Figured Eight Consulting LLC

Figured Eight Consulting LLC (“Figured Eight,” “we,” “us,” “our”) is a Massachusetts limited liability company, which has an address of Somerville, MA 02143, which offers strategic, technical, and scientific consulting services. This Privacy Policy (“Policy”) describes our practices and procedures in connection with our collection, use, and disclosure of information about you which may be disclosed, provided, or accessed via your engagement and use of our services, including the receipt of consulting services from us, communications (e.g., emails, phone calls, and texts), mobile applications, and features thereof (collectively, the “Service(s)”) and the use of our website www.figured8consulting.com (the “Site” or “Website”). The terms “you,” “your,” and “Clients” shall refer to users of our Website and our Services.

We respect and value the privacy of Clients and will only collect and use information in a manner consistent with your rights and our obligations under the law. When you use our Services, you consent to the collection, use, and disclosure of information about you as described in this Policy. Before using our Services, we recommend that you read this Policy to understand what information we collect, how we use it, and with whom we may share it. Additionally, this Policy provides you with information about how you can control the use and disclosure of your information.

A. WHAT INFORMATION DO WE COLLECT OR RECEIVE? WHY DO WE COLLECT INFORMATION? HOW MAY THE INFORMATION BE COLLECTED?

We may collect, process, transmit, and store information about you in connection with your visits to our Website or use of our Services, including any information that you send to or through the Website or through use of the Services. We use such information to communicate with you, fulfill your requests, improve the Service’s quality and functionality, engage in research and analysis relating to the Service, personalize your experience and content, track usage of the Service, provide feedback to third parties who are essential to or providing services as part of Figured Eight’s Services to Clients, display relevant advertising, market the Service, provide support, back up our systems, allow for disaster recovery, enhance security of the Service, and comply with our legal obligations. We are deemed a “data controller” as it relates to any Personal Data we collect. Even when we do not retain such information, it still must be transmitted to the servers that we use for our Website and Services initially and stored long enough to process. Having accurate information permits us to provide you with a smooth, efficient, and customized experience when visiting our Site and/or using our Services and enables us to communicate with you effectively.

We may collect and use the following information. Please note that this Site is currently hosted by Squarespace. We may share data with Squarespace as set forth in this Policy so that it can run this Site, and to protect and improve its platform and services. Squarespace analyzes the data in a de-personalized form. For more information about the data to which Squarespace may have access and how they may use and share that data, please review their Privacy Policy.

1. Personal Information: You may visit our Site without disclosing any Personal Data or Personal Information (as those terms are defined by applicable law) (hereafter, collectively “Personal Information”). You may choose to provide certain Personal Information, such as your name, address, payment information, company name, company website, telephone number, IP address, and/or email address on the Site; however, you may be required to share Personal Information with us in order to use our Services and to communicate with us. The Personal Information that we collect from you as part of the Services, may be shared with Partners, third party service providers (as described later herein), and other Members.

2. Non-Personal Information: We may collect certain aggregate and non-personal information when you visit the Site, use, or interact with the Services, such as information about your browser, network, device, web pages that you visited prior to visiting our Website. Aggregate and non-personal information does not relate to a single, identifiable person. For example, it tells us such things as how many users visited our Site and how Services are being utilized and may be improved, the number of clicks made on the Website, internal links accessed, pages viewed, information about scrolling, searches, timestamps, and additional information as further described later herein. By collecting this information, we learn how to tailor our Site and Services to meet your needs. Information that we collect may be shared by you with us directly, or it may be collected indirectly.

3. Cookies and Other Tracking Tools; Third Party Analytics Services. We may use cookies, clear GIFs, web beacons, tracking technologies or other similar solutions (“Tracking Technologies”) to collect or receive certain information when you visit or use our website or read an email, newsletter, or otherwise interact with content from us. These Tracking Technologies may include first party cookies (i.e., those placed by the website being visited) and third-party cookies (i.e., those placed by a website other than the one being visited), local shared objects (commonly referred to as “Flash Cookies” or “HTML 5 Cookies”) and tracking pixels (including transparent or clear gifs).

Cookies are small data files which are placed on your computer or mobile device when you visit a website or use an online service. For example, cookies enable us to identify and authenticate you and remember your preferences so we can enhance your experience on our Website and in connection with our Services.

We strongly recommend that you leave the cookies activated, however, because cookies enable you to take advantage of some of the features of our Services and the Website’s features and if you decline or delete them then parts of the website may not work properly. Where legally permitted, we will assume that you have agreed to receive all cookies on our website through your continued use; otherwise, your acceptance of such cookies by way of your browser settings shall be deemed your acceptance of the use of such Tracking Technologies.

We may use several different types of cookies on our Website, including the following. Please note that our Website is currently hosted by Squarespace. For additional information about the Tracking Technologies that Squarespace uses, please visit their website.

Necessary. Strictly necessary cookies facilitate the operation of our Website which allow Squarespace, our hosting platform, to securely serve this website to you. Without the use of these cookies, portions of our Website would not function properly. For example, we may use essential cookies to help us identify whether you have an account with us.

Performance, Analytics, and Functional Cookies. Performance cookies help us monitor the performance of our Website and how users interact with them. These cookies collect information such as how often users visit our Website, what pages they visit when they do so, and what other Websites they used prior to coming to our Website, and provide us with information that allows us to improve our Website and Services. Figured Eight may also use functional cookies on its Website. Functional cookies are used to remember your preferences on our Website and to authenticate your identity. For example, we may use functional cookies to recognize and save your name and password on our Website. When you use our Website or content posted on it that employs Macromedia Flash Player, a small Flash Cookie may be used. The purpose of using these cookies is to store your flash player preferences and enhance your browsing experience.
Advertising Cookies. Figured Eight may use advertising cookies, including behavioral advertising, in order to provide you with advertising that is tailored to your interests when you visit the Site on and off our Site. Advertising cookies analyze information about your interests and your browsing history and provide you with advertisements on and off our network that match these interests. Behavioral advertising is a type of advertising that is based on your web browsing activity over a period of time. It is different than advertising that you may see when you are using a search engine (e.g., Google, Yahoo, or Bing) or on a website that you may be visiting at a particular time. Although our Website does not currently respond to “do not track” browser headers, you can limit tracking through third-party programs and by taking the other steps discussed in this section. You may opt-out of internet-based advertising by removing cookies or by setting your web browser settings to refuse cookies and similar Tracking Technologies. Please note that web browsers operate using different identifiers. As such, you must adjust your settings in each web browser and for each computer or device that you would like to opt-out on. Further, if you simply delete your cookies, you will need to remove cookies from your device after every visit to websites. You may download a browser plugin that will help you maintain your opt-out choices by visiting www.aboutads.info/pmc. You may block cookies entirely by disabling cookie use in your browser or by setting your browser to ask for your permission before setting a cookie. Blocking cookies entirely may cause some websites to work incorrectly.

Please note that the use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Privacy Policy. You may remove yourself from the targeted advertising of companies within the Network Advertising Initiative, or of companies participating in the Digital Advertising Alliance program, the Digital Advertising Alliance of Canada (DAAC) (for Canadian users); or the European Interactive Digital Advertising Alliance (EDAA) (for users in the EU).

4. Google reCAPTCHA. In addition to the foregoing, in order to protect our registration forms and other website features, we may use Google reCAPTCHA provided by Google Inc. (“reCAPTCHA”). We employ reCAPTCHA to check whether data is entered into our forms by a person or by an automated program, script or bot. reCAPTCHA analyzes the behavior of the person entering the data using various features. This analysis starts automatically as soon as the website is accessed. For analysis, reCAPTCHA evaluates various information (e.g., IP address, browser type, settings, and plugins, URL of the referring website, time spent on the respective website, mouse movements, input characteristics of the data entry, including speed, sequence and selection of inputs, etc.). The data collected during the analysis is forwarded to a Google server in the US, where it is stored and evaluated. We carry out this processing based on our legitimate interest in preventing the misuse of our Website through automated means. You can find Google’s current privacy policy at: https://policies.google.com/privacy. Detailed information about Google reCAPTCHA can be found at the following address: https://www.google.com/recaptcha.

5. Fonts. This Site serves font files from and renders fonts using Google Fonts and Adobe Fonts. To properly display this Site to you, these third parties may receive Personal Information about you, including Information about your browser, network, or device, Information about this site and the page you’re viewing on it, and Your IP address.

B. LAWFUL BASIS FOR THE COLLECTION AND USE OF YOUR INFORMATION

We only collect and process your Personal Information as permitted by applicable law.

For residents located in the European Economic Area, the United Kingdom, and Switzerland certain laws and regulations, including the EU General Data Protection Regulation (“EU GDPR”), the UK General Data Protection Regulation (“UK GDPR”), and other similar laws require data controllers such as Figured Eight to identify the lawful basis that applies to and is relied upon to process the Personal Data of such residents. The lawful basis includes where such processing is necessary for the performance of a contract to which you are a party; necessary for us to take steps, at your request, to enter into such a contract; necessary for the purposes of our legitimate interests or those of a third party and not overridden by the interests or fundamental rights and freedoms of any data subject; where you provide us with consent; or where necessary for compliance with a legal obligation to which we are subject. Under applicable law, we may be obliged to secure and maintain technical and organizational measures to protect the security of your data, investigate and report any (suspected) breaches of those technical and organizational measures, or comply with legal and regulatory obligations, including, but not limited to, complying with minimum retention periods for certain types of data.

C. HOW WE USE YOUR INFORMATION

We may use, aggregate, and retain your Personal Information as needed to provide you with access to our Website and Services and for other legitimate business purposes with your consent. At a high level, we may use such Personal Information as follows:

To provide you with our Services including, information that you request, access, or which may be of interest to you, and to purchase our Services;
To create your account or user profile and purchase history;
To send you satisfaction questionnaires, surveys, and marketing information;
To deliver or display content, advertisements, and other materials that match your interests and responsibilities;
To tailor marketing materials and newsletters delivered to you based on your activity, interests, and responsibilities;
To contact and communicate with you for direct marketing purposes regarding products, services, and events relevant to your professional interests and responsibilities;
To offer you opportunities to connect directly with providers of services that may be of interest to you;
To power our site analytics
To operate our Site and improve our Services;
To understand trends, usage statistics, purchase, and purchase intent data;
To respond to your inquiries or support requests and comments;
To test and evaluate potential new Services and features;
To diagnose and resolve problems, analyze trends, and monitor usage and resource needs; and
For any other purpose that we tell you about when you give us your Personal Information.

For example, we may analyze information collected from you to (a) help us recognize your computer as a previous visitor, and save and remember any preferences that you may have while you were visiting our Website, (b) track, accumulate and report information on our Website and content usage to our partners and third parties who may be providing services in connection with or related to our Services, (c) help us customize the content that you are shown while visiting the Site and potentially other websites, (d) to help us improve the quality and presentation of our Site and Services, (e) personalize your user experience, and (f) identify market sensitivities and relative market interest in specific product categories. We may also use the information that is collected to link your activity to your user account.

D. PARTIES WITH WHOM WE SHARE YOUR PERSONAL DATA

We do not sell, rent, trade or otherwise disclose Personal Information, except as described herein. We share information with service providers and other third parties where it is necessary to meet the requirements of our Terms of Use, to provide our services, or for other purposes as described below.

Partners: Generally, Partners are the entities that may be engaged by us to manage or to provide certain aspects of our Services. We may share your information, including your Personal Information, with these parties in order to complete or assist with the provision of Services, facilitate communication between the parties, and assist with Services and maintenance, or as otherwise may be agreed upon by you.
Service Providers: We rely on third party service providers to support or provide services for us in connection with your use of the Website and the Service, such as communications, security and fraud prevention, technical and customer support, storage, business administration, tracking and reporting usage of the Service and gathering and providing analytics in connection with the Website and Services, quality assurance testing, payment processing, marketing, the hosting of our website, and other functions. We share information from or about you with these service providers so that they can perform services on our behalf or in connection with your requests. Please note that our Website is currently hosted by Squarespace. For more information about the data to which Squarespace may have access and how they may use and share that data, please review their Privacy Policy. We may also share this information with our email provider, Google.
Business Transfers, Affiliates, and Subsidiaries. We may share or transfer the information that we collect 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. We may share your Personal Information within our organization, including with our affiliates and subsidiaries, in order to facilitate the provision of services in connection with your use of our Site or our Services.
Third-Party Analytics and Interest-Based Advertising Partners. We may allow our third-party analytics and interest-based advertising partners to collect certain information on our Site as set forth elsewhere herein.
Legal Compliance and Safety: We may share your Personal Information when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (a) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (b) enforce our agreements, (c) investigate and defend ourselves against any third-party claims or allegations, (d) protect the security or integrity of our services; or (e) exercise or protect the rights and safety of our users, personnel, or others. We may attempt to notify users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Vital Interests: We may disclose the information that we collect where we believe that it is necessary in order to protect the vital interests of any person, or to exercise, establish, or defend our legal rights.
Other Ways in which You Specifically Consent: We may share the information that we collect in other ways to which you specifically consent.

E. THIRD PARTY WEBSITES

The Site and Services may contain links to external websites that are operated by third parties and entities that are not affiliates with Figured Eight. Please be aware that these third-party websites are not owned or controlled by Figured Eight and that the activities on and interactions with such third party websites are governed by such third parties’ policies.

Where Figured Eight provides such third party links, no representations or endorsements are made in connection with such sites. Figured Eight has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party websites or services. If you access a third party website from the Site, you do so at your own risk, and you understand that this Policy does not apply to your use of such websites. You expressly relieve Figured Eight from any and all liability arising from your use of any third party website or services or third party-owned content.

F. INFORMATION RETENTION AND SECURITY

We retain your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain users’ Personal Information for so long as we need to in order to provide our Services, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. We may retain Personal Data after you no longer use our Services if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this Policy and our Terms of Use. We may also retain Personal Information if requested by law enforcement.

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. However, because no data transmission is completely secure, and no system of physical or electronic security is impenetrable. We cannot guarantee the security of the information you send to us or the security of our servers, networks or databases. By using the Site and the Services you agree to assume all risk in connection with the information sent to us or provided to us when you access, visit and/or use the Site or use our Services, including without limitation your Personal Information, and we are not responsible for any loss of such information or the consequences thereof which are in our immediate, commercially reasonable control.

G. COMMUNICATIONS WITH US

Our communications with you, including phone calls, may be monitored and recorded for quality purposes. When you use certain features, you are opting to receive messages from other users, businesses, and Figured Eight. You can manage some of your messaging preferences in your account settings, but note that you cannot opt out of receiving certain administrative, transactional, or legal messages from Figured Eight. We may also track your actions in response to the messages you receive from us or through the Service, such as whether you deleted, opened, or forwarded such messages, and share that information with other parties to your messages. We reserve the right to refuse to deliver messages we deem inappropriate. If you send or receive messages through the Service via SMS text message, we may log phone numbers, phone carriers, and the date and time that the messages were processed. Carriers may charge recipients for texts that they receive. We may also store information that you provide through communications to us, including from phone calls, letters, emails and other electronic messages, or in person. We may contact you, including by phone or email, using the contact information that you provide us, make publicly available, or that we have on record for your business.

H. MODIFICATION AND AVAILABILITY

Figured Eight may, at any time, delete, modify or supplement the content of the Site without prior notice. Figured Eight reserves the right, for any reason, at its sole discretion, to terminate, change, suspend or discontinue any aspect of the Site or other Services, including, but not limited to, content, features or hours of availability. Figured Eight may also impose limits on certain features of the Services or restrict your access to part or all of the Sites or other Services without notice or penalty.

I. Your Data Rights

Figured Eight strives to maintain a high level of privacy for anyone who shares information with us, regardless of where they reside. We take commercially reasonable steps to ensure that your Personal Information is accurate and kept up-to-date. We also take measures to minimize the amount of Personal Information that we collect and retain in our records.

Certain regions and laws may afford you with additional rights in connection with your data, including those set forth below. Please note that Figured Eight is operated from the United States. If you are visiting the Site from outside the United States or are otherwise using the Services from outside of the United States, where legally permitted, you agree to the processing of your Personal Information in the United States. Such information may be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. Those countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Policy.

1. Your EU and UK GDPR Privacy Rights

If you wish to access, rectify, erase, restrict, transfer, or object to the use of your information, or deactivate your account, please access our EU and UK GDPR Rights Request Form. If you have any other questions in connection with this Policy or the use of your Personal Information, please send us an email at privacy@figured8consulting.com.

Every commercial or marketing email sent by or on the behalf of Figured Eight includes information as to how you can easily unsubscribe from future communications. Subject to applicable law, you have the following rights in relation to your Personal Data:

Right of access: If you ask us, we will confirm whether we are processing your Personal Information and, if so, provide you with a copy of that Personal Information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Right to rectification: If your Personal Information is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Information with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly.

Right to erasure: You may ask us to delete or remove your Personal Information and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion, for example if we are required by law to keep it). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly.

Right to restrict processing: You may ask us to restrict or block the processing of your Personal Information in certain circumstances, such as where you contest the accuracy of that Personal Information or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Information with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly.

Right to data portability: You have the right to obtain your Personal Information from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Information in a structured, commonly used and machine-readable format. You may reuse it elsewhere.

Right to object: You may ask us at any time to stop processing your Personal Information, and we will do so if we are processing your Personal Information for direct marketing and otherwise. However, if we are relying on a legitimate interest to process your Personal Information and we demonstrate compelling legitimate grounds for the processing we may continue.

Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Information, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent.

Right to withdraw consent: If we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time. Your withdrawal of consent will not affect apply to data that was processed prior to our receipt of your withdrawal of consent.

Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Information, you can report it to the data protection authority that is authorized to hear those concerns.

2. Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act, as amended (CCPA), permits you to request information regarding the disclosure of your personal data. To learn more about your California privacy rights, please read our California Privacy Notice.

J. CHILDREN’S PRIVACY

Our Services are directed towards professionals. Our business is not directed at children, and we do not solicit or knowingly collect any Personal Data from children under the age of sixteen (16) without verifiable parental consent. If you are not eighteen (18) or older, you are not authorized to use our Services. Parents should be aware that there are parental control tools available online that you can use to prevent children from submitting information online without parental permission or from accessing material that is harmful to minors. If you learn that a child under thirteen (13) has provided us with Personal Data without consent, please contact us using one of the contact methods provided later herein.

K. REVISIONS TO THIS POLICY

Figured Eight reserves the right to change this Privacy Policy, without notice, at its discretion, by posting updates on our website. If we change our Privacy Policy, we will post those changes in addition to updating the “Last Updated” or “Effective Date” date at the bottom of this Policy. You are encouraged to revisit this page periodically in order to stay informed of any changes. The Policy posted at any time via our website shall be deemed to be the Policy then in effect. Where applicable, your continued use of our services, website, or content posted on our website shall constitute your acceptance of the modified or amended Policy. If there will be any changes made to the use of your Personal Data in a manner materially different from that stated at the time of collection, we will notify you by posting a notice on our Website.

L. CORRECTING OR UPDATING YOUR INFORMATION

You are invited to help us keep your Personal Information up to date by notifying us of any changes. You may contact us to correct or update your Personal Information.

M. HOW TO CONTACT US

If you have questions about this Policy, you may contact us at the following address and phone number. You may also contact us by email at privacy@figured8consulting.com

Figured Eight Consulting LLC

Attn: Sylvia Smullin

PO Box 400019

Cambridge, MA 02140

Phone No.: 1-617-286-6438

For security purposes, we may take such steps as we deem necessary to confirm your identity before completing your request or sharing any Personal Information with you.

To the extent of any conflict between the English language version of this Policy and any translations which we may make available, this Policy shall govern. Translated versions of our Policy may be provided for convenience only.

Effective: February 6, 2025