beBOLD Privacy Policy

Last updated: Sept 19th, 2026

1. Introduction

This Privacy Policy describes how beBOLD Digital Inc. ("beBOLD," "Company," "We," "Us," or "Our") collects, uses, discloses, and protects information when you use our website located at https://www.bebolddigital.com/ (the "Service"), and explains your privacy rights and how the law protects you.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

2. Interpretation and Definitions

2.1 Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

2.2 Definitions

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Company (referred to as either "the Company," "We," "Us," or "Our" in this Agreement) refers to beBOLD Digital Inc., 1670 Santa Ana Ave, STE A, Costa Mesa, California.
  • Cookies are small files placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history among its many uses.
  • Country refers to: California, United States.
  • Device means any device that can access the Service, such as a computer, a cellphone, or a digital tablet.
  • Personal Data (or Personal Information) means any information that relates to an identified or identifiable individual, or that is reasonably linkable, directly or indirectly, to a particular consumer or household.
  • Sensitive Personal Information means certain categories of Personal Information given heightened protection under applicable state privacy laws — for example, government identifiers, precise geolocation, account log-in credentials, and information concerning health, sex life, sexual orientation, racial or ethnic origin, religious beliefs, union membership, or citizenship or immigration status, as well as Personal Information of consumers the Company has actual knowledge are under 16 years old. beBOLD does not intentionally collect Sensitive Personal Information through the Service.
  • Sell and Share have the meanings given to them under applicable U.S. state privacy laws, including the CCPA. "Share" generally includes disclosing Personal Information to a third party for cross-context behavioral advertising, whether or not for money, such as through certain advertising or analytics cookies.
  • Opt-Out Preference Signal means a technical signal, such as the Global Privacy Control (GPC), sent by or on behalf of a consumer's browser or device that communicates the consumer's choice to opt out of the sale or sharing of their Personal Information.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes data on behalf of the Company.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
  • Website refers to beBOLD Digital, accessible from https://www.bebolddigital.com/.
  • 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.

3. Collecting and Using Your Personal Data

3.1 Types of Data Collected

Personal Data. While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You, including: email address; first and last name; phone number; and Usage Data.

Usage Data. Usage Data is collected automatically when using the Service, and may include information such as Your device's Internet Protocol (IP) address, browser type and version, the pages of our Service that You visit, the time and date of Your visit, time spent on those pages, unique device identifiers, and other diagnostic data. When You access the Service through a mobile device, We may also collect the type of device, its unique ID, mobile operating system, and mobile browser type.

3.2 Tracking Technologies and Cookies

We use Cookies and similar tracking technologies (such as beacons, tags, and scripts) to track activity on Our Service, remember preferences, and analyze how the Service is used. This includes analytics and tag-management tools such as Google Tag Manager, and advertising tools including the Meta Pixel, the Google Ads remarketing tag, and the LinkedIn Insight Tag. beBOLD has confirmed no other trackers are currently live on the site beyond these four.

  • Necessary/Essential Cookies (Session) — required to provide the Website's features and to authenticate users and prevent fraudulent use.
  • Cookies Policy/Notice Acceptance Cookies (Persistent) — identify whether users have accepted the use of cookies on the Website.
  • Functionality Cookies (Persistent) — remember choices You make, such as login details or language preference.

3.3 Advertising Cookies and Cross-Context Behavioral Advertising

beBOLD uses the Meta Pixel, the Google Ads remarketing tag, and the LinkedIn Insight Tag on the Service to deliver ads that are targeted to Your interests across other websites. This activity is considered "Sharing" of Personal Information — specifically, cross-context behavioral advertising — under the CCPA and similar state laws, even though no money changes hands. You have the right to opt out of this Sharing; see Section 11 ("Your Privacy Rights") below.

4. Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • 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, where applicable.
  • For the performance of a contract: the development, compliance, and undertaking of any contract with You through the Service.
  • To contact You by email, telephone, SMS, or other electronic means regarding updates or informative communications related to Our services, including security updates, when necessary or reasonable.
  • To provide You with news, offers, and general information about goods, services, and events similar to those You have already purchased or inquired about, unless You have opted out of such communications.
  • To manage and respond to Your requests to Us.
  • For business transfers: to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets.
  • For other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns, and evaluating and improving Our Service and Your experience.

5. Sharing of Your Personal Information

We may share Your Personal Information in the following situations:

  • With Service Providers, to monitor and analyze use of the Service and to contact You.
  • For business transfers, in connection with a merger, sale of Company assets, financing, or acquisition.
  • With Affiliates, who will be required to honor this Privacy Policy.
  • With business partners, to offer You certain products, services, or promotions.
  • With other users, when You voluntarily share information in public or shared areas of the Service.
  • With Your consent, for any other disclosed purpose.

beBOLD does not sell Personal Information for money or other valuable consideration. However, as described in Section 3.3 above, Our use of the Meta Pixel, Google Ads remarketing tag, and LinkedIn Insight Tag is considered "Sharing" of Personal Information under the CCPA and similar state laws. You may opt out of this Sharing as described in Section 11 below.

6. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, including to comply with legal obligations, resolve disputes, and enforce Our agreements and policies. Usage Data is generally retained for a shorter period, except when needed to strengthen security, improve functionality, or comply with a legal retention obligation.

7. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. Because beBOLD provides services to clients in the United States, Canada, and Mexico, Your information may be transferred to, and maintained on, computers located outside of Your state, province, or country, where data protection laws may differ from those in Your jurisdiction. Your submission of such information represents Your agreement to that transfer. The Company will take reasonable steps to ensure Your data is treated securely and in accordance with this Privacy Policy.

8. Disclosure of Your Personal Data

8.1 Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

8.2 Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.

8.3 Other Legal Requirements

The Company may disclose Your Personal Data in the good-faith belief that such action is necessary to comply with a legal obligation; 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; or protect against legal liability.

9. Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

10. Children's Privacy

Our Service does not address anyone under the age of 13, and We do not knowingly collect personally identifiable information from anyone under 13. If You are a parent or guardian and are aware Your child has provided Us with Personal Data, please contact Us, and We will take steps to remove that information. Where consent is required as a legal basis for processing and Your country requires parental consent, We may require a parent's consent before collecting and using that information.

Effective January 1, 2026, California treats the Personal Information of consumers the Company has actual knowledge are under 16 years old as Sensitive Personal Information, which may not be sold or shared without opt-in consent (and, for consumers under 13, without parental consent). The Service is not directed to children, and We do not knowingly sell or share the Personal Information of individuals under 16.

11. Your Privacy Rights

11.1 California Privacy Rights (CCPA/CPRA)

If You are a California resident, You have the following rights regarding Your Personal Information, subject to certain exceptions and verification requirements:

  • Right to Know/Access — the categories and specific pieces of Personal Information We have collected about You, and the categories of sources, purposes, and third parties involved.
  • Right to Delete — to request deletion of Personal Information We have collected from You, subject to certain exceptions.
  • Right to Correct — to request correction of inaccurate Personal Information We maintain about You.
  • Right to Opt Out of Sale or Sharing — to direct Us not to sell or share Your Personal Information.
  • Right to Limit Use of Sensitive Personal Information — to the extent We use or disclose Sensitive Personal Information for purposes beyond those necessary to provide the Service.
  • Right to Non-Discrimination — We will not discriminate against You for exercising any of these rights.

To exercise these rights, please contact Us using the information in the "Contact Us" section below. We will verify Your request using the information associated with Your account or submission and will respond within 45 days (extendable by an additional 45 days when reasonably necessary, with notice to You). You may designate an authorized agent to submit a request on Your behalf.

Opt-Out Preference Signals: We honor Opt-Out Preference Signals, such as the Global Privacy Control, as a valid request to opt out of the sale or sharing of Personal Information for the browser or device on which the signal is sent, and will display a confirmation when such a signal has been honored. [CONFIRM/BUILD — now required, not optional: because beBOLD confirmed the Meta Pixel, Google Ads remarketing tag, and LinkedIn Insight Tag are live, the CCPA requires an actual working opt-out mechanism before this Policy is published — either a "Do Not Sell or Share My Personal Information" link, or GPC detection with an on-page confirmation, consistent with the regulatory amendments effective January 1, 2026. This needs to be built (or at least scoped with your web team and counsel) before this sentence goes live, so the Policy doesn't promise a mechanism that doesn't exist yet.]

11.2 Other State Privacy Rights

If You reside in Colorado, Connecticut, Virginia, Utah, Oregon, Texas, Indiana, Kentucky, Rhode Island, or another state with a comprehensive consumer privacy law, You may have similar rights to know, access, correct, delete, and opt out of the sale, sharing, or use of Your Personal Information for targeted advertising, as well as the right to opt out of certain profiling in furtherance of decisions that produce legal or similarly significant effects. To exercise these rights, please contact Us using the information in the "Contact Us" section below.

11.3 Automated Decision-Making

beBOLD does not currently use automated decision-making technology to make decisions that produce legal or similarly significant effects concerning individuals. If this changes, We will update this Policy to describe applicable notice, opt-out, and appeal rights.

12. International Users

beBOLD is based in the United States and primarily serves clients located in the United States, Canada, and Mexico. beBOLD also receives Personal Data from individuals located in the European Economic Area ("EEA") and United Kingdom ("UK") in the course of business communications with international clients and prospects. If You access the Service from outside the United States, Your information will be transferred to, and processed in, the United States and other countries as described in Section 7 ("Transfer of Your Personal Data") above.

12.1 European Economic Area and United Kingdom (GDPR / UK GDPR)

If You are located in the EEA or UK, We process Your Personal Data on one or more of the following legal bases: (a) Your consent; (b) performance of a contract with You; (c) compliance with a legal obligation; or (d) Our legitimate interests in operating and promoting Our business, provided those interests are not overridden by Your data protection interests or fundamental rights.

Subject to applicable exceptions, You have the right to: request access to the Personal Data We hold about You; request correction or deletion of that data; restrict or object to certain processing; request portability of Your data; withdraw consent at any time where processing is based on consent; and lodge a complaint with Your local data protection supervisory authority.

[CONFIRM/BUILD WITH COUNSEL: This is a starting point, not a complete GDPR compliance section. Now that beBOLD has confirmed it receives Personal Data from EEA/UK contacts, please have counsel review: (1) the lawful mechanism for transferring that data to the United States, such as Standard Contractual Clauses; (2) whether beBOLD needs to appoint an EU and/or UK representative under Art. 27 GDPR; and (3) whether the specific legal bases listed above accurately describe how beBOLD actually uses EEA/UK contacts' data (e.g., sales outreach vs. contract performance).]

13. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.

14. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date above. Where required, We will also notify You by email and/or a prominent notice on Our Service prior to the change becoming effective. You are advised to review this Privacy Policy periodically for any changes; changes are effective when posted on this page.

15. Contact Us

If you have any questions about this Privacy Policy, or would like to exercise any of the rights described above, You can contact us: