Privacy Policy

This Privacy Policy describes Our policies and procedureson the collection, use and disclosure of Your information when You use theService and tells You about Your privacy rights and how the law protects You.

Last updated: May 19, 2026

We use Your Personal data to provide and improve theService. By using the Service, You agree to the collection and use ofinformation in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized havemeanings defined under the following conditions.

The following definitions shall have the same meaningregardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

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.

Under GDPR (General Data Protection Regulation), You can bereferred to as the Data Subject or as the User as you are the individual usingthe Service.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Pivoting Strategies LLC, 4918A Barbour Drive, Alexandria, VA 22304.

For the purpose of the GDPR, the Company is the DataController.

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.
Account means a unique account created for You to access our Service or parts of our Service.
Website refers to Pivoting Strategies, accessible from www.pivotingstrategies.com
Service refers to the Website.
Country refers to: Virginia, United States
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.

For the purpose of the GDPR, Service Providers areconsidered Data Processors.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
Facebook Fan Page is a public profile named Pivoting Strategies specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/pivotingstrategies
Instagram is a public profile named Pivoting Strategies specifically created by the Company on the Instagram social network, accessible from https://www.instagram.com/pivotingstrategies
LinkedIn is a public profile page named Pivoting Strategies specifically created by the Company on LinkedIn social media, accessible from https://www.linkedin.com/company/pivoting-strategies-llc
Personal Data is any information that relates to an identified or identifiable individual.

For the purposes for GDPR, Personal Data means anyinformation relating to You such as a name, an identification number, locationdata, online identifier or to one or more factors specific to the physical,physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means anyinformation that identifies, relates to, describes or is capable of beingassociated with, or could reasonably be linked, directly or indirectly, withYou.

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.
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).
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal information to another business or a third party for monetary or other valuable consideration.

Collecting and Using Your PersonalData

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us withcertain personally identifiable information that can be used to contact oridentify You. Personally identifiable information may include, but is notlimited to:

Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Usage Data

Usage Data

Usage Data is collected automatically when using theService.

Usage Data may include information such as Your Device’sInternet Protocol address (e.g. IP address), browser type, browser version, thepages of our Service that You visit, the time and date of Your visit, the timespent 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 limitedto, the type of mobile device You use, Your mobile device unique ID, the IPaddress of Your mobile device, Your mobile operating system, the type of mobileInternet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sendswhenever You visit our Service or when You access the Service by or through amobile device.

Information from Third-Party SocialMedia Services

The Company allows You to create an account and log in touse the Service through the following Third-party Social Media Services:

Google
Facebook
Instagram
LinkedIn
Medium
Substack

If You decide to register through or otherwise grant usaccess to a Third-Party Social Media Service, We may collect Personal data thatis already associated with Your Third-Party Social Media Service’s account,such as Your name, Your email address, Your activities or Your contact listassociated with that account.

You may also have the option of sharing additionalinformation with the Company through Your Third-Party Social Media Service’saccount. If You choose to provide such information and Personal Data, duringregistration or otherwise, You are giving the Company permission to use, share,and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to trackthe activity on Our Service and store certain information. Trackingtechnologies used are beacons, tags, and scripts to collect and trackinformation and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or toindicate 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.

Cookies can be “Persistent” or “Session” Cookies.Persistent Cookies remain on your personal computer or mobile device when Yougo offline, while Session Cookies are deleted as soon as You close your webbrowser.

We use both session and persistent Cookies for the purposesset out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You withservices available through the Website and to enable You to use some of itsfeatures. They help to authenticate users and prevent fraudulent use of useraccounts. Without these Cookies, the services that You have asked for cannot beprovided, 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 theuse of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices Youmake when You use the Website, such as remembering your login details orlanguage preference. The purpose of these Cookies is to provide You with a morepersonal experience and to avoid You having to re-enter your preferences everytime You use the Website.

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information abouttraffic to the Website and how users use the Website. The information gatheredvia these Cookies may directly or indirectly identify you as an individualvisitor. This is because the information collected is typically linked to apseudonymous identifier associated with the device you use to access theWebsite. We may also use these Cookies to test new advertisements, pages,features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and yourchoices regarding cookies, please visit our Cookies Policy.

Use of Your Personal Data

The Company may use Personal Data for the followingpurposes:

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.

We may share your personal information in the followingsituations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to contact You, to advertise on third party websites to You after You visited our Service or for payment processing.
For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see You name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

Retention of Your Personal Data

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

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

Transfer of Your Personal Data

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

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

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

Disclosure of Your Personal Data

Business Transactions

We may disclose personal information that we collect or youprovide as described:

If the Company is involved in a merger, acquisition or asset sale, buyer, or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Pivoting Strategies’ assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Pivoting Strategies about our Website users is among the assets transferred.
To contractors, service providers, and other third parties we use to support our business.
To fulfill the purpose for which your provided it.
For any other purpose disclosed by us when you provide the information.
With your consent.

Your Personal Data may be transferred. We will providenotice before Your Personal Data is transferred and becomes subject to adifferent Privacy Policy.

Law enforcement

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

Other legal requirements

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

Comply with a legal obligation.

To enforce or apply our terms of use pivotingstrategies.com/terms-of-use and other agreements, including for billing and collection purposes.

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.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Pivoting Strategies, our customers or others. This includes exchanging information with other companies and organizations the purposes of fraud protection and credit risk reduction.

Security of Your Personal Data

The security of Your Personal Data is important to Us, butremember that no method of transmission over the Internet, or method ofelectronic storage is 100% secure. While We strive to use commerciallyacceptable means to protect Your Personal Data, We cannot guarantee itsabsolute security.

Detailed Information on the Processingof Your Personal Data

Service Providers have access to Your Personal Data only toperform their tasks on Our behalf and are obligated not to disclose or use itfor any other purpose.

Analytics

We may use third-party Service providers to monitor andanalyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered byGoogle that tracks and reports website traffic. Google uses the data collectedto track and monitor the use of our Service. This data is shared with otherGoogle services. Google may use the collected data to contextualize andpersonalize the ads of its own advertising network.

You can opt-out of having made your activity on the Serviceavailable to Google Analytics by installing the Google Analytics opt-outbrowser add-on. The add-on prevents the Google Analytics JavaScript (ga.js,analytics.js and dc.js) from sharing information with Google Analytics aboutvisits activity.

For more information on the privacy practices of Google,please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Email Marketing

We may use Your Personal Data to contact You withnewsletters, marketing or promotional materials and other information that maybe of interest to You. You may opt-out of receiving any, or all, of thesecommunications from Us by following the unsubscribe link or instructionsprovided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage andsend emails to You.

Mailchimp

Mailchimp is an email marketing sending service provided byThe Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp,please visit their Privacy policy: https://mailchimp.com/legal/privacy/

Behavioral Remarketing

The Company uses remarketing services to advertise on thirdparty websites to You after You visited our Service. We and Our third-partyvendors use cookies to inform, optimize and serve ads based on Your past visitsto our Service.

Facebook
LinkedIn
Instagram

LinkedIn remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising fromFacebook by visiting this page:

https://www.facebook.com/help/247395082112892/?helpref=related_articles

To opt-out from Facebook’s interest-based ads, follow theseinstructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles forOnline Behavioral Advertising established by the Digital Advertising Alliance.You can also opt-out from Facebook and other participating companies throughthe Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, theDigital Advertising Alliance of Canada in Canada http://youradchoices.ca/ orthe European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, oropt-out using your mobile device settings.

For more information on the privacy practices of Facebook,please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

LinkedIn

LinkedIn remarketing service is provided by Microsoft Inc.

You can learn more about interest-based ads, follow theseinstructions from LinkedIn: https://www.linkedin.com/help/lms?lang=en

You can learn more about LinkedIn’s privacy practices andpolicies by visiting their Privacy Policy page: https://www.linkedin.com/legal/privacy-policy

Google

Google AdWords remarketing service is provided by GoogleLLC.

You can learn more about interest-based ads, follow theseinstructions from Google: https://support.google.com/google-ads/?hl=en#topic=7456157

You can learn more about Google’s privacy practices andpolicies by visiting their Privacy Policy page: https://support.google.com/adspolicy/answer/54817?hl=en

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide betterimprovement of our Service.

Invisible reCAPTCHA

We use an invisible captcha service named reCAPTCHA.reCAPTCHA is operated by Google.

The reCAPTCHA service may collect information from You andfrom Your Device for security purposes.

The information gathered by reCAPTCHA is held in accordancewith the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

GDPR Privacy

Legal Basis for Processing PersonalData under GDPR

We may process Personal Data under the followingconditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify thespecific legal basis that applies to the processing, and in particular whetherthe provision of Personal Data is a statutory or contractual requirement, or arequirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality ofYour Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law ifYou are within the EU, to:

Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR DataProtection Rights

You may exercise Your rights of access, rectification,cancellation and opposition by contacting Us. Please note that we may ask Youto verify Your identity before responding to such requests. If You make arequest, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data ProtectionAuthority about Our collection and use of Your Personal Data. For moreinformation, if You are in the European Economic Area (EEA), please contactYour local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook FanPage

The Company is the Data Controller of Your Personal Datacollected while using the Service. As operator of the Facebook Fan Page https://https://www.facebook.com/pivotingstrategies, theCompany and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook thatdefine the terms for use of the Facebook Fan Page, among other things. Theseterms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php formore information about how Facebook manages Personal data or contact Facebookonline, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road,Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection withthe operation of the Facebook Fan Page and on the basis of the GDPR, in orderto obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device ofthe user visiting Our Facebook Fan Page. Each Cookie contains a uniqueidentifier code and remains active for a period of two years, except when it isdeleted before the end of this period.

Facebook receives, records and processes the informationstored in the Cookie, especially when the user visits the Facebook services,services that are provided by other members of the Facebook Fan Page andservices by other companies that use Facebook services.

For more information on the privacy practices of Facebook,please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

CCPA Privacy

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a residentof California, You have the following rights:

The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.
The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our “Do Not Sell My Personal Information” section or web page.
The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom We share Personal Data
- The specific pieces of Personal Data we collected about You
The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer’s rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data ProtectionRights

In order to exercise any of Your rights under the CCPA, andif you are a California resident, You can email or call us or visit our “Do NotSell My Personal Information” section or web page.

The Company will disclose and deliver the requiredinformation free of charge within 45 days of receiving Your verifiable request.The time period to provide the required information may be extended once by anadditional 45 days when reasonable necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the ServiceProviders we partner with (for example, our advertising partners) may usetechnology on the Service that “sells” personal information as defined by theCCPA law.

If you wish to opt out of the use of your personalinformation for interest-based advertising purposes and these potential salesas defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser Youuse. You may need to opt out on every browser that you use.

Website

You can opt out of receiving ads that are personalized asserved by our Service Providers by following our instructions presented on theService:

From Our “Cookie Consent” notice banner
Or from Our “CCPA Opt-out” notice banner
Or from Our “Do Not Sell My Personal Information” notice banner
Or from Our “Do Not Sell My Personal Information” link

The opt out will place a cookie on Your computer that isunique to the browser You use to opt out. If you change browsers or delete thecookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out ofthe use of information about the apps you use in order to serve you ads thatare targeted to your interests:

“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
“Limit Ad Tracking” on iOS devices

You can also stop the collection of location informationfrom Your mobile device by changing the preferences on your mobile device.

“Do Not Track” Policy as Required byCalifornia Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Youbrowsing activities. If You are visiting such websites, You can set Yourpreferences in Your web browser to inform websites that You do not want to betracked. You can enable or disable DNT by visiting the preferences or settingspage of Your web browser.

Children’s Privacy

Our Service does not address anyone under the age of 13. Wedo not knowingly collect personally identifiable information from anyone underthe age of 13. If You are a parent or guardian and You are aware that Yourchild has provided Us with Personal Data, please contact Us. If We become awarethat We have collected Personal Data from anyone under the age of 13 withoutverification of parental consent, We take steps to remove that information fromOur servers.

We also may limit how We collect, use, and store some ofthe information of Users between 13 and 18 years old. In some cases, this meansWe will be unable to provide certain functionality of the Service to theseusers.

If We need to rely on consent as a legal basis forprocessing Your information and Your country requires consent from a parent, Wemay 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 arenot operated by Us. If You click on a third party link, You will be directed tothat third party’s site. We strongly advise You to review the Privacy Policy ofevery site You visit.

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

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We willnotify 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 onOur Service, prior to the change becoming effective and update the “Lastupdated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodicallyfor any changes. Changes to this Privacy Policy are effective when they areposted on this page.

Contact Us

If you have any questions about this Privacy Policy, Youcan contact us:

By email: info@pivotingstrategies.com
By visiting this page on our website: www.pivotingstrategies.com/contact
By mail: 4918A Barbour Drive, Alexandria, VA 22304

COOKIES POLICY

Last updated: May 19, 2026

This Cookies Policy explains what Cookies are and how Weuse them. You should read this policy so You can understand what type ofcookies We use, or the information We collect using Cookies and how thatinformation is used.

Cookies do not typically contain any information thatpersonally identifies a user, but personal information that we store about Youmay be linked to the information stored in and obtained from Cookies. Forfurther information on how We use, store and keep your personal data secure,see our Privacy Policy.

We do not store sensitive personal information, such asmailing addresses, account passwords, etc. in the Cookies We use.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized havemeanings defined under the following conditions.

The following definitions shall have the same meaningregardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Cookies Policy:

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Cookies Policy) refers to Pivoting Strategies, 4918A Barbour Drive, Alexandria, VA 22304.
You means the individual accessing or using the Website, or a company, or any legal entity on behalf of which such individual is accessing or using the Website, as applicable.
Cookies means small files that are placed on Your computer, mobile device or any other device by a website, containing details of your browsing history on that website among its many uses.
Website refers to Pivoting Strategies, accessible from www.pivotingstrategies.com

The use of the Cookies

Type of Cookies We Use

We use both session and persistent Cookies for the purposesset 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.
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 login details or 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.
Tracking and Performance Cookies Type: Persistent Cookies Administered by: Third-Parties Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.
Targeting and Advertising Cookies Type: Persistent Cookies Administered by: Third-Parties Purpose: These Cookies track your browsing habits to enable Us to show advertising which is more likely to be of interest to You. These Cookies use information about your browsing history to group You with other users who have similar interests. Based on that information, and with Our permission, third party advertisers can place Cookies to enable them to show adverts which We think will be relevant to your interests while You are on third party websites.

Your Choices Regarding Cookies

If You prefer to avoid the use of Cookies on the Website,first You must disable the use of Cookies in your browser and then delete theCookies saved in your browser associated with this website. You may use thisoption for preventing the use of Cookies at any time.

If You do not accept Our Cookies, You may experience someinconvenience in your use of the Website and some features may not functionproperly.

If You’d like to delete Cookies or instruct your webbrowser to delete or refuse Cookies, please visit the help pages of your webbrowser.

For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
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For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
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PERSONAL DATA PROCESSED BY THE AITOOLS

Last updated: May 19, 2026

This notice gives you information on how PivotingStrategies (“We”, “Us”, and “Our”) protects your personal data in our use ofthe AI Tools (software applications that incorporate AI technology). Wewill collect your personal data directly from you as a client. Our AI tools uselanguage models licensed from Zoho and Poe.com services. Our third party AImodel LLM providers and third party bot developers may receive details aboutyour interactions with bots on Zoho and Poe (including the contents of your chats)to provide and generally improve their services, which they may process intheir legitimate business interests. Your Zoho user account information (e.g.,username and email) is not shared with our third party AI model providers ordevelopers. Third party developers that create bots on Zoho and Poe using APIsmay view and store your anonymized chats on their servers to train theirmodels. In most cases, we process your personal data using the AI Tools toimprove the efficiency, quality, and speed of our business processes and forthe purpose of providing marketing consulting services.

In using the AI Tools, we may process different types ofpersonal data, such as, but not limited to:

1. Contactpersonal data (e.g., full name, email address, telephone number, job titles andname).

2. Identificationand background information (e.g., a client’s relationship with a marketingconsultant).

https://poe.com/login

In very rare circumstances we may process special categorydata, but we will ensure we have the necessary lawful basis in place beforedoing so.

For this purpose, we rely on our legitimate interest inusing the AI Tools. This legitimate interest is to improve the delivery of ourmarketing consulting services to you.

For further information on how We use, store and keep yourpersonal data secure, see our Privacy Policy.

We do not store sensitive personal information, such asmailing addresses, account passwords, etc. the AI Tools We use.

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More Information about AI Tools

You can learn more about AI Tools at the followingthird-party websites:

Poe.com:
Zoho: https://www.zoho.com/salesiq/chatbot.html

Contact Us

If you have any questions about this AI Tools Policy, Youcan contact us:

By email: mailto:info@pivotingstrategies.com
By visiting this page on our website: www.pivotingstrategies.com/contact
By mail: 4918A Barbour Drive, Alexandria, VA 22304

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