1. INTRODUCTION 

This Privacy Policy (“Policy”) describes how SBJ Global Communications Works LLC dba  GCW Agency (“GCW Agency,” “we,” “us,” or “our”), a public relations agency located at 5031  Heatherglen, Houston, TX 77096, collects, uses, stores, shares, and protects your personal  information when you visit our website at GCW.Agency (“Website”) or interact with our  services. 

We respect your privacy and are committed to protecting your personal information. This Policy  explains our practices regarding the collection, use, and disclosure of your information through  our Website, as well as your rights and choices concerning your personal information. 

By accessing or using our Website, you acknowledge that you have read, understood, and agree  to be bound by this Privacy Policy. If you do not agree with our policies and practices, please do  not use our Website. 

This Privacy Policy is designed to comply with applicable privacy laws, including the Federal  Trade Commission Act (15 U.S.C. §§ 41-58) and the Texas Business and Commerce Code  Chapter 35 (Deceptive Trade Practices Act). 

2. INFORMATION WE COLLECT 

2.1 Personal Information 

We collect the following categories of personal information from users of our Website: 

• Identity Information: Name and other identifying information you provide through our  contact forms. 

• Contact Information: Email address and any other contact details you provide to us. 

• Technical Information: Internet Protocol (IP) address, browser type and version, operating  system, and other technology identifiers on the devices you use to access our Website. 

• Usage Information: Information about how you use our Website, including pages visited,  time spent on pages, and other interaction data. 

2.2 Methods of Collection 

We collect personal information through the following methods: 

• Direct Interactions: Information you provide by filling in forms on our Website, including  contact forms and subscription forms.

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• Automated Technologies: As you navigate through our Website, we may automatically  collect technical information and usage information using cookies and similar technologies. 

• Third-Party Services: We collect information through third-party services such as Google  Analytics and Microsoft Clarity, which help us understand how visitors interact with our  Website. 

2.3 Information We Do Not Collect 

We do not knowingly collect: 

• Sensitive personal information such as health data, financial information, or biometric data • Government-issued identification numbers 

• Credit card or payment information (unless specifically provided for services) • Information from children under the age of 13 

Our collection practices comply with the Federal Trade Commission Act (15 U.S.C. §§ 41-58)  regarding material information disclosure requirements and the Computer Fraud and Abuse Act  (18 U.S.C. § 1030) regarding authorized data collection practices. 

3. HOW WE USE YOUR INFORMATION 

3.1 Primary Purposes 

We use the personal information we collect for the following purposes: 

• To provide, maintain, and improve our Website and services 

• To respond to your inquiries, comments, or questions 

• To communicate with you about our services, including updates or changes • To analyze Website usage and improve user experience 

• To protect the security and integrity of our Website 

• To comply with applicable laws, regulations, and legal processes 

3.2 Legal Basis for Processing 

We process your personal information based on one or more of the following legal grounds: • Your consent 

• Performance of a contract with you 

• Compliance with a legal obligation 

• Our legitimate interests, provided they do not override your fundamental rights and  freedoms

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3.3 Non-Marketing Uses 

We want to emphasize that: 

• We do not sell your personal information to third parties 

• We do not use your personal information for targeted advertising 

• We do not use your information for automated decision-making or profiling 

Our use of your information complies with the Electronic Communications Privacy Act (18  U.S.C. §§ 2510-2522) regarding lawful use of electronic communications and the Federal Trade  Commission Act (15 U.S.C. §§ 41-58) prohibiting unfair or deceptive practices. 

4. INFORMATION SHARING AND DISCLOSURE 

4.1 Limited Disclosure 

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

• Service Providers: We may share your information with trusted third-party service  providers who perform services on our behalf, such as website hosting, data analysis, and  customer service. These service providers are contractually obligated to use your  information only for the purposes of providing services to us and in accordance with this  Privacy Policy. 

• Legal Requirements: We may disclose your information if required to do so by law or in  response to valid requests by public authorities (e.g., a court or government agency). 

• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our  assets, your information may be transferred as part of the transaction. We will notify you  via email and/or a prominent notice on our Website of any change in ownership or uses of  your personal information. 

• Protection of Rights: We may disclose your information when we believe in good faith  that disclosure is necessary to protect our rights, protect your safety or the safety of others,  investigate fraud, or respond to a government request. 

4.2 Geographic Restrictions 

All data is stored and processed within the United States only. We do not transfer your personal  information outside the United States. 

4.3 Aggregated and De-identified Information 

We may use and share aggregated and de-identified information, which cannot reasonably be  used to identify you, for any lawful business purpose without obligation to you.

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Our information sharing practices comply with the Federal Trade Commission Act (15 U.S.C. §§  41-58) regarding required disclosure of data sharing practices and the Texas Business and  Commerce Code Chapter 521 (Identity Theft Enforcement and Protection Act). 

5. DATA SECURITY MEASURES 

5.1 Security Safeguards 

We implement and maintain reasonable security measures designed to protect your personal  information from unauthorized access, disclosure, alteration, and destruction. These measures  include: 

• Encryption of data in transit using Secure Socket Layer (SSL) technology • Secure storage of data on protected servers 

• Access controls and authentication procedures for our systems 

• Regular security assessments and vulnerability testing 

• Employee training on data security and privacy practices 

• Physical security measures at our facilities 

5.2 Limitations 

While we strive to protect your personal information, no method of transmission over the  Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute  security. If you have reason to believe that your interaction with us is no longer secure, please  immediately notify us using the contact information provided in Section 12. 

5.3 Your Role in Security 

You are responsible for maintaining the confidentiality of any account credentials and for  restricting access to your devices. We recommend using strong, unique passwords and keeping  your login information confidential. 

Our security measures comply with the Texas Business and Commerce Code Chapter 521  (Identity Theft Enforcement and Protection Act) security requirements and the Computer Fraud  and Abuse Act (18 U.S.C. § 1030) data protection standards. 

6. THIRD-PARTY SERVICES 

6.1 Analytics Services 

We use the following third-party analytics services to help us understand how users engage with  our Website: 

• Google Analytics: A web analytics service provided by Google LLC that tracks and reports  website traffic. Google Analytics uses cookies to help us analyze how users use our  Website. The information generated by the cookie about your use of the Website (including 

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your IP address) may be transmitted to and stored by Google on servers in the United  States. Google may use this information for the purpose of evaluating your use of the  Website, compiling reports on website activity, and providing other services relating to  website activity and internet usage. You can learn more about how Google uses data when  you use our Website by visiting: https://policies.google.com/technologies/partner-sites 

• Microsoft Clarity: A user behavior analytics tool provided by Microsoft Corporation that  helps us understand how users interact with our Website through session recordings,  heatmaps, and other analytics features. Microsoft Clarity collects information such as  

mouse movements, clicks, scrolls, and form interactions. You can learn more about  Microsoft Clarity’s privacy practices at: https://clarity.microsoft.com/terms 

6.2 Third-Party Links 

Our Website may contain links to third-party websites, plugins, and applications. Clicking on  those links or enabling those connections may allow third parties to collect or share data about  you. We do not control these third-party websites and are not responsible for their privacy  statements. When you leave our Website, we encourage you to read the privacy policy of every  website you visit. 

6.3 Social Media Features 

Our Website may include social media features, such as the Facebook Like button or Twitter  sharing widgets. These features may collect your IP address and which page you are visiting on  our Website, and may set a cookie to enable the feature to function properly. Social media  features are either hosted by a third party or hosted directly on our Website. Your interactions  with these features are governed by the privacy policy of the company providing them. 

Our disclosure of third-party services complies with the Federal Trade Commission Act (15  U.S.C. §§ 41-58) regarding required disclosure of third-party data practices and the Electronic  Communications Privacy Act (18 U.S.C. §§ 2510-2522) regarding third-party access to  communications. 

7. DATA RETENTION 

7.1 Retention Period 

We retain your personal information for as long as necessary to fulfill the purposes outlined in  this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria  used to determine our retention periods include: 

• The length of time we have an ongoing relationship with you 

• Whether there is a legal obligation to which we are subject 

• Whether retention is advisable in light of our legal position (such as in regard to applicable  statutes of limitations, litigation, or regulatory investigations)

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7.2 Data Deletion 

When we no longer need to use your personal information, we will either delete it from our  systems or anonymize it so that it can no longer be associated with you. However, we may retain  certain information as necessary to: 

• Comply with legal or regulatory obligations 

• Resolve disputes 

• Enforce our agreements 

• Protect against fraudulent or illegal activity 

7.3 Backup Retention 

For technical reasons, copies of your personal information may remain in our backup systems for  a limited period after deletion from our active systems. These backups are maintained with the  same level of security as our active systems and are not used for any other purpose than disaster  recovery. 

Our data retention practices comply with the Federal Trade Commission Act (15 U.S.C. §§ 41- 58) material practice disclosure requirements and the Texas Business and Commerce Code  Chapter 521 data retention compliance standards. 

8. YOUR PRIVACY RIGHTS 

8.1 Access, Correction, and Deletion Rights 

You have the right to: 

• Access: Request information about the personal information we hold about you and how we  use it. 

• Correction: Request that we correct or update any personal information that is inaccurate,  incomplete, or outdated. 

• Deletion: Request that we delete your personal information, subject to certain exceptions  provided by law. 

8.2 How to Exercise Your Rights 

To exercise your privacy rights, please submit a request by: 

• Emailing us at privacy@gcw.agency 

• Calling us at 646.964.4446 

• Writing to us at: SBJ Global Communications Works LLC, 5031 Heatherglen, Houston, TX  77096

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We will respond to your request within 48 hours. We may need to verify your identity before  processing your request. In some cases, we may deny your request if we are legally permitted or  required to do so. 

8.3 No Discrimination 

We will not discriminate against you for exercising any of your privacy rights. This means we  will not: 

• Deny you goods or services 

• Charge you different prices or rates for goods or services 

• Provide you with a different level or quality of goods or services 

• Suggest that you may receive a different price or rate for goods or services or a different  level or quality of goods or services 

Our privacy rights practices comply with the Federal Trade Commission Act (15 U.S.C. §§ 41- 58) user rights disclosure requirements and the Texas Business and Commerce Code Chapter  521 individual rights regarding personal data. 

9. CHILDREN’S PRIVACY PROTECTION 

9.1 Age Restrictions 

Our Website is not directed to children under 13 years of age, and we do not knowingly collect  personal information from children under 13. If we learn we have collected or received personal  information from a child under 13 without verification of parental consent, we will delete that  information. 

9.2 Parental Rights 

If you are a parent or guardian and believe we may have inadvertently collected personal  information from your child under the age of 13, please contact us immediately at  privacy@gcw.agency so that we can promptly remove such information from our records. 

9.3 Teen Privacy 

While our Website is not directed at individuals under 18, we recognize that visitors between the  ages of 13 and 18 may use our Website. We encourage parents and guardians to monitor their  children’s Internet usage and to help enforce this Privacy Policy by instructing their children  never to provide personal information through our Website without their permission. 

Our children’s privacy protection practices comply with the Children’s Online Privacy  Protection Act (15 U.S.C. §§ 6501-6506).

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10. DATA BREACH NOTIFICATION 

10.1 Breach Response 

In the event of a data breach that compromises the security, confidentiality, or integrity of your  personal information, we will take appropriate measures to address the breach, including: 

• Conducting a thorough investigation to determine the scope of the breach • Taking steps to contain and mitigate the breach 

• Implementing measures to prevent future breaches 

10.2 Notification Procedures 

If we determine that a breach has occurred that requires notification under applicable law, we  will notify affected individuals in a timely manner. Our notification will include: 

• A description of the breach 

• The types of information involved 

• Steps we are taking to protect against further unauthorized access 

• Steps individuals can take to protect themselves 

• Contact information for further assistance 

10.3 Regulatory Reporting 

We will also notify appropriate regulatory authorities as required by applicable law, including  the Texas Attorney General if the breach affects a specified number of Texas residents. 

Our data breach notification practices comply with the Texas Business and Commerce Code  Chapter 521 (Identity Theft Enforcement and Protection Act) notification requirements and the  Texas Penal Code Chapter 33A provisions regarding computer crimes and unauthorized access. 

11. CHANGES TO THIS PRIVACY POLICY 

11.1 Policy Updates 

We may update this Privacy Policy from time to time to reflect changes in our practices,  technology, legal requirements, or other factors. When we make changes to this Privacy Policy,  we will update the “Effective Date” at the top of this Privacy Policy. 

11.2 Notification of Material Changes 

If we make material changes to this Privacy Policy, we will notify you by: • Posting a notice on our Website prior to the changes becoming effective • Sending an email to the email address you have provided to us

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• Any other method as required by applicable law 

11.3 Continued Use 

Your continued use of our Website after we make changes to this Privacy Policy constitutes your  acceptance of the revised Privacy Policy. We encourage you to periodically review this Privacy  Policy to stay informed about how we collect, use, and protect your personal information. 

Our policy update practices comply with the Federal Trade Commission Act (15 U.S.C. §§ 41- 58) requirements for policy update notifications. 

12. CONTACT INFORMATION 

12.1 Contact Details 

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

SBJ Global Communications Works LLC dba GCW Agency 

Attn: Brad Ginsburg 

5031 Heatherglen 

Houston, TX 77096 

Email: privacy@gcw.agency 

Phone: 646.964.4446 

12.2 Response Time 

We strive to respond to all legitimate inquiries within 48 hours. In some cases, we may require  additional information to verify your identity before responding to your request. 

12.3 Complaints 

If you have a complaint about our privacy practices, please contact us directly first so that we can  address your concerns. If you are not satisfied with our response, you may have the right to file a  complaint with a regulatory authority. 

Our contact information practices comply with the Federal Trade Commission Act (15 U.S.C. §§  41-58) required contact means for privacy concerns and the Texas Business and Commerce Code  Chapter 521 complete business information requirements.

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