# Privacy Policy

> How Koombea collects, uses, shares and protects personal information, and the privacy choices available to you.

Source: https://www.koombea.com/privacy-policy/

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**Effective date:** August 17, 2026
**Last updated:** August 17, 2026

Koombea, Inc. ("Koombea", "we", "us", or "our") builds digital products for
business clients. This Privacy Policy explains how we collect, use, disclose,
and protect personal information through koombea.com and related Koombea
marketing pages, forms, chat, downloadable content, and communications.

This policy covers our website, marketing, sales, recruiting, and business
development activities. It does not govern personal information we process on
behalf of a client inside a product, platform, or system that we build or
maintain for that client. In those cases, the client is responsible for its own
privacy notice, and our processing is governed by our contract with the client.

## 1. Personal information we collect

We collect the categories of personal information below.

| Category | Examples |
| --- | --- |
| Contact identifiers | Name, business email, phone number, company, job title, and address if you provide one. |
| Business and project information | Information you submit in a form, chat, email, discovery call, request for proposal, design audit request, partner inquiry, job inquiry, or other message. |
| Commercial and relationship information | Services or content you ask about, pages or forms you interact with, event or newsletter preferences, lead status, and related business communications. |
| Device and internet activity information | IP address, browser and device type, operating system, referring URL, pages viewed, timestamps, session activity, cookie identifiers, and similar online activity data. |
| Approximate location | General location inferred from IP address, such as city, region, or country. |
| Marketing and attribution data | UTM parameters, ad click identifiers, referral source, campaign information, HubSpot tracking identifiers, Google identifiers, and similar measurement data. |
| Job inquiry information | Resume, portfolio, LinkedIn profile, work history, and other information you choose to send when asking about roles. |

We do not ask you to submit sensitive personal information through this website,
such as government identification numbers, financial account credentials,
health information, biometric data, precise geolocation, or information about
children. Please do not send that information through the site unless we have
specifically agreed on a secure process for receiving it.

## 2. Sources of personal information

We collect personal information from:

- you, when you fill out a form, use chat, email us, book a call, request a
  proposal, request a design audit, subscribe to updates, apply for a role, or
  otherwise communicate with us;
- your browser or device, through cookies, pixels, local storage, session
  storage, server logs, and similar technologies;
- service providers and business tools we use for hosting, analytics, forms,
  CRM, advertising, security, website performance, and communications;
- advertising, analytics, and business-contact identification partners, where
  those tools are enabled; and
- public or business sources, such as your company website, LinkedIn profile,
  or business directories, when relevant to a business conversation.

## 3. How we use personal information

We use personal information to:

- respond to you and provide information you request;
- evaluate, scope, price, and propose software, design, AI, commerce, or
  related services;
- operate, secure, troubleshoot, and improve the website;
- process design audit, partner, Shopify, StorefrontOS, ScopeGen, contact, and
  other lead forms;
- manage our CRM, pipeline, sales communications, and customer relationships;
- send marketing communications about Koombea services, events, updates, and
  content, subject to your communication preferences and applicable law;
- measure website performance, advertising performance, referral sources, and
  conversion activity;
- personalize or improve website experiences and business communications;
- support recruiting and evaluate job inquiries;
- detect, prevent, and respond to fraud, spam, abuse, security incidents, and
  technical issues;
- comply with legal, tax, accounting, and regulatory obligations; and
- establish, exercise, or defend legal claims.

We do not use personal information submitted through this website to make
decisions that produce legal or similarly significant effects about you by
fully automated means.

## 4. AI processing

Koombea is an AI-First software delivery company. We may use AI tools
to support business activities such as summarizing an inquiry, preparing a
scoping note, drafting a project brief, classifying a lead, improving internal
workflow, or helping our team respond more accurately.

AI processing does not replace human review for sales, scoping,
contracting, hiring, or client delivery decisions. Do not submit confidential,
regulated, or sensitive information through website forms or chat unless we
have agreed in writing on the process and protections for that information.

For client work, the use of AI tools is governed by the applicable Master
Services Agreement, Statement of Work, data processing terms, and security
requirements.

## 5. Cookies and similar technologies

We use cookies, pixels, tags, local storage, session storage, and similar
technologies to operate the site and understand how it is used.

The site may use:

- **necessary and preference technologies**, such as local storage for theme and
  motion preferences, session storage for attribution during a visit, security
  controls, and form functionality;
- **analytics and performance tools**, including tools loaded through Google
  Tag Manager, Google Analytics, Core Web Vitals RUM, HubSpot, and similar
  measurement services;
- **advertising and conversion tools**, including Google Ads, Meta, LinkedIn,
  and other tags that may be managed through Google Tag Manager;
- **session and behavior analytics**, such as Microsoft Clarity or similar tools
  when enabled through our tag manager;
- **business-contact identification and enrichment tools**, such as RB2B or
  similar providers when enabled; and
- **chat and form tools**, including HubSpot forms, HubSpot tracking, and
  HubSpot Conversations.

Some tags are managed through Google Tag Manager or vendor dashboards and may
change over time as we add, pause, or remove business tools.

You can control cookies through your browser settings. Some browsers also offer
privacy, tracking-prevention, or opt-out preference features. Because those
signals are not implemented uniformly across all browsers and vendors, you may
also contact us at legal@koombea.com to ask us to process an opt-out request
under applicable law.

## 6. When we disclose personal information

We disclose personal information to the following categories of recipients:

- **Service providers and processors** that host, secure, analyze, maintain, or
  support the website, CRM, forms, analytics, email, chat, advertising,
  recruiting, and business operations.
- **Professional advisers**, such as lawyers, accountants, auditors, insurers,
  and consultants.
- **Advertising, analytics, and measurement partners**, when we use their tags,
  pixels, cookies, or platforms to measure performance, attribute leads, or
  reach business audiences.
- **Business-contact and enrichment providers**, when used to identify or
  enrich business contacts or company-level website visits.
- **Affiliates, contractors, and team members** who need the information for
  the purposes described in this policy.
- **Prospective or actual transaction parties**, if we are involved in a merger,
  financing, acquisition, reorganization, diligence process, or sale of assets.
- **Authorities, courts, and other parties** where required by law, legal
  process, security needs, or to protect rights, safety, and property.

We do not sell personal information for money. Some disclosures to advertising,
analytics, measurement, or business-contact identification partners may be
considered a "sale", "sharing", or "targeted advertising" under certain state
privacy laws, even when no money changes hands. Where those laws apply, you may
have the right to opt out as described below.

## 7. State privacy rights

Depending on where you live and whether a particular privacy law applies to
Koombea, you may have rights to:

- confirm whether we process your personal information;
- access the personal information we maintain about you;
- receive a copy of personal information you provided to us in a portable
  format;
- correct inaccurate personal information;
- delete personal information, subject to legal and operational exceptions;
- opt out of targeted advertising, sale, or sharing of personal information;
- limit certain uses or disclosures of sensitive personal information, if any;
- withdraw consent where processing is based on consent; and
- appeal a decision we make about a privacy request, where applicable.

California residents may have rights under the California Consumer Privacy Act,
as amended by the California Privacy Rights Act, including the rights to know,
access, delete, correct, opt out of sale or sharing, limit certain uses of
sensitive personal information, and not be discriminated against for exercising
privacy rights. We do not knowingly sell or share personal information of
children under 16.

Florida residents may have rights under Florida privacy laws where those laws
apply. The Florida Digital Bill of Rights applies to certain large controllers
and includes rights such as access, deletion, correction, portability, and
opt-out rights. Florida law also requires reasonable measures to protect
personal information and provides breach-notification obligations for covered
entities.

To submit a privacy request, email legal@koombea.com. Please describe the right
you want to exercise and provide enough information for us to verify and locate
your records. We may need to verify your identity or authority before acting on
the request. We will respond within the time required by applicable law. If a
law does not require us to fulfill a specific request, we may still try to help
where doing so is reasonable and consistent with our legal obligations.

You may use an authorized agent where applicable law allows. We may ask for
proof that the agent is authorized to act for you.

## 8. Email and marketing choices

You can unsubscribe from marketing emails by using the unsubscribe link in the
message or by contacting us at legal@koombea.com. We may continue to send
transactional or relationship messages, such as responses to your request,
security notices, legal notices, or service-related communications.

Our commercial email practices are intended to comply with the CAN-SPAM Act and
other applicable marketing laws.

## 9. Retention

We keep personal information for as long as reasonably necessary for the
purposes described in this policy, unless a longer period is required or
permitted by law.

Typical retention periods include:

| Type of information | Typical retention |
| --- | --- |
| Website inquiries, proposal requests, partner inquiries, and sales communications | Up to 24 months after the last meaningful interaction, unless the relationship becomes a client relationship or a longer period is needed for legal, tax, accounting, security, or dispute purposes. |
| Client and contract records | For the term of the relationship and then as required for legal, tax, accounting, audit, and dispute purposes, typically up to seven years or longer if required. |
| Marketing subscriptions | Until you unsubscribe or the list is retired. We may keep suppression records to honor opt-outs. |
| Job inquiries | Up to two years unless you ask us to delete the information earlier or we need to keep it for legal reasons. |
| Security logs and technical records | As long as needed for security, fraud prevention, troubleshooting, and legal purposes. |
| Analytics and advertising records | According to the settings and retention periods in the relevant provider platforms. Aggregated or deidentified reports may be retained longer. |

When information is no longer needed, we delete it, deidentify it, aggregate it,
or retain it only as legally required or permitted.

## 10. Security

We use administrative, technical, and physical safeguards designed to protect
personal information. These may include access controls, encryption in transit,
least-privilege access, credential management, vendor controls, monitoring,
backups, and incident-response processes.

No website, network, or system is perfectly secure. If we determine that a
security incident requires notice, we will provide notice as required by
applicable law.

## 11. International processing

Koombea operates from the United States and Colombia, and our service providers
may process information in the United States, Colombia, and other countries.
Those countries may have privacy laws that differ from the laws where you live.
Where required, we use contractual, organizational, and technical safeguards for
international transfers.

## 12. Children

This website is intended for business audiences and is not directed to children
under 16. We do not knowingly collect personal information from children through
this website. If you believe a child has provided personal information to us,
contact legal@koombea.com and we will take appropriate steps.

## 13. Third-party links and services

The site may link to third-party websites, platforms, social networks, app
stores, or services. Their privacy practices are governed by their own privacy
policies, not this one.

## 14. Changes to this policy

We may update this Privacy Policy from time to time. The updated version will
be posted on this page with a new "Last updated" date. Material changes may be
communicated more prominently where appropriate.

## 15. Contact

**Koombea, Inc.**
3811 Airport Road N, Suite 100A
Naples, FL 34105
United States

Email: [legal@koombea.com](mailto:legal@koombea.com)

