Legal

Privacy Policy

How Frozen Crow collects, uses, shares, and protects information — and the choices you have.

Last updated: August 13, 2026

Privacy Policy

Effective Date: August 13, 2026
Last Updated: August 13, 2026

This Privacy Policy explains how Frozen Crow Inc. ("Frozen Crow," "we," "us," or "our") collects, uses, discloses, sells, shares, and retains personal information, and describes the rights and choices available to you. It applies to frozencrow.com and its subdomains and related properties, to our marketing, information technology, communications, development, hosting, and data services, to our software and game products, and to our offline interactions with prospects, clients, affiliates, vendors, and members of the public.

Please read the section titled Data We Obtain From Third-Party Sources carefully. Frozen Crow licenses consumer and business audience data from third-party database marketing providers and makes audience segments and prospect files available to our clients. This means we may hold personal information about you even if you have never visited our website, contacted us, or done business with us. We describe that practice plainly because you are entitled to know it, and the rights described in this Policy apply to that information.

Contents

Your Choices at a Glance

  • Stop the sale or sharing of your information: use our Your Privacy Choices page, email privacy@frozencrow.com, or call +1 (949) 749-0002. No account, purchase, or prior relationship is required, and we will not ask you to verify your identity.
  • See what we hold, correct it, or delete it: see Your California Privacy Rights or Other U.S. State Privacy Rights.
  • Stop marketing email: use the unsubscribe link in any message, or email privacy@frozencrow.com.
  • Stop text messages: reply STOP to any message, or email or call us. Any reasonable method works.
  • Stop phone calls: tell us on any call, call +1 (949) 749-0002, or email privacy@frozencrow.com, and we will add you to our internal do-not-call list.
  • Your information appeared in one of our audiences and you never contacted us? See Data We Obtain From Third-Party Sources. Every right above applies to you.

Who We Are

Frozen Crow Inc. is a marketing and information technology agency headquartered in Orange County, California. We provide search engine optimization, paid advertising management, social media marketing, content marketing, email marketing, customer relationship management and marketing automation services, information technology and communications services including cloud infrastructure, system integrations, and business VOIP and SMS, web and mobile application development, and hosting. We also operate our own software-as-a-service products and games, and we license and deploy third-party audience data.

For the personal information described in this Policy, Frozen Crow Inc. is the business (and, where applicable law uses the term, the controller) responsible for the processing described here, except where we act as a service provider, processor, or contractor for one of our clients. When we operate campaigns, systems, or communications programs on a client's behalf, the client determines the purposes and means of that processing, the client's own privacy policy governs, and you should direct your requests to that client. We will make reasonable efforts to route requests we receive to the appropriate client and to suppress your information within our own systems where we are able to do so.

Scope and Exclusions

This Policy does not apply to:

  • Personal information we process solely as a service provider, processor, or contractor on behalf of a client, which is governed by that client's privacy policy and our contract with that client;
  • Third-party websites, platforms, applications, or services that we do not control, even where we link to them or embed their content;
  • Information about our job applicants, personnel, and their dependents, which is handled under a separate notice available on request; and
  • De-identified and aggregate information, which is described in De-Identified and Aggregate Information.

Terms Used in This Policy

  • Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular individual or household. This includes business contact information — a work email address, a direct business line, an executive's name and title — where it relates to an identifiable individual.
  • Licensed audience data means consumer and business records we obtain under license from a third-party database marketing provider, rather than from you.
  • Audience segment means a filtered subset of licensed audience data, built to match a marketing objective.
  • Prospect file means a deliverable containing audience records, provided or made available for download to a client for that client's own marketing use.
  • Suppression record means the minimum information — usually an email address, telephone number, or record identifier — that we keep after you opt out or ask us to delete, so that we can recognize you and avoid contacting you or re-adding you to an audience. A suppression record exists only to honor your choice. It is never used for any other purpose, never sold or shared, and never included in an audience.
  • Service provider and contractor mean a vendor that processes personal information on our behalf under a written contract that limits it to the purposes we authorize and prohibits it from selling, sharing, or retaining the information for its own purposes.
  • Third party means a recipient that is not a service provider or contractor and that may use the information for its own purposes — for example, a client that licenses a prospect file, or an advertising platform.
  • Sale and sharing have the meanings given under California law and are explained under Sale and Sharing of Personal Information.

Notice at Collection — Summary

At or before the point at which we collect personal information from you, we provide notice of the categories we collect, the purposes for which we use them, whether we sell or share them, and how long we retain them. The detailed disclosures follow, but in summary:

  • We collect identifiers, contact and account information, commercial and transaction information, internet and device activity, approximate geolocation, professional and employment information, audio and electronic recordings (chat transcripts and, where disclosed, call recordings), a limited set of sensitive personal information described below, and inferences drawn from the foregoing.
  • We collect it directly from you, automatically from your device when you use our website, from our clients and partners, from public sources, and from third-party data licensors and database marketing providers.
  • We use it to operate and secure our website and services, to deliver and support the services our clients purchase, to market our own services, to build and deploy marketing audiences, to process payments, to comply with law, and to defend legal claims.
  • We sell and share personal information as those terms are defined under California law, subject to the exclusions in What We Never Sell or Share. You have the right to direct us to stop. See Do Not Sell or Share My Personal Information.
  • We retain each category on the basis described under Data Retention.

Where We Give Notice at Collection

Where we collect personal information directly from you, we give notice at or before the point of collection, either at the collection point itself or through a conspicuous link to this Policy, which describes the categories of personal information we collect, the purposes for which we use them, whether we sell or share them, how long we keep them, and how to opt out. The points at which we collect personal information directly from you include:

  • Contact, quote request, and lead forms on frozencrow.com;
  • Our online booking calendar and our live chat widget;
  • Newsletter and email list signup forms;
  • Checkout and account creation for purchases and subscriptions;
  • Affiliate program applications;
  • Text message and telephone consent forms; and
  • Any page on which an audience summary, prospect file, or gated resource is requested or downloaded, including pages under frozencrow.com/audience/.

Personal Information We Collect, Our Sources, and Our Purposes

The categories below track the categories used in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"). We have collected each of these categories within the twelve months preceding the Last Updated date above. Not every category applies to every individual — what we hold about you depends on how you interact with us, and whether your information appears in a licensed audience.

Every "sold or shared" designation below is subject to the exclusions in What We Never Sell or Share. That section is controlling where the two appear to conflict.

Identifiers

What: Real name, alias, postal address, email address, telephone number including mobile number, account name and login credentials, IP address, cookie and pixel identifiers, mobile advertising identifiers, hashed email addresses and other online identifiers, and unique customer or record identifiers.

Sources: Directly from you when you submit a form, request a quote, book a consultation, start a chat, place an order, subscribe to our email list, create an account, join our affiliate program, call us, or email us; automatically from your device and browser; from our clients when they engage us; and from third-party data licensors and database marketing providers.

Purposes: To respond to you, provide and administer services, authenticate accounts, process orders and payments, deliver email and text messages you have consented to receive, prevent fraud and secure our systems, build and deploy marketing audiences, measure advertising performance, and comply with legal obligations.

Sold or shared: Yes, as to identifiers held in or derived from licensed audience data, our own marketing records, and website advertising and analytics activity. Subject to the exclusions in What We Never Sell or Share.

Customer Records and Contact Information

What: Name, signature, postal address, telephone number, email address, employer and job title, and payment-related information such as billing address, card brand, last four digits, and expiration date. We do not collect or store full payment card numbers or card security codes on our own systems — card data is transmitted directly to and processed by our payment processor.

Sources: Directly from you; from our payment processor; from our clients; from third-party data licensors.

Purposes: Order processing, invoicing and collections, account administration, service delivery, customer support, affiliate payouts and tax reporting, fraud prevention, and legal compliance.

Sold or shared: Contact information held in or derived from licensed audience data is sold and shared. Payment, billing, and banking records are never sold or shared and are disclosed only to our payment, accounting, and audit providers and, where required, to tax and legal authorities. Subject to the exclusions in What We Never Sell or Share.

Commercial Information

What: Products and services purchased, considered, or inquired about; order and subscription history; amounts paid; quotes and proposals; support history; and consuming histories or tendencies inferred from the foregoing or supplied by a data licensor.

Sources: Directly from you; from our e-commerce and payment systems; from our customer relationship management platform; from third-party data licensors.

Purposes: Fulfilling orders, account management, service improvement, forecasting, marketing our own services, and audience building and segmentation.

Sold or shared: Yes, as to information held in or derived from licensed audience data. Our own clients' and customers' purchase records are not sold or shared.

Internet or Other Electronic Network Activity Information

What: Browsing and search activity on our website, pages viewed and time spent, referring and exit URLs, clickstream data, interaction with our emails including opens and link clicks, interaction with our advertisements, device and browser type, operating system, language, screen characteristics, and cookie and tag data.

Sources: Automatically from your device and browser through cookies, pixels, tags, software development kits, and server logs; from our analytics and advertising providers.

Purposes: Operating and securing the website, measuring and improving performance, analytics, attribution, advertising and remarketing, and detecting abuse.

Sold or shared: Yes. Advertising and analytics identifiers disclosed to advertising platforms for cross-context behavioral advertising constitute a sale and/or a share under California law.

Geolocation Data

What: Approximate location derived from IP address, such as country, state, city or region, and postal-code-level location contained in postal address records.

Sources: Automatically from your device; from postal address records you provide; from third-party data licensors.

Purposes: Analytics, content and advertising relevance, geographic audience segmentation, fraud prevention, and compliance with jurisdiction-specific legal requirements.

Sold or shared: Yes, where contained in licensed audience data or transmitted to advertising and analytics platforms. We do not collect, license, deploy, or sell precise geolocation data, and we require our data providers to exclude precise geolocation attributes from the data they supply to us.

Audio, Electronic, and Visual Information

What: Live chat transcripts and associated metadata; recordings or monitoring of telephone calls where we disclose that recording is occurring; voicemail; images and video you submit to us.

Sources: Directly from you when you initiate a chat, call, or submission.

Purposes: Responding to inquiries, service delivery, quality assurance, training, dispute resolution, and record-keeping.

Sold or shared: No. Chat transcripts, call recordings, voicemail, and the contents of email you send us are never sold, licensed, or shared for cross-context behavioral advertising, and are never contributed to any audience data set.

Professional and Employment-Related Information

What: Employer name, job title and function, seniority or executive level, business email address and business telephone number, industry and standard industrial classification, company employee-count and sales ranges, and business location.

Sources: Directly from you; from our clients; from public and publicly available sources; and, substantially, from third-party business data licensors.

Purposes: Business-to-business audience building, segmentation, prospecting, account-based marketing, campaign deployment, and lead generation for us and for our clients.

Sold or shared: Yes. Business contact information that identifies or is reasonably capable of being associated with an individual is personal information under California law. We treat it as such, and the rights described in this Policy apply to it.

Inferences

What: Profiles reflecting preferences, characteristics, predispositions, purchase propensities, interests, and likely behavior, drawn from the categories above or supplied by a data licensor.

Sources: Derived by us from information we hold; supplied by third-party data licensors and advertising platforms.

Purposes: Audience segmentation, targeting, personalization, lookalike modeling, and campaign optimization.

Sold or shared: Yes.

Sensitive Personal Information

"Sensitive personal information" is a defined subset under California law that includes government identifiers, account log-in credentials in combination with access credentials, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, the contents of certain communications where the business is not the intended recipient, genetic and biometric data, health information, and information concerning sex life or sexual orientation.

Acting for ourselves, the categories of sensitive personal information we collect are:

  • Account log-in credentials in combination with a password or other credentials allowing access to an account. We collect these only to authenticate you and secure your account.
  • Government identifiers — specifically, the taxpayer identification number appearing on the IRS Form W-9 or W-8 series form that affiliate program participants, vendors, and contractors must provide before we can pay them. For an individual or sole proprietor that number is a Social Security number. We collect it solely to meet our tax reporting and withholding obligations. See Affiliate Program Participants.

We use and disclose each of these categories only for purposes that California law permits without triggering the right to limit — performing the services requested, processing payments and meeting tax and withholding obligations, preventing and investigating security incidents and fraud, ensuring physical safety, short-term transient use, and verifying and maintaining the quality and safety of our services. We do not use sensitive personal information to infer characteristics about you, and we do not sell or share it.

Acting as a service provider for our clients, we operate customer relationship management, email, telephone, and messaging systems in which the contents of our clients' communications with third parties are stored. We access those contents only as necessary to provide the service our client engaged us for and as our contract with that client permits. That processing is governed by the client's own privacy policy, and requests concerning it should be directed to the client.

You may also voluntarily provide sensitive information in a chat, email, or form — for example, if you describe a health condition in a free-text field. Please do not submit sensitive information to us that we have not asked for. We do not require it, we do not want it, and if you provide it we will use it only to respond to you.

Limit the Use of My Sensitive Personal Information

Because we use sensitive personal information only for purposes California law permits without triggering the right to limit, and because we do not use it to infer characteristics about you and do not sell or share it, we are not required to provide a separate "Limit the Use of My Sensitive Personal Information" link. We nonetheless accept and act on requests to limit the use of sensitive personal information, and our Your Privacy Choices page includes that request type. If our practices change so that a separate mechanism is required, we will update this Policy and provide it. You may in any event contact us at privacy@frozencrow.com with a request concerning sensitive personal information and we will respond.

De-Identified and Aggregate Information

We take reasonable measures to ensure that information we treat as de-identified cannot be associated with, or reasonably linked to, an identifiable individual or household. We publicly commit to maintain and use such information only in de-identified form, and we do not attempt to reidentify it, except as expressly permitted by law to test the effectiveness of our own de-identification, in which case the test data is destroyed on completion. We contractually require any recipient of de-identified or aggregate information from us to comply with the same restrictions and to prohibit onward reidentification. De-identified and aggregate information is not personal information and is not subject to the rights described in this Policy.

Information We Collect Automatically

Server Logs

Our servers and our hosting provider automatically record technical information sent by your browser when you visit frozencrow.com, including your IP address, request method and path, response codes, timestamps, referring URL, user agent, and diagnostic and error data. We use log data to operate and secure the site, diagnose problems, detect abuse and automated traffic, and understand aggregate usage. Log retention is stated under Data Retention.

Analytics

We use Google Analytics 4, implemented through Google Site Kit, to understand how visitors find and use our website. Google Analytics sets cookies and identifiers and collects device and browser information, pages viewed, events, referring sources and campaign parameters, and approximate location derived from your IP address. We also use Google Search Console, which reports on how our pages appear in Google search results; Search Console does not track individual visitors on our site.

Advertising Pixels and Tags

We use advertising and conversion measurement technologies provided by advertising platforms, which may include Google advertising tags and the Meta (Facebook and Instagram) pixel and conversions interfaces, and comparable tags for other paid social, search, programmatic, and connected television platforms we use. These technologies allow us and those platforms to measure the performance of our advertising and to show you our advertisements on other websites, apps, and platforms. Activity of this kind constitutes a sale and/or a share of personal information under California law. See Do Not Sell or Share My Personal Information.

Live Chat and Online Booking

Our live chat and appointment booking are provided by our customer relationship management platform, GoHighLevel (HighLevel, Inc.), and are embedded from that provider's systems.

Live chat conversations are recorded and transcribed, and a service provider processes them on our behalf. By starting a chat with us you consent to that recording and transcription. Where we display a pre-chat notice, it says so and links to this Policy. The transcript, together with any name, email address, telephone number, or other information you enter, the page you were viewing, your approximate location, and your device and browser information, is stored and added to our records. We use transcripts to answer your question, follow up with you, train our team, resolve disputes, and improve our services, and we may contact you using the details you provide.

If you do not want a conversation recorded, do not use the chat widget. You can reach us instead by telephone at +1 (949) 749-0002 or by email at privacy@frozencrow.com. Please do not enter payment card numbers, passwords, government identification numbers, or health information into the chat.

Other Embedded Third-Party Components

Our website includes components supplied by third parties that may set cookies or receive your IP address, referring URL, and device information when the component loads, including an accessibility toolbar (accessiBe), review and social proof widgets (including Trustindex and Google Reviews components), e-commerce and checkout functionality (WooCommerce with Stripe), lead forms (WPForms), email marketing and automation (FluentCRM), and affiliate attribution (SliceWP). Which of these are service providers and which are third parties is explained under Disclosure of Personal Information.

Data We Obtain From Third-Party Sources

This section describes practices that are central to our business. We are stating them directly rather than in general terms.

If You Found Us Because Your Information Appeared in One of Our Audiences

You do not need an account, a purchase, or any prior relationship with us. Go to our Your Privacy Choices page, email privacy@frozencrow.com, or call +1 (949) 749-0002. Giving us the email address, telephone number, or postal address you want suppressed helps us find the record. We will suppress you from sale and sharing within 15 business days, we will not ask you to verify your identity to do it, and we will not charge you or treat you differently for asking. You may also ask us what we hold, ask us to correct it, and ask us to delete it.

Licensed Consumer and Business Audience Data

Frozen Crow licenses consumer and business audience data from a third-party database marketing platform and other data providers. We did not collect this information from you. Categories of information we obtain from these sources may include:

  • Name, postal address, email address, and telephone number, including mobile numbers;
  • Approximate geographic location, such as state, county, city, and postal code;
  • Demographic attributes and household attributes;
  • Inferred interests, purchase propensities, and consumer segments;
  • Online identifiers, including advertising identifiers and hashed email addresses used for audience matching;
  • For business records: company name, business address, standard industrial classification and industry codes, annual sales range, employee-count range, executive and management job titles, and business contact details for named individuals.

Where This Data Came From, and the Limits of What We Know

We require our data providers to represent that the information they supply was lawfully collected and may lawfully be licensed, deployed, and sublicensed for the marketing purposes described in this Policy, and that individuals received the notice and opt-out opportunity required by applicable law at the time of collection. If you want to know where a record we hold about you came from, ask us and we will identify the applicable provider and tell you what we are able to tell you about the source of that record.

We rely on those contractual representations. We were not present at collection, we do not receive a record of the notice any individual saw, and we do not receive the collection history of individual records. If you believe your information was included in a licensed audience without lawful notice or consent, tell us at privacy@frozencrow.com or through our Your Privacy Choices page, and we will suppress you and raise the matter with the provider. Licensed data may be incomplete, out of date, or inaccurate; if a record we hold about you is wrong, use the right to correct and we will act on it.

What We Do With Licensed Data

  • Build, segment, model, and analyze marketing audiences for ourselves and for our clients;
  • Publish aggregate audience summaries on our website — for example, total record counts, counts by state, industry classification breakdowns, executive title distributions, and business size ranges. These summary pages display aggregate counts only. They do not display, preview, or make downloadable any individual record, and we suppress result sets that are small enough that a count could be narrowed to identify a specific individual or business. Counts are supplied by our data provider, are estimates as of the date shown, and are not guaranteed;
  • Deploy marketing campaigns across email, paid social, paid search, programmatic and connected television, telephone outreach, and direct mail;
  • Make audience segments and prospect files available to contracted clients for their own marketing use, under a written license that restricts how they may use them;
  • Append and enrich records supplied by a client — where a client asks us to add attributes from licensed data to the client's own customer or prospect records. When we do this we act as that client's service provider, the client remains responsible for the lawfulness of the underlying list and of the resulting marketing, and the client's own privacy policy governs its use of the enriched records;
  • Match, enrich, and validate records we already hold; and
  • Apply suppression — removing from campaigns and files those records that must not be contacted.

Restrictions We Place on Clients Who Receive Audience Data

Where we license or deliver an audience segment or prospect file to a client, our terms require the client to: use it only for its own marketing, and not resell, sublicense, or re-broker it; obtain any consent required before calling, texting, or emailing anyone in it; scrub against the National Do Not Call Registry, applicable state registries, and its own internal do-not-call and suppression lists; honor opt-out, unsubscribe, and deletion requests it receives; apply any suppression instruction we forward to it; not use the data for any purpose described in Our Data Is Not a Consumer Report; and delete or stop using the data when the license ends.

We cannot monitor every client's use, and a client's breach of those terms is not within our control. If you tell us that a client contacted you unlawfully using data we provided, we will suppress you in our own systems, notify the client of your request, and take the action our agreement with that client permits, up to termination and a demand for destruction of the data.

Our Commitments Regarding Licensed Data

We do not knowingly include in any audience we build, license, deploy, or make available for download:

  • Information about an individual we know to be under 18 years of age;
  • Mobile telephone numbers, SMS opt-in records, or SMS consent data collected through our own messaging programs;
  • Records of individuals who have exercised an opt-out, unsubscribe, do-not-call, or deletion right with us, to the extent we can match them;
  • Precise geolocation, government identifiers, account credentials, health data, or other sensitive personal information; or
  • Chat transcripts, call recordings, or the contents of communications.

Your Rights Regarding Third-Party-Sourced Data

You may exercise every right described in this Policy with respect to information we obtained about you from a third-party source, even if you have never been our customer and have never contacted us. Contact us at privacy@frozencrow.com, call +1 (949) 749-0002, or use our Your Privacy Choices page. We will not discriminate against you for exercising these rights.

Two honest limitations you should understand:

  • Removing yourself from our systems does not remove you from the source database. Our data provider maintains its own records independently. On request we will identify the applicable provider and, where the provider offers one, direct you to its opt-out or deletion process.
  • We cannot retrieve data already delivered to a client. Where a prospect file was licensed and delivered before we received your request, that client holds its own copy. We will notify every third party to whom we sold or shared your personal information in the 90 days before your request and direct them to honor your opt-out, and our client license agreements require recipients to apply suppression instructions we forward to them. We do not, however, control what a recipient does with a file already in its possession. On request we will tell you who received your information so that you can contact them directly.

Other Third-Party Sources

We also obtain personal information from: our clients (contact and campaign data they supply or approve); advertising and social platforms (aggregate and, in limited cases, individual-level campaign and audience data); our payment processor (transaction outcomes and limited card metadata); public sources including government records, business registries, professional networking sites, and publicly accessible web pages; referral partners and affiliates; event and webinar co-hosts; and service providers acting on our behalf.

Our Data Is Not a Consumer Report

Frozen Crow Inc. is not a consumer reporting agency, and the audience data, prospect files, segments, and reports we provide are not consumer reports as defined by the Fair Credit Reporting Act and are not intended to be used as consumer reports. We do not assemble or evaluate information for the purpose of furnishing consumer reports, and our data is not collected, verified, or maintained to the standards of that Act.

We license and provide this data solely for marketing, advertising, audience building, market research, and prospecting. Neither we nor our clients may use it, in whole or in part, as a factor in establishing an individual's eligibility for credit, insurance, employment, housing or tenancy, educational admission, government benefits or licensing, or for any other purpose covered by the Fair Credit Reporting Act or a comparable state law, or for any other decision producing a legal or similarly significant effect concerning an individual. Our client agreements and data license terms expressly prohibit these uses, require the licensee to maintain reasonable controls against them, and permit us to terminate the license and require destruction of the data on breach.

If you believe data we licensed has been used for a purpose covered by the Fair Credit Reporting Act, contact us at privacy@frozencrow.com.

Consumer Health Data

Several states, including Washington and Nevada, regulate consumer health data — a category defined broadly enough in some states to include inferences about health status, condition, treatment, or reproductive or sexual health. We do not knowingly collect, license, deploy, sell, or share consumer health data, and we require our data providers to exclude health, condition, treatment, reproductive, and biometric attributes and inferences from the data they supply to us. If you are a resident of a state with a consumer health data law and you believe we hold consumer health data about you, contact us at privacy@frozencrow.com and we will investigate, delete it, and suppress the record.

How We Use Personal Information

We use personal information for the following business and commercial purposes:

  • Providing services. Delivering the marketing, advertising, search, information technology, communications, development, hosting, software, and data services our clients purchase; managing accounts; and providing support.
  • Communicating with you. Responding to inquiries, quotes, chats, calls, and support requests; sending transactional and administrative messages about accounts, orders, appointments, and services.
  • Marketing our own services. Sending email and, with consent, text messages; placing telephone calls; sending direct mail; delivering and measuring advertising; personalizing content and offers.
  • Audience building and deployment. Constructing, segmenting, modeling, matching, enriching, suppressing, licensing, and deploying marketing audiences and prospect files for ourselves and our clients.
  • Analytics and improvement. Measuring website and campaign performance, attribution, testing, research, and product and service development.
  • Payments and administration. Processing orders and subscriptions, invoicing, collections, affiliate commission calculation and payout, accounting, tax reporting, and audit.
  • Security and integrity. Detecting, investigating, and preventing fraud, abuse, spam, security incidents, and unlawful activity; protecting our systems, our clients, and the public; and debugging.
  • Legal compliance and defense. Complying with applicable law and legal process; responding to lawful requests from public authorities; establishing, exercising, and defending legal claims; enforcing our terms and agreements; and maintaining records required by law.
  • Corporate transactions. Evaluating, negotiating, and completing a merger, acquisition, financing, reorganization, or sale of all or part of our business or assets, including in bankruptcy or a similar proceeding.

We will not use personal information we previously collected for a materially different, unrelated, or incompatible purpose without first providing notice and, where the law requires it, obtaining your consent.

Automated Decision-Making

We use automation and algorithmic tools for audience segmentation, propensity modeling, lead scoring, campaign optimization, and spam and fraud detection. We do not use automated decision-making technology to make decisions that produce legal or similarly significant effects concerning you — such as decisions about credit, lending, housing, insurance, employment, education, or access to essential goods and services — and our data license terms prohibit our clients from using data we provide for those purposes. See Our Data Is Not a Consumer Report.

Disclosure of Personal Information

Service Providers and Third Parties — the Difference Matters

Service providers and contractors process personal information only on our behalf, under written contracts that limit them to the purposes we authorize, prohibit them from selling or sharing the information, and prohibit them from retaining, using, or disclosing it outside their direct business relationship with us. These include our hosting provider (SiteGround), our payment and e-commerce providers (Stripe, WooCommerce), our customer relationship management, booking, and chat provider (GoHighLevel / HighLevel, Inc.), our email marketing platform (FluentCRM), our form and workflow tools (WPForms, Uncanny Automator), our affiliate tracking platform (SliceWP), our accessibility tool (accessiBe), our messaging, telephony, and VOIP providers, and our professional advisors.

Third parties receive personal information for their own purposes. These include the advertising and analytics platforms whose tags run on our site and to which we upload audience data (including Google and Meta), our data licensors and audience partners, and our clients when we deliver audience data or prospect files to them. Disclosures to third parties in this second group constitute a sale or a share under California law, and you can stop them using the methods described under Do Not Sell or Share My Personal Information.

Some embedded components — including our accessibility toolbar, our review and social feed widgets, and our booking and chat widget — may receive your IP address, referring URL, and device information when they load. We will tell you which of these we treat as service providers and which as third parties on request at privacy@frozencrow.com.

Other Categories of Recipients

  • Professional advisors — accountants, auditors, insurers, bankers, and attorneys, under duties of confidentiality.
  • Affiliates and corporate entities under common ownership or control.
  • Government authorities, courts, and law enforcement — where required by law, subpoena, court order, or other legal process, or where we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, or to investigate fraud or respond to a lawful government request.
  • Acquirers and counterparties in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, subject to appropriate confidentiality protections.

Sale and Sharing of Personal Information

WE SELL AND SHARE PERSONAL INFORMATION AS THOSE TERMS ARE DEFINED UNDER CALIFORNIA LAW. We state this plainly because it is accurate and because you have the right to stop it.

Under California law, a sale is the disclosure of personal information to a third party for monetary or other valuable consideration. Sharing is the disclosure of personal information to a third party for cross-context behavioral advertising, whether or not for money. Both are subject to the same opt-out right.

How We Sell Personal Information

  • By licensing, delivering, or otherwise making available audience segments and prospect files to contracted clients and partners for their own marketing use, in exchange for fees.
  • By deploying licensed audiences on behalf of paying clients across email, paid social, search, programmatic, connected television, telephone, and direct mail channels.

How We Share Personal Information

  • By transmitting identifiers and audience data to advertising platforms — including Google and Meta — for custom audience matching, lookalike modeling, conversion measurement, and cross-context behavioral advertising.
  • By operating advertising and analytics cookies, pixels, and tags on frozencrow.com that transmit identifiers and browsing activity to those platforms.

WHAT WE NEVER SELL OR SHARE

To be precise about the limits of the disclosure above, we do not sell or share, and we do not include in any audience segment, prospect file, or data set we license or make available to any client or partner:

  • Mobile telephone numbers, text message opt-in records, or SMS consent data collected through our own messaging programs;
  • Live chat transcripts, call recordings, voicemail, or the contents of email you send us;
  • Payment card data, bank account details, or affiliate payout information;
  • Government identifiers, including taxpayer identification numbers collected from affiliates, vendors, and contractors;
  • Account log-in credentials or passwords;
  • Precise geolocation or consumer health data;
  • Records of individuals we know to be under 18;
  • Records of individuals who have opted out with us, other than the minimal suppression record needed to keep honoring that opt-out; or
  • Personal information we hold solely as a service provider or contractor on behalf of a client.

Where a category under Personal Information We Collect is marked as sold or shared, that marking refers to information of that category held in or derived from licensed audience data, our own marketing records, and website advertising and analytics activity — not to the items listed immediately above. In particular: a telephone number, including a mobile number, that appears in licensed audience data may be sold or shared as part of that data. We do not sell or share the record you create by giving us your number through our own text message opt-in or messaging program. Because those are two separate records from two separate sources, however, opting out of our messaging program does not by itself remove an independently licensed record containing the same number; to suppress both, submit a request through our Your Privacy Choices page. The distinction between information you gave us and information we licensed is explained under Text Messages.

Categories Sold or Shared in the Preceding Twelve Months

In the twelve months preceding the Last Updated date, we sold and/or shared the following categories of personal information, subject to the exclusions above: identifiers; customer records and contact information; commercial information; internet and electronic network activity information; approximate geolocation; professional and employment-related information; and inferences.

The categories of third parties to whom those categories were sold or shared are: advertising platforms and networks; data licensors and audience partners; analytics providers; and our clients and their authorized agencies and vendors.

Categories Disclosed for a Business Purpose

In the same period, we disclosed each category of personal information listed under Personal Information We Collect to service providers and contractors for the business purposes described under How We Use Personal Information, including hosting, analytics, communications, customer relationship management, payment processing, security, professional advice, and legal compliance.

Minors

We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. See Children's Privacy.

Do Not Sell or Share My Personal Information

YOU HAVE THE RIGHT TO DIRECT US NOT TO SELL OR SHARE YOUR PERSONAL INFORMATION. YOU DO NOT NEED TO BE OUR CUSTOMER TO EXERCISE THIS RIGHT, AND WE WILL NOT DISCRIMINATE AGAINST YOU FOR EXERCISING IT.

How to Opt Out

Use any of these. All of them work equally well, none requires an account, and we will not ask you to verify your identity to honor an opt-out.

  • Our opt-out page: https://frozencrow.com/your-privacy-choices/ — also reachable from the "Your Privacy Choices" link in the footer of frozencrow.com.
  • Email: privacy@frozencrow.com. Any message asking us to stop selling or sharing your information is enough.
  • Telephone: +1 (949) 749-0002.
  • Browser signal: send a Global Privacy Control signal; we honor it automatically for that browser.

It helps us find every record if you give us the email address, telephone number, and postal address you want suppressed, but none of that is required — give us whatever you are comfortable giving and we will suppress what we can match.

Opt-Out Preference Signals and Global Privacy Control

We treat a Global Privacy Control (GPC) signal transmitted by your browser or a browser extension as a valid request to opt out of the sale and sharing of personal information associated with that browser and device. When we detect the signal, before our advertising and analytics tags load we set them to deny advertising storage, advertising user data, advertising personalization, and analytics storage, so that the activity that would otherwise constitute a sale or share does not take place, and we apply the opt-out to any account we can associate with that browser.

Because a preference signal is tied to a single browser and device, it does not by itself apply to information we hold offline, in our customer relationship management system, or in licensed audience data. To apply your choice across all of our systems, including licensed audience data, submit a request using one of the methods above. If you clear cookies, change browsers, or use another device, you may need to send the signal again.

What Happens After You Opt Out

  • We will process your opt-out request within 15 business days of receipt.
  • We will notify the third parties to whom we sold or shared your personal information in the 90 days preceding your request and direct them to comply with your opt-out.
  • We will maintain your opt-out in a suppression record so that we do not re-add you to a sale or share audience. We retain that suppression record solely to honor your choice.
  • We will not ask you to reauthorize the sale or sharing of your personal information for at least 12 months after you opt out.
  • An opt-out from sale and sharing does not stop transactional or service communications relating to an active account, order, or engagement, and does not by itself delete information we hold. To request deletion, see Right to Delete.

Data Broker Laws and Deletion Requests

California, Texas, Oregon, and Vermont regulate businesses that sell personal information about consumers with whom they do not have a direct relationship. California maintains a public data broker registry and a centralized deletion mechanism through which California residents can submit a single deletion request that reaches participating businesses. We assess our obligations under these laws on an ongoing basis and comply with those that apply to us.

Your rights under this Policy do not depend on how we are classified under those statutes. Where we receive a deletion request submitted through California's centralized deletion mechanism, we process it on the schedule the law requires; where we cannot verify such a request, we treat it as a request to opt out of the sale and sharing of your personal information. You may also submit a deletion or opt-out request to us directly, at any time and at no cost, using our Your Privacy Choices page or any of the other methods described in this Policy.

Your California Privacy Rights

If you are a California resident, you have the following rights under the CCPA. These rights apply to information we obtained from third-party sources as well as to information you gave us directly.

Right to Know and Access

You may request that we disclose: the categories of personal information we collected about you; the categories of sources from which it was collected; the business or commercial purposes for collecting, selling, or sharing it; the categories of third parties to whom we disclosed, sold, or shared it; and the specific pieces of personal information we hold about you. You may also request a copy in a portable and, to the extent technically feasible, readily usable format.

Right to Delete

You may request that we delete personal information we hold about you. We honor deletion requests for information we collected from you directly and for information we obtained about you from third-party sources, including licensed audience data, whether or not you have ever been our customer. We will delete it from our records and direct our service providers and contractors to do the same.

Deletion is subject to the exceptions permitted by law. We may retain information where necessary to complete a transaction or provide a service you requested; detect, investigate, or prosecute security incidents or fraudulent, deceptive, or illegal activity; debug and repair errors; exercise free speech or another right provided by law; comply with a legal obligation or retain records the law requires; enable solely internal uses reasonably aligned with your expectations based on your relationship with us; or establish, exercise, or defend legal claims. We will also retain a minimal suppression record — typically an email address, telephone number, or record identifier — solely so that we can honor your request and avoid re-collecting or re-contacting you. If we decline a request in whole or in part, we will tell you and explain why.

Right to Correct

You may request that we correct inaccurate personal information we hold about you. We will consider the nature of the information, the purposes for which it is processed, and any documentation you provide. Because much of the audience data we hold comes from third-party licensors and may be inaccurate, incomplete, or out of date, we encourage correction requests — but correcting a record in our systems does not correct it at the source, and we will tell you how to reach the source provider so that you can correct it there as well.

Right to Opt Out of Sale and Sharing

You may direct us not to sell or share your personal information, as described under Do Not Sell or Share My Personal Information. We will not require you to verify your identity to honor an opt-out, although we may ask for information sufficient to locate your records, and we may require proof of authority where an agent submits the request for you.

Right to Limit Use of Sensitive Personal Information

Where a business uses or discloses sensitive personal information beyond the purposes permitted by law, consumers may direct it to limit that use. See Limit the Use of My Sensitive Personal Information.

Right to Non-Discrimination

We will not discriminate against you for exercising any privacy right. We will not deny you goods or services, charge you a different price or rate, impose penalties, provide a different level or quality of goods or services, or suggest that we will do any of those things because you exercised a right.

Financial Incentives

We do not offer financial incentives or price or service differences in exchange for the retention, sale, or sharing of personal information. Free resources we offer — such as an audit, guide, proposal, or assessment provided in exchange for your contact information — are provided so that we can respond to you and market our services. They are not conditioned on your agreeing to the sale or sharing of your information, and you may opt out of sale and sharing and still receive them.

How to Submit a Request

You may submit a request to know, delete, correct, or opt out by any of the following designated methods:

Verification

Except for opt-out requests, we must verify that you are the person about whom we hold information before we act. We will ask you to provide information that allows us to match your request against records we already hold — typically your name, email address, telephone number, and postal address, and for account holders, verification through your account. For requests seeking specific pieces of personal information, we apply a higher standard of verification and may ask for additional information or a signed declaration under penalty of perjury.

We use information you provide for verification only to verify your identity and process your request. We do not use it for any other purpose, and we do not add it to our marketing databases or to any audience. We retain a record of your request and our response for 24 months, as California regulations require, and we delete any verification material not needed for that record once your request is complete. If we cannot verify you, we will tell you and, where the request was a deletion request, we may treat it as an opt-out of sale and sharing instead.

Authorized Agents

You may use an authorized agent to submit a request on your behalf. We will require the agent to provide written permission signed by you, and we may contact you directly to confirm that you authorized the request and to verify your identity. If the agent has a valid power of attorney under California law, we will not require the additional written permission. For opt-out requests submitted by an agent, we will require proof that the agent is authorized but will not require you to verify your own identity.

Response Timelines

  • We will acknowledge receipt of a request to know, delete, or correct within 10 business days and describe how we will process it.
  • We will respond substantively within 45 calendar days of receipt. Where reasonably necessary, we may extend that period by an additional 45 days (90 days total), and we will notify you of the extension and the reason within the first 45-day period.
  • We will process opt-out requests within 15 business days.
  • Requests to know cover the 12-month period preceding the request unless a longer period is required by law and providing it would not be impossible or involve disproportionate effort.
  • Requests are free of charge. We are not required to provide the information responsive to a request to know more than twice in any 12-month period. There is no limit on how often you may opt out of the sale or sharing of your personal information, and we will always honor an opt-out. We may decline or charge a reasonable fee only for a request that is manifestly unfounded or excessive, and if we do we will tell you why.

California "Shine the Light"

California Civil Code Section 1798.83 gives California residents rights concerning the disclosure of personal information to third parties for those third parties' own direct marketing purposes. Frozen Crow maintains a policy of not disclosing your personal information to third parties for their own direct marketing purposes where you have directed us not to do so, and we provide a cost-free means of exercising that choice. To exercise it, use any of the methods under How to Opt Out, or email privacy@frozencrow.com with the subject line "Shine the Light Request." There is no charge, and we will confirm your election in writing.

Other U.S. State Privacy Rights

A growing number of U.S. states have enacted comprehensive consumer privacy laws. Depending on your state of residence, you may have some or all of the following rights, and the exact scope, exceptions, and thresholds vary by state:

  • Right to confirm and access the personal data we process about you;
  • Right to obtain a copy in a portable and readily usable format;
  • Right to correct inaccuracies;
  • Right to delete personal data we hold, including data we obtained from third-party sources;
  • Right to opt out of the sale of personal data;
  • Right to opt out of targeted advertising;
  • Right to opt out of profiling in furtherance of decisions producing legal or similarly significant effects;
  • Right to limit or withhold consent for processing of sensitive data, which several states require to be opt-in; and
  • Right to be free from discrimination for exercising these rights.

How to exercise these rights: use the same designated methods listed under How to Submit a Request. We handle all state privacy requests through a single intake process, and we will apply the rights available to you under the law of your state.

Appeals

Most states outside California give you the right to appeal a decision in which we decline to act on your request. To appeal, reply to our response or email privacy@frozencrow.com with the subject line "Privacy Request Appeal," and include the original request and the reason you believe our decision was incorrect. We will respond to the appeal within the period required by the applicable state law, and if we deny the appeal we will provide you with a method to contact your state attorney general to submit a complaint.

Universal Opt-Out Mechanisms

Several states require businesses to honor a universal opt-out mechanism or opt-out preference signal. We treat a detected Global Privacy Control signal as an opt-out of sale, sharing, and targeted advertising for that browser and device, regardless of the state you reside in. See Opt-Out Preference Signals and Global Privacy Control.

Nevada

Nevada residents may direct us not to sell covered information about them as Nevada law defines that term. Email privacy@frozencrow.com — including "Nevada" in the subject line helps us route it, but is not required — with your name, the email address associated with any account, and a statement that you do not want your covered information sold. We will respond within 60 days, and we may extend that period by up to 30 days where reasonably necessary, in which case we will tell you.

Email Marketing and Commercial Email

We send commercial and transactional email to prospects, clients, subscribers, affiliates, and audiences we are permitted to contact, using our email marketing and automation platform (FluentCRM) and our delivery providers.

How We Obtain Email Addresses

  • Directly from you — when you submit a form, request a quote, book a consultation, start a chat, create an account, make a purchase, subscribe, or join our affiliate program;
  • From your interactions with us — email you send us, calls you place to us, and events you attend;
  • From third-party data licensors — meaning we may hold your email address even though you never gave it to us;
  • From our clients — when we operate email campaigns on a client's behalf, the client supplies or approves the list and is responsible for the lawfulness of that list. In that role we act as the client's service provider.

Your Choices

  • Commercial email we send on our own behalf includes a functioning unsubscribe mechanism and our valid physical postal address, identifies the message as an advertisement where required, and uses accurate header and subject line information.
  • Where we operate an email program on a client's behalf, the client is the sender, the client's identity and postal address appear in the message, and unsubscribe requests are processed against the client's list. If you received such a message and want to reach the sender, use the unsubscribe link or reply-to address in that message. If you contact us instead, we will forward your request to the client and suppress your address in the systems we operate.
  • You may unsubscribe using the link in any message, or by emailing privacy@frozencrow.com with the address to be removed. We do not require you to log in, pay a fee, or provide any information beyond your email address and your opt-out preference.
  • We process unsubscribe requests promptly and, in any event, within 10 business days.
  • We maintain a suppression list of unsubscribed addresses, retained solely to prevent future mailings. Suppressed addresses are never used for any other purpose, sold, shared, or included in licensed audiences.
  • Unsubscribing from marketing email does not stop transactional or service messages relating to an active account, order, subscription, or engagement.
  • If you received a marketing email from us because your address appeared in a licensed audience, unsubscribing suppresses you across our own systems. It does not remove you from the third-party source database. Contact us and we will identify the applicable provider and, where one exists, provide its opt-out process.

Email Tracking

Our marketing emails may contain tracking pixels and coded links that tell us whether a message was opened, which links were clicked, the approximate time and location of the interaction, and the device and email client used. We use this to measure performance and tailor future messages. You can limit it by disabling remote image loading in your email client.

Text Messages (SMS/MMS)

  • Marketing text messages. We send marketing text messages only to individuals who have given us prior express written consent directly. We do not send marketing text messages to telephone numbers obtained from licensed audience data or from third-party lead sources.
  • How we obtain consent. Through a clearly labeled, separately checked, non-pre-checked opt-in on our forms, by written agreement, or by your text message request to a number we publish. Consent to receive marketing text messages is never a condition of purchasing any product or service.
  • Third-party consent. We do not treat a consent record obtained by a data provider or lead seller as prior express written consent to contact you on our behalf unless Frozen Crow Inc. was specifically identified to you by name at the time you gave that consent and the provider furnishes the underlying consent record on request.
  • Consent records. When you opt in, we record the date and time, the web page or document where consent was given, the exact disclosure language displayed to you, your IP address where available, and the identifying information you submitted. We retain this record as proof of consent for the period stated under Data Retention.

What to Expect

  • Program: Frozen Crow Inc. account, appointment, service, and marketing notifications.
  • Message frequency: Message frequency varies.
  • Cost: Message and data rates may apply. We do not charge for the messages; your wireless carrier's rates apply.
  • Carriers: Wireless carriers are not liable for delayed or undelivered messages.
  • Help: Reply HELP to any message, email privacy@frozencrow.com, or call +1 (949) 749-0002.

How to Stop

You may revoke consent at any time, by any reasonable means that clearly communicates that you no longer wish to receive messages. We do not require you to use any single method.

  • Reply STOP, QUIT, END, CANCEL, UNSUBSCRIBE, OPT-OUT, or REVOKE to any message from us;
  • Email privacy@frozencrow.com or call +1 (949) 749-0002 and tell us to stop;
  • Tell any Frozen Crow representative, in any channel, in writing or by voice.

After you reply STOP we will send a single confirmation message containing no marketing content, and then stop. We honor revocation as soon as practicable and in no event later than 10 business days after receipt. We apply your revocation across our messaging programs unless you tell us you want to continue receiving a specific type of message.

How We Handle Mobile Numbers and SMS Consent Data

MOBILE NUMBERS AND CONSENT RECORDS FROM OUR OWN MESSAGING PROGRAMS. Mobile telephone numbers, SMS opt-in records, and SMS consent data that you provide to us directly through our own forms, agreements, or messaging programs are used only to operate the messaging program you consented to. We do not sell, rent, license, share, or otherwise transfer that information to any third party or affiliate for that party's own marketing or promotional purposes. We disclose it only to the messaging platform, telecommunications, and technology providers that deliver messages on our behalf, only to the extent necessary for them to do so, and under contracts prohibiting any other use. We do not contribute mobile numbers or consent records collected through our own messaging programs to any audience data set that we license, resell, or make available to clients or partners, and we impose the same restriction on any third party operating a messaging program on our behalf.

Telephone numbers contained in licensed audience data are different, and we want you to understand the distinction. Audience data we license from third-party database marketing providers may contain telephone numbers, including mobile numbers, that we did not collect from you and that are not associated with any consent you gave us. Those records are part of the audience data we license and deploy, they are subject to the sale and sharing disclosures and the opt-out right described in this Policy, and we do not send marketing text messages to them. The commitments in the preceding paragraph apply to information you gave us; they do not describe licensed third-party data.

Telephone Calls and Call Recording

  • Automated or prerecorded marketing calls. We place marketing calls using an automatic telephone dialing system or an artificial or prerecorded voice only where we hold prior express written consent obtained directly from the called party, or where a recognized exemption applies.
  • Other outbound calls. Not every call we place rests on prior express written consent, and we do not claim that it does. We and our clients may place manually dialed, live-agent calls to telephone numbers contained in licensed audience data, including business telephone numbers, in reliance on the exemptions available under federal and state telemarketing law. You can stop those calls at any time by telling us on the call, by calling +1 (949) 749-0002, or by submitting a request through our Your Privacy Choices page.
  • Do-not-call requirements. Outbound telemarketing calls are subject to the National Do Not Call Registry, applicable state registries, and internal do-not-call requirements. Where we place telemarketing calls, we and our calling providers follow those requirements and keep the records the law requires, and our client and license terms require any client that calls using data we provide to scrub against those registries and against its own internal do-not-call list before calling.
  • Internal do-not-call list. If you ask us not to call you, we add you to our internal do-not-call list, honor the request within 10 business days, and retain the entry for at least five years. If you ask us to stop calling, we stop.
  • Calling hours. We place telemarketing calls only between 8:00 a.m. and 9:00 p.m. in the called party's local time.
  • Call recording. California is an all-party consent state. Where we record or monitor a call, we give the notice the law requires before or at the start of the recording, and continuing the call after that notice indicates your consent. If you do not want to be recorded, tell us and we will either stop the recording or end the call. Any recordings we make are used for quality assurance, training, dispute resolution, and record-keeping.

Our VOIP and Business Messaging Services

We also provide business telephone (VOIP) and business messaging services to our customers. When we do, our customer — not Frozen Crow — determines who is called or messaged, what is said, and whether the required consent exists. Our customer is responsible for compliance with telemarketing, do-not-call, messaging, carrier, and state law requirements. If you received a call or message from a business using our platform, please contact that business directly. If you contact us, we will make reasonable efforts to route your request to our customer and to suppress your number within our systems where we are able to do so.

Cookies and Tracking Technologies

We and our providers use cookies, pixels, tags, software development kits, local storage, and similar technologies on frozencrow.com. The categories we use are:

  • Strictly necessary. Session management, shopping cart and checkout, login state, security, load balancing, and fraud prevention, including identifiers set by our payment processor. These cannot be switched off without breaking the site.
  • Functional. Remembering preferences, accessibility settings set through our accessibility tool, and the state of our chat and booking widgets.
  • Analytics and performance. Google Analytics 4, which reports how visitors find and use the site.
  • Advertising and cross-context behavioral advertising. Advertising and conversion tags from Google, Meta, and other platforms we use. Some of this activity constitutes a sale or share of personal information under California law.
  • Affiliate attribution. A first-party cookie recording which affiliate referred you so commissions are credited correctly. Its lifespan is set in our affiliate tracking platform, and you can delete it at any time through your browser.
  • Consent notice. Our cookie notice lets you accept or reject non-essential cookies, and the choice you make is saved and applied. You can change that choice at any time using the Manage cookie preferences control on our Your Privacy Choices page.
  • Opt-out preference signals. We recognize Global Privacy Control as described under Opt-Out Preference Signals and Global Privacy Control.
  • Browser controls. Most browsers allow you to block or delete cookies. Blocking strictly necessary cookies will break parts of the site.
  • Platform controls. You can limit advertising personalization directly through Google's and Meta's own advertising settings, and through the industry opt-out tools operated by the Digital Advertising Alliance and the Network Advertising Initiative.
  • Do Not Track. Browsers may transmit a "Do Not Track" signal. There is no common industry standard for responding to it, and we do not respond to Do Not Track signals. We do respond to Global Privacy Control as described above.

Affiliate Program Participants

We operate an affiliate program. If you apply to or participate in it, we collect information beyond what we collect from ordinary website visitors, and we use it for different purposes.

What we collect from affiliates: your name, business name, email address, telephone number, postal address, website and social media URLs, the promotional methods you describe, login credentials for your affiliate dashboard, your referral link and referral activity, the orders and revenue attributed to you, commission balances, and payout records.

Tax information. Before we pay any commission we are required to collect a completed IRS Form W-9 (or a Form W-8 series form, where applicable). That form contains your taxpayer identification number, which for an individual or sole proprietor is your Social Security number. A Social Security number is a government identifier and is sensitive personal information under California law. We collect it solely to meet our tax reporting and withholding obligations. We use and disclose it only for that purpose and only to our accounting, tax, payment, and audit providers and to taxing authorities. We never sell it, share it, include it in any audience segment or prospect file, or use it to infer characteristics about you.

Payout information. We collect the details needed to pay you, which may include a payment-platform address or bank account and routing information. We use these only to make payments and to investigate payment failures, reversals, and disputes. We never sell or share them.

What we disclose to affiliates. We tell an affiliate the fact and value of a qualifying referral so that commissions can be calculated. We do not disclose to affiliates the identity, contact information, or purchase details of the people they refer.

Affiliate attribution cookie. When you click an affiliate's link to our site, we set a first-party cookie recording which affiliate referred you so commissions are credited correctly. Its lifespan is set in our affiliate tracking platform, and you can delete it at any time through your browser.

Testimonials, Reviews, Client Names, and Case Studies

We publish testimonials, reviews, client names and logos, and case studies describing work we have done. That involves personal information, so we describe it here.

Testimonials and Case Studies

Where we publish a named testimonial or a case study, we may publish the individual's name and, where relevant, their job title, company, photograph, the statement they gave us, and performance figures from that engagement. We publish this material on the basis of permission from the individual or organization concerned, and we will remove or amend it at their request. Where the person or organization has received anything of value from us in connection with the statement — including compensation, a discount, free or discounted services, or a commission under our affiliate program — we disclose that connection in or next to the testimonial.

About Published Results

Performance figures shown on our website describe the results of specific client engagements over specific periods, are supplied by or measured with the advertising and analytics platforms named, and are not a prediction, projection, or guarantee of the results any other client will achieve. Results vary based on budget, market, offer, competition, and factors outside our control. Frozen Crow does not guarantee any level of return on ad spend, revenue, ranking, traffic, or conversion. See our Terms and Conditions for the full results disclaimer.

Reviews Displayed From Third-Party Platforms

Our website displays review and social proof widgets that pull publicly posted reviews and ratings — including the reviewer's display name, profile image, star rating, review text, and date — from third-party platforms such as Google. We do not author, edit, or alter these reviews. The complete set of reviews for our business, including any that a widget on our site does not display, remains available on the source platform. The information originates from the platform, which collected it under its own privacy policy. Loading these widgets may allow the provider to set cookies and to receive your IP address, referring URL, and device information.

Withdrawal and Removal

If you gave us a testimonial, appear in a case study, or own a name, logo, or mark displayed on our website and you want it removed or changed, email privacy@frozencrow.com or call +1 (949) 749-0002. We will remove or amend the material on properties we control promptly after we verify the request, at no cost and without prejudice to anyone's rights. We cannot remove copies already distributed or printed, cached by search engines, or held by third parties outside our control. If you posted a review on a third-party platform and want it removed, you must do that through that platform.

Our Software, SaaS Products, and Games

In addition to our agency services, we operate our own software-as-a-service products and games. When you use one of them, we may collect: the account information you provide; device identifiers, operating system and application version, and crash and diagnostic data; in-app activity, progress, preferences, and settings; purchase and subscription records processed by our payment provider or by the application store through which you bought; and support correspondence.

Where a product is distributed through a third-party application store or platform, that store or platform collects information about your download, purchase, and device under its own privacy policy, and we receive only the limited information it passes to us.

Our software and games are intended for users 18 years of age and older. We do not direct them to children, we do not knowingly collect personal information from children, and we do not use in-application advertising identifiers to build any audience that we license, deploy, or resell. Where a specific product's data practices differ from this Policy, the notice made available within that product governs for that product. See also Children's Privacy.

Data Retention

We retain personal information for as long as it is needed for the purposes described in this Policy, on the basis described below, and then delete or de-identify it. Actual retention may be longer where a legal hold, an open dispute, an audit, or a legal obligation requires it.

  • Prospect and lead records — for as long as the record remains relevant to an active or prospective business relationship, after which we delete or de-identify it unless you have become a client, an active subscriber, or an affiliate. We review inactive records periodically.
  • Client account, engagement, and deliverable records — for the term of the engagement and for the period afterward required by our contracts, our accounting and audit obligations, and the applicable statutes of limitation.
  • Order, invoice, payment, and tax records — for the period required by applicable tax, accounting, and corporate record-keeping law.
  • Automatic renewal and subscription consent records — at least three years from the date consent was given, or one year after the subscription terminates, whichever is longer, as California's automatic renewal law requires. These records include the date and time of consent, the automatic renewal terms displayed, and the acknowledgment we sent you.
  • Text message consent records — for at least the period required by applicable telemarketing law after consent is given or revoked, so that we can demonstrate compliance and defend claims.
  • Unsubscribe records, do-not-call entries, and suppression lists — retained for as long as necessary to continue honoring your choice, which for suppression entries means indefinitely, and used for no other purpose.
  • Sensitive personal information — account credentials are retained for the life of the account and deleted or rendered unusable promptly after closure; taxpayer identification numbers and tax forms are retained for the period required by federal and California tax and record-keeping law and then destroyed.
  • Affiliate referral, commission, payout, and clawback records — for the period required by applicable tax and record-keeping law, and for as long as needed for audit and dispute purposes.
  • Licensed audience data — for the term of the applicable data license, and deleted, returned, or rendered unusable on expiry or termination in accordance with that license. Records suppressed at your request are retained only in suppression form.
  • Website analytics, server logs, and advertising identifiers — server logs for the limited period needed for security, diagnostics, and abuse detection; Google Analytics user and event data for the period set by the data-retention setting configured in our Analytics property.
  • Chat transcripts and any call recordings — for the period needed for the purposes for which they were created, including support, quality assurance, training, dispute resolution, and record-keeping, and longer where an open dispute or legal hold requires it.
  • Consumer privacy requests and our responses — 24 months, as California regulations require.
  • Chargeback, payment dispute, and fraud investigation records — until the matter is resolved and for the period afterward needed to address related claims and to satisfy card network and processor requirements.
  • Security and incident records — for the period needed to investigate, remediate, and defend claims relating to the incident, and to satisfy any applicable legal requirement.

Where a period above depends on circumstances, the criteria we apply are: the nature and sensitivity of the information; whether the purpose for which it was collected remains active; whether you remain a client, prospect, subscriber, or affiliate; applicable statutes of limitation; contractual and license obligations; and applicable legal, tax, and audit requirements.

Security

We implement and maintain reasonable administrative, technical, physical, and organizational security procedures and practices appropriate to the nature of the personal information we hold, designed to protect it against unauthorized access, use, disclosure, alteration, and destruction. The specific safeguards we use vary by system and by the sensitivity of the information involved, and we review and update them as our systems, our vendors, and the risks we face change. As described under Customer Records and Contact Information, full payment card numbers and card security codes are not stored on our own systems; card data is transmitted directly to and processed by our payment processor.

NO SYSTEM IS IMPENETRABLE. NO METHOD OF TRANSMISSION OVER THE INTERNET AND NO METHOD OF ELECTRONIC STORAGE IS COMPLETELY SECURE. WHILE WE WORK TO PROTECT PERSONAL INFORMATION, WE CANNOT GUARANTEE THAT OUR SYSTEMS OR THOSE OF OUR SERVICE PROVIDERS WILL NEVER BE SUBJECT TO UNAUTHORIZED ACCESS, AND TO THE FULLEST EXTENT PERMITTED BY LAW WE DO NOT ASSUME LIABILITY FOR EVENTS OUTSIDE OUR REASONABLE CONTROL.

Nothing in this Policy limits, waives, or is intended to limit or waive any right or remedy you have under the California Consumer Privacy Act, including its private right of action for a data breach resulting from a failure to implement and maintain reasonable security procedures, or under any other law providing rights that may not be waived. Nothing in this Policy limits any liability that cannot lawfully be limited, including liability for fraud, willful misconduct, or gross negligence.

You are responsible for keeping your account credentials confidential, for using a unique and strong password, and for notifying us promptly at privacy@frozencrow.com or +1 (949) 749-0002 if you believe your account has been compromised. We will notify affected individuals and regulators of a security incident where and as required by applicable law.

Children's Privacy

Our website, our agency and technology services, and our business software are intended for businesses and for adults 18 years of age and older, and are not directed to children. We do not knowingly collect personal information from anyone under 18.

Where we publish a game or consumer application, the age rating, audience, and data practices of that product are described in the notice made available within that product. Where a product is directed to or knowingly used by children, we obtain verifiable parental consent and limit collection as required by the Children's Online Privacy Protection Act before collecting any personal information from a child.

We require our audience data providers to warrant in writing that licensed records exclude known minors, and we apply age suppression to audiences we build, license, deploy, or make available. We do not knowingly sell or share the personal information of consumers under 16 years of age. If you believe we hold information about a person under 18, or that a record concerning a minor appears in data we hold, contact us at privacy@frozencrow.com; we will investigate, delete the information, and add a suppression record.

Our website, emails, and communications may contain links to, and embedded content from, websites, platforms, and services operated by third parties, including advertising and social platforms, review platforms, our booking and chat provider, our payment processor, and our clients' properties. We do not control these third parties, we do not endorse them, and we are not responsible for their content, security, data practices, or privacy policies. Information you provide directly to a third party is governed by that party's own privacy policy and terms, and we encourage you to read them. Clicking a link or interacting with an embedded component may allow that third party to collect information about you independently of us.

Visitors From Outside the United States

Frozen Crow Inc. is a United States business. Our website, services, products, and marketing are directed to the United States market. We do not offer goods or services to, and do not intentionally monitor the behavior of, individuals located in the European Economic Area, the United Kingdom, or Switzerland, and we do not intentionally license, build, or deploy audience data concerning individuals located in those jurisdictions.

Our website is nonetheless reachable worldwide. If you access our website or provide information to us from outside the United States, you do so at your own initiative, and you understand that your information will be transferred to, processed in, and stored in the United States, where data protection law differs from, and may offer less protection than, the law of your country.

If you believe we hold personal data about you and you are located in a jurisdiction whose law applies to that processing, contact us at privacy@frozencrow.com and we will address your request, including any request to access, correct, delete, restrict, or object to processing, to receive a copy in a portable format, or to withdraw consent. You may also have the right to lodge a complaint with your supervisory authority.

Automated and AI-Generated Content

Some content published on frozencrow.com, including certain blog articles and accompanying images, is generated using artificial intelligence tools and published on an automated schedule. That content is topical, is not generated from and does not incorporate personal information about our visitors, prospects, or clients, is not individually reviewed before publication, may contain errors or outdated information, does not describe any specific client engagement or result, and should not be relied on as advice. Articles generated this way are labeled as such. See our Terms and Conditions for the applicable disclaimer.

Artificial intelligence features in the tools we use. Several of the platforms we use to run our business — including our customer relationship management, email marketing, support, accessibility, and productivity tools — include artificial intelligence features that may process information you submit to us, such as summarizing a chat transcript, drafting a reply, or scoring a lead. Where they do, those providers act as our service providers under contracts that restrict them to processing the information for the purposes we authorize.

We require our artificial intelligence vendors to refrain from using information we submit to train their general-purpose models, and it is not our practice to submit personal information collected through this website to generative artificial intelligence tools. We do not use artificial intelligence or other automated decision-making technology to make decisions that produce legal or similarly significant effects concerning any individual. See Automated Decision-Making.

General

No waiver of rights. Nothing in this Policy waives, limits, or is intended to waive or limit any right or remedy available to you under the California Consumer Privacy Act, any other state or federal privacy or consumer protection law, or any other law providing rights that may not be waived by agreement. Nothing in this Policy limits liability for fraud, willful misconduct, or gross negligence, or any other liability that may not lawfully be limited. Where any statement in this Policy conflicts with a right the law gives you, the law controls.

Severability. If any provision of this Policy is held invalid, unenforceable, or inapplicable in whole or in part, that provision is modified to the minimum extent necessary to make it enforceable, or if it cannot be so modified, is severed, and the remaining provisions remain in full force and effect.

Relationship to our agreements. This Policy describes our privacy practices. It is a notice, not a contract, and it does not create rights or obligations beyond those provided by applicable law or by a written agreement between you and Frozen Crow. Where you have a signed agreement with us, that agreement governs the services we provide; this Policy governs how we handle personal information. Where a data processing agreement between Frozen Crow and a client conflicts with this Policy as to information we process on that client's behalf, the data processing agreement controls.

Accessibility. We work to make this Policy accessible to individuals with disabilities. If you use assistive technology and have difficulty accessing this Policy, or if you need it or help exercising a privacy right in an alternative format, contact privacy@frozencrow.com or call +1 (949) 749-0002 and we will provide it in a format you can use. We will not require you to use an inaccessible channel to exercise a privacy right.

Languages. If we provide this Policy in a language other than English and the versions conflict, contact us and we will resolve the discrepancy in the manner most protective of your rights.

Changes to This Policy

We may update this Policy to reflect changes in our practices, our technology, or applicable law. When we do, we will post the revised Policy on this page and update the "Last Updated" date. Where a change is material, we will provide notice before the change takes effect, which may include a prominent notice on our website or a message to the email address associated with your account.

We will not use personal information we previously collected for a materially different purpose that is incompatible with the purpose disclosed at the time of collection without first providing you notice and, where the law requires it, obtaining your consent. Changes to this Policy apply going forward from their effective date. We update this Policy, including the twelve-month collection, sale, sharing, and disclosure statements, at least once every twelve months. Prior versions are available on request at privacy@frozencrow.com.

Contact Us

If you have questions about this Policy, want to exercise a privacy right, or want to raise a concern about how we handle personal information, contact us:

  • Frozen Crow Inc.
  • Privacy requests, legal notices, and accessibility assistance: privacy@frozencrow.com
  • Privacy request form: https://frozencrow.com/your-privacy-choices/
  • Telephone: +1 (949) 749-0002 — Monday through Friday, 9:00 a.m. to 6:00 p.m. Pacific time; Saturday and Sunday by appointment
  • Website: https://frozencrow.com

If you are dissatisfied with our response, you may have the right to lodge a complaint with your state attorney general, the California Privacy Protection Agency, or, where applicable, your local data protection authority.