Andrew Brodsky

Privacy Policy

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use our website. By using our website, you agree to the collection and use of information in accordance with this Privacy Policy.

Andrew Brodsky (also referred to as abrodsky.com) is dedicated to safeguarding the privacy of individuals who engage with our website. In the course of our regular operations, we gather various types of information from our website visitors. However, we have designed our website to offer visitors the choice to explore without disclosing personal information or revealing their identity. To maintain your privacy during your website visit, you can consider the following options:

  • Adjust your browser settings to disable cookies before navigating to our website.
  • Opt not to submit information through the web forms available on our website.
  • Avoid downloading free resources or making purchases if you prefer not to.
  • Opt not to participate in certain programs offered on our websites.
  • Opt not to complete any surveys provided on our website.

The ensuing section delineates the nature of the information we collect and elucidates how this information is utilized to ensure our visitors enjoy an optimal online experience.

Interpretation and Definitions

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Andrew Brodsky and abrodsky.com.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: Texas, United States

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Service refers to the Abrodsky.com Website (https://abrodsky.com).

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to abrodsky.com, accessible from https://abrodsky.com

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Usage Data

Submitting Forms

While navigating through our website, we gather information related to your computer and the pages visited, presented in an aggregated format rather than individual or personal details. This commonly termed clickstream or navigation data is employed for research, analysis, and reporting purposes. Our objective is to enhance website navigation, refine page structure, and optimize content to facilitate quicker information retrieval. This assists visitors in finding relevant information promptly and increases the overall value of their experience on our website.

For interactive elements such as forms on specific pages, designed to facilitate requests for information about our services or access valuable resources, including white papers and research documents, we may request contact information like your name, phone number, and/or email address. By voluntarily submitting a form on our website, you implicitly agree to our privacy policy. It’s important to note that the data you provide may not be governed by EU regulations, including the GDPR, as our company and website are based in the United States.

When you voluntarily submit a form on our website, you are providing explicit consent to our privacy policy.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies on the Free Privacy Policy website article.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Please be aware that, in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceedings, court order, or legal process. We may also share your personal information to protect our rights or property, or that of our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been, or could be, affected.

We may place email links on this site to allow you to contact us directly via email. The information you provide is used to respond directly to your questions or comments. Those comments may be stored to improve the quality of our site and our services.

Personal Data Security

We are committed to safeguarding your personal information and ensuring its accuracy. Employing sensible physical, administrative, and technical measures, we aim to prevent unauthorized access, use, and disclosure of your personal information. We also mandate that our partners and suppliers uphold similar standards to safeguard such information from unauthorized access, use, and disclosure.

Specifically, we pledge to:

  1. Manage Client personal information in strict adherence to applicable laws and regulations.
  2. Process Client personal information solely for the purpose of delivering Services, restricting access to individuals with a genuine need to know.
  3. Establish and uphold safeguards ensuring the security, confidentiality, reliability, and integrity of Client personal information, covering physical and logical access control, data transfer control, and availability control.
  4. Promptly inform the Client of any security incidents involving the misuse or accidental or unlawful destruction or disclosure of their personal information, conducting thorough investigations and taking corrective actions.
  5. Regularly audit business processes and security measures, incorporating vulnerability and penetration testing, and promptly applying security updates.
  6. Ensure sub-processors handling Client personal information meet the necessary protection standards. The approved sub-processors include Box, Inc., Salesforce.com, Marketo, Thought Industries, Inc., and NetSuite, Inc., as acknowledged by the Client.
  7. Conduct any international transfer of Client personal information in compliance with the Standard Contractual Clauses established by the European Commission.
  8. Adhere to a security program and policy that not only satisfies or exceeds legal requirements but also aligns with established industry standards.

Regarding the type and purpose of personal information:

  • Nature and Purpose: Company offers training, consulting, and facilitation services, collecting and using personal information to deliver agreed-upon services to the Client.
  • Categories of Data Subjects: Employees of the Client participating in training sessions.
  • Categories of Data: Identification information (such as name, employer), contact information (telephone number, email address), job-related information (title, office location), IP address, or online identifier.
  • Special Categories of Data: None.
  • Processing Operations: Personal information will be processed in accordance with the services agreed upon by the Client and Company.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

While we retain usage data for internal analysis, you can request the deletion of your personal data. To do so, please contact us via contact@abrodsky.com.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 17. We do not knowingly collect personally identifiable information from anyone under the age of 17. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 17 without verification of parental consent, We will take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

California Privacy Rights Act (CPRA) Compliance

Effective Date: Effective date: 04 July 2024

This section applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Privacy Rights Act of 2020 (CPRA) and any terms defined in the CPRA have the same meaning when used in this section.

Your Rights under CPRA:

Right to Know:

  • You have the right to request that we disclose certain information about our collection and use of your personal information over the past 12 months. Upon receiving and verifying your request, we will provide you with details about:
    • The categories of personal information we have collected.
    • The categories of sources from which the personal information was collected.
    • Our business or commercial purpose for collecting or selling personal information.
    • The categories of third parties with whom we share personal information.

Right to Delete:

  • You have the right to request the deletion of your personal information collected or maintained by us. Once we receive and verify your request, we will delete your personal information from our records, unless an exception applies.

Right to Opt-Out of Sale:

  • We do not sell personal information. However, if this practice changes, you will have the right to opt-out of the sale of your personal information.

Non-Discrimination:

  • We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:

Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

Provide you 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.

To exercise your right to know, delete, or opt-out of the sale of personal information, please submit a verifiable consumer request by emailing contact@abrodsky.com.

Exercising Your CPRA Rights:

To exercise your rights under the CPRA, please submit a verifiable consumer request to us by either:

  • Sending an email to contact@abrodsky.com.
  • Visiting https://abrodsky.com.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

We will respond to a verifiable consumer request within 45 days of receiving it, unless we need more time, in which case, we will let you know.

General Data Protection Regulation (GDPR) Compliance

Effective Date: Effective date: 22 February 2024

If you are a resident of the European Economic Area (EEA) or you interact with our services while in the EEA, the processing of your personal data may be subject to the General Data Protection Regulation (GDPR). This section outlines our commitment to GDPR compliance and the rights granted to you under the regulation. For GDPR-related inquiries or to exercise your rights, please contact our Data Protection Officer at contact@abrodsky.com.

Data Controller: 

The data controller for the purposes of the GDPR is Andrew Brodsky. You can contact him at contact@abrodsky.com for any questions or concerns related to your personal data.

Legal Basis for Processing:

We process personal data under the following lawful bases as defined in Article 6 of the GDPR:

  1. Consent: You have given clear consent for us to process your personal data for a specific purpose.
  2. Contractual Necessity: The processing is necessary for the performance of a contract to which you are a party or for the steps at your request prior to entering into a contract.
  3. Legal Obligation: The processing is necessary for compliance with a legal obligation to which we are subject.
  4. Legitimate Interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data that overrides those legitimate interests.

Rights of Data Subjects:

Under the GDPR, you have the following rights with respect to your personal data:

  1. Right to Access: You have the right to request access to your personal data and receive a copy of it.
  2. Right to Rectification: You have the right to request the correction of inaccurate personal data.
  3. Right to Erasure: You have the right to request the deletion of your personal data under certain circumstances.
  4. Right to Restriction of Processing: You have the right to request the restriction of processing of your personal data under certain circumstances.
  5. Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller.
  6. Right to Object: You have the right to object to the processing of your personal data under certain circumstances.
  7. Automated Decision Making and Profiling: We do not engage in automated decision-making processes or profiling.

Data Protection Officer (DPO):

We have appointed a Data Protection Officer who can be contacted at contact@abrodsky.com for matters related to the processing of personal data and GDPR compliance.

International Data Transfers:

Any transfer of personal data to a third country or an international organization outside the EEA will be based on an adequacy decision, appropriate safeguards, or other derogations as permitted by the GDPR.

Data Breach Notification:

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority within 72 hours of becoming aware of the breach.

Thank you for entrusting us with your personal data. If you have any questions or concerns about our GDPR compliance, please contact our Data Protection Officer at contact@abrodsky.com.

Contact Me

Your Privacy Rights:

You have the right to access, update, or correct your personal information, and you can object to direct marketing. To exercise these rights or raise objections, please contact us via email at contact@abrodsky.com. Specify our company name and provide details of your request. We will reach out if additional information is needed to process your request.

Depending on your local laws, you may have additional rights. For instance, under the EU General Data Protection Regulation (GDPR), if your personal information is processed based on legitimate interests, you can object to the processing based on your specific situation. GDPR also grants you the right to request the deletion or restriction of your personal information and ask for its portability. Make these requests by emailing contact@abrodsky.com with the details of your request.

Lodging a Complaint:

If you believe our processing of your personal information doesn’t comply with applicable data protection laws, you can file a complaint with us by emailing contact@abrodsky.com. Provide specific details, including the company’s name related to the complaint. You may also have the option to lodge a complaint with the relevant data protection authority.

Children’s Privacy:

We prioritize the privacy of young children and do not knowingly collect personal information from children under 17. If we discover such information, we will promptly delete it from our records and systems.

Security Measures

We implement procedural and technical measures to safeguard your personal information from loss, unauthorized access, disclosure, alteration, or destruction. While we strive to protect your information, we cannot guarantee immunity from third-party breaches. By using our website, you acknowledge the potential risk of unauthorized access to your information. We disclaim any warranty or guarantee against misuse, appropriation, alteration, or loss of your information, to the fullest extent permitted by law.

External Links Disclaimer:

Our website may feature links to other sites, and we want to emphasize that we are not responsible for the privacy practices of those external sites. Before providing personally identifiable information, we recommend reviewing the privacy statements of each website. This privacy statement applies exclusively to information collected on this website.

Questions About the Privacy Policy:

Your privacy matters to us. If you have any questions about this Privacy Policy, You can contact us:

By email: contact@abrodsky.com

By visiting this page on our website: https://abrodsky.com/contact 

We reserve the right to modify or alter this privacy policy at any time.

Effective date: 04 July 2024