Privacy Policy

Contents

1. Overview

Cichocki LLC ("Company," "we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy describes our practices regarding the collection, use, disclosure, and protection of personal data when you:

• Visit our websites, including cichocki.com and threadsync.io
• Engage our consulting, advisory, or professional services
• Communicate with us via email, phone, or other channels
• Attend our events, webinars, or workshops
• Apply for employment or contractor positions

This Policy applies to all personal data processed by Cichocki LLC, regardless of the media on which that data is stored or whether it relates to past or present clients, employees, contractors, or other individuals.

2. Definitions

For purposes of this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, IP address, location data, and online identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure, or destruction.
• "Data Subject" means the individual to whom Personal Data relates.
• "Controller" means the entity that determines the purposes and means of Processing Personal Data.
• "Processor" means an entity that Processes Personal Data on behalf of the Controller.
• "Sensitive Personal Data" means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, or data concerning sexual orientation.

3. Data Controller

Cichocki LLC is the Controller of your Personal Data collected through our websites and services. Our contact information is:

For EU/EEA data subjects, you may also contact our EU Representative (where applicable) at the address above.

4. Information We Collect

4.1 Information You Provide

• Identity Data: Name, title, company name, professional credentials
• Contact Data: Email address, phone number, mailing address
• Financial Data: Billing address, payment card details, bank account information
• Transaction Data: Details of services provided, invoices, payment history
• Communications Data: Correspondence, meeting notes, project documentation
• Professional Data: Resume, work history, references (for employment)

4.2 Information Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device identifiers
• Usage Data: Pages visited, time spent, click patterns, referring URLs
• Location Data: General geographic location based on IP address
• Cookie Data: Information stored via cookies and similar technologies (see Section 11)

4.3 Information from Third Parties

• Business Partners: Referrals and introductions from professional networks
• Public Sources: Professional information from LinkedIn, company websites
• Service Providers: Analytics and marketing partners

5. Legal Basis for Processing (GDPR)

We process your Personal Data only when we have a valid legal basis:

6. How We Use Your Information

• Service Delivery: Provide, maintain, and improve our consulting and advisory services
• Client Relationship: Manage our relationship, including onboarding and ongoing communication
• Billing & Payments: Process invoices, payments, and financial reconciliation
• Communications: Respond to inquiries, provide support, and send service-related notices
• Marketing: Send newsletters, thought leadership content, and promotional materials (with consent)
• Analytics: Analyze website usage to improve user experience and service offerings
• Security: Detect, prevent, and respond to fraud, security threats, and technical issues
• Legal Compliance: Comply with applicable laws, regulations, and legal processes
• Business Operations: Support internal operations, audits, and corporate governance

7. Data Sharing & Disclosure

We may share your Personal Data with the following categories of recipients:

7.1 Service Providers

• Cloud hosting providers (infrastructure)
• Payment processors (billing)
• Email service providers (communications)
• Analytics providers (website optimization)
• Professional advisors (legal, accounting)

7.2 Legal & Compliance

• Law enforcement or government agencies when required by law
• Courts or tribunals in connection with legal proceedings
• Regulatory authorities for compliance purposes

7.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your Personal Data may be transferred to the acquiring entity, subject to the same privacy protections.

8. International Data Transfers

Your Personal Data may be transferred to, stored, and processed in countries outside your country of residence, including the United States. When we transfer data internationally, we implement appropriate safeguards:

• Standard Contractual Clauses (SCCs): EU-approved contractual protections
• Data Processing Agreements: Binding agreements with all processors
• Security Measures: Technical and organizational safeguards
• Adequacy Decisions: Transfers to countries with adequate protection levels

You may request a copy of the safeguards we use by contacting our Privacy Officer.

9. Data Retention

We retain Personal Data only as long as necessary for the purposes described in this Policy:

10. Security Measures

We implement comprehensive technical and organizational measures to protect your Personal Data:

Technical Safeguards

• TLS 1.3 encryption for data in transit
• AES-256 encryption for data at rest
• Multi-factor authentication (MFA)
• Regular security assessments and penetration testing
• Intrusion detection and prevention systems
• Automated security patching

Organizational Safeguards

• Role-based access controls (least privilege)
• Employee security training and awareness programs
• Incident response and breach notification procedures
• Vendor security assessments
• Regular policy reviews and updates

11. Cookies & Tracking Technologies

We use cookies and similar technologies to enhance your experience:

Types of Cookies

• Essential Cookies: Required for website functionality (cannot be disabled)
• Analytics Cookies: Help us understand how visitors use our site
• Preference Cookies: Remember your settings and preferences
• Marketing Cookies: Track effectiveness of our marketing (with consent)

Managing Cookies

You can control cookies through your browser settings. Note that disabling certain cookies may impact website functionality. Most browsers allow you to:

• View and delete existing cookies
• Block all or certain cookies
• Set preferences for specific websites

12. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights:

• Right of Access: Obtain confirmation of whether we process your data and receive a copy
• Right to Rectification: Correct inaccurate or incomplete Personal Data
• Right to Erasure: Request deletion of your Personal Data ("right to be forgotten")
• Right to Restriction: Limit how we process your data in certain circumstances
• Right to Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent at any time (without affecting prior processing)
• Right to Lodge a Complaint: File a complaint with a supervisory authority

13. California Privacy Rights (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Your California Rights

• Right to Know: Categories and specific pieces of Personal Information collected
• Right to Delete: Request deletion of your Personal Information
• Right to Correct: Correct inaccurate Personal Information
• Right to Opt-Out: Opt out of sale/sharing of Personal Information
• Right to Limit: Limit use of Sensitive Personal Information
• Right to Non-Discrimination: Equal service regardless of exercising rights

Categories of Information Collected

In the preceding 12 months, we have collected: Identifiers, Commercial Information, Internet Activity, Professional Information, and Inferences. We do not sell Personal Information as defined by CCPA.

14. Children's Privacy

Our services are designed for business professionals and are not directed at children under 16. We do not knowingly collect Personal Data from children. If we learn that we have collected data from a child under 16, we will delete it promptly. If you believe we have collected such data, please contact us immediately.

15. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes:

• We will update the "Last Updated" date at the top of this Policy
• We will notify you via email (for clients) or prominent website notice
• We will obtain consent where required by law

We encourage you to review this Policy periodically. Continued use of our services after changes constitutes acceptance of the updated Policy.

16. Contact Us

For privacy-related inquiries, requests, or complaints:

If you are not satisfied with our response, you may lodge a complaint with your local data protection authority.