Privacy Policy

GroupA LLC (“GroupA,” “we,” “our,” or “us”) respects your privacy. This Privacy Policy explains how we collect, use, and disclose information when you visit our website (the “Site”) or otherwise interact with us through digital channels. This policy is designed to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA/CPRA”), the California Online Privacy Protection Act (“CalOPPA”), California Civil Code § 1798.83 (“Shine the Light”), and other applicable laws.

1. Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information as defined by the CCPA/CPRA:

• Identifiers — name, business email address, postal address, phone number, IP address, online identifiers
• Customer Records — information you provide in contact forms or correspondence (employer, title, contact details)
• Internet/Network Activity — browsing history on the Site, pages viewed, time spent, referring URLs, interaction data
• Geolocation Data — approximate (city/region-level) location derived from IP address
• Inferences — interests inferred from your interaction with the Site for the purpose of evaluating GroupA’s services

We do not knowingly collect “sensitive personal information” as defined by the CPRA through this Site.

2. Sources of Information

• Directly from you (forms, email, downloads)
• Automatically from your device (cookies, server logs, analytics)
• From service providers acting on our behalf (analytics, hosting, email delivery)

3. Purposes for Which We Use Personal Information

• To respond to inquiries and provide requested information
• To operate, maintain, secure, and improve the Site
• To understand how visitors interact with the Site through analytics
• To communicate with you about GroupA services, where permitted
• To comply with legal obligations and protect our rights, property, and safety
• For other purposes disclosed at the time of collection

4. Disclosure of Personal Information

We do not sell personal information for monetary consideration. Within the broad CCPA/CPRA definitions of “sell” and “share,” our practices are:

• Sale of Personal Information — We do not sell personal information.
• Sharing for Cross-Context Behavioral Advertising — We do not share personal information for cross-context behavioral advertising.
• Disclosure to Service Providers — We disclose personal information to service providers that perform functions on our behalf (such as website hosting, analytics, and email delivery) under written contracts that limit their use of the information to the services they provide to us.
• Disclosure for Legal/Business Purposes — We may disclose personal information to professional advisors (auditors, counsel), parties to a corporate transaction (such as a merger or acquisition), and regulators or law enforcement when required by law or to protect rights, property, or safety.

5. Your California Privacy Rights (CCPA/CPRA)

California residents have the following rights with respect to their personal information:

• Right to Know — request the categories and specific pieces of personal information we have collected, the sources, the purposes for collection, and the categories of third parties to whom we have disclosed it
• Right to Delete — request deletion of personal information we have collected, subject to legal exceptions
• Right to Correct — request correction of inaccurate personal information
• Right to Opt Out of Sale or Sharing — direct us not to sell or share personal information for cross-context behavioral advertising
• Right to Limit Use of Sensitive Personal Information — restrict use of sensitive personal information to specified purposes (we do not use sensitive personal information beyond what is permitted by default)
• Right to Non-Discrimination — exercise these rights without discriminatory treatment
• Right to Designate an Authorized Agent — authorize an agent to make requests on your behalf, subject to verification

To exercise these rights, contact us at info@groupainc.com with the subject “California Privacy Rights Request.” We will verify your identity before responding, generally by matching information you provide against information we already hold. We will respond within the timeframes required by law (generally 45 days, with one 45-day extension if needed). You may also designate an authorized agent to make a request on your behalf; we will require proof of authorization and may require you to verify your identity directly.

6. “Shine the Light” Disclosure

California Civil Code § 1798.83 permits California residents to request, once per year, information about the personal information we have shared with third parties for those parties’ direct marketing purposes during the prior calendar year. We do not share personal information with third parties for their direct marketing purposes.

7. “Do Not Track” Disclosure (CalOPPA)

Some browsers transmit “Do Not Track” signals. Because there is no industry-standard interpretation of these signals, we do not currently respond to them. We will update this section if our practices change.

8. Cookies and Similar Technologies

We use first-party and third-party cookies, pixels, and similar technologies for site functionality, analytics, and performance measurement. You can control cookies through your browser settings or through the cookie preference controls available on the Site. The Site supports the Global Privacy Control (“GPC”) signal as a valid opt-out request from California residents for the sale or sharing of personal information.

9. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods are determined based on the type of information and the purpose for which it was collected.

10. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.

11. Other U.S. State Privacy Rights

Residents of other U.S. states with comprehensive privacy laws (including but not limited to Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, and others) may have similar rights to those described above for California residents, including rights to access, delete, correct, and opt out of certain processing. To exercise any such rights, contact us at info@groupainc.com.

12. EEA, UK, and Swiss Residents (GDPR/UK GDPR)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you may have rights to access, correct, delete, restrict, or object to processing of your personal data, and to data portability. The legal bases for our processing are typically your consent, our legitimate interests in operating and marketing our business, and our compliance with legal obligations. You may also lodge a complaint with your local supervisory authority.

13. International Transfers

GroupA is based in the United States and information we collect may be processed in the U.S. or other jurisdictions that may not have data protection laws equivalent to those in your country.

14. Children

The Site is not directed to individuals under 16, and we do not knowingly collect personal information from children. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

15. Third-Party Services

The Site is hosted on Vercel (which provides edge hosting and basic request analytics). No additional third-party advertising, analytics, or tracking technologies are loaded. Vercel’s privacy practices are governed by its own policy.

16. Changes

We may update this Privacy Policy from time to time. The “Effective Date” above indicates when it was last revised. Material changes will be communicated through a notice on the Site.

17. Contact

To exercise privacy rights or ask questions about this policy, contact: