Privacy Policy

We collect information in two ways: information you provide to us directly and information collected automatically through your use of our website and services.

Information you provide directly:

• Contact and inquiry data: Name, business name, email address, phone number, and message content submitted through our contact forms, discovery call booking tools, or direct email.
• Client account data: Billing information (processed securely through our payment processor), business address, service area details, and account credentials for platforms we manage on your behalf.
• Communication data: Records of email correspondence, call recordings (where legally permitted and disclosed), meeting notes, and support requests.
• Marketing intake data: Business goals, current marketing spend, monthly revenue, customer demographics, and other information you share during onboarding questionnaires or strategy sessions.

Information collected automatically:

• Usage data: IP address, browser type and version, operating system, referring URLs, pages visited, time spent on pages, and click behavior on our website, collected via cookies and similar tracking technologies.
• Device data: Device identifiers, screen resolution, and language settings.
• Analytics data: Aggregated website traffic and behavior data collected through Google Analytics and similar tools.
• Campaign performance data: Ad impressions, clicks, conversions, call recordings attributed to marketing campaigns, and lead source attribution data collected through tools such as CallRail, Google Ads, and Google Analytics on behalf of our clients.

We do not knowingly collect sensitive personal information such as Social Security numbers, government-issued ID numbers, or protected health information. Please do not submit such data through our website or communications.

We use the information we collect for the following purposes:

• Service delivery: To provide, manage, and improve the digital marketing services outlined in your service agreement, including managing ad campaigns, optimizing your website, and delivering monthly performance reports.
• Client communication: To respond to inquiries, send service-related notifications, schedule and conduct strategy calls, and provide customer support.
• Billing and payments: To process payments, issue invoices, and maintain accurate financial records in compliance with applicable accounting standards.
• Business development: To send marketing communications about new services, case studies, industry insights, and promotions. You may opt out of marketing communications at any time by following the unsubscribe link in any email or by contacting us directly.
• Analytics and improvement: To analyze website traffic, measure the effectiveness of our own marketing, identify trends, and improve the content and functionality of our website and service offerings.
• Legal compliance: To comply with applicable laws and regulations, respond to lawful requests from public authorities, and protect the rights, property, or safety of PolarWerks, our clients, or others.
• Aggregate reporting: To produce anonymized, aggregated benchmark reports about marketing performance across home service industries, which do not identify individual clients.

We do not sell, rent, or lease your personal information to third parties for their own marketing purposes.

For individuals located in jurisdictions that require a legal basis for the processing of personal data (including the European Economic Area and the United Kingdom), PolarWerks relies on the following legal bases:

• Contract performance: Processing is necessary to perform the services described in your service agreement with us, including managing campaigns, delivering reports, and communicating about your account.
• Legitimate interests: Processing is necessary for our legitimate business interests, including operating and improving our website, securing our systems, preventing fraud, conducting internal analytics, and sending relevant business communications to existing and prospective clients, provided these interests are not overridden by your rights and interests.
• Consent: Where we rely on consent (for example, for optional marketing emails or the placement of non-essential cookies), you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Legal obligation: Processing is necessary to comply with applicable laws, regulations, court orders, or other legal obligations to which PolarWerks is subject.

Residents of California may also have rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). Please see the "Your Rights & Choices" section below for more information.

We do not sell your personal information. We may share your information in the following limited circumstances:

• Service providers: We engage trusted third-party vendors and subprocessors who assist us in operating our business and delivering services, including payment processors (Stripe, ACH processors), email service providers, project management tools, cloud storage providers, CRM platforms, and analytics tools. These vendors are contractually obligated to process your information only as directed by us and in accordance with appropriate security standards.
• Advertising platforms: In the course of managing your campaigns, we will share necessary data (such as audience lists, conversion data, and campaign parameters) with platforms including Google, Meta, and Microsoft on your behalf. This sharing is performed under your instruction and in accordance with each platform's respective data processing agreements.
• Call tracking: We may share phone numbers and campaign attribution data with call tracking providers such as CallRail to enable lead attribution and call recording services on your behalf.
• Business transfers: In the event of a merger, acquisition, reorganization, or sale of all or substantially all of PolarWerks's assets, your information may be transferred to the successor entity. We will notify you via email or prominent notice on our website before your information becomes subject to a different privacy policy.
• Legal requirements: We may disclose your information where required by law, subpoena, court order, or governmental regulation, or where we believe in good faith that disclosure is necessary to protect the rights, property, or safety of PolarWerks, our clients, or the public.
• With your consent: We may share your information for any other purpose with your explicit consent.

All third-party service providers with access to personal data are required to maintain appropriate technical and organizational security measures and are prohibited from using your data for any purpose other than providing the contracted services.

Our website uses cookies and similar tracking technologies (such as web beacons and pixel tags) to operate the site, analyze usage, and deliver relevant content. Cookies are small text files stored on your device by your browser.

We use the following categories of cookies:

• Strictly necessary cookies: These cookies are essential for the website to function and cannot be switched off. They are typically set in response to actions you take, such as setting your privacy preferences, logging in, or filling in forms.
• Analytics and performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. We use Google Analytics for this purpose. The information collected is aggregated and anonymous.
• Marketing and targeting cookies: These cookies may be set through our site by advertising partners (including Google and Meta) to build a profile of your interests and show you relevant advertisements on other sites. They do not store personal information directly but are based on uniquely identifying your browser and device.
• Functionality cookies: These cookies enable enhanced functionality and personalization, such as remembering your preferences between visits.

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. However, disabling certain cookies may affect the functionality of our website. You may also opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.

We do not currently respond to browser "Do Not Track" signals. If this practice changes, we will update this policy accordingly.

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. The following general retention guidelines apply:

• Active client data: Retained for the duration of the service engagement plus a minimum of three (3) years after termination, to comply with applicable accounting, tax, and legal requirements and to facilitate potential re-engagement.
• Prospect and inquiry data: Retained for up to two (2) years from the date of last contact. If you do not become a client and do not interact with us within that period, your data will be deleted or anonymized.
• Website analytics data: Aggregated and anonymized analytics data may be retained indefinitely. Raw user-level analytics data is retained in accordance with the retention settings configured in our analytics platforms (typically 14 months for Google Analytics).
• Financial records: Invoices, payment records, and related financial data are retained for a minimum of seven (7) years in compliance with IRS record-keeping requirements.
• Communication records: Email correspondence and meeting notes are retained for the duration of the client relationship plus three (3) years. Call recordings are retained for up to one (1) year unless otherwise required by law or agreed upon with the client.

When personal information is no longer needed for the purposes described above, we will delete it or anonymize it in a manner that prevents re-identification.

PolarWerks takes the security of your personal information seriously. We implement and maintain appropriate technical, administrative, and physical safeguards designed to protect your information against unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encrypted data transmission using TLS/SSL protocols for all web communications.
• Access controls that restrict access to personal data on a need-to-know basis, with role-based permissions enforced across internal systems.
• Multi-factor authentication (MFA) requirements for access to client accounts and internal systems containing sensitive data.
• Use of reputable, SOC 2-compliant or equivalent cloud service providers for data storage and processing.
• Regular review of our security practices and vendor relationships to identify and address potential vulnerabilities.
• Employee training on data privacy and security best practices.

No method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your personal information, we cannot guarantee absolute security. In the event of a data breach that is likely to affect your rights and freedoms, we will notify you as required by applicable law.

You are responsible for maintaining the confidentiality of any passwords or access credentials used to access platforms managed by PolarWerks on your behalf. Please notify us immediately if you suspect any unauthorized access to your accounts.

Depending on your location and applicable law, you may have certain rights regarding the personal information we hold about you. These rights may include:

• Right of access: The right to request a copy of the personal information we hold about you and to receive information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal information.
• Right to erasure: The right to request deletion of your personal information, subject to certain exceptions (such as where retention is required by law or necessary for the establishment, exercise, or defense of legal claims).
• Right to restriction of processing: The right to request that we limit the processing of your personal information in certain circumstances.
• Right to data portability: The right to receive your personal information in a structured, commonly used, machine-readable format and to transmit that data to another controller, where technically feasible.
• Right to object: The right to object to the processing of your personal information where we rely on legitimate interests as our legal basis, including for direct marketing purposes.
• Right to withdraw consent: Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

California residents may additionally have rights under the CCPA/CPRA, including the right to know what personal information is collected, sold, or disclosed; the right to opt out of the sale or sharing of personal information; the right to non-discrimination for exercising privacy rights; and the right to limit the use of sensitive personal information. PolarWerks does not sell personal information as defined by the CCPA.

To exercise any of the above rights, please contact us at the information provided in the "Changes to This Policy & Contact" section below. We will respond to verifiable requests within the timeframe required by applicable law (generally 30 to 45 days). We may need to verify your identity before fulfilling your request.

You also have the right to lodge a complaint with your relevant data protection supervisory authority if you believe we have processed your personal information in violation of applicable law.

Our website and services are not directed to individuals under the age of 18 ("minors"), and we do not knowingly collect personal information from minors. PolarWerks's services are designed for and marketed exclusively to business owners and operators in the home service industry, who are expected to be adults.

If we become aware that we have inadvertently collected personal information from a minor without appropriate parental or guardian consent, we will take prompt steps to delete such information from our records. If you are a parent or guardian and believe that your child has provided personal information to us, please contact us immediately using the details in the "Changes to This Policy & Contact" section so that we can take appropriate action.

Our website may contain links to third-party websites or services that are not operated by us. 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.

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the "Effective" date at the top of this page and, where appropriate, notify you by email or through a prominent notice on our website. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Your continued use of our website or services after the effective date of any updated Privacy Policy constitutes your acceptance of the changes. If you do not agree to the updated policy, you should discontinue use of our website and services and contact us to discuss your options.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Company: PolarWerks LLC
• Phone:(770) 316-1806
• Website: polarwerks.com
• Contact page: polarwerks.com/contact
• Business hours: Monday – Friday, 8:00 AM – 5:00 PM Eastern Time

We are committed to working with you to resolve any concerns about your privacy in a fair and timely manner. If you are located in the EEA or UK and are not satisfied with our response, you have the right to contact your local data protection authority.