Privacy Policy — Stintwell, LLC

1. Scope and Data Roles

This Privacy Policy applies to business clients, prospective clients, and authorized representatives interacting with Stintwell.

Depending on the context, Stintwell may act as an independent data controller or as a service provider/processor. In most engagements, Stintwell acts as a controller of business contact information, assessment responses, and engagement-related data. In limited circumstances, Stintwell may process information on behalf of a client pursuant to a written agreement.

This policy does not apply to consumer products or consumer data unrelated to a business relationship.

2. Information We Collect

We collect information necessary to deliver our services, operate our platform, and meet legal obligations.

Information You Provide

• Business contact information
  Name, business email address, phone number, job title, and company name.
• Assessment responses
  Responses to questionnaires, operational assessments, and structured inputs.
• Organizational information
  Org charts, role titles, headcount estimates, and functional descriptions.
• Aggregated financial information
  Revenue ranges, margin percentages, runway estimates, and similar high-level summaries.

Information Collected Automatically

• Website and platform analytics
  Pages visited, session duration, navigation paths, device and browser type.
• Session recordings
  Mouse movement, scrolling behavior, and click interactions captured through tools such as Mouseflow.

We do not record keystrokes, credentials, passwords, or form inputs prior to submission. Data is captured only after information is intentionally saved.

Information We Do Not Collect

We do not intentionally collect:

• Social Security numbers or government identifiers
• Bank account or routing numbers
• Detailed financial statements
• Payment card data (handled by third-party processors)
• Protected health information (PHI)
• Consumer personal data unrelated to a business engagement

Clients are instructed not to submit sensitive personal information or regulated data. If such information is inadvertently provided, Stintwell will take reasonable steps to limit use and delete the information where feasible.

3. How We Use Information

We use information for the following purposes:

• Service Delivery
  Providing assessments and advisory services
  Supporting client engagements and platform functionality
• Communication
  Responding to inquiries
  Coordinating services
  Sending service-related notices and updates
• Product Improvement and Model Development
  Improving assessments, scoring systems, analytical models, and platform features
  Developing aggregated benchmarks and insights
  Stintwell may use aggregated and de-identified information derived from client engagements for these purposes. We do not use identifiable client data for secondary purposes without consent.
• Marketing and Business Development
  Sending periodic business insights, updates, or product information
  CRM-based nurturing communications
  You may opt out of marketing communications at any time.
• Legal and Operational Purposes
  Fulfilling contractual obligations
  Complying with applicable laws
  Protecting against misuse, fraud, or security incidents

4. Aggregated Insights and Benchmarking

Stintwell may publish or share high-level, aggregated, and anonymized insights such as industry benchmarks, trends, or performance summaries. These materials do not identify individual clients.

Client names, logos, testimonials, or identifiable engagement details are never used in case studies or marketing materials without explicit written permission.

5. Information Sharing

We may share information with:

• Service Providers
  Third-party vendors that support our operations, such as:
  CRM systems
  Analytics and session-recording providers
  Email and communications platforms
  Cloud hosting providers
  Payment processors
  These providers may access information only as necessary to perform services on our behalf.
• Business Transfers
  In connection with a merger, acquisition, or sale of assets, subject to appropriate safeguards.
• Legal Requirements
  Where required by law, regulation, court order, or governmental request.
• With Consent
  Where you explicitly authorize sharing.

6. Data Retention

We retain information only as long as necessary for legitimate business purposes.

• Engagement data: Retained for the duration of the engagement and deleted upon client request following data export, except where limited retention is required for legal, contractual, or accounting purposes.
• Marketing data: Retained until you opt out.
• Analytics and session data: Typically retained for 24–36 months.

Retention periods may vary based on legal obligations or contractual terms.

7. Data Security

We implement administrative, technical, and organizational safeguards appropriate to the nature of the information processed and consistent with industry practices for B2B advisory and software services. These include access controls, encryption where appropriate, and secure cloud infrastructure.

No system can be guaranteed to be completely secure.

8. Your Rights and Choices

General Rights

You may request to:

• Access your information
• Correct inaccuracies
• Export your data in commonly used formats such as JSON or CSV
• Delete your data after export
• Opt out of marketing communications

These rights are subject to legal, contractual, and professional obligations.

California Privacy Rights

If you are a California resident, you have rights under applicable California privacy laws, including the right to access, delete, or correct personal information and the right not to be discriminated against for exercising these rights.

Stintwell does not sell personal information, as "sell" is defined under applicable California privacy laws.

Canadian Privacy Rights

If you are located in Canada, you may request access to or correction of your personal information and may withdraw consent subject to legal or contractual restrictions. Information may be processed or stored outside Canada, including in the United States.

9. Cookies and Session Recording

We use cookies and similar technologies for functionality, analytics, and session recording. Session recording tools are enabled only where permitted by law and are governed by cookie and tracking preferences. Where required, session recordings are collected only after consent is provided through browser or site controls.

10. Children's Privacy

Stintwell does not knowingly collect information from individuals under 18 years of age.

11. Contact Information

For questions or requests related to this Privacy Policy, contact:

Email: steve@stintwell.com
Mailing Address:
7520 NW 104th Ave Ste A103 PMB 4210
Doral, FL 33178-3374
United States

12. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted with a revised "Last Updated" date.