CFO Advisors LLC, doing business as CFO Advisors ("CFO Advisors," "we," "us," or "our"), offers fractional CFO services. This Privacy Policy ("Privacy Policy") outlines our practices in processing personal information concerning the marketing and sale of our services to potential customers, the delivery of services to our clients, and the overall operation of our business.
We gather, utilize, and disclose information primarily for the purpose of marketing, selling, and providing services to businesses and organizations within the United States, rather than individual consumers. In instances where we process personal information about an individual ("you"), it is either for the purpose of marketing and selling to the organization employing you (or with which you are associated) or in connection with (a) delivering our services to the organization that has collected your data and (b) enhancing or operating our services. As service providers to organizations, we do not intentionally process data of individuals under the age of sixteen.
For inquiries about our Privacy Policy or practices, or if you are a resident of California or Virginia and would like to exercise any of the rights outlined below, please reach out to us at startups@cfoadvisors.com.
Our Privacy Policy encompasses the following sections:
INFORMATION FOR PROSPECTIVE CUSTOMERS
This section pertains to you if you are a visitor to our website, if you have participated in an event organized or sponsored by CFO Advisors (whether online or in person), if we have acquired your contact information through our various marketing and sales initiatives (such as referrals, lead purchases, or marketing surveys), or if you are in the process of acquiring our Services on behalf of your employer.
Information We Process
The types of personal information we gathered within the past twelve months in the course of our sales and marketing endeavors, along with the sources from which we acquire this personal information, are detailed in the table provided below. Additionally, the "General Information" section outlines disclosures of personal information beyond CFO Advisors.
Personal Information Category
Example
Source(s)
Website visitor; Event attendee; Referral, lead purchase, or other marketing; Representative of prospective customer purchasing Services
Identifiers
∙ Name
∙ Business email address
∙ Business phone number
∙ Business address
∙ You, if you choose to provide your name and contact information
∙ Someone else in your organization if they provide us with your name and business contact information
∙ An acquaintance of yours who thinks your organization could use our Services may provide us with your business contact information
∙ Our third-party data enrichment vendors
∙ Publicly available information
∙ Social media sites
∙ Promotional partners
∙ Integration partners
∙ Lead sellers
Employment-related information
∙ Your employer’s name
∙ Your job title
∙ You, if you choose to provide this information
∙ Someone else in your organization if they provide us with your name, title and the company where you work
∙ An acquaintance of yours who thinks your organization could use our Services may provide us with your business contact information
∙ Our third-party data enrichment vendors
∙ Publicly available information
∙ Social media sites
∙ Promotional partners
∙ Integration partners
∙ Lead sellers
Website visitor; Representative of prospective customer purchasing Services
Identifiers
∙ Internet protocol (IP) address
∙ Cookie identifier
∙ Our tools for measuring activity on and use of our website collect your IP address and set Cookies on your browser
∙ Our tools for identifying the organization with which you are associated based on your IP address collect your IP address
Internet activity information
∙ Information about your visit to our websites, including referring pages and your navigation through our websites
∙ Information about your interactions with our marketing emails
∙ Our tools for managing email campaigns
∙ Our tools for measuring activity on and use of our website and engagement with email marketing efforts, which include the use of Cookies
∙ Our tools for monitoring the effectiveness of our advertising and sales campaigns, which include the use of Cookies
Inferences from personal information
∙ Analysis of effective ways to position our products by sales personnel based on communications with you and/or your engagement with our website or marketing materials
∙ Sales and marketing service providers that provide scoring and analytical tools
Geolocation data
∙ IP address
∙ Our tools for measuring activity on and use of our website collect your IP address
Event attendee
Other
∙ Dietary restrictions (for example, if you attend a live event)
∙ You
Event attendee; Representative of prospective customer purchasing Services
Audio and visual information
∙ Recording of your voice and likeness in calls or videoconferences with our sales and service delivery personnel
∙ Recording of your voice and likeness at events, if you attend an event, such as a virtual event, and ask a question that is recorded
∙ You, with your consent as required by law
How We Use Your Information
We gather and process personal information for the business purposes of marketing and selling our Services. Our processing of your personal information is aimed at establishing an agreement to provide our Services to your employer or the organization with which you are associated. This involves, for instance:
It is important to note that during the sales process, you may provide samples of your business's financial data or grant access to repositories containing such data. This information is utilized to determine the appropriate Services to quote you. While this financial data may include personal information, we do not control its content. We only use it as part of your financial transactions data to assess the suitable Services for quoting. If you provide this sample financial data, we store it in our email and file storage systems and analyze it using software tools provided by our service providers.
Operation of Our Corporate Website
Cookies and Tracking Technologies: In adherence to applicable laws, CFO Advisors, our service providers, and other third-party website service providers whose services we employ on our corporate website utilize commonly-used tools such as cookies, web beacons, pixels, local shared objects, local storage, event trackers, and other tracking technologies (collectively referred to as "Cookies") to recognize your visit and monitor your interactions with our corporate website, including subpages.
We leverage this tracking data to manage our corporate website effectively. For instance, we use Cookies to personalize and enhance your experience on our corporate website, as well as to record your preferences. If you identify yourself on our corporate website, such as by completing a web form, we match your identifying information with a Cookie associated with you (which does not identify you by name, email, or phone number). This matching aids in analyzing the effectiveness of our marketing efforts, communicating with you, providing relevant information, and determining sales efforts tailored to your company.
It's important to note that third-party website service providers may collect personal information from visitors to our websites for their own purposes.
Additionally, we utilize Google Analytics to analyze visitor interactions with our corporate website. When visiting a website with Google Analytics enabled, the URL of the webpage and your internet protocol address are sent to Google for analytics services. Google also reads Google Analytics Cookies placed on your browser when you visit our corporate website. Please refer to Google's Privacy & Terms for more information.
Social Media Features: Our corporate website incorporates social media features (e.g., buttons) enabling content sharing on social media platforms ("Social Media Features"). These may collect your internet protocol address, the page you are visiting within our corporate website, and may set a Cookie to enable proper feature functionality. Interactions with these features are subject to the privacy policy of the company providing the relevant Social Media Features.
Links to Other Sites: Our corporate website contains links to other websites with privacy practices that may differ from those of CFO Advisors. If you visit or submit personal information to any of these sites, your information is governed by their privacy policies. We recommend carefully reading the privacy policy of any website you visit.
Re-targeted Advertising: Re-targeted or behavioral advertising utilizes information about an individual's web browsing behavior to display more relevant ads. The information is linked to a cookie ID. Opt-out options for re-targeted advertising from CFO Advisors can be accessed through the opt-out pages of the Network Advertising Initiative and the Digital Advertising Alliance. Residents of California or Virginia may also opt-out of our corporate website placing targeting Cookies by clicking the "Do not sell or share my personal information" link at the bottom of our corporate website. Note that this does not opt you out of receiving generic ads.
Retention of Information for Prospective Customers: We retain your business contact information and related sales and marketing activity in our systems to maintain records of relationships, analyze and improve efforts and services, comply with legal obligations, resolve disputes, enforce agreements, complete transactions, and prevent fraud. This information is generally retained until either your request for deletion or our determination that it is no longer needed for marketing and selling services to your employer. Business email addresses may be retained indefinitely for record-keeping of email marketing opt-out or deletion requests.
If you have not identified yourself on our website, the primary marketing tool we use to monitor website and email marketing activity deletes records of your visit or email engagement starting 90 days or 365 days after your last activity, following their retention policies. Retention of internet activity information collected by third-party website service providers is determined by the applicable third party.
INFORMATION FOR CUSTOMERS
This section is relevant if you are affiliated with one of our customers and seek to understand how we handle personal data in the context of providing our Services and managing our business.
Information Processing:
In the provision of our Services, we process three categories of data: Customer Data, Business Records Data, and Administrative Data. The following sections elaborate on each data category, outlining the purposes of processing and the duration of retention. The "General Information" section details disclosures of personal information beyond CFO Advisors.
Customer Data:
Customer Data comprises information provided by our customers or at their direction for the provision of services, including financial and business information. This information may be sourced directly from customers or authorized third-party data repositories. Examples include transaction data from payment processing services, payroll providers, or other relevant service providers. It may also involve metadata from these repositories.
This data may include personal information such as identifiers, names of individuals, relationships with our customers, commercial or employment-related information, and details related to entities. For tax preparation, it may encompass corporate officers' and directors' names, ownership information, business contact details, and social security numbers. Stock administration services may involve employment status, personal contact information, and social security numbers.
Customer Data also includes financial information generated during service provision, such as reports of financial data and statements prepared on behalf of customers. For long-term customers subscribing to multiple services, information from prior years may be used for current services.
Important Note: Customers grant us access to third-party systems, and the information practices of these third parties are governed by their respective privacy policies and data governance programs, beyond CFO Advisors’s control.
How we use Customer Data:
We process Customer Data on behalf of customers to provide, monitor, and improve our Services. This includes:
Additionally, we may process Customer Data for customer service, technical support, and research purposes. In research, we may share non-identifiable information about customers for academic, marketing, or promotional purposes.
Retention of Customer Data:
Except as discussed for Business Records Data, tax-related Customer Data is retained for at least seven years, and other Customer Data is retained for post-termination assistance, legal obligations, dispute resolution, agreement enforcement, transaction completion, and fraud prevention. The retention period generally extends until we receive a deletion request, and we take steps to remove or de-identify non-Business Record Data. Former customer credentials are queued for deletion 120 days after the relationship ends.
Business Record Data:
In delivering our Services, our personnel communicate with customer representatives through various channels, generating Business Record Data. This includes customer instructions, authorizations, work papers, and information related to service delivery. The types of personal information collected and sources are detailed in the following table.
Personal Information Category
Example
Source(s)
Identifiers
∙ Name
∙ Business email address
∙ Business phone number
∙ Business address
∙ Individual points of contact of our customers who correspond with us as we provide our services.
∙ Customer points of contact provide personal information about additional points of contact.
Employment-related information
∙ Your employer’s name and your job title
∙ Individual points of contact of our customers who correspond with us as we provide our services, for example, a job title commonly appears in an email signature.
∙ Customer points of contact provide personal information about additional points of contact.
Audio and visual information
∙ Recording of your voice and likeness in calls or video conferences with our sales and service delivery personnel
∙ Individual points of contact of our customers who participate in calls or video conferences, with their consent
Inferences from personal information
∙ Customer satisfaction survey results
∙ Individual points of contact of our customers who respond to customer satisfaction surveys
How we Utilize Business Record Data: We gather and process Business Record Data for our business operations, encompassing activities such as:
Retention of Business Record Data: We retain Business Record Data to document customer instructions and approvals, maintain a record of customer relationships, comply with legal obligations, resolve disputes, enforce agreements, complete transactions, and prevent fraud. This data is retained for as long as we have a legal or business justification, at least until the end of the longest applicable statute of limitations period. The deletion of this data may occur earlier if deemed unnecessary for the mentioned purposes. If Customer Data is present in emails, messages, or call recordings within Business Record Data, it is incidental to our primary purpose and processed solely for recordkeeping and legal purposes within the context of our business relationships. The retention period for service fulfillment partners is subject to the service fulfillment partners' privacy policy and data governance practices.
Administrative Data: Administrative Data encompasses information related to Service management (e.g., user account credentials, billing details), usage of our Services (e.g., log data, metadata from service delivery communications), information derived from Customer Data for service delivery, sales, marketing, and operational purposes, and Usage Data.
Categories of Personal Information: The table below outlines the categories of personal information collected in the last twelve months and the sources from which this information is obtained.
Personal Information Category
Example
Source(s)
Identifiers
∙ Name
∙ Business email address
∙ Business phone number
∙ Business address
∙ Internet protocol address
∙ Cookie identifiers
∙ You, if you choose to provide this information
∙ Individual points of contact of our customers who correspond with us as we provide our services.
∙ Customer points of contact provide personal information about additional points of contact
∙ CFO Advisors’s systems collect identifiers like internet protocol addresses and Cookies automatically
Employment-related information
∙ Your employer’s name and your job title
∙ You, if you choose to provide this information
∙ Our third-party data enrichment services
Internet activity information
∙ Information about a user’s navigation through our application
∙ Your responses to a customer satisfaction survey included in the email signatures of correspondence related to CFO Advisors Services
∙ Our tools for measuring activity on and use of our application, which include the use of Cookies
Inferences from personal information
∙ Analysis of effective ways to improve our services for all customers
∙ Our analysis of metadata that we collect about the use of our products and services
How we Utilize Administrative Data: We gather and process Administrative Data for various business purposes, encompassing:
Account Registration: We may utilize your name, business address, business phone number, and business email address for account registration in certain Services we offer. This information is also used for communication purposes, including the conveyance of crucial information. If your account is accessible to others, please be aware that they may view and potentially modify or erase your personal information.
To Provide Our Services and Operate Our Business: We leverage your information to operate our business, deliver Services to your employer, offer support related to our Services, and safeguard our Services against fraud. For instance:
Customer Service and Technical Support: Your name, business address, business phone number, business email address, interaction details with our Services, and information about your computer configuration may be utilized for resolving queries and following up on your experience.
Communication and Offers: We may use your business contact information to communicate about our Services and extend offers for third-party products and services (e.g., Integration Partners) that may be beneficial to you.
Improving and Developing Services: Administrative Data aids in personalizing user experiences, developing new features or services, and enhancing the overall quality of our Services. This includes the collection of Usage Data to improve our application.
Feedback and Research: Suggestions and survey responses may be used to better understand Services and improve them. Participation in surveys is optional.
Research Sharing: Non-identifiable information about customers may be shared with third parties for research, academic, marketing, or promotional purposes. Aggregated findings may be publicly reported in a manner that does not allow identification of individual customers.
Retention of Administrative Data: We retain Administrative Data as long as necessary for service provision, maintaining customer accounts, legal compliance, dispute resolution, agreement enforcement, fraud detection and prevention, service improvement, new service development, and other business uses. Administrative Data is retained according to applicable laws and CFO Advisors’s records management policies. Specific types of Administrative Data, such as the record of a customer's account existence, billing information, and associated individuals, are retained indefinitely. When an account is closed, we may continue to communicate about Services, provide essential business updates, and, unless opted out, share information about relevant products and services.
GENERAL INFORMATION
Call Recordings: As previously mentioned, we capture calls and video conferences during both sales and service delivery interactions. These recordings encompass participant identifiers, such as names, and include audio and visual elements if participants have cameras enabled in video conferences. These recordings serve various purposes, including training, note-taking, service delivery, process analysis and optimization, recordkeeping (e.g., as Business Record information), and research and development. Access to these recordings is granted to CFO Advisors personnel requiring it for these business functions. The recordings are stored in our systems, including those of our vendors utilized for storage and analysis. We retain recordings until either you request deletion of your information (subject to any legal limitations) or we determine that the information is no longer needed for the initially intended purpose, typically within a three-year timeframe.
How We Disclose Your Personal Information: In the course of delivering our Services and managing our business, personal information is disclosed outside of CFO Advisors in the following ways:
Service Providers: We share information, including personal data and Usage Data, with service providers performing various functions to support our Services and business operations. These functions include website design, telephony and system administration, marketing, sales, customer support, data enrichment, email communications, communication management, fraud detection and prevention, data storage, and analytics. Our agreements with these third parties mandate confidentiality, restricting the use of personal information to specified purposes.
Service Fulfillment Partners: Non-affiliated tax service providers, fulfilling specific Services, may receive customer business contact information and Customer Data for service fulfillment purposes. These partners' activities are governed by their privacy policies.
Integration Partners: We access Customer Data through integrations with vendors providing back office or financial services. Information exchange enhances service efficiency, and disclosures are made in accordance with the privacy policies of these integration partners.
Promotional Partners: Events or content presented with partners may involve sharing attendee information, with attendees' consent, for subsequent partner contact. Partner activities adhere to their respective privacy policies.
Third Party Website Services Providers: Non-service provider third parties, such as ad networks and analytics services, are used on our website for marketing and analytics purposes.
Response to Legal Requests: Information may be shared with courts, law enforcement agencies, or other government bodies when required by law, court order, subpoena, search warrant, or other legal request.
Protection of CFO Advisors and Others: Account information, personal data, and Usage Data may be shared to enforce agreements, protect CFO Advisors, Services, users, or others, including fraud protection and credit risk reduction.
Affiliates: Information may be disclosed to affiliates for service delivery purposes.
Sale of Our Business: In the event of a sale, merger, or transfer of our business, information may be transferred to the acquiring entity.
Business Advisors: Professional advisors, subject to confidentiality requirements, may receive information for consultation purposes.
Per Customer Instructions: At the direction of a CFO Advisors customer's authorized representative, information may be disclosed to third parties, including personal information.
With Your Consent: Except as outlined above, notice and an opportunity to choose will be provided before sharing personal information with other third parties.
De-identified and Aggregated Data: Once de-identified or aggregated, data no longer constitutes personal information and may be used and retained for any purpose.
International Data Transfers: In accordance with applicable laws, we may transfer, process, and store information outside your country of residence to locations where we or our third-party service providers operate.
How to Contact Us: For questions or comments about this Privacy Policy, please contact us via email at startups@cfoadvisors.com or via direct mail at CFO Advisors LLC dba CFO Advisors, 555 Salvatierra Walk, Stanford, CA 94305.
Changes to Our Privacy Policy: We reserve the right to make changes or updates to our Privacy Policy, with notice provided through our Services or other communication channels.
Your Rights and Managing Your Privacy: You have the right to update information, access and review your personal information, and request corrections or deletions. Instructions for managing marketing communications, SMS communications, Cookies, and tracking technologies are provided. Our Services and corporate website do not currently respond to browsers' "Do Not Track" signals.
California and Virginia Privacy Rights
California and Virginia Privacy Rights: If you fall under the purview of the California Consumer Privacy Act (CCPA) or the Virginia Consumer Data Protection Act (VCDPA), for instance, if you are deemed a "consumer" as per the CCPA, you possess the subsequent rights concerning personal information handled by us in our role as a "business" under the CCPA or "controller" under the VCDPA. This includes personal information outlined in the following sections and subsections:
A. "Information for Prospective Customers," B. "Information for Customers" a. "Business Record Data" (excluding any "Customer Data" within "Business Record Data") and b. "Administrative Data" sections of "Information for Customers," C. "General Information" a. "Call Recordings"
Upon submitting a verifiable consumer request, you reserve the right, subject to the CCPA or VCDPA as applicable: • To obtain disclosure regarding: o The categories of personal information collected about you; o The sources of the personal information collected about you; o The business or commercial purpose for collecting, selling, or sharing your personal information; o The categories of third parties to whom we disclose your personal information (Note: This Privacy Policy contains information provided upon verifiable request for this data category and the aforementioned three data categories); o The categories of personal information sold or shared; o The categories of third parties to whom personal information was sold or shared; o The categories of third parties to whom personal information was disclosed for a business purpose; and o The specific pieces of personal information collected about you (subject to applicable legal limitations); • To request deletion of your personal information by us, subject to applicable legal limitations; • To request correction of inaccurate personal information; • To be free from discrimination based on the exercise of your rights under the CCPA or VCDPA.
In the preceding twelve months, we have "sold" or "shared" within the CCPA's meaning, the following categories of personal information with the specified categories of third parties: [Details to be provided based on the actual data-sharing activities.]
Category of Personal Information
Category of Third Party to Whom Disclosed
Identifier (cookie or internet protocol address)
Third party web services providers
Internet activity information
Third party web services providers
Geolocation data (to the extent that is determinable from your internet protocol address)
Third party web services providers
The purpose for selling or sharing the information above is targeted advertising and marketing.
In the last twelve months, we have disclosed the following categories of personal information to the following categories of third party:
Information for Prospective Customers:
Personal Information Category
Categories of Third Parties (not Service Providers) to whom Disclosed for Business Purpose (see “General Information - How We Disclose Your Personal Information” section)
Website visitor; Event attendee; Referral, lead purchase, or other marketing; Representative of prospective customer purchasing Services
Identifiers
∙ Integration partners
∙ Promotional partners
Employment-related information
∙ Integration partners
∙ Promotional partners
Website visitor; Representative of prospective customer purchasing Services
Identifiers
- Third party website services providers
Internet activity information
- Third party website services providers
Geolocation data
- Third party website services providers
Event attendee; representative of prospective customer purchasing Services
Audio and visual information
∙ Promotional partners
∙ Publicly on our website
Information for Customers - Business Record Data
Identifiers
∙ Service fulfillment partners
∙ Integration partners
Employment-related information
∙ Service fulfillment partners
∙ Integration partners
For additional disclosures required by CCPA Section 1798.110(c) and Section 1798.115(c)(2), as well as additional information related to our data processing in our capacity as a “business” under the CCPA, please see the tables and sections set forth above in this Privacy Policy.
You have the right to opt out of “sales” or “sharing” within the meaning of the CCPA of your personal information if you are a California resident. You can opt out of our “selling” or “sharing” of your personal information if you are a California resident, or targeted advertising if you are a Virginia resident, by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of our webpages.
To our knowledge, we have not sold or shared personal information of consumers (as defined in the CCPA) under 16 years of age. For California residents: CFO Advisors does not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the California Consumer Privacy Act Regulations (“Section 7027(m)”). The purposes described in Section 7027(m) include performing services reasonably expected by an average California resident who requests the services; preventing, detecting, and investigating security incidents; resisting malicious, deceptive, fraudulent, or illegal actions directed at us; ensuring the physical safety of natural persons; short-term, transient use; performing services on our behalf; verifying or maintaining the quality of our Services; and/or other collecting or processing of sensitive personal information where the collection or processing is not for the purpose of inferring characteristics about a California resident.
If you have any questions about how we handle your information, the contents of this Policy, how to update your records or how to obtain a copy of the information that we hold about you or exercise your rights under the CCPA or VCDPA, please write to startups@cfoadvisors.com. We will generally verify your identity using information in your inquiry and data in our possession. We may ask you for additional information to verify your request. A consumer’s authorized agent may also submit a request on behalf of the consumer. The authorized agent should follow the process outlined above. CFO Advisors will request proof that the consumer gave the authorization written permission to submit the request and, depending on the nature of the information, will require the consumer to either verify their own identity directly with CFO Advisors or directly confirm with CFO Advisors that they provided the authorized agent permission to submit the request.