Privacy Policy - Shergroup Digital

Shergroup Global Consulting LLC d/b/a “Shergroup Digital” (“we”, “us”, “our”) is committed to
protecting your personal information and handling it with care. This Privacy Policy explains what
information we collect, why we collect it, how we use and share it, and the rights you have in
relation to it.

We operate globally with clients across the United States, United Kingdom, Canada, Australia,
New Zealand and the Middle East. Our principal place of business is in Florida, USA. This
Privacy Policy is designed primarily to comply with Florida law — including the Florida Digital Bill
of Rights (Fla. Stat. § 501.701 et seq.) and the Florida Information Protection Act (Fla. Stat. §
501.171) — and also with the UK General Data Protection Regulation (UK GDPR), the EU
General Data Protection Regulation (EU GDPR), and the California Consumer Privacy Act
(CCPA) as amended by the California Privacy Rights Act, where each applies.

1. Who We Are and How to Contact Us

The entity responsible for personal information collected through our website and in connection
with our services is:

Shergroup Global Consulting LLC d/b/a “Shergroup Digital”

Suite 200, 1420 Celebration Boulevard, Celebration, FL 34747, USA
Phone: +1 407 545 7337
Email: hub@shergroup.com
Web: https://shergroupdigital.com

For any privacy-related matter, including to exercise any right described in this policy, contact us
at hub@shergroup.com or by mail to the address above, marked “Privacy”.

2. The Information We Collect

We collect the following categories of personal information. Not every category applies to every
person — what we collect depends on how you interact with us.

Identity information: your name, job title, company name, and professional role.
Contact information: your email address, telephone number, postal address, and preferred method of contact.
Enquiry information: the content of messages you send us through contact forms, email, telephone or other channels, together with any information you choose to provide about your business, goals or current digital marketing situation.
Service information: information provided in the course of delivering our services to you as a client, including website access credentials, brand assets, content, and approvals.
Marketing preferences: your consent and preferences in relation to receiving marketing communications from us.
Technical information: Internet Protocol (IP) address, browser type and version, time zone setting, operating system, device information, referring URL, pages viewed, and time spent on pages.
Cookie and analytics information: see section 7 for detail on our use of cookies and similar technologies.
Sensitive personal information: we do not intentionally collect sensitive personal information as defined under the Florida Digital Bill of Rights or other applicable law. If you provide sensitive personal information to us voluntarily (for example, in the body of an enquiry), we will handle it with the care required by law and will process it only as needed to respond to you.

3. How We Collect This Information

Directly from you, when you complete a contact or enquiry form on our website, subscribe to our newsletter, request a digital audit, book a consultation, sign a proposal, or communicate with us by email, telephone or messaging.
Automatically, when you visit our website, through cookies, analytics tools and server logs (see section 7).
From third-party tools we use to deliver our services, including our customer relationship management platform (ActiveDemand), our advertising platforms (Google, Meta and others), and our contact list and data enrichment platform (RampedUp).
From publicly available sources, including business directories and professional networking sites, where we identify organisations that may benefit from our services.

4. Why We Process Your Information and the Legal Basis

We process personal information for the following purposes and on the following legal bases:

To respond to your enquiries and deliver the services you have requested. Legal basis: performance of a contract, and our legitimate interest in running our business.
To manage our client relationships, deliver contracted services, and fulfil our obligations to you as a client. Legal basis: performance of a contract.
To send marketing communications about our services, events and insights where you have consented or where we have a legitimate interest in contacting business prospects in a manner consistent with the CAN-SPAM Act and the Florida Telephone Solicitation Act. Legal basis: consent, or our legitimate interest in promoting our services.
To improve our website, services and marketing through analytics, A/B testing, and performance measurement. Legal basis: our legitimate interest in operating and improving our business.
To comply with our legal, regulatory and tax obligations, including record-keeping and responding to lawful requests from authorities. Legal basis: compliance with legal obligation.
To protect our rights, our property, and the security of our website and systems, including by detecting and preventing fraud, unauthorised access and misuse. Legal basis: our legitimate interest in protecting our business.

5. How We Share Your Information

We do not sell personal information as the term “sale” is defined under the Florida Digital Bill of
Rights or the California Consumer Privacy Act, and we do not share personal information for
cross-context behavioural advertising, except as described in the Cookies section below in
connection with advertising cookies that you can control through your browser settings or our
cookie preferences tool.

We share personal information only in the following circumstances:

With service providers and sub-processors that help us operate our business and deliver our services, including website hosting (WP Engine), customer relationship management and email marketing (ActiveDemand), contact list and data enrichment (RampedUp), analytics (Google Analytics), and advertising platforms (Google and Meta). All such providers are contractually required to handle personal information securely and only for the purposes we specify.
With professional advisers where necessary, including our lawyers, accountants, insurers, and LegalShield legal services.
With regulatory and law enforcement authorities, where required by law, court order or other legal process, or where reasonably necessary to protect our rights, our property, or the safety of any person.
In connection with a merger, acquisition, financing or sale of all or part of our business, in which case personal information may be transferred to the successor entity, subject to appropriate confidentiality protections.

6. International Data Transfers

Because we operate globally, personal information we collect may be transferred to and processed in countries outside the country where you are located, including the United States and the United Kingdom. Where personal information is transferred from the United Kingdom or European Economic Area to a country that has not been recognised as providing an adequate level of data protection, we put in place appropriate safeguards, such as the UK International Data Transfer Agreement or the EU Standard Contractual Clauses, to ensure that your information continues to be protected in accordance with UK GDPR and EU GDPR requirements.

7. Cookies and Similar Technologies

Our website uses cookies and similar technologies to help the site function, to measure how it is used, and to improve it over time. A cookie is a small text file stored on your device when you visit a website.

We use the following categories of cookie:

Strictly necessary cookies, which are required for the website to function correctly and cannot be switched off in our systems.
Performance and analytics cookies, which help us understand how visitors interact with the website. We use Google Analytics 4 for this purpose.
Functionality cookies, which enable the website to provide enhanced functionality and personalisation.
Advertising and targeting cookies, which we and our advertising partners may use to measure the effectiveness of our marketing campaigns and to deliver relevant advertising. You can control these through your browser settings and through our cookie preferences tool where available.

You can control cookies through your browser settings, including by blocking or deleting them. Please note that disabling certain cookies may affect the functionality of the website.

8. Data Retention

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

Client records are retained for a minimum of seven (7) years following the end of the engagement, consistent with standard United States business record-keeping and tax requirements.
Marketing contact information is retained until you withdraw consent, unsubscribe, or request deletion, subject to our legal obligations.
Website analytics data is retained for the default Google Analytics retention period applicable to our account.

When we no longer need personal information, we either delete it or de-identify it in a way that
is not reasonably capable of being associated with you.

9. Your Rights — Florida Residents

If you are a Florida resident, the Florida Digital Bill of Rights gives you, where it applies to us as a controller, the following rights in relation to your personal information:

The right to confirm whether we are processing your personal information and to access that information.
The right to correct inaccuracies in your personal information.
The right to request deletion of your personal information.
The right to obtain a portable copy of your personal information in a readily usable format where technically feasible.
The right to opt out of the processing of your personal information for targeted advertising, the sale of personal information, or certain kinds of profiling.
The right not to receive discriminatory treatment for exercising these rights.

To exercise any of these rights, contact us at hub@shergroup.com. We will respond within fortyfive (45) days, extendable by a further forty-five (45) days where reasonably necessary, and we will let you know if an extension is needed. If we decline to act on your request, we will tell you why and explain how you can appeal our decision.

10. Your Rights — UK and EU Residents

If you are based in the United Kingdom or the European Economic Area, you have the following rights under the UK GDPR or EU GDPR:

The right to access the personal information we hold about you.
The right to correct inaccurate or incomplete information.
The right to request deletion of your information (“right to be forgotten”).
The right to restrict or object to our processing.
The right to data portability.
The right to withdraw consent at any time, where processing is based on consent.
The right to lodge a complaint with a supervisory authority — in the United Kingdom, the Information Commissioner’s Office at ico.org.uk; in the European Economic Area, your local data protection authority.

To exercise any of these rights, contact us at hub@shergroup.com. We will respond within one
(1) month, extendable by up to two further months for complex requests.

11. Your Rights — California Residents

If you are a California resident, the California Consumer Privacy Act as amended by the California Privacy Rights Act gives you the right to know what personal information we have collected about you, to request deletion, to request correction, to opt out of the “sale” or “sharing” of personal information, and to limit the use of sensitive personal information. We do not sell personal information and we do not share personal information for cross-context behavioural advertising outside the cookie controls described in section 7.

12. Security

We take reasonable technical, organisational and administrative measures to protect personal information against unauthorised access, loss, misuse, alteration and destruction. These measures include encryption in transit, access controls, secure hosting, and staff training. No system is perfectly secure, and we cannot guarantee absolute security of information transmitted over the internet.

In the event of a security breach affecting personal information, we will comply with our notification obligations under the Florida Information Protection Act (Fla. Stat. § 501.171), and with any other applicable breach notification law.

13. Children’s Privacy

Our website and services are directed to businesses and professionals. We do not knowingly collect personal information from children under the age of thirteen (13), and we do not direct our services to children. If we become aware that we have collected personal information from a child under thirteen, we will take steps to delete it.

14. Do-Not-Track Signals

Some browsers transmit “do not track” signals. There is no industry-standard response to these signals, and we do not currently change our collection or use of personal information in response to them. We respond to the cookie and advertising preferences you set through our cookie preferences tool and through your browser settings.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our services, or applicable law. The date at the top of this page shows when it was last updated. Where changes are material, we will provide a more prominent notice. We encourage you to review this policy periodically.

16. Complaints and Regulatory Contacts

If you have a concern about how we handle your personal information, please contact us first at
hub@shergroup.com. We will do our best to resolve it promptly.

If you remain dissatisfied, you may also contact the relevant regulator:

Florida residents: the Florida Department of Legal Affairs, Office of the Attorney General, at myfloridalegal.com.
United Kingdom residents: the Information Commissioner’s Office at ico.org.uk.
European Economic Area residents: your national data protection authority.
California residents: the California Privacy Protection Agency at cppa.ca.gov.