process this information under its own privacy policy and terms.

Transaction and Payment Information

When you purchase a service through the Website, we and our service providers may collect information associated with the transaction, including:

  • Your name and contact information;

  • Billing address;

  • The service purchased;

  • Purchase amount;

  • Transaction date;

  • Payment status;

  • Order, invoice, or transaction identifiers; and

  • Information needed to complete the transaction, prevent fraud, process refunds, or resolve payment issues.

Depending on the transaction and available checkout methods, payments may be processed using:

  • Squarespace Payments;

  • Stripe;

  • PayPal;

  • Afterpay or Clearpay; and/or

  • Other payment services made available through Squarespace.

Commva does not ordinarily receive or store your complete payment-card number or card security code. Payment credentials are generally submitted directly to and processed by the applicable payment provider.

Payment providers process information under their own privacy policies and terms.

Information Collected Automatically

When you visit or interact with the Website, we and our service providers may automatically collect information such as:

  • Internet Protocol address;

  • Browser type and version;

  • Device type;

  • Operating system;

  • Device and browser identifiers;

  • General geographic location inferred from your IP address;

  • Referring website, advertisement, search engine, or source;

  • Search terms that led to the Website;

  • Pages viewed;

  • Links, buttons, forms, videos, or advertisements interacted with;

  • Date and time of visits;

  • Time spent on pages;

  • Website navigation and interaction information;

  • Form-start and form-submission activity;

  • Shopping-cart, checkout, and purchase activity;

  • Cookie and pixel identifiers;

  • Advertising identifiers;

  • Conversion events;

  • Chat interactions;

  • Video-viewing activity; and

  • Information regarding how you interact with our emails.

We and our service providers may collect this information using cookies, pixels, tags, scripts, application programming interfaces, local storage, server logs, analytics tools, and similar technologies.

Information from Third Parties

We may receive information from third parties, including:

  • Squarespace, which hosts and operates our Website and may provide forms, ecommerce, analytics, checkout, payment, and other Website functionality;

  • GoDaddy, which provides domain registration, domain name system, and related domain services;

  • Klaviyo, which we use for email marketing, contact management, audience segmentation, automation, and campaign measurement;

  • Meta Platforms, Inc., including Facebook and Instagram, which may provide Instant Form submissions, advertising information, audience data, pixel events, and conversion data;

  • Google Analytics 4, which provides Website traffic and interaction analytics;

  • Google Ads, which provides advertising, attribution, and conversion information;

  • Google Search Console, which provides information regarding the Website’s visibility and performance in Google Search;

  • Calendly, which may provide appointment and consultation information;

  • Zapier, which may transfer information between the systems and applications we use;

  • PandaDoc, which may provide proposal, agreement, document-viewing, and electronic-signature information;

  • YouTube, when videos are embedded or linked on the Website;

  • Instagram, when feeds, posts, or other Instagram content are embedded or displayed;

  • CAPTCHA or reCAPTCHA providers, which help us detect spam, abuse, and automated activity;

  • Chat-widget providers, which facilitate online conversations and support;

  • Payment processors, including Squarespace Payments, Stripe, PayPal, Afterpay, and Clearpay, as applicable;

  • Analytics and advertising providers;

  • Referral partners;

  • Publicly available sources;

  • Clients, vendors, and business partners; and

  • Other systems used to provide or support our services.

For example, Meta may tell us that a visitor interacted with an advertisement, Klaviyo may provide information about email activity, Squarespace may provide information about Website visits and purchases, and Google may provide aggregated information about traffic, advertising conversions, or search performance.

2. How We Use Information

We may use personal information for the following purposes.

Providing Services and Responding to Requests

We may use information to:

  • Respond to inquiries;

  • Contact you regarding a submitted form;

  • Evaluate prospective projects;

  • Schedule and conduct consultations;

  • Prepare estimates, proposals, agreements, and scopes of work;

  • Process purchases and payments;

  • Provide requested services;

  • Communicate about a project, transaction, document, or account;

  • Deliver reports, content, files, and other work product;

  • Provide customer support; and

  • Manage client, prospect, vendor, and business relationships.

Operating and Improving the Website

We may use information to:

  • Operate, maintain, and troubleshoot the Website;

  • Provide Website and ecommerce functionality;

  • Understand how visitors find and use the Website;

  • Improve Website performance, usability, content, accessibility, and design;

  • Analyze Website traffic, engagement, and conversion activity;

  • Test Website features, forms, offers, and messaging;

  • Diagnose technical issues;

  • Monitor search-engine performance;

  • Prevent spam and automated abuse; and

  • Develop or improve our services.

Marketing and Advertising

Subject to applicable law, we may use information to:

  • Send newsletters, offers, business updates, educational content, and promotional communications;

  • Follow up on inquiries, form submissions, consultations, or incomplete transactions;

  • Measure email opens, clicks, and conversions;

  • Segment contacts based on their interests or interactions;

  • Automate marketing communications;

  • Measure the effectiveness of advertisements and marketing campaigns;

  • Create and manage advertising audiences;

  • Deliver, personalize, and measure advertisements;

  • Retarget visitors who have interacted with the Website;

  • Attribute inquiries, purchases, and other conversions to marketing sources;

  • Understand how users interact with our advertisements and content; and

  • Personalize communications based on your interactions with Commva.

Documents, Agreements, and Electronic Signatures

We may use information through PandaDoc or similar platforms to:

  • Prepare and deliver proposals, agreements, and other business documents;

  • Track document delivery, opening, and viewing;

  • Obtain electronic signatures;

  • Maintain records of acceptance or execution; and

  • Manage our contractual relationship with you.

Security, Fraud Prevention, and Legal Compliance

We may use information to:

  • Protect the security and integrity of the Website and our systems;

  • Detect, prevent, or investigate fraud, spam, abuse, malicious activity, or unlawful conduct;

  • Verify that interactions are made by a person rather than an automated system;

  • Enforce our contracts, policies, and legal rights;

  • Protect our rights, property, personnel, clients, users, and others;

  • Resolve disputes;

  • Establish, exercise, or defend legal claims;

  • Comply with legal, tax, accounting, regulatory, or reporting obligations; and

  • Respond to lawful requests from courts, regulators, law-enforcement agencies, or government authorities.

Business Administration

We may also use information for internal business purposes, including:

  • Bookkeeping and accounting;

  • Invoicing and collections;

  • Vendor management;

  • Business planning;

  • Maintaining records;

  • Conducting audits;

  • Evaluating business performance; and

  • Evaluating or completing a business transaction.

3. Marketing Email Notice and Consent

When you submit a form to Commva, you agree that we may use the information you provide to respond to your request and contact you regarding our services.

You may also receive marketing emails from Commva, subject to the consent language displayed on the applicable form and the requirements of applicable law.

Marketing communications may include:

  • Service information;

  • Educational content;

  • Business updates;

  • Offers and promotions;

  • Invitations;

  • Follow-up communications; and

  • Other information we believe may be relevant to your business or inquiry.

Where applicable law requires express or affirmative consent, we will rely on the consent mechanism presented with the applicable form before sending marketing communications.

You may unsubscribe from promotional emails at any time by selecting the unsubscribe link included in the email or by contacting us at pgonzalez@commva.com.

Unsubscribing from promotional emails does not prevent us from sending nonpromotional communications relating to:

  • A purchase;

  • A requested consultation;

  • A project;

  • An agreement;

  • An invoice or payment;

  • Customer support;

  • Security;

  • Legal notices; or

  • An ongoing business relationship.

4. Legal Bases for Processing

Where applicable law requires us to identify a legal basis for processing personal information, we may rely on one or more of the following:

  • Contract: Processing is necessary to enter into or perform a contract with you.

  • Legitimate interests: Processing supports our legitimate business interests, provided those interests are not overridden by your rights and interests.

  • Consent: You have consented to a particular use of your information.

  • Legal obligation: Processing is necessary to comply with a legal obligation.

  • Protection of rights: Processing is necessary to protect our rights or the rights, safety, or property of another person.

  • Other lawful bases: Processing is otherwise permitted under applicable law.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before consent was withdrawn.

5. How We Disclose Information

We may disclose personal information to the following categories of recipients.

Website, Hosting, and Domain Providers

We may disclose information to:

  • Squarespace, which hosts and operates our Website and may provide analytics, forms, ecommerce, checkout, payment, and other Website functionality; and

  • GoDaddy, which provides domain-registration, DNS, and related domain services.

Payment and Financial-Service Providers

Depending on the payment method selected, information may be disclosed to:

  • Squarespace Payments;

  • Stripe;

  • PayPal;

  • Afterpay;

  • Clearpay;

  • Financial institutions; and

  • Fraud-prevention and payment-security providers.

These providers may process information under their own privacy policies and terms.

Email-Marketing and Customer-Relationship Providers

We may disclose information to Klaviyo to:

  • Store and manage contact profiles;

  • Record subscription and unsubscribe preferences;

  • Send marketing or service-related communications;

  • Segment audiences;

  • Track email opens, clicks, and conversions;

  • Automate email sequences;

  • Connect Website activity to known contacts; and

  • Analyze campaign performance.

Klaviyo may use cookies, pixels, and similar technologies in emails and on connected websites.

Advertising and Social-Media Platforms

We may disclose or make information available to Meta, Google, and other advertising or social-media platforms for purposes such as:

  • Displaying advertisements;

  • Processing Instant Form submissions;

  • Measuring advertising performance;

  • Tracking conversions;

  • Creating custom, matched, or similar audiences;

  • Retargeting Website visitors;

  • Understanding advertising interactions;

  • Limiting advertisement frequency; and

  • Improving campaign effectiveness.

Depending on the integration, information may include:

  • Contact information;

  • Hashed contact information;

  • Device and browser information;

  • Cookie or advertising identifiers;

  • Website activity;

  • Form activity;

  • Purchase or conversion events; and

  • Advertising interaction data.

Analytics and Search-Performance Providers

We may disclose or make Website usage information available to:

  • Google Analytics 4;

  • Google Ads Conversion Tracking;

  • Google Search Console;

  • Squarespace Analytics; and

  • Other analytics, attribution, or Website-performance providers.

Google Search Console generally provides us with aggregated information about search visibility and Website performance rather than information directly submitted by individual visitors.

Scheduling and Communication Providers

We may disclose information to:

  • Calendly or another scheduling provider;

  • Chat-widget providers;

  • Video-conferencing providers;

  • Customer-support tools; and

  • Other communication services used to respond to or communicate with you.

Automation and Integration Providers

We may use Zapier or similar services to transfer information between our systems.

For example, information from a Meta Instant Form may be transferred to Klaviyo, or information from a form or payment system may be transferred to another platform used to respond to the request or deliver our services.

Document and Electronic-Signature Providers

We may disclose information to PandaDoc or another document provider to:

  • Prepare and send proposals or agreements;

  • Track document engagement;

  • Collect electronic signatures;

  • Maintain executed documents; and

  • Manage our business relationship with you.

Embedded Content and Social-Media Providers

The Website may include or display content from YouTube, Instagram, or other third-party platforms.

These providers may receive information about your browser, device, and interaction with embedded content, subject to their own privacy policies and settings.

Security and Spam-Prevention Providers

We may disclose information to CAPTCHA, reCAPTCHA, cybersecurity, fraud-prevention, and spam-detection providers to protect the Website and determine whether an interaction is legitimate.

Other Service Providers and Contractors

We may provide information to other companies that perform services for us, including:

  • Cloud-storage providers;

  • Customer-relationship-management systems;

  • Project-management and communication platforms;

  • Form, survey, and questionnaire providers;

  • Accounting, invoicing, and bookkeeping providers;

  • Cybersecurity providers;

  • Consultants;

  • Contractors; and

  • Other vendors supporting our operations.

Professional Advisers

We may disclose information to attorneys, accountants, insurers, consultants, and other professional advisers when reasonably necessary for them to provide services to us.

Legal and Safety Disclosures

We may disclose information when we reasonably believe disclosure is necessary to:

  • Comply with a law, regulation, subpoena, court order, or legal process;

  • Cooperate with a lawful government or law-enforcement request;

  • Investigate or prevent fraud, security incidents, or illegal activity;

  • Protect the rights, safety, or property of Commva or another person; or

  • Enforce an agreement, policy, or legal right.

Business Transactions

We may disclose or transfer information in connection with an actual or proposed:

  • Merger;

  • Acquisition;

  • Sale of assets;

  • Financing;

  • Reorganization;

  • Bankruptcy;

  • Change in ownership; or

  • Similar business transaction.

The recipient may continue to use the information in accordance with this Privacy Policy unless you are notified otherwise.

At Your Direction

We may disclose information to another party when you direct us to do so, authorize the disclosure, or intentionally interact with that party.

6. Sale, Sharing, and Targeted Advertising

Commva does not sell personal information for money in the ordinary meaning of the word “sell.”

However, we use or may use analytics, advertising, conversion-measurement, audience-building, and retargeting technologies, including:

  • Meta Pixel and related Meta advertising tools;

  • Google Ads Conversion Tracking;

  • Google Analytics 4;

  • Klaviyo tracking technologies; and

  • Similar advertising or analytics services.

These technologies may involve disclosing identifiers, hashed contact information, device information, cookie identifiers, advertising identifiers, or Website activity to advertising, analytics, and marketing platforms.

Some privacy laws may define these activities as:

  • A sale of personal information;

  • Sharing personal information;

  • Targeted advertising; or

  • Cross-context behavioral advertising.

Where required by applicable law, you may opt out through available cookie-preference controls, a recognized browser-based opt-out signal, or by contacting us as described in this Privacy Policy.

We do not knowingly sell or share the personal information of individuals under 16 years of age.

7. Cookies, Pixels, and Similar Technologies

Cookies are small files or identifiers stored on or accessed from your browser or device.

We and our providers may use:

  • Cookies;

  • Tracking pixels;

  • Tags;

  • Scripts;

  • Local-storage technologies;

  • Device identifiers;

  • Server logs; and

  • Similar technologies.

These technologies may be used for the purposes described below.

Squarespace Technologies

Because our Website is built and hosted on Squarespace, Squarespace may use cookies and similar technologies to provide:

  • Website security;

  • Website navigation and functionality;

  • Form submission functionality;

  • Shopping-cart and checkout functions;

  • Payment functionality;

  • Session management;

  • Device recognition;

  • Analytics; and

  • Website performance measurement.

Klaviyo Technologies

Klaviyo may use cookies, pixels, and similar technologies to help us:

  • Manage email subscriptions;

  • Recognize known Website visitors;

  • Measure email opens and clicks;

  • Connect Website activity with marketing campaigns;

  • Segment audiences;

  • Measure conversions;

  • Automate communications; and

  • Personalize marketing.

Meta Technologies

We may use Meta Pixel and related Meta advertising technologies.

These technologies may collect information about:

  • Pages viewed;

  • Links and buttons clicked;

  • Forms started or submitted;

  • Purchases or other conversion events;

  • Browser and device information;

  • IP address;

  • Cookie identifiers;

  • Advertising identifiers; and

  • Interactions with our advertisements.

Meta may process this information under its own privacy policy, including for advertising measurement, audience creation, personalization, security, and other platform purposes.

Google Analytics and Advertising Technologies

We may use Google Analytics 4, Google Ads Conversion Tracking, and related Google technologies to collect or receive information about:

  • Website visits;

  • Page views;

  • Referral sources;

  • Interactions;

  • Events;

  • Conversions;

  • Device and browser characteristics;

  • Approximate location;

  • Advertising interactions; and

  • Campaign performance.

Google may process this information under its own privacy policy and account settings.

Embedded Content

Embedded YouTube videos, Instagram feeds, chat features, and other third-party content may use cookies or similar technologies.

The applicable third party may receive information when the embedded content loads or when you interact with it.

CAPTCHA and reCAPTCHA

We may use CAPTCHA or Google reCAPTCHA to protect forms and other Website features from spam, fraud, and automated abuse.

These tools may analyze device, browser, interaction, and network information to determine whether an interaction appears to be made by a person.

Cookie Categories

Essential Cookies

Essential technologies support functions such as:

  • Security;

  • Network management;

  • Website navigation;

  • Session management;

  • Shopping carts;

  • Checkout;

  • Payment processing;

  • Form submission;

  • Fraud prevention; and

  • Remembering privacy choices.

Disabling essential technologies may prevent parts of the Website from functioning correctly.

Functional Cookies

Functional technologies remember preferences and support enhanced Website features, embedded content, chat functions, and other personalized functionality.

Analytics Cookies

Analytics technologies help us understand:

  • Website traffic;

  • Visitor behavior;

  • Engagement;

  • Referral sources;

  • Search visibility;

  • Conversion activity; and

  • Website performance.

Advertising Cookies

Advertising technologies may be used to:

  • Measure advertising performance;

  • Attribute inquiries or purchases to advertisements;

  • Create advertising audiences;

  • Limit how often an advertisement appears;

  • Personalize advertising;

  • Track conversions; and

  • Retarget Website visitors on other platforms.

Managing Cookies

Depending on your location and the technologies active on the Website, you may be able to manage nonessential cookies through a cookie banner or cookie-preference tool.

You may also configure your browser to block or delete cookies. Browser controls vary, and blocking cookies may affect Website functionality.

Cookie and privacy selections may be specific to your browser or device. You may need to repeat your selections on each browser and device you use.

8. Your Privacy Choices

Depending on your location and applicable law, you may have the right to opt out of certain:

  • Sales of personal information;

  • Sharing of personal information;

  • Targeted advertising;

  • Cross-context behavioral advertising; or

  • Marketing communications.

You may exercise available choices by:

  • Adjusting the cookie-preference settings made available on the Website;

  • Blocking or deleting cookies through your browser;

  • Using browser or device privacy controls;

  • Enabling a legally recognized opt-out preference signal;

  • Adjusting advertising preferences through Facebook, Instagram, Google, or other advertising services;

  • Selecting the unsubscribe link in a marketing email; or

  • Emailing pgonzalez@commva.com.

Because some privacy choices are browser- or device-specific, you may need to repeat your selection on each browser or device you use.

9. Global Privacy Control and Browser Signals

Certain browsers and browser extensions allow users to send an opt-out preference signal, such as Global Privacy Control, or “GPC.”

Where required by applicable law and where the signal is technically detectable by our Website or consent-management tools, we will process a recognized opt-out preference signal as a request to opt out of covered sale or sharing activity associated with that browser or device.

A browser-based signal may not identify you by name and may not apply to:

  • Other browsers or devices;

  • Offline information;

  • Information submitted directly to us;

  • Information associated with a different email address or identifier; or

  • Processing that is exempt from an applicable opt-out right.

Other than legally recognized opt-out preference signals, we may not respond to “Do Not Track” settings because there is no single universally adopted standard governing those signals.

10. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to:

  • Respond to inquiries;

  • Provide services;

  • Maintain client and transaction records;

  • Manage business relationships;

  • Fulfill contracts;

  • Process and document transactions;

  • Maintain marketing preferences;

  • Comply with tax, accounting, regulatory, and legal obligations;

  • Resolve disputes;

  • Enforce agreements;

  • Prevent fraud; and

  • Protect our legal rights.

Retention periods may vary based on:

  • The type and sensitivity of the information;

  • The nature and duration of our relationship with you;

  • The purpose for which the information was collected;

  • Whether you remain subscribed to marketing communications;

  • Contractual requirements;

  • Legal limitation periods;

  • Tax and accounting requirements;

  • Security and fraud-prevention considerations; and

  • Whether information is needed to establish, exercise, or defend a legal claim.

When information is no longer reasonably necessary, we may delete, anonymize, aggregate, or securely dispose of it, subject to applicable law and technical limitations.

Residual copies may remain for a limited period in:

  • Backups;

  • Archives;

  • Security logs;

  • Fraud-prevention systems;

  • Executed agreements; and

  • Records maintained to satisfy legal obligations.

Information may also remain in systems operated by Squarespace, Klaviyo, Meta, Google, GoDaddy, Calendly, Zapier, PandaDoc, payment processors, or other providers according to their own retention practices and legal obligations.

11. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, destruction, loss, or misuse.

We also rely on safeguards maintained by the service providers supporting our Website and business operations.

Nevertheless, no website, internet transmission, email system, electronic-storage system, payment method, or security measure is completely secure.

We cannot guarantee the absolute security of personal information. You should use appropriate care when transmitting sensitive or confidential information electronically.

12. Your Privacy Rights

Where required by applicable law, you may have some or all of the following rights:

  • Access: Request confirmation of whether we process your personal information and obtain access to covered information.

  • Know: Request information about the categories or specific pieces of personal information we have collected.

  • Correction: Request correction of inaccurate personal information.

  • Deletion: Request deletion of certain personal information.

  • Portability: Request a portable copy of certain personal information.

  • Restriction: Request that we restrict certain processing.

  • Objection: Object to certain processing.

  • Withdraw consent: Withdraw consent for processing based on your consent.

  • Opt out of sale: Opt out of covered sales of personal information.

  • Opt out of sharing: Opt out of covered sharing for cross-context behavioral advertising.

  • Opt out of targeted advertising: Opt out of covered processing for targeted advertising.

  • Opt out of profiling: Opt out of certain covered profiling used to make decisions producing legal or similarly significant effects.

  • Limit sensitive-information use: Request limitations on certain uses or disclosures of sensitive personal information.

  • Non-discrimination: Exercise applicable privacy rights without unlawful discrimination or retaliation.

  • Appeal: Appeal our refusal to act on a request where applicable law provides an appeal right.

  • Complaint: Submit a complaint to an applicable privacy or data-protection authority.

Privacy rights are not absolute.

Applicable law may permit or require us to deny a request, retain information, or continue processing information. For example, we may retain information when reasonably necessary to:

  • Complete a transaction;

  • Provide requested services;

  • Maintain an executed agreement;

  • Detect or prevent security incidents;

  • Protect against fraud;

  • Exercise or defend legal rights;

  • Comply with law; or

  • Maintain legally required business, accounting, or tax records.

13. How to Submit a Privacy Request

To submit a privacy request, email:

pgonzalez@commva.com

Please use the subject line “Privacy Request” and describe:

  • The right you wish to exercise;

  • The information or interaction involved; and

  • Any details reasonably necessary for us to locate the relevant records.

Verification

We may need to verify your identity before completing certain requests.

Verification may include:

  • Confirming information already associated with you;

  • Asking you to respond from an email address connected to your prior interaction with us;

  • Confirming information relating to an inquiry or transaction; or

  • Requesting other information reasonably necessary to verify the request.

We will not intentionally request more information than reasonably necessary to verify and fulfill a request.

If we cannot reasonably verify your identity, we may be unable to complete the request.

Authorized Agents

Where permitted by applicable law, you may designate an authorized agent to submit a request on your behalf.

We may require:

  • Proof that you authorized the agent;

  • Verification of your identity directly with us; or

  • Evidence that the agent has legally valid authority to act for you.

Response Timing

We will respond within the timeframe required by applicable law.

Where permitted, we may extend the response period and will provide notice of the extension and the reason for it.

Appeals

Where applicable law provides an appeal right, you may appeal a denied privacy request by emailing pgonzalez@commva.com with the subject line:

“Privacy Request Appeal”

14. Supplemental Notice for California Residents

This section supplements the remainder of this Privacy Policy for California residents and applies only to the extent the California Consumer Privacy Act, as amended, collectively the “CCPA,” applies to Commva or the relevant processing activity.

Categories of Personal Information

During the preceding 12 months, we may have collected the following categories of personal information:

CCPA categoryExamples we may collectIdentifiersName, email address, telephone number, IP address, cookie identifier, advertising identifier, account identifier, order identifier, or transaction identifierPersonal information described in customer-record lawsContact information, billing address, payment-related information, and transaction recordsCommercial informationServices purchased, considered, requested, or discussed; inquiry and transaction historyInternet or electronic-network activityBrowsing activity, Website interactions, form activity, referral sources, advertising interactions, video interactions, chat activity, email engagement, and cookie informationApproximate geolocationGeneral location inferred from an IP addressProfessional or employment-related informationCompany, role, industry, business details, and project-related informationAudio, electronic, visual, or similar informationFiles, recordings, photographs, video-meeting content, or other materials you provide, where applicableInferencesInferences concerning interests, service needs, business objectives, or likelihood of responding to an offerSensitive personal informationPayment, account-access, or authentication information when legally classified as sensitive and when required to complete a transaction or secure an account

We collect these categories from the sources described in Information We Collect, use them for the purposes described in How We Use Information, and disclose them to the recipients described in How We Disclose Information.

Categories Sold or Shared

We do not sell personal information for money.

During the preceding 12 months, advertising, analytics, conversion-measurement, audience-building, or retargeting activities may have involved the sale or sharing, as those terms are defined under California law, of the following categories:

  • Identifiers;

  • Internet or electronic-network activity;

  • Approximate geolocation information; and

  • Inferences derived from online activity.

These categories may be disclosed or made available to:

  • Advertising providers;

  • Analytics providers;

  • Social-media platforms;

  • Email-marketing providers; and

  • Marketing-technology providers.

Business-Purpose Disclosures

During the preceding 12 months, we may have disclosed the categories identified above to service providers, contractors, payment processors, professional advisers, and other recipients for the business purposes described in this Privacy Policy.

These recipients may include:

  • Squarespace;

  • GoDaddy;

  • Klaviyo;

  • Meta;

  • Google;

  • Calendly;

  • Zapier;

  • PandaDoc;

  • Chat-widget providers;

  • CAPTCHA or reCAPTCHA providers;

  • Squarespace Payments;

  • Stripe;

  • PayPal;

  • Afterpay;

  • Clearpay; and

  • Other providers supporting our operations.

Sensitive Personal Information

We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.

Where we process sensitive personal information, we use it for permitted purposes such as:

  • Completing a transaction;

  • Providing requested services;

  • Authenticating an interaction;

  • Maintaining security;

  • Preventing fraud;

  • Processing payments; and

  • Complying with legal obligations.

California Privacy Rights

Where the CCPA applies, California residents may have the right to request:

  • Access to categories and specific pieces of personal information;

  • Correction of inaccurate personal information;

  • Deletion of personal information;

  • Information regarding sources, purposes, and recipients;

  • Opt-out from covered sale or sharing;

  • Limitation of certain uses of sensitive personal information; and

  • Freedom from unlawful discrimination or retaliation for exercising CCPA rights.

Requests may be submitted using the process described in How to Submit a Privacy Request.

California “Shine the Light”

California Civil Code Section 1798.83 may permit certain California residents to request information concerning disclosures of personal information to third parties for their own direct-marketing purposes.

You may submit such a request by emailing pgonzalez@commva.com.

15. Residents of Other U.S. States

Where applicable state law applies to Commva or the relevant processing, residents of states with comprehensive privacy laws may have certain rights described in Your Privacy Rights.

The availability and scope of these rights depend on:

  • Your state of residence;

  • Whether the applicable law applies to Commva;

  • The nature of the processing;

  • The type of information involved;

  • The purpose for which the information is processed; and

  • Applicable thresholds, exceptions, and exemptions.

Where required by applicable law, we will process requests to opt out of covered:

  • Sales;

  • Sharing;

  • Targeted advertising;

  • Qualifying profiling; or

  • Other regulated processing.

16. International Visitors

Commva is based in the United States.

If you access the Website from outside the United States, your information may be transferred to, stored in, or processed in the United States and other countries where our providers operate.

Those providers may include:

  • Squarespace;

  • Klaviyo;

  • Meta;

  • Google;

  • GoDaddy;

  • Calendly;

  • Zapier;

  • PandaDoc;

  • Payment providers; and

  • Other service providers.

Privacy laws in those countries may differ from the laws in your country of residence.

Where required by applicable law, we may rely on:

  • Contractual protections;

  • Approved transfer mechanisms;

  • Consent;

  • Necessity for contract performance; or

  • Other lawful mechanisms for international data transfers.

Residents of the European Economic Area, United Kingdom, Switzerland, and other jurisdictions may have applicable rights described in Your Privacy Rights, including the right to complain to a competent data-protection authority.

17. Children’s Privacy

The Website and our services are intended for businesses and adults. They are not directed to children under 13 years of age.

We do not knowingly collect personal information online from children under 13.

If you believe a child has provided personal information to Commva, please email pgonzalez@commva.com. We will take reasonable steps to investigate and delete the information where required.

We do not knowingly sell or share the personal information of individuals under 16 years of age.

18. Third-Party Websites and Services

The Website may contain links to, integrations with, or content provided by third-party websites, applications, platforms, or services, including:

  • Squarespace;

  • Klaviyo;

  • Meta;

  • Facebook;

  • Instagram;

  • Google;

  • YouTube;

  • GoDaddy;

  • Calendly;

  • Zapier;

  • PandaDoc;

  • Payment providers;

  • CAPTCHA or reCAPTCHA providers; and

  • Chat-widget providers.

We do not control and are not responsible for the independent privacy, security, content, or business practices of third parties.

This Privacy Policy does not apply to information a third party processes independently under its own privacy policy.

We encourage you to review the privacy notices and settings of third-party services before providing information or interacting with them.

19. Social-Media Features and Embedded Content

The Website may contain:

  • Social-media links;

  • Instagram feeds;

  • Facebook or Instagram content;

  • YouTube videos;

  • Social sharing tools;

  • Advertising pixels;

  • Embedded posts; and

  • Other third-party content.

When these features load or when you interact with them, the applicable third party may receive information about your:

  • Browser;

  • Device;

  • IP address;

  • Website activity;

  • Account;

  • Cookie identifiers; and

  • Interaction with the content.

A platform may collect information even when you are not actively logged into an account with that platform.

Your interaction with social-media and embedded-content providers is governed by their respective privacy policies, terms, and account settings.

20. Information Processed on Behalf of Clients

As a digital-marketing agency, Commva may process personal information on behalf of clients while providing services such as:

  • Website development or management;

  • Search-engine optimization;

  • Advertising;

  • Analytics;

  • Email marketing;

  • Automation;

  • Lead generation;

  • Ecommerce support; and

  • Related consulting or implementation services.

When we process personal information solely on behalf of a client:

  • The client generally determines the purposes and means of processing;

  • The client’s privacy policy governs its relationship with its customers, prospects, subscribers, or Website visitors;

  • Commva processes information according to the client’s instructions, our agreement with the client, and applicable law; and

  • Commva may act as a service provider, contractor, processor, or similar regulated entity.

Privacy requests concerning information controlled by one of our clients should ordinarily be submitted directly to that client.

Where appropriate, we may forward a request to the relevant client or assist the client in responding.

21. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

  • Changes to the Website;

  • Changes to our services;

  • Changes to the providers and platforms we use;

  • Changes to our collection, use, disclosure, or retention practices;

  • Changes in legal or regulatory requirements; or

  • Other business or operational developments.

When we update this Privacy Policy, we will revise the Last Updated date at the top of the page.

Where required by applicable law, we will provide additional notice or obtain consent before materially changing how we use previously collected personal information.

We encourage you to review this page periodically.

22. Contact Us

For questions about this Privacy Policy, our privacy practices, or a privacy request, contact:

Commva Inc
Email: pgonzalez@commva.com
Website: https://www.commva.com/