This Privacy Policy describes how RFCE LLC, a Wyoming limited liability company doing business as Control CFO (“Control CFO,” “we,” “us,” or “our”), collects, uses, discloses, and safeguards information in connection with the website located at https://controlcfo.com and any related pages and features (collectively, the “Website”). This Privacy Policy applies to information collected through the Website. It does not apply to information that we collect or process under a separate written engagement agreement for accounting, bookkeeping, financial reporting, accounts receivable, collections, fractional chief financial officer, or government contract compliance services (collectively, the “Services”), which information is governed by the terms of that engagement agreement and by the additional commitments described in Section 6. By accessing or using the Website, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect.

We collect information in the following ways.

1.1 Information You Provide to Us. When you submit a contact or lead form, request a consultation, subscribe to a newsletter or mailing list, or otherwise communicate with us through the Website, we collect the information you choose to provide, which may include your name, business name, email address, telephone number, and the contents of any message you send to us.

1.2 Information We Collect Automatically. When you access or use the Website, we and our analytics providers automatically collect certain information about your device and your use of the Website, which may include your internet protocol (IP) address, browser type, operating system, referring and exit pages, the pages you view, the dates and times of your visits, and similar usage data. We collect this information through cookies and similar technologies, as described in Section 3.

1.3 Information Collected Through a Client Portal. Control CFO may, in the future, make available a secured client portal or online account (the “Portal”). If and when the Portal becomes available and you register for or use it, we may collect account registration information, authentication credentials, billing and payment information, and the financial and business records that you or your authorized representatives upload or transmit through the Portal. This Section 1.3 describes functionality that is not currently active.

2. How We Use Information.

We use the information we collect to (i) respond to your inquiries and provide the information or consultation you request; (ii) communicate with you about the Services, including sending administrative messages and, where permitted, marketing communications; (iii) operate, maintain, analyze, and improve the Website; (iv) personalize and improve your experience; (v) detect, prevent, and address technical issues, security incidents, fraud, and other unlawful activity; (vi) establish, manage, and perform an engagement for the Services if you become a client; and (vii) comply with applicable legal obligations and enforce our agreements. We do not sell the information we collect through the Website, and we do not share it for cross-context behavioral advertising, as those terms are defined under applicable law.

3. Cookies and Analytics.

The Website uses cookies and similar technologies to operate, to remember your preferences, and to understand how visitors use the Website. A cookie is a small data file stored on your device. We use both session cookies, which expire when you close your browser, and persistent cookies, which remain until they expire or you delete them.

We use Google Analytics, a web analytics service provided by Google LLC, to help us understand how visitors interact with the Website. Google Analytics uses cookies and similar technologies to collect and analyze information about Website usage, including the automatically collected information described in Section 1.2. Information generated about your use of the Website may be transmitted to and stored by Google. You can learn about Google’s practices by visiting Google’s privacy and terms pages, and you can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on available from Google.

Most web browsers allow you to control cookies through their settings, including by refusing or deleting cookies. If you disable cookies, some features of the Website may not function properly. We respond to web browser “Do Not Track” signals and other opt-out preference signals as described in Section 9.

4. How We Disclose Information.

We may disclose information in the following circumstances.

4.1 Service Providers. We disclose information to third-party vendors and service providers that perform functions on our behalf, including website hosting, analytics, email and marketing platforms, customer relationship management, payment processing, and the accounting and financial software platforms we use to deliver the Services. These providers are authorized to use the information only as necessary to provide services to us.

4.2 Legal and Protective Disclosures. We may disclose information where we believe in good faith that disclosure is necessary to (i) comply with any applicable law, regulation, legal process, subpoena, or governmental request; (ii) enforce our Terms of Service or other agreements; or (iii) protect the rights, property, or safety of Control CFO, our clients, our users, or others.

4.3 Business Transfers. If Control CFO is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, or in the event of insolvency, information may be transferred as part of that transaction, subject to the commitments described in this Privacy Policy.

We do not sell your personal information for money, and we do not disclose your personal information except as described in this Privacy Policy.

5. Third-Party Service Providers.

To operate the Website and to deliver the Services, we rely on reputable third-party platforms, which may include, by way of example, accounting and bookkeeping software, document-capture and expense-management tools, accounts receivable and payment platforms, payroll providers, timekeeping systems, analytics providers, and email and marketing services. Each such provider maintains its own privacy practices, and we encourage you to review the privacy policies of any platform through which you interact with us. We endeavor to engage providers that maintain appropriate technical and organizational safeguards for the information they process on our behalf.

6. Safeguarding of Client Financial Information.

We understand that the financial and business records we handle in connection with the Services are sensitive and, in the case of government contract clients, may be subject to confidentiality and records requirements. We maintain administrative, technical, and physical safeguards designed to protect such information, and we limit access to it to personnel and authorized service providers who need it to perform the Services. Our handling of information collected in connection with an engagement for the Services is governed by the applicable engagement agreement and by this Section 6, and not solely by the Website-focused provisions of this Privacy Policy.

7. Data Security.

We implement reasonable administrative, technical, and physical measures designed to protect the information we collect against unauthorized access, loss, misuse, alteration, and disclosure. No method of transmission over the internet and no method of electronic storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of any account credentials and for using reasonable measures to protect your own information.

8. Data Retention.

We retain the information we collect for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide the Services, to maintain business records, to comply with our legal, tax, and regulatory obligations, to resolve disputes, and to enforce our agreements. When information is no longer required for these purposes, we take reasonable steps to delete, anonymize, or securely store it. Certain records relating to government contract clients may be subject to extended retention requirements under applicable law and the terms of the applicable engagement.

9. Your Privacy Choices and Rights.

9.1 Marketing Communications. You may opt out of marketing emails at any time by following the unsubscribe instructions in those emails or by contacting us using the information in Section 13. Even if you opt out of marketing communications, we may continue to send you administrative or transactional communications relating to an active engagement.

9.2 Cookies and Tracking. You can manage cookies through your browser settings and can opt out of Google Analytics as described in Section 3. We honor browser-based opt-out preference signals, including the Global Privacy Control (GPC), where required by applicable law.

9.3 Access and Other Requests. Subject to applicable law, you may have the right to request access to, correction of, or deletion of certain personal information that we hold about you. To make a request, please contact us using the information in Section 13. We will respond to your request as required by applicable law, and we may need to verify your identity before fulfilling it.

10. State Privacy Rights.

10.1 California Residents. If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), provides you with certain rights regarding your personal information, subject to exceptions. These rights may include the right to know the categories and specific pieces of personal information we have collected about you, the right to request deletion of your personal information, the right to request correction of inaccurate personal information, and the right to opt out of the sale or sharing of personal information. Control CFO does not sell personal information and does not share personal information for cross-context behavioral advertising, as those terms are defined under the CCPA. We will not discriminate against you for exercising any of your CCPA rights. To exercise your rights, please contact us using the information in Section 13.

10.2 Other State Privacy Laws. Residents of certain other states, including, where applicable, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others that have enacted comprehensive privacy laws, may have rights similar to those described in Section 10.1, including rights to access, correct, delete, and obtain a copy of certain personal information, and to opt out of certain processing. To exercise any such rights, please contact us using the information in Section 13. We will honor verified requests as required by the applicable law of your state of residence.

11. Children’s Privacy.

The Website is intended for businesses and for individuals who are at least eighteen (18) years of age. The Website is not directed to children, and we do not knowingly collect personal information from any person under the age of eighteen (18). If we learn that we have collected personal information from a person under the age of eighteen (18), we will take reasonable steps to delete that information. If you believe that we may have collected information from a child, please contact us using the information in Section 13.

12. Third-Party Links and Changes to This Policy.

12.1 Third-Party Links. The Website may contain links to third-party websites and services. We are not responsible for the privacy practices of those third parties, and this Privacy Policy does not apply to any third-party website or service. We encourage you to review the privacy policies of any third party before providing information to it.

12.2 Changes to This Privacy Policy. We may update this Privacy Policy from time to time. When we make changes, we will revise the “Last Updated” date at the top of this Privacy Policy and will post the updated Privacy Policy on the Website. Your continued use of the Website after the updated Privacy Policy is posted constitutes your acknowledgment of the changes. We encourage you to review this Privacy Policy periodically.

13. Contact Us.

If you have any questions about this Privacy Policy or our privacy practices, or if you wish to exercise any of your rights, you may contact us at [email protected]