Privacy Policy

Last updated: June 25, 2024

Conversant Group, LLC, including all its group companies and subsidiaries: Athena7, LLC, Grypho5, LLC, Fenix24, Inc., and Fenix24 Ltd. (collectively, “Conversant”, “we”, “our”, “us”) respect your privacy as part of our mission, ethical duties, and commitment to excellence. This Privacy Policy explains how we collect, use, and share your personal information as part of our information practices. “Personal Information” means any information that identifies or relates to a particular individual, and also includes information referred to as “personally identifiable information”, “personal data”, or “protected health information” under applicable data privacy laws, rules or regulations.

This Privacy Policy only applies to personal information that we collect when you visit, interact with, or use our website https://conversantgroup.com/, other websites that we operate (https://athena7.com/; https://grypho5.com/; https://fenix24.com/) which link to this Privacy Policy (collectively, our “Website”), and when you use or interact with our products or services (“Services”).

This Privacy Policy does not apply to the privacy practices of any third-party websites, including those that may be linked through our Website or Services. Such third-party websites are governed by their own privacy policies. Please read the privacy policy of the third-party website you link to for further information about their privacy practices. This Privacy Policy also does not apply where Conversant processes personal information of our customers on their behalf as a data processor. Our collection and processing of such personal information is governed by our agreements with those customers.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the end of this Privacy Policy.

We recommend that you read this Privacy Policy in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Policy, then you can click on the relevant link in the Table of Contents below to jump to that section.

Personal information we collect
How we use your personal information
Legal basis (EEA and UK only)
Sharing of personal information
Cookies and similar tracking technologies
International data transfers
Data security
Data retention
Your Data Protection rights (EEA and UK residents)
U.S. State Data Privacy
Updates to this Privacy Policy
How to contact us

1. Personal information we collect

The personal information that we collect about you depends on how you interact with us:

a) Information that you provide voluntarily

Conversant collects certain personal information from you when you choose to provide us with this information on our Website or through our Services. Such personal information may include:

Contact information: such as your name, email address, phone number, company name, mailing address.
Marketing information: such as your email address and contact preferences if you subscribe to our newsletter/marketing emails.
Account log-in credentials: such as your email address or username and password when you create an account with us.
Content and communications: such as if you correspond with us by email or phone, submit a message on our website contact form, or otherwise request information or support from us.
Payment information: such as your credit card information, billing address, and other payment information to fulfill a transaction.

b) Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area (“EEA”), this information may be considered personal information under applicable data protection laws. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked. Some of this information may be collected using cookies and similar tracking technologies, as explained further in the “Cookies and similar tracking technologies” section below.

c) Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources including: our affiliates; our business customers/clients (who may provide personal information about their employees for example); third parties who are assisting or who have assisted you with responding to a security matter; vendors and service providers who help us operate our business; social networks and advertising providers; business partners who may be co-sponsoring a program or event with us which you have registered to attend; and publicly available sources.

2. How we use your personal information

We use and process your personal information for the following purposes:

To improve our Services: to provide you with information about the Services that you have requested or purchased, and to provide you with more relevant content and service offerings on our Website.
Customer relationship management and delivering our Services: to establish you as a customer on our systems, provide you with information on products or Services that you have requested or purchased, and to manage our customer relationship with you.
Transactional considerations: to complete transactions and to send you related information, including purchase confirmations and invoices.
Service-related communications: We may send you service, technical and other administrative communications or notifications about product or service updates.
To send marketing communications: to communicate with you about our Services, newsletters, promotions or events we think may be of interest to you.
To promote the security of our Website and Services: to investigate and prevent fraudulent transactions, unauthorized access to our Website, Services, and other illegal activities.
Handling contact and support requests: If you fill out a “Contact Us” webform or request support as a user, or if you contact us by other means including via a phone call, we process your personal information in order to assist with your request.
For our business purposes: such as to conduct internal analytics and reporting, aggregate statistical data regarding usage of our Website and Services.
Online advertising: to deliver personalized advertising and marketing campaigns to you based upon your activities and interests.
Complying with legal obligations: to honor our legal obligations under applicable laws, including our obligations to respond to your requests or those of any government authorities under applicable data protection law.

3. Legal basis for processing personal information (EEA and UK only)

If you are a resident of the EEA or the UK, we are required to explain the legal basis for processing your personal information. Our legal basis for collecting and using the categories of personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, in general we collect your personal information only pursuant to the following legal bases, as applicable:

Consent: we may use your personal information when we have your explicit consent to do so, where required or permitted under applicable law;
Legitimate Interests:we may use your personal information when the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.
To contract with you: we may use your personal information in order to perform a contract with you.
Compliance with legal obligations: we may use your personal information in order to comply with a legal obligation under applicable laws, or to protect your vital interests or those of another person.

We may disclose or share your personal information to the following categories of recipients:

Our group companies and affiliates: including Athena7, LLC, Grypho5, LLC, Fenix24, Inc., and Fenix24 Ltd., for purposes that are described in this Privacy Policy.
Business partners: who partner with us in offering various services, such as CrowdStrike Inc.
Third party service providers and vendors: who provide operational or data processing services to us or who otherwise process personal information for purposes that are described in this Privacy Policy.
Law enforcement bodies, regulatory or governmental agencies, and/or courts: in response to legal process or when we believe in good faith that the law requires it, for example, in response to a court order, subpoena or a law enforcement agency’s request.
A strategic transaction partner like a company we consider purchasing or collaborating with as a joint venture (or its agents / advisers): We might share limited contact information in connection with any actual or proposed strategic combination, provided we inform the partner it must use personal information only for the purposes disclosed in this Privacy Policy.
Advertising partners, networks, and social media platforms for marketing and advertising related purposes.

5. Cookies and similar tracking technologies

Our Website uses cookies and other similar tracking technologies (collectively, “Cookies”). We may use Cookies in the following ways: to ensure our Website functions properly; to collect statistical information about how users use our Website which in turn helps us improve our Website; and to enable certain personalization features on our Website to display personalized advertising. You can accept or decline these cookies at any time by adjusting your cookie choices in our cookie banner (which pops up when you visit our Website), and you can also manage your cookie preferences in our Cookie Policy itself. Please note that if you choose to disable certain cookies, this could affect certain features or functionality of our Website.

For further information about the types of Cookies we use, how we use them, and how you can control and opt out from such Cookies, please see our Cookie Policy at Cookie Policy.

6. International data transfers

Your personal information may be stored and processed in your region, in the United States, or in any other country where we or our affiliates or service providers have facilities. Specifically, our Website servers are located in the United States. These countries may have data protection laws that are different from the laws of your country. Of course, none of our storage or processing (or that of our affiliates or service providers) will be in any country subject to the comprehensive export embargoes of the US Department of Commerce.

For personal information transferred from the European Economic Area, Switzerland, or the United Kingdom, to countries which are not subject to an adequacy decision, we have taken appropriate safeguards, including through the use of standard contractual clauses, to ensure that such transfers of personal information will remain protected in accordance with this Privacy Policy.

7. Data security

We use appropriate technical and organisational security measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

Please be advised, however, that while we deploy these security measures and strive to protect your personal information, the use of the internet is not 100% secure, and for this reason we cannot guarantee the security or integrity of any personal information that you transmit or disclose to us or to a third party or vendor who provides services to you online. You should only access our Website and Services within a secure environment.

8. Data retention

We retain your personal information only for as long as we require it for the purposes set out in this Privacy Policy. However, we may also keep some of your personal information for a specified period of time as required by certain laws (for example to comply with applicable legal, tax or accounting requirements).

9. Your Data Protection rights (EEA and UK residents)

Depending on your location, and subject to applicable law, you may have certain rights regarding the personal information we collect about you. Individuals located in the EEA and UK have the following data protection rights:

You may access, correct, or request deletion of your personal information.
You may object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing e-mails we send you.
If we have collected and processed your personal information based on your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

To exercise any of the above rights, please use the contact details provided under the “How to contact us” heading below. We respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

10. U.S. State Data Privacy

California

Additional Disclosures for California residents

This section only applies to residents of California, USA. The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), requires us to provide California consumers with some additional information regarding how we collect, use, and disclose your personal information, and the rights available to California consumers under the CCPA. The terms used in this section have the same meaning as in the CCPA.

As described in section 1 of this Privacy Policy, we may collect the following categories of information about you through our Services or when you visit our Website:

Identifiers, such as your name and email address;
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your contact information;
Device identifiers, such as your IP address;
Internet or other network activity information, such as your browsing history or app usage;
Geolocation data; such as your approximate location based on your IP address and other information that identifies or can be reasonably associated with your device;
Commercial information, such as transaction data;
Your account log-in information i.e. username and password to access your account (if you have an account with us);
Professional or other employment related information, such as where you work and your title; and
Financial information, such as credit card and payment data

The sources from which we collect personal information are also described in section 1 of this Privacy Policy. The business and commercial purposes for which we collect this information are described in section 2. The categories of third parties to whom we disclose this information for a business purpose are described in section 4 of this Privacy Policy.

California Privacy Rights

If you are a California resident, you may have the following rights under the CCPA, subject to certain limitations and exceptions under applicable law:

Know and Access: You have the right to request to know and access the following information covering the 12 months preceding your request:
- the categories of personal information we have collected about you;
- the categories of sources from which your personal information was collected;
- the business or commercial purposes for collecting, “selling” and/or “sharing” your personal information;
- the categories of third parties to whom we have disclosed, “sold” or “shared” personal information about you; and
- the specific pieces of personal information we have collected about you.
You have the right to receive your personal information in a portable and commonly used format.
Correct: You have the right to request that we correct any of your personal information that we have collected from you that is inaccurate.
Delete: You may have the right to request that we delete certain personal information we have collected from you.
Opt out of the “Sale” and “Sharing” of your personal information: You have the right to request that a business not “sell” or “share” your personal information with a third party, as those terms are defined under the CCPA. Conversant does not sell personal information as the term “sell” is traditionally understood (i.e. for money). However, we do process personal information through cookies and other similar technologies for the purpose of displaying targeted advertisements if you instruct us to do so, which could be deemed a “sale” or “sharing” of personal information under the CCPA. You have the right to opt out of such sharing of personal information. You may modify your cookies choices at any time by adjusting your cookie choices in our cookie banner or in our Cookie Policy.
Limit the Use and Disclosure of Your Sensitive Personal Information: We do not use or disclose “sensitive personal information,” as defined by the CCPA other than as described in the “How We Use Your Personal Information” section above or as otherwise permitted under applicable data privacy law. As a result, we do not offer an ability to limit the use or disclosure of sensitive personal information.
Non-Discrimination: You have the right to not be discriminated against for exercising any of your CCPA rights.

Please note that the rights described above are not absolute, and where an exception under applicable law applies, we may be entitled to refuse requests in whole or in part. In California, an authorized agent may submit a rights request on your behalf. We may require an authorized agent to verify their authority to submit a request on your behalf, or we may require you to verify your own identity or confirm with us that you provided the agent with permission to submit the request. We will only use the information provided for verification to confirm the requestor’s identity or authority to make the request, and for our compliance records.

To exercise any of the above rights, please refer to our contact details in the “How to contact us” section below. We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period (up to a total of 90 days) in writing.

Additional U.S. States

This section is for residents of certain U.S. states which may have an applicable data privacy law currently in effect, including to the extent that their statutes apply, Colorado, Connecticut, Utah, and Virginia, or other applicable US state laws. Depending on your U.S. state of residency, you may have the following privacy rights (as and to the extent applicable):

Know and Access: You have the right to request to know and access the Personal Information that we have collected about you.
Data Portability: You have the right to obtain your Personal Information in a portable and readily usable format.
Correction: You have the right to request that we correct inaccuracies in your Personal Information.
Deletion: You have the right to request to delete your Personal Information.
Opt-out of Data Processing for purposes of Targeted Advertising; Sales to Third Parties; and Profiling: As described in the California section above, we do not sell Personal Information to third parties for money, nor for the purpose of profiling in connection with decisions that produce legal or similarly significant effects. However, we do process Personal Information for the purpose of displaying targeted advertisements, if you instruct us to do so. You have the right to opt out of the processing of Personal Information for targeted advertising purposes at any time by changing your cookies choices via our cookie banner and/or Cookie Policy.
Appeal: You have the right to appeal a refusal to take action on your request. You may ask us to reconsider our decision within 45 days after we send you our decision. We will endeavor to respond to your appeal within 60 days of such an appeal, including a written explanation of the reasons for the decision, and any action taken or not taken in response to the appeal.

Please note that the rights listed above only apply to a resident in Colorado, Connecticut, Utah, and Virginia who is acting in an individual or household context only, and do not include residents acting in a commercial or employment context. If you reside in a U.S. state which has an applicable data privacy law currently in effect, and wish to submit a rights request, please refer to the “How to contact us” section below.

11. Updates to this Privacy Policy

We may update this Privacy Policy from time to time. You can see when it was last updated by checking the “last updated” date at the top of this Privacy Policy. We encourage you to check on this page periodically so that you can keep up to date with any changes.

If we make any material changes to this Privacy Policy, we will take appropriate measure to inform you, consistent with the significance of the change, for example, posting a prominent notice on the Website, and/or notifying you via email or through our Services.

12. How to contact us

If you have any questions or concerns about this Privacy Policy, or wish to submit a privacy rights request, please contact us by using the following contact details:

Conversant Group, LLC
Attention, Legal/Privacy
1513 Cowart Street,
Chattanooga, TN 37408, United States
Email: privacy@conversantgroup.com
Phone number: Toll-free: (877) 313-1388

For any marketing opt-out, please note the content above related to your cookie selections, and for any email, state MARKETING OPT-OUT in the subject line.
For any individual request to know, delete or correct data, we may require verification of your identity.