CAVU

Privacy Policy

1. OUR APPROACH TO PRIVACY

1.1 The CAVU Advisors operating segment of WSL Consulting, LLC (“WSL”, “CAVU” “we”, “our” or “us”) is committed to protecting your privacy.  This privacy policy sets out how we collect, use, share, store, process, transfer, and retain data that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context (“personal information”) and information regarding our use of cookies and similar technologies.  This privacy policy also sets out your rights with respect to your personal information.

1.2 CAVU provides accounting outsourcing and financial consulting (the “Service”).

1.3 This privacy policy applies to our Website and the Service.

1.4 Before accessing or using the Service, please ensure that you have read and understood our collection, use, disclosure, storage, process, transfer, and retention of your personal information as described in this privacy policy. By accessing or using the Service, you are accepting and consenting to the practices described in this privacy policy.

2. TYPES OF INFORMATION WE COLLECT

2.1 Information you give to us. We collect personal information about you when you voluntarily submit information directly to us by filling in forms on our Website, completing online surveys, or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our Website, subscribe to the Service, participate in any discussion boards, forums or other social media functions on our site, and when you report a problem with our Website, or use some other feature of the Service as available from time to time.  We collect your contact information and basic personal details, such as your full name, title, company name, billing address, email address, phone number, business website address, username, and password.  In addition, we collect details, such as your credit card information with authorization to charge for recurring monthly charges.  If you choose not to provide personal information, we may not be able to provide the Service to you or respond to your other requests.

2.2 Information we receive from other sources. We may receive personal information about you from individuals or corporate entities which are subscribers to the Service (“Subscribers”) where you are to be designated a user of the Service. We may receive personal information about you if you use any of the other websites we operate or the other services we provide from time to time. We also work closely with third parties (e.g., subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them, subject to your agreements with them.  In addition, we may receive personal information about you through the API access granted by you to CAVU from your source systems (e.g., order management software, CRM software, shipping software, Amazon AWS accounts, and accounting software).

2.3 Information collected automatically.  We, as well as third parties that provide content, analytics, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, web beacons, and other technologies (“cookies”) to automatically collect personal information about you as to how you access and use the Service and information about the device you use to access the Service, which are stored in log files.  Cookies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole.  We may receive reports based on the use of these cookies by these companies on an individual as well as aggregated basis.  We may use the following types of cookies:

  1. Strictly necessary cookies. These cookies are required for the essential operation of our Service such as to authenticate you and prevent fraudulent use.
  2. Analytical/performance cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors navigate our Service when they are using it. This helps us to improve the way our Service works, for example, by ensuring that you can find information easily.
  3. Functionality cookies. These cookies are used to recognize you when you return to our Service. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  4. Targeting cookies. These cookies record your visit to our Service, your location, the pages you have visited and the links you have followed. We will use this information to make our Service more efficient and easier to use. We may also share this information with third parties for this purpose.

We also automatically collect information, which may include Internet protocol (IP) addresses, browsers and applications connected to the Service through your device, internet service provider (ISP) or mobile network, referring/exit pages, operating system, date/time stamp, and/or clickstream data.

3. HOW WE USE THE INFORMATION WE COLLECT

3.1 To Provide the Service.  We will use the information collected to operate, maintain and provide the features and functionality of the Service for which our clients have engaged us.   We use information collected about your device to enable the Service to be presented to you on your device.

3.2 To Personalize User Experience.  We may link or combine the personal information we collect and/or receive about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.

3.3 To Monitor and Improve the Service.  We use the information we collect to monitor and improve the Service, our Website and for internal operations.  We also use the information to address your questions, issues and concerns and resolve your customer service issues.  We may anonymize and aggregate any of the personal information we collect (so that it does not identify you). We may use anonymized information for purposes that include testing our IT systems, research, internal data analysis, analytics, improving the Service, developing new products or features, and any other legally permissible purpose.

3.4 For Administrative Purposes.  We may use collected information about you for administrative purposes, including to measure interest in our Service, develop new products and services, ensure internal quality control, verify individual identity, verify account information, account management, customer service, system maintenance, process payment for Services, and prevent potentially prohibited or illegal activities. We may also use the information to facilitate payment for use of the Service through a third-party intermediary to manage credit card processing, and to detect and prevent fraud.

3.5 For Marketing Purposes.   We use the information we collect to communicate with you, including sending statements, news, alerts, and marketing communications.  We may use personal information to provide you with materials about offers, products, and Services that may be of interest to you, including new content or services.  You may contact us at any time to opt-out of the use of your personal information for marketing purposes, as further described below.

4. SHARING THE INFORMATION WE COLLECT

4.1 With Our Team.  We may share your personal information with any member of our team in connection with the Service.  We may share anonymized or aggregated information internally for our own purposes.

4.2 With Selected Third Parties.  We will not sell or share your personal information with any third parties, except as described in this privacy policy or in connection with the Service. We may share such information with others for their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.  We may share your personal information with selected third parties, including:

  1. Vendors, suppliers and subcontractors who perform services on our behalf (these companies are authorized to use your personal information only as necessary to provide these services to us);
  2. Analytics and search engine providers that assist us in the improvement and optimization of our Website;
  3. Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
  4. Payment processors for the purpose of fulfilling relevant payment transactions;
  5. Business partners in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

4.3 As Required or Necessary.  We may access, preserve, and disclose your personal information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests or legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect the rights, property, or safety of CAVU, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; (iv) to enforce CAVU policies or contracts; (v) to collect amounts owed to CAVU; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

4.4 For Testimonials. With consent, we may display personal testimonials of satisfied customers on our site, along with other endorsements. If you wish to update or delete your testimonial, you can contact us at info@cavuadvisors.com.

5. STORING THE INFORMATION WE COLLECT

All information you provide to us is stored on secure servers in a controlled environment with limited access. Any payment transactions will be encrypted in transit using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Service, you are responsible for keeping this password confidential. Subscribers should not share their password with anyone.  While no transmission of information via the internet is completely secure, we take reasonable measures to protect your personal information. We cannot guarantee the security of your personal information transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

6. PROCESSING THE INFORMATION WE COLLECT

The processing of information we collect is necessary for our legitimate interests, including to: (i) perform our obligations under the applicable User License Agreement for the Service, (ii) communicate with you effectively for the purposes of resolving customer service issues, (iii) administer and improve the Service and our business; (iv) develop new services, (v) tailor the Service to the user and other marketing purposes, and (vi) conduct relevant analysis to improve the Service.

7. TRANSFERING THE INFORMATION WE COLLECT

7.1 We may store all information we collect anywhere in the world, including but not limited to, in the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers.  The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations.

7.2 IF YOU ARE A USER ACCESSING THE SITE OR SERVICES FROM THE EUROPEAN UNION, ASIA, OR ANY OTHER REGION WITH LAWS OR REGULATIONS GOVERNING PERSONAL DATA COLLECTION, USE AND DISCLOSURE THAT DIFFER FROM THE UNITED STATES LAWS, PLEASE BE ADVISED THAT THROUGH YOUR CONTINUED USE OF THE SITE OR SERVICES, WHICH IS GOVERNED BY UNITED STATES LAW AND THIS PRIVACY POLICY, YOU ARE TRANSFERRING YOUR PERSONAL INFORMATION TO THE UNITED STATES, AND YOU CONSENT TO THAT TRANSFER.  ADDITIONALLY, YOU UNDERSTAND THAT YOUR PERSONAL INFORMATION MAY BE PROCESSED IN COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING PERSONAL INFORMATION MAY BE DIFFERENT OR LESS STRINGENT THAT IN YOUR HOME JURISDICTION.

8. RETAINING THE INFORMATION WE COLLECT

8.1 We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.  We will retain your information for as long as your account is active, or as needed to provide you Services.

8.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.

9. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

9.1 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

  • Right of access and portability. The right to obtain access to your personal information, and to receive that personal information in a commonly used format and to have it ported to another data controller.
  • Right to rectification. The right to obtain rectification of your personal information, or modify or update your account information, without undue delay where that personal information is inaccurate or incomplete.
  • Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
  • Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
  • Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.

9.2 If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct or request deletion of your personal information by logging into your account, or by contacting us at info@cavuadvisors.com. We will respond to your request within 30 days.

10. LINKS TO THIRD PARTY SITES

10.1 The Service may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

10.2 Some of the pages on our Website may utilize framing techniques to serve content to/from our partners while preserving the look and feel of our Website. Please be aware that you are providing your personal information to these third parties and not to CAVU.

11. OUR POLICY TOWARDS CHILDREN

The Service is not directed at persons under 18 and we do not intend to collect personal information from children under 18. If you become aware that a child has provided us with personal information without appropriate consent, then please contact us using the details below so that we can take the appropriate steps in accordance with our legal obligations and this privacy policy.

12. YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are residents of the State of California in the United States to annually request and obtain, at no charge, information about the personal information (if any) we have disclosed to third parties for direct marketing purposes in the preceding calendar year.  This information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year.  If you are a California resident and would like to make such a request, please submit your request to info@cavuadvisors.com.

13. CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.  Your continued use of the Website or Service constitutes your agreement to be bound by such changes to the privacy policy.  Your only remedy, if you do not accept the terms of this privacy policy, is to discontinue use of the Website and Service.

14. CONTACTING YOU

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Website or through the Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

15. CONTACTING US

Regardless of your location, any questions, comments and requests regarding this privacy policy are welcome and should be addressed to our Data Protection Officer, at info@cavuadvisors.com. Communication can also be addressed to:

CAVU Advisors
Attn: Data Protection Officer
7160 Columbia Gateway Drive
Suite 200
Columbia, MD 21046

Last Modified Date: April 1, 2019