Privacy Policy

This Privacy Policy applies to information we collect through the Site and through related communications. It does not govern information we receive in the course of providing professional finance and accounting services under a separate, executed engagement letter or master services agreement. Information handled under those engagements is governed by the confidentiality and data-handling terms set out in the applicable engagement documents.

By accessing or using the Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described here, please do not use the Site or submit information to us.

1. Information We Collect

We collect information in three ways: information you provide directly, information collected automatically when you use the Site, and information we receive from third-party sources.

1.1 Information You Provide Directly

When you complete a contact form, request a consultation, subscribe to our newsletter, download a resource, or otherwise communicate with us, you may provide:

Identification information: full name, job title, and company name.
Contact information: business email address, phone number, and mailing address.
Business context: company size, revenue range, industry, services of interest, and the nature of your inquiry.
Communications: the content of messages, emails, voicemails, and meeting notes you share with us.

1.2 Information Collected Automatically

When you visit the Site, we and our service providers may automatically collect:

Device and browser information, including IP address, browser type, operating system, and device identifiers.
Usage information, including pages viewed, time spent on pages, referring URLs, click paths, and search terms used to reach the Site.
Approximate location derived from IP address (city or region level).
Cookies, pixels, tags, and similar tracking technologies, as described in Section 6.

1.3 Information from Third Parties

We may receive information about you from:

Marketing and lead-generation platforms, including LinkedIn, Google, and Substack (where you have subscribed to our newsletter).
Analytics providers and advertising networks.
Publicly available business sources, including company websites, professional directories, and public records.
Referrals from professional advisors, clients, and partners.

1.4 Sensitive Financial Information

If you submit information through the Site, we ask that you not include account numbers, tax identification numbers, login credentials, bank or payroll system passwords, or other sensitive financial data. Sensitive financial information necessary to deliver our services is collected only after a written engagement is in place and is handled under the security and confidentiality terms of that engagement.

2. How We Use Information We Collect

We use the information described above for the following business purposes:

Responding to inquiries, scheduling consultations, and providing requested information.
Evaluating prospective client engagements and preparing proposals.
Sending newsletters, market commentary, service updates, and other communications you have agreed to receive.
Operating, maintaining, securing, and improving the Site and our services.
Analyzing usage patterns to refine content, navigation, and the user experience.
Detecting, preventing, and responding to fraud, security incidents, and misuse of the Site.
Complying with applicable laws, regulations, court orders, and legitimate requests from government authorities.
Establishing, exercising, or defending legal claims.

We do not sell your personal information for monetary consideration. We do not use information collected through the Site to make decisions that produce legal or similarly significant effects about you without human review.

3. Legal Bases for Processing (EEA, UK, and Switzerland)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under the General Data Protection Regulation (GDPR) and the UK GDPR to process your personal information:

Consent: where you have given us clear consent, for example by subscribing to our newsletter or accepting non-essential cookies.
Contract: where processing is necessary to take steps at your request before entering into a contract, or to perform a contract with you or your employer.
Legitimate interests: where we have a legitimate business interest, such as marketing our services to business contacts, securing the Site, and improving our content, provided your interests and rights do not override ours.
Legal obligation: where processing is required to comply with a legal duty.

You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

4. How We Share Information

We share information only as described below.

4.1 Service Providers

We engage third-party vendors to operate our website, deliver email communications, provide analytics, host data, support customer relationship management, and process forms. These vendors are bound by contractual obligations to use information only as instructed and to protect it appropriately. Categories include hosting providers, email service providers, CRM platforms, analytics platforms, advertising platforms, and scheduling tools.

4.2 Professional Advisors

We may share information with our attorneys, auditors, accountants, insurers, and other professional advisors where necessary and subject to obligations of confidentiality.

4.3 Legal and Compliance Disclosures

We may disclose information when required to comply with applicable law, valid legal process, or governmental request, or where we believe in good faith that disclosure is necessary to investigate or respond to suspected fraud, security incidents, violations of our terms, or threats to the rights, property, or safety of any person.

4.4 Business Transfers

4.5 With Your Direction

We may share information with other parties at your direction, including when you ask us to make an introduction to a member of our professional network.

5. Cookies and Tracking Technologies

The Site uses cookies and similar technologies to operate, secure, and improve the user experience, and to support marketing. We use the following categories:

Strictly necessary cookies: required for the Site to function and cannot be disabled in our systems.
Performance and analytics cookies: help us understand how visitors interact with the Site (for example, Google Analytics).
Functional cookies: remember preferences and improve the experience.
Advertising and marketing cookies: support measurement and remarketing through platforms such as LinkedIn Insight Tag, Google Ads, and Meta Pixel.

You can control cookies through your browser settings and through the cookie preference controls available on the Site. Disabling certain cookies may affect functionality. For details on Google Analytics, you may install the Google Analytics Opt-Out Browser Add-on.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes set out in this Privacy Policy, to comply with our legal, accounting, tax, and reporting obligations, and to establish, exercise, or defend legal claims. Retention periods are determined based on the nature of the information, the purpose of processing, and applicable legal requirements. When information is no longer required, we delete it or render it anonymous.

7. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and disclosure. These include access controls, encryption in transit, secure password practices, and vetting of vendors that handle data on our behalf.

No method of transmission over the internet and no method of electronic storage is fully secure. We cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately

8. International Data Transfers

Frak Finance is based in the United States. If you access the Site or provide information from outside the United States, your information will be transferred to and processed in the United States and in other jurisdictions where our service providers operate. These jurisdictions may have data protection laws that differ from those in your country.

Where we transfer personal information from the EEA, the United Kingdom, or Switzerland to a country that has not received an adequacy decision, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or other lawful transfer mechanisms. You may request a copy of the relevant safeguards by contacting us at contact@frakfinance.com.

9. Your Privacy Rights

Depending on where you reside, you may have rights regarding your personal information, including:

The right to know what personal information we collect, use, disclose, and retain about you.
The right to access a copy of your personal information.
The right to correct inaccurate personal information.
The right to delete personal information, subject to legal exceptions.
The right to restrict or object to certain processing.
The right to data portability.
The right to opt out of marketing communications and certain advertising-related processing.
The right not to receive discriminatory treatment for exercising these rights.

To exercise any of these rights, contact us at privacy@frakfinance.com. We will verify your request and respond within the timeframes required by applicable law. You may designate an authorized agent to make a request on your behalf, subject to verification.

9.1 California Residents (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), provides you with the rights described in Section 10 above, as well as the right to opt out of the “sale” or “sharing” of personal information as those terms are defined under the CCPA.

We do not sell personal information for monetary consideration. Some of our use of advertising and analytics cookies may qualify as “sharing” for cross-context behavioral advertising under the CCPA. You may opt out by using the cookie controls on the Site, by sending us a Global Privacy Control signal through your browser, or by emailing privacy@frakfinance.com with the subject line “Do Not Sell or Share My Personal Information.”

Categories of personal information collected and disclosed in the past twelve months are described in Section 2. We do not knowingly collect personal information from California residents under 16 without consent.

Notice of Financial Incentive

We do not offer financial incentives in exchange for the collection, sale, or retention of personal information.

9.2 EEA, United Kingdom, and Switzerland Residents

If you are located in the EEA, the United Kingdom, or Switzerland, you have the rights described in Section 10 under the GDPR or the UK GDPR. You also have the right to lodge a complaint with your local supervisory authority, including the Information Commissioner’s Office in the United Kingdom or the data protection authority in your country of residence.

9.3 Other US State Residents

Residents of certain other US states, including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and others, may have rights similar to those described above under their state privacy laws. To exercise these rights, contact us at privacy@frakfinance.com. If we deny your request, you may have the right to appeal our decision by replying to our response with the subject line “Privacy Appeal.”

10. Children’s Privacy

11. Marketing Communications

If you have provided a business email address or subscribed to our newsletter “Built to Exit,” we may send you market commentary, service announcements, event invitations, and related communications. You may unsubscribe at any time using the link in any marketing email or by emailing privacy@frakfinance.com. We will continue to send you operational communications related to your inquiries or engagements.

12. Third-Party Websites and Services

The Site may contain links to third-party websites, services, and platforms, including LinkedIn, Substack, Calendly, and software providers we reference such as QuickBooks, Sage, Gusto, ADP, Bill.com, and others. These third parties operate independently and have their own privacy policies. We are not responsible for their content or privacy practices. We encourage you to review the privacy policies of any third-party site or service you visit.

13. Do Not Track Signals

Some browsers offer a “Do Not Track” setting. There is no industry-standard interpretation of this signal at this time, and the Site does not currently respond to Do Not Track signals. We do honor Global Privacy Control signals where required by applicable law.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The version in effect is identified by the date at the top of this page. Material changes will be communicated by posting a notice on the Site or by other appropriate means. Your continued use of the Site after changes are posted constitutes your acknowledgment of the updated Privacy Policy.