Privacy Policy

This Privacy Policy describes how Crestwell Partners, LLC ("Crestwell," "we," "us," or "our") collects, uses, discloses, and protects your personal information when you visit crestwellpartners.com (the "Site") or use our services. By using the Site, you consent to the data practices described in this policy.

1. Information We Collect

1.1 Information You Provide Directly

We collect personal information that you voluntarily provide when you interact with the Site:

• Contact form submissions: Name, email address, phone number, organization name, area of interest, and message content.
• Executive applications: Full name, email address, phone number, and LinkedIn profile URL.
• Newsletter subscriptions: Email address.
• Resource downloads: Email address (for gated content such as guides, checklists, and templates).
• Discovery call scheduling: Name, email address, and any information you provide through the Calendly scheduling tool.

1.2 Information Collected Automatically

When you visit the Site, certain information is collected automatically through cookies and similar technologies:

• Device and browser information: Browser type, operating system, device type, screen resolution, and language preferences.
• Usage data: Pages visited, time spent on pages, click behavior, referring URLs, and navigation paths.
• Network information: IP address (which may indicate your approximate geographic location), internet service provider, and connection type.
• Analytics identifiers: Anonymous identifiers assigned by Google Analytics and Vercel Analytics for usage tracking.

1.3 Information Not Collected

We do not collect financial information (such as credit card numbers) directly through the Site. We do not collect Social Security numbers, government IDs, or other sensitive personal identifiers through the Site. Quiz responses on the Fractional Readiness Quiz are processed entirely in your browser and are not stored on or transmitted to our servers.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Service delivery: To respond to your inquiries, process executive applications, schedule discovery calls, and provide our placement services.
• Communications: To send you requested resources, deliver the newsletter you subscribed to, and follow up on form submissions.
• Website improvement: To analyze how visitors use the Site, identify technical issues, and improve the user experience.
• Security: To detect and prevent fraud, abuse, or unauthorized access to the Site.
• Legal compliance: To comply with applicable laws, regulations, and legal processes.
• Business operations: To manage and improve our internal business operations, including record-keeping and quality assurance.

We will not use your personal information for purposes materially different from those described here without your consent.

3. Legal Bases for Processing

Where applicable (such as under the GDPR for visitors from the European Economic Area), we process your personal information based on one or more of the following legal grounds:

• Consent: You have given us consent to process your data (for example, by subscribing to the newsletter or submitting a form).
• Contractual necessity: Processing is necessary to perform our services or respond to your request.
• Legitimate interests: Processing is necessary for our legitimate business interests, such as improving the Site and marketing our services, provided these interests are not overridden by your rights.
• Legal obligation: Processing is necessary to comply with a legal obligation.

4. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties. We may share your information in the following limited circumstances:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf:

• Vercel: Website hosting, deployment, and web analytics.
• Google Analytics (Google LLC): Website usage analytics. Google may process data in accordance with its own privacy policy.
• Kit (ConvertKit, Inc.): Email newsletter delivery and subscriber management.
• Resend (Resend, Inc.): Transactional email delivery for form confirmations.
• Calendly (Calendly LLC): Scheduling discovery calls.
• Sanity (Sanity AS): Content management system.

These providers are contractually obligated to use your information only for the purposes of providing their services to us and in compliance with applicable data protection laws.

4.2 Legal Requirements

We may disclose your personal information if required to do so by law or in good-faith belief that such action is necessary to: (a) comply with a legal obligation, court order, or legal process; (b) protect and defend the rights or property of Crestwell Partners; (c) prevent or investigate possible wrongdoing in connection with the Site or services; (d) protect the personal safety of users of the Site or the public; or (e) protect against legal liability.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. We will notify you via email or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your information.

4.4 With Your Consent

We may share your information with third parties when you explicitly consent to or direct us to do so.

5. Cookies and Tracking Technologies

5.1 Cookies We Set

The Site uses the following first-party cookies:

5.2 Third-Party Cookies

The following third-party services may set their own cookies when you use the Site:

• Google Analytics: Sets cookies (such as _ga, _gid, and _gat) to distinguish unique users and throttle request rates. These cookies collect anonymous usage data. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.
• Calendly: May set cookies when you interact with the scheduling widget.

5.3 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can set your browser to refuse all cookies, accept only first-party cookies, or delete cookies when you close your browser. Note that disabling cookies may affect some functionality of the Site. For more information about managing cookies, visit allaboutcookies.org.

6. Do Not Track Signals

Some browsers include a "Do Not Track" (DNT) feature that sends a signal to websites you visit indicating that you do not wish to be tracked. There is no uniform standard for interpreting DNT signals, and the Site does not currently respond to DNT signals. However, you can manage your privacy preferences through browser cookie settings as described above.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including:

• Contact form data: Retained for the duration of our business relationship and for a reasonable period afterward for follow-up and legal compliance purposes.
• Executive application data: Retained for as long as the applicant remains in our network, or until the applicant requests deletion.
• Newsletter subscriber data: Retained until you unsubscribe. You can unsubscribe at any time using the link at the bottom of every email.
• Resource download data: Retained for the purpose of delivering the resource and for marketing communications, until you opt out.
• Analytics data: Retained according to the retention settings of the respective analytics provider (typically 14 to 26 months for Google Analytics).

When personal information is no longer necessary for the purposes described above, we will delete or anonymize it in a reasonable timeframe.

8. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include HTTPS encryption for all data transmitted between your browser and our servers, secure hosting through Vercel, and restricted access to personal data on a need-to-know basis. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

9. Children's Privacy

The Site is not directed at children under the age of 16, and we do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16 without parental consent, we will take steps to delete that information promptly. If you believe we have collected information from a child under 16, please contact us immediately.

10. Your Rights and Choices

10.1 General Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Right to access: Request a copy of the personal information we hold about you.
• Right to correction: Request correction of inaccurate or incomplete personal information.
• Right to deletion: Request that we delete your personal information, subject to certain legal exceptions.
• Right to restrict processing: Request that we limit how we use your personal information.
• Right to data portability: Request a copy of your data in a structured, machine-readable format.
• Right to object: Object to our processing of your personal information for certain purposes, including direct marketing.
• Right to withdraw consent: Where processing is based on consent, withdraw that consent at any time.

10.2 California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with additional rights:

• Right to know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collecting it, and the categories of third parties with whom we share it.
• Right to delete: You have the right to request deletion of your personal information, subject to certain exceptions.
• Right to opt out of sale: We do not sell your personal information. If this changes in the future, we will provide a "Do Not Sell My Personal Information" link on the Site.
• Right to non-discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

In the preceding 12 months, we have collected the following categories of personal information: identifiers (name, email, phone), internet activity information (browsing history on our Site), and professional information (LinkedIn URL for executive applications). We have not sold any personal information.

10.3 European Economic Area (EEA) Residents

If you are located in the EEA, you have the rights described in Section 10.1 above under the General Data Protection Regulation (GDPR). You also have the right to lodge a complaint with your local supervisory authority if you believe our processing of your personal information violates applicable law. Crestwell Partners is based in the United States, and by using the Site, you acknowledge that your personal information will be transferred to and processed in the United States, which may have data protection laws different from those in your country.

10.4 How to Exercise Your Rights

To exercise any of the rights described above, please contact us at privacy@crestwellpartners.com or through our contact form. We will respond to verifiable requests within 30 days (or within the timeframe required by applicable law). We may need to verify your identity before processing your request.

11. International Data Transfers

Crestwell Partners is headquartered in the United States. Your personal information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. These countries may have data protection laws that are different from those in your country of residence. By using the Site, you consent to the transfer of your information to the United States and other countries as described in this policy. Where required by law, we will ensure appropriate safeguards are in place for such transfers.

12. Third-Party Links

The Site may contain links to third-party websites or services that are not operated by Crestwell Partners, such as LinkedIn, Calendly, and other external resources. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party websites or services. We encourage you to review the privacy policies of every site you visit.

13. Email Communications

If you subscribe to our newsletter, we will send you periodic emails with content about fractional leadership, our services, and related topics. Every email will include an unsubscribe link at the bottom.

If you submit a contact form, executive application, or resource download form, we may send you transactional emails related to your submission (such as confirmations or follow-ups). These transactional emails are not marketing communications and are necessary to fulfill your request.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date at the top of this page. If we make significant changes to how we use your personal information, we will notify you by posting a prominent notice on the Site or by sending you an email (if we have your email address). Your continued use of the Site after any changes constitutes your acceptance of the revised policy.

15. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Crestwell Partners, LLC
• Email: privacy@crestwellpartners.com
• Website: crestwellpartners.com/contact

For data protection inquiries, we aim to respond within 30 days. For California residents exercising CCPA/CPRA rights, we will respond within 45 days as required by law.