1. Introduction

Aspiron Influence LLC (“Aspiron Influence”, “we”, “us”, or “our”) is a company incorporated in the United States. We operate internationally and are committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website, use our services, or otherwise interact with us. It also explains your rights under applicable data protection laws, including:

• The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), where applicable

• Other applicable US state privacy laws (including Virginia CDPA, Colorado CPA, and others)

• The EU General Data Protection Regulation (EU GDPR) where applicable to our international operations

• Other applicable international data protection laws

Please read this policy carefully. If you do not agree with the terms of this policy, please discontinue use of our website and services.

2. Who We Are (Data Controller / Business)

The business responsible for your personal data is: hi@aspironinfluence.com

If you have any questions about this policy or our data practices, please contact us using the details above or via our dedicated privacy contact at: hi@aspironinfluence.com
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3. Personal Data We Collect

We may collect and process the following categories of personal data:

3.1 Data You Provide Directly

• Contact information (name, email address, telephone number, job title, company name)

• Enquiry details and correspondence when you contact us

• CV/resume data and professional information if you apply for a position or submit an enquiry brief

• Billing information (where applicable for services)

3.2 Data We Collect Automatically

• Technical data such as IP address, browser type and version, operating system, and device information

• Usage data such as pages visited, time spent on pages, referring URLs, and clickstream data

• Cookie data and similar tracking technologies (see Section 9 – Cookies)

3.3 Data We Receive from Third Parties

• Publicly available professional information (e.g. LinkedIn profiles, company websites)

• Information from referrals or introductions

• Data from our clients or partners in connection with client engagements
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4. How We Use Your Personal Data

We use your personal data for the following purposes and on the following legal bases:

4.1 Providing Our Services (Contractual Necessity)

• Conducting public relations, communications, and talent advisory services on behalf of our clients

• Communicating with you regarding potential opportunities or assignments

• Managing our business relationship with clients and contacts

4.2 Legitimate Interests

• Maintaining and building our professional network

• Sending relevant market insights, sector updates, and service information

• Improving our website and services through analytics

• Ensuring the security of our website and systems

• Conducting due diligence and background research in connection with client engagements

4.3 Legal Compliance

• Complying with applicable laws, regulations, and legal obligations

• Responding to lawful requests from regulatory or law enforcement authorities

4.4 Consent

• Sending marketing communications where you have opted in to receive them

• Processing special categories of data, where required and lawful consent has been obtained
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5. International Data Transfers

Aspiron Influence LLC operates internationally. As a result, your personal data may be transferred to, stored in, or processed in countries outside the United States, including countries that may not provide the same level of data protection as your home country.

Where we transfer personal data internationally, we ensure appropriate safeguards are in place, which may include:

• Transfers to countries with EU adequacy decisions or other recognised frameworks

• Use of EU Standard Contractual Clauses (SCCs) or other approved transfer mechanisms

• Other lawful transfer mechanisms under applicable data protection law

For further information about the safeguards in place for international transfers, please contact us.
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6. Sharing Your Personal Data

We do not sell your personal data. We may share your personal data with:

• Client organisations – in connection with client engagements, with your knowledge and at the appropriate stage of a process

• Trusted service providers – who assist us in operating our business (e.g. IT service providers, CRM platforms, cloud storage), subject to appropriate data processing agreements

• Professional advisers – such as lawyers, accountants, and auditors, where necessary

• Regulatory and government authorities – where required by law or to protect our legal rights

• Prospective buyers or investors – in the event of a business reorganisation, merger, or acquisition (subject to appropriate confidentiality obligations)

We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements.

For contact and professional data held in connection with our client and business development activity, we typically retain data for up to 5 years from the date of last meaningful contact, unless you request deletion earlier or we have an ongoing legitimate business reason to retain it.

When determining the appropriate retention period, we consider the nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, and applicable legal requirements.
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8. Your Data Protection Rights

Under applicable US privacy laws (including the CCPA/CPRA for California residents) and, where applicable, the EU GDPR, you may have the following rights in relation to your personal data:

• Right of Access – You may request a copy of the personal data we hold about you.

• Right to Rectification – You may ask us to correct inaccurate or incomplete data.

• Right to Erasure – You may ask us to delete your personal data in certain circumstances.

• Right to Restriction – You may ask us to restrict the processing of your data in certain circumstances.

• Right to Data Portability – You may request a copy of your data in a structured, machine-readable format.

• Right to Object – You may object to processing based on legitimate interests or for direct marketing purposes.

• Right to Withdraw Consent – Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

• Right not to be subject to automated decision-making – You have the right not to be subject to solely automated decisions that produce significant effects.

To exercise any of these rights, please contact us at [privacy@aspironinfluence.com or equivalent]. We will respond within 45 days as required under applicable US law, with an option to extend by a further 45 days where reasonably necessary. We may need to verify your identity before processing your request.

California residents also have the right to lodge a complaint with the California Privacy Protection Agency (CPPA) or the California Attorney General. If you are based in another jurisdiction, you may have the right to contact your applicable local data protection or privacy authority.
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9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your experience, analyse site traffic, and support our marketing activities. Cookies are small text files placed on your device.

We use the following types of cookies:

• Strictly Necessary Cookies – Required for the website to function properly.

• Analytics Cookies – Help us understand how visitors interact with our website (e.g. Google Analytics).

• Functional Cookies – Remember your preferences and settings.

• Marketing Cookies – Used to deliver relevant advertisements and track campaign performance.

You can control cookies through your browser settings or our cookie consent tool. Please note that disabling certain cookies may affect the functionality of our website. For more information, please see our Cookie Policy [link if separate].
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10. Data Security

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include encryption, access controls, and regular security assessments.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your data, we cannot guarantee absolute security. In the event of a data breach, we will notify you and the relevant regulatory authorities as required by applicable US federal and state law.
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11. Third-Party Links

Our website may contain links to third-party websites, platforms, or services. We are not responsible for the privacy practices of those third parties and encourage you to read their privacy notices. This policy applies solely to data collected by Aspiron Influence LLC.
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12. Children's Privacy

Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a minor, please contact us and we will take steps to delete it promptly.
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13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make material changes, we will update the "Last Reviewed" date at the top of this page and, where appropriate, notify you by email or prominent notice on our website.

We encourage you to review this policy periodically. Continued use of our website or services after changes are posted constitutes your acceptance of the revised policy.

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