This privacy statement (the “Privacy Statement”) applies to the collection, storage, use, and disclosure of personal information that may be collected by CFO Interventions LLC, d/b/a Stepupcfo (“Stepupcfo,” “we,” “us,” or “our”) when you interact with Stepupcfo, such as when you visit or use our website, located at https://stepupcfo.com (“Site”). We have created this Privacy Policy to tell you what information our Site collects or may collect, how we use that information, and who we may or will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with.

By visiting and/or using our Site, you are agreeing to the terms of this Privacy Policy. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions. By utilizing the Site, you authorize us to collect and/or receive such information.
This Privacy Policy will explain how we use the personal data we collect from you when you use our website.

Topics:
• Data Collection: Information we collect or receive. How we collect your data. How information is used. How information is shared.
• Cookies: What are cookies. How we use cookies. Types of cookies we use. How to manage your cookies.
• Communication preferences.
• How we protect your data.
• External websites.
• Children’s privacy.
• Your Privacy Rights: How we handle Do Not Track Signals. California Privacy Rights. Nevada Privacy Rights. Non-US Privacy Rights. Your data protection rights.
• Changes to This Privacy Policy.
• Contacts: How to contact us. How to contact the appropriate authorities.

1. Information We Collect or Receive.
We may collect Personal Information (as defined below) about you directly from you and from third parties, as well as automatically through your use of our Site. In the course of operating the Site, we may collect and/or receive the following types of information:
• Personal Information. We only receive or collect information that identifies you personally (“Personal Information”) if you choose to provide such personally identifiable information to us via email or other means. When you contact us, you may be required to provide us with Personal Information about yourself. This Personal Information may include your name, date of birth, e-mail address, physical address, and/or phone number. We do not collect any of your Personal Information when you use the Site unless you voluntarily provide us with the information.
• Third-Party Analytics. We and any third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which we may work may use third-party analytics services (e.g., Google Analytics, Google reCAPTCHA, and Google G Suite for Email) to evaluate your use of the Site, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Site and mobile and Internet usage. Our third-party technology providers may utilize Google Analytics and Google reCAPTCHA. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Without limiting the generality of the foregoing, Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the sites, compile reports on the sites’ activity, and provide other services related to site’s activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor and any referring website. The information generated by Google Analytics may be transmitted to and stored by Google and will be subject to Google’s privacy policy: https://policies.google.com/?hl=en. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google click here: https://policies.google.com/technologies/partner-sites. For more information on Google Analytics, and how it collects and processes data, go to the site “How Google uses data when you use our partners’ site or apps”, which may be located at the website google.com/policies/privacy/partners/, or any other URL Google may provide from time to time. For more information on these third parties, including how to opt out from certain data collection, please go to section 9, “Information Collected by or Through Third-Party Advertisers”, or visit https://www. stepupcfo.com/privacy-policy. Please be advised that if you opt out of any such service, you may not be able to use the full functionality of the Site.
• Other Information. In addition to the Personal Information, we may automatically collect or receive additional information regarding you and your use of the Site; your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the Site. Such other information may include:
o From You. Additional information about yourself that you voluntarily provide to us, such as your age, a username, and your product and service preferences.
o From Your Activity. We may collect or receive information regarding: your IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device; browser type and language; how you encountered the Site; referring and exit pages and URLs; date and time of your activity; and details regarding your activity on the Site, such as search queries and other performance and usage data.
o About Your Mobile Device. We may collect or receive information regarding: the type of mobile device you are using; advertising Identifier (“IDFA” or “AdID”); the operating system and version (e.g., iOS, Android or Windows); your carrier; and the network type being utilized (WiFi, 3G, 4G, LTE).

2. How We Collect Your Data.
You directly provide us with most of the data we collect. We collect data and process data when you:
• If you contact us directly, we will collect information which may include your name, email address, phone number, contact details, the content, date and time of your message and any attachments thereto, and other information you may directly provide to us. Users initiating contact us through the Site will be requested to complete Google reCAPTCHA. You may choose to submit your email address and phone number on our Site to receive our updates. You may also provide us with your reviews of our services or complete surveys regarding our services. If you reach out to us with inquires or requests, we will keep a record of how your inquiry or request was handled.
• Administration and personalization of your profile.We may collect any Personal Information you provide to us. You may voluntarily provide us with information about yourself so that we can personalize your experience with us.
• Online usage data.We may automatically collect the following information about your use of our Site through: cookies, web beacons, and similar technologies; your domain name; browser type; operating system type, name and version; page views; links you click; your IP address; location information; the length of time you visit or use our Site; referring URL; access date and time; mobile device ID; language information; device name and model; and other information about your activities within the services and communications that we send you. Please see the sections listed under the “Cookies” topic and the section labeled “Information Collected by or Through Third-Party Advertisers” below for more information. Where required under applicable law, we will only perform such data collection with your consent.
• Complete Google reCAPTCHA.Google reCAPTCHA works by implementing an algorithm to analyze a user’s activity by taking a screenshot of the user’s browser window. If the activity is deemed as mechanical or a made-up word is used, the activity is flagged by the system. Google reCAPTCHA may collect and analyze typing patterns, the amount of mouse clicks done on the Site, what language the user browser is using, cookies that have been placed on the Site, answers to question fields on the Site, plug-ins installed on the browser and cascading style sheets information, and may recognize IP addresses that have been previously recognized as humans through cookies.

3. How Information is Used.
We collect your data so that we can: provide our services and enable you to access and use the Site; improve our overall Site, and your experience with our Site (such as making suggestions, and ranking search results); publish client testimonials; process and confirm your purchase, and to manage your account; email you with special offers on other services we think you might like and administer our promotional programs; solicit your feedback and provide you with customer services; and comply with our legal obligations and ensure compliance with Stepupcfo policies (such as verifying information or identifications provided by you, resolve disputes, enforce our terms of service and other policies, conduct security investigations and risk assessments, and detecting or preventing fraud and other harmful activity).

4. How Information is Shared.
o In order to provide our services and administer our promotional programs, we may share your information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
o We may engage third-party companies and individuals to perform functions on our behalf. Examples include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the information only as necessary to perform their functions and to the extent permitted by law.
o In an ongoing effort to better understand our users, the Site, and our products and services, we may analyze certain information in anonymized and aggregate form to operate, maintain, manage, and improve the Site, and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the Site, and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.
o We may share some or all of your information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
o As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the information may be part of the transferred assets.
o To the extent permitted by law, we may also disclose the information:
 when required by law, court order, or other government or law enforcement authority or regulatory agency; or
 whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

5. What are cookies?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

6. How we use cookies.
We use (or may use) cookies in a range of ways to improve your experience on our Site, including understanding how you use our Site and personalizing your experience with the Site; identifying the type of device you are using; analyzing which portions of the Site are visited and used most frequently; measuring and optimizing advertising and promotional effectiveness; and understanding and tailoring the user experience.

7. Types of cookies we use.
There are a number of different types of cookies, however, our Site uses (or may use) the cookies listed below.
We use (or may use) session cookies, which expire once you close the Site, and persistent cookies, which stay on your mobile device or computer until you delete them and other technologies to help us collect data and to enhance your experience with the Site.
We use (or may use) functionality cookies so that we recognize you on our Site and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
We use (or may use) advertising cookies to collect information about your visit to our Site, the content you viewed, the links you followed and information about your browser, device, and your IP address.
We may sometimes share some limited aspects of this data with third parties for advertising purposes.
We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our Site.

8. How to manage cookies.
If you do not want us to deploy cookies in the Site, you can opt out by setting your mobile device or computer to reject cookies. You can still use the Site if you choose to disable cookies, although your ability to use some of the features may be affected.

9. Information Collected by or Through Third-Party Advertising Companies.We may share information about your activity on the Site with third parties for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, retargeting, analyzing, managing, reporting, and optimizing of ads)). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect information for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data.

10. Communication Preferences.
If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We utilize Constant Contact to administer our newsletters and email campaigns. When you subscribe, you are added to an email list that we can then use to send updates on Stepupcfo content, products and other services available. You should be aware that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to the Site (e.g., requests for support).

11. How We Protect Your Information.
We take commercially reasonable steps to protect your data and information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We securely store your data with a cloud host. All of our servers are encrypted, with a standard process for data deletion. Sensitive data such as your passwords are stored as hashed values. Our third-party provider utilizes a number of proprietary methods to safeguard information. You can find more information about our third-party providers, safeguard measures by visiting https://www.constantcontact.com. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that your information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mails sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

12. External Websites.
The Site may contain links to third-party websites. We have no control over the privacy practices or the content of these third-party websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

13. Children’s Privacy.
The Site is not directed to children under the age of 18. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child as determined in the applicable jurisdiction. We ask that minors not use the Site. If a child has provided us with Personal Information, a parent or guardian of that child may contact us at info@ stepupcfo.com and request that such information be deleted from our records. For more information about the Children’s Online Privacy Protection Act (COPPA), please visit www.ftc.gov.

14. How we handle Do Not Track signals.
We honor Do Not Track signals and do not track, plant cookies, or use targeted advertising when a Do Not Track browser mechanism is in place.

15. California Privacy Rights.
Under the California Consumer Privacy Act, California residents who have an established business relationship with us may choose to opt out of our sharing their contact information with third parties for direct marketing purposes. If you are a California resident and you wish to opt out, please send an e-mail to info@ stepupcfo.com. California residents who are our users in California now have the right to see a report summarizing all of their personal data that we have collected and to request the removal of their data from our computer systems.
California law permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those third parties. See the “Contact Us” section for where to send such requests. Stepupcfo does not share Personal Information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your Personal Information to third parties for their direct marketing purposes by withholding consent.
Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ Personal Information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of Personal Information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes or collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.
Users can visit our Site anonymously. We do not sell your Personal Information to third parties. We do allow third parties to collect certain Personal Information through our services and share Personal Information with third parties for the business purposes described in this Privacy Policy, including without limitation advertising and marketing on our Site and elsewhere based on users’ online activities over time and across different sites, services, and devices.
Notice to California Minors. If you are a California resident under 18 years old and a registered user, you can request that we remove content or information that you have posted to our Site or other online services. Note that fulfillment of the request may not ensure complete or comprehensive removal (e.g. if the content has been reposted by another user). To request removal of content or information, please email info@ stepupcfo.com.

16. Nevada.
StepupCFO does not sell your Personal Information. However, we believe it is important that you are aware you have the right to opt-out of the sale of your Personal Information. Access requests may be made directly to info@ stepupcfo.com.
17. Important Notices to Non-U.S. Residents.
The Site and its servers are operated in the United States. If you are located outside of the United States, please be aware that your information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Site, you hereby consent to such transfer, processing, and use in the United States and elsewhere.
These Services are not marketed to users outside the United States. If you are located in the European Economic Area (“EEA”), we only process your Personal Information based on a valid legal ground, including when:
• Consent. You have consented to the use of your Personal Information, for example for marketing purposes or to track your online activities via cookies and similar technologies.
• Contract. We need your Personal Information to provide you with our services, for example for account registration and management or to respond to your inquiries.
• Legal Obligation. We have a legal obligation to use your Personal Information, for example to comply with tax and accounting obligations, or anti-terrorism laws.
• Legitimate interest. We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

18. Your Data Protection Rights.
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access. You have the right to request copies of your personal data.
The right to rectification. You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we complete information you believe is incomplete.
The right to erasure. You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing. You have the right to request that we restrict the processing of your personal data, under certain conditions.The right to object to processing. You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability. You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please don’t hesitate to contact us at info@ stepupcfo.com.

19. Changes to This Privacy Policy.
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the Site. By accessing the Site after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

20. How to Contact Us.
If you have questions about this Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us. If you choose to e-mail us, please write “Privacy Policy” in the subject line. You may contact us at info@ stepupcfo.com.