GCC Portfolio LLC is a limited liability corporation organized under the laws of Texas (“GCC” “GCC Portfolio” or “we”, “our”, “us”).

This Privacy Policy describes the personal information that GCC Portfolio: (a) collects through our website at www.gccportfolio.com and equivalent domains (the “Site”) and our use of that information, as well as (b) how we use your personal information in our services (“Services”) to the entities with whom we contract (our “Clients”).

Please read the following carefully to understand our practices regarding your personal information and how we will treat it.

For persons using our Site, by visiting the Site you are accepting and consenting to the practices described in this Privacy Policy. For persons whose personal information is collected by our Clients and used by us in performance of Services for Clients, we serve only as a Data Processor and any consents that are required for collection under applicable law are the responsibility of the Data Controller (as defined under General Data Protection Regulation (“GDPR”) (EU) 2016/679).

What does “personal information” mean?

Personal information is any information about you that identifies you or by which your identity may be reasonably determined.

Information We Collect or Use

We do NOT collect personal information from data subjects as part of our Services for Clients.

The Site does not collect personal information about you unless you expressly provide such information, such as your name, physical address and email address, to us on a voluntary basis; for example, when subscribing to our blog, CRM Success Tips, or request more information to be sent to you about GCC Portfolio or requesting that we contact you (“Site Collected Data”). We may also add the personal information you expressly provide to our databases, subscriber lists or contact lists. We use the Site Collected Data as follows: (1) to provide you with information and updates about our services and industry; (2) provide you with written content we believe you will find useful.

If you decide at any time that you no longer wish to receive communications from us, please see “To Unsubscribe from Our Communications” below. On rare occasions, we may send important administrative information regarding the Site or services to users using their email addresses; because such information may be important to your use of the Site, it may not be possible to “opt out” of receiving such emails.

Our legal basis for the collection and use of Site Data in this fashion is your affirmative consent, in accordance with GDPR Article 49.

For our Services, we may use personal Information regarding your contact data, including your name, address, phone number, email, place of employment, job title, website data, biography data, a link to your professional social media profile(s), and in some cases, your gender (“Services Information”).

Our legal basis for the processing and use of Services Information in this fashion is the use of Standard Contractual Clauses (Processors) between our organization and our Clients pursuant to the European Commission’s decision (C(2010)593) of 5 February 2010 on Standard Contractual Clauses for the transfer of personal data to processors established in third countries which do not ensure an adequate level of data protection.

How Do We Collect Your Personal Information?

For Site users, we collect your personal information only as you enter it into our Site. For our Services, we do not directly collect any personal information about you. We only obtain personal information about you through our Clients.

Non-Personally Identifiable Information

We also automatically collect non-personally identifiable information through cookies and log files when you access the Site. Such information includes, without limitation, the following: your internet service provider, the IP address of the computer you are using, the type of browser software and operating system that you use, the date and time you access the Site, your length of stay on the Site, the pages that you visit on the Site, the Web site address, if any, from which you linked directly to the Site, the Web site address, if any, to which you travel from the Site and other similar traffic information.

We may aggregate your non-personally identifiable information with similar data collected from other users to help us improve our Site and the services we provide through our Site. We do not use such data in any way to create or maintain a personal profile of you or to collect personal information from you.

How Do We Use Your Personal Information?

We use your personal information in the following ways:

For Site Users:

• to send you the subscriptions you request;
• to respond to your inquiries and comments; and
• from time to time, to send you information regarding events and developments that we think may be of interest to you.

In Providing Services to Clients

Disclosure of Your Personal Information

For Site Users: Generally, we do not disclose personal information that we collect through your use of the Site to unaffiliated third parties without your consent. However, we reserve the right to provide such personal information to our employees, contractors, agents and designees to the extent necessary to enable them to perform certain Site-related services on our behalf.

GCC Portfolio reserves the right to transfer any and all personal information we collect from users, or that we otherwise collect in connection with the Site, including, without limitation, to unaffiliated third parties, in the event of a sale or transfer of assets or portion of our business.

For Personal Information Relating to our Services: We do not disclose personal information that we collect through our Services to persons outside of our organization. However, we reserve the right to provide such personal information to our employees, contractors, agents, and designees to the extent necessary to enable them to perform their responsibilities required in our contracts relating to the Services.

We also reserve the right to disclose such personal information to any third party if we believe that we are required to do so for any of all of the following reasons: (i) by law; (ii) to comply with legal processes or governmental requests; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of the Site or our network; or (iv) to protect the rights, property, or safety of GCC Portfolio and its affiliates, their partners, members, and employees, users of the Site, or the public. These disclosures will be made in accordance with applicable laws and regulations.

Where We Store, Process, or Use, Your Personal Data

For Site Users: The personal information that you give us or that we collect from you will be transferred to and stored on servers in the United States. While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

In Providing Services to Clients: We do not store data on GCC servers. Information is accessed by us through our Clients or is transferred to us by our Clients. If we access your personal information, we access it through a secure connection and use our Clients’ systems. If your personal information is transferred to us, it is transferred via a secure FTP and is stored using a cloud storage vendor and is not stored in an insecure manner on our systems. Once stored on a cloud server, it is accessed via that system.

Security

GCC Portfolio employs security measures designed to protect against loss, misuse or alteration of personal information under our control. Unfortunately, no security system, or system of transmitting data over the Internet can be guaranteed to be 100% secure. Therefore, we cannot guarantee the security of third party servers, the means by which information is transmitted between your computer and those servers or any information provided to us or to any third party through or in connection with the Site.

Retention of Personal Information

How long we keep personal information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your personal information or, if this is not possible, then we will securely store your personal information and isolate it from any further use until deletion is possible.

We retain personal information that you provide to us where we have an ongoing legitimate business need to do so (for example, as required in our contracts with Clients, in order to contact you, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

Links to Other Web Sites

The Site may contain links to Web sites owned by third parties. If you link to any such Web site, any information you disclose on that site is not subject to this Privacy Policy. You should consult the privacy policies of each Web site you visit. We are not responsible for the privacy practices of others. Any Site link to a Web site owned by a third party does not constitute an endorsement, approval, association, sponsorship or affiliation with the linked site unless specifically stated.

Children Under 16

The Site is not directed to children under 16 years of age, and we do not knowingly collect personal information from such children. If you are younger than 16, please do not provide any personal information while using the Site.

Cookies

In order to improve the Site, we may use small files commonly known as “cookies.” A cookie is a small amount of data which often includes a unique identifier that is sent from the Site to your browser or the hard drive of your computer, tablet or mobile phone (‘device’). A cookie records on your device information relating to your internet activity, such as whether you have visited the Site before.

The cookies we use on the Site are solely for website analytical purposes. We do not use cookies to collect any personal information about you. We use the following cookies on the Site:

Google Analytics

We use Google Analytics which is a web analytics service provided by Google Inc. in order to understand how visitors to the Site use the Site.

The Google Analytics cookies collect information about how people are using the Site, for example which pages are visited the most often, how people are moving from one link to another and if they get error messages from certain pages. The cookies do not gather any information that identifies you. The information these cookies collect is grouped together with information from other people’s use of the Site on an anonymous basis. Overall, these cookies provide us with analytical information about how the Site is performing and how we can improve it.

You can opt out of Google Analytics without affecting your use of the Site. For more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page.

If you wish to restrict or block the cookies which are set by the Site, or indeed any other website, you can do this through your browser settings. Your web browser’s help function should tell you how to do this.

How to Access and Control Your Personal Information

Reviewing, Correcting and Removing Your Personal Information

You have the following data protection rights:

• You can request access, correction, updates or deletion of your personal information.
• You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)

To exercise any of these rights, please contact us at hello@gccportfolio.com or by mail to PO BOX 261812, Plano, TX 75026, Attention: Privacy.

We will respond to your request to change, correct, or delete your personal information within a reasonable timeframe and notify you of the action we have taken.

To Unsubscribe from Our Communications

If you would like to unsubscribe from receiving materials from us, please contact us at hello@gccportfolio.com. Alternatively, when you receive materials from us by email, you may make use of the “Update Your Preferences” or “Unsubscribe” provision in such email to let us know your preferences or that you no longer wish to receive such communications from us.

If you have any questions about this Privacy Policy or our collection and use of your personal information, please contact us at hello@gccportfolio.com.

[Last updated: April 2023]