Welcome to Elliott Barry LLC (“Elliott Barry,” “we,” “us,” or “our”). We are a digital marketing agency committed to protecting the privacy and security of the personal information we collect and process. This Privacy Policy outlines our practices concerning the collection, use, disclosure, and protection of personal information obtained through our website (https://elliottbarry.com/), our services, and other interactions with us.

This policy is designed to comply with applicable data protection laws in the United States, including key state-level regulations such as the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and considers principles from other major global regulations for best practice.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OUR WEBSITE OR USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT ACCESS OUR WEBSITE OR USE OUR SERVICES.

2. Information We Collect

We collect various types of information, including information that identifies or can reasonably be linked to an individual (“Personal Information”). The types of information we collect depend on your interaction with us:

  • Information You Provide ly:
    • Contact Information: Name, email address, phone number, physical address.
    • Account Information: Usernames, passwords (when you create an account, if applicable).
    • Business Information: Company name, job title, industry.
    • Payment Information: Credit card details, billing address (processed securely via third-party payment processors).
    • Communication Content: Information you provide when you contact us via forms, emails, calls, or surveys.
    • Client Project Information: Data, assets, and information you provide when engaging our services (see Section 11).
  • Information We Collect Automatically:
    • Log Data: IP address, browser type and settings, operating system, device information, date/time stamps.
    • Usage Data: Pages visited, features used, time spent on pages, links clicked, referring/exit pages.
    • Location Data: General geographic location (derived from IP address).
    • Cookies and Tracking Data: Information collected through cookies, web beacons, pixels, and similar technologies (see Section 6).
  • Information We Collect from Third Parties:
    • Social Media: Information from your public profiles if you interact with us via social media platforms.
    • Analytics Providers: Aggregated or de-identified data from services like Google Analytics.
    • Business Partners & Clients: Information shared in the context of providing services or through referrals.

3. How We Collect Information

  • ly: When you fill out forms, register for an account, sign up for newsletters, request information, engage our services, or communicate with us.
  • Automatically: As you navigate our website, using cookies and other standard tracking technologies.
  • From Others: From third-party services, partners, or publicly available sources, in accordance with their privacy policies and applicable laws.

4. How We Use Your Information

We use the information we collect for various business purposes, including:

  • Providing and Managing Services: To deliver our digital marketing services, manage client accounts, process payments, and fulfill contractual obligations.
  • Communication: To respond to inquiries, send service-related updates, provide customer support, and send administrative information.
  • Marketing and Promotion: To send newsletters, promotional materials, and other information about our services (where permitted by law and with your consent where required). You can opt-out at any time.
  • Website Improvement: To analyze website usage, understand user preferences, improve website functionality, and enhance user experience.
  • Personalization: To tailor website content and marketing communications to your interests.
  • Security: To protect our website, services, and users from fraud, security threats, and other illegal or harmful activities.
  • Compliance and Legal Obligations: To comply with applicable laws, regulations, legal processes, and governmental requests.
  • Analytics and Research: To perform data analysis, conduct research, and generate aggregated insights (usually using de-identified data).

5. How We Share and Disclose Information

We do not “sell” Personal Information in the traditional sense. However, some sharing practices under laws like the CCPA/CPRA might be considered a “sale” or “sharing” (for cross-context behavioral advertising). We may share your information in the following circumstances:

  • Service Providers & Sub-Processors: With third-party vendors, contractors, and agents who perform services on our behalf (e.g., website hosting, payment processing, analytics, email delivery, CRM platforms, advertising platforms). These parties are contractually obligated to protect your data and use it only for the purposes we specify.
  • Clients (Aggregate/Anonymized Data): We may share anonymized or aggregated performance data related to campaigns with our clients.
  • Third-Party Platforms: When providing services (e.g., PPC, Social Media Marketing), we interact with platforms like Google, Meta, LinkedIn, etc. This may involve sharing information as necessary to manage campaigns, subject to their respective privacy policies and your settings on those platforms.
  • Legal Requirements: If required by law, subpoena, court order, or other governmental/regulatory request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, or to investigate fraud.
  • Business Transfers: In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of the transaction.
  • With Your Consent: We may share your information with other third parties when we have your explicit consent to do so.

6. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar technologies to collect information automatically, improve user experience, perform analytics, and support our marketing efforts.

  • What are Cookies? Small text files stored on your device that help us recognize you and remember your preferences.
  • Types of Cookies: We use session cookies (temporary) and persistent cookies (remain for a set period), as well as first-party and third-party cookies. We categorize them as Strictly Necessary, Performance/Analytics, Functional, and Targeting/Advertising.
  • Your Choices: You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. You can also often manage preferences via a cookie consent banner or tool on our website. Please note that blocking essential cookies may affect website functionality. We also aim to recognize and honor Global Privacy Control (GPC) signals where technically feasible and legally required.

7. Data Security

We implement reasonable administrative, technical, and physical security measures designed to protect your Personal Information from unauthorized access, use, disclosure, alteration, or destruction. These measures include encryption, access controls, regular security assessments, and staff training. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

8. Data Retention

We retain Personal Information for as long as necessary to fulfill the purposes for which it was collected, to provide our services, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. The retention period varies depending on the type of information and the purpose of collection. When information is no longer needed, we will securely delete or anonymize it.

9. Your Privacy Rights (US Residents)

Depending on your state of residence, you may have certain rights regarding your Personal Information. These may include:

  • Right to Know/Access: The right to request information about the categories and specific pieces of Personal Information we have collected, used, and disclosed.
  • Right to Delete: The right to request the deletion of your Personal Information, subject to certain exceptions.
  • Right to Correct: The right to request correction of inaccurate Personal Information.
  • Right to Opt-Out of Sale/Sharing: The right to opt-out of the “sale” or “sharing” of your Personal Information, including for cross-context behavioral advertising or targeted advertising.
  • Right to Limit Use of Sensitive Personal Information: The right to limit the use and disclosure of sensitive Personal Information (if we collect it) to specific purposes.
  • Right to Non-Discrimination: The right not to be discriminated against for exercising your privacy rights.

How to Exercise Your Rights: To exercise any of these rights, please contact us using the information in Section 15 below. We will need to verify your identity before processing your request. We may require you to provide certain information to match our records. You may also authorize an agent to make a request on your behalf, subject to verification.

10. Children’s Privacy

Our website and services are not directed to children under the age of 16 (or 13, depending on applicable law), and we do not knowingly collect Personal Information from children. If we become aware that we have inadvertently collected Personal Information from a child without parental consent, we will take steps to delete it promptly. If you believe we might have any information from or about a child, please contact us.

11. Client Data (Data Processor Role)

When providing digital marketing services, Elliott Barry LLC often acts as a “Service Provider” or “Data Processor” on behalf of our clients. In these instances:

  • We process Personal Information provided by our clients or collected through campaigns based solely on our clients’ instructions and our contractual agreements (SOWs and Terms of Service).
  • Our clients, as “Businesses” or “Data Controllers,” are responsible for ensuring they have the necessary legal basis, consents, and notices in place to collect and share that data with us.
  • We handle such data in accordance with our contractual obligations and implement appropriate security measures.
  • Requests from individuals regarding data processed on behalf of a client should generally be directed to that client.

12. International Data Transfers

Elliott Barry LLC operates primarily in the United States. If you are accessing our website or services from outside the US, please be aware that your information may be transferred to, stored, and processed in the United States. We take steps to ensure that any international data transfers comply with applicable laws, which may include using Standard Contractual Clauses or other appropriate mechanisms.

13. Links to Other Websites

Our website may contain links to third-party websites. This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of any third-party sites you visit.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post any changes on this page and update the “Last Updated” date at the top. We encourage you to review this policy periodically. For significant changes, we may provide more prominent notice (e.g., via email or a website banner).

15. Contact Us

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