PRIVACY POLICY 

At Gamut Marketing, Inc. (hereinafter referred to as the “Gamut Ascent”), your privacy is our priority. We believe that your personal data is inherently yours, and you have the full authority to decide its sharing and usage. Our commitment is to ensure a protected space for your personal data management and controlled sharing according to your preferences.

By interacting with our website: tinyleadslist.com  (the “Website”), you are granting us explicit authorization, without any reservations, to gather, utilize, process, and disseminate any information you supply or that we collect from you as detailed in this Privacy Policy (the “Policy”). We urge you to read this Policy attentively as it influences your legal rights and responsibilities. Should you disagree with this Policy or our data handling practices, we recommend refraining from using the Website.

Consent withdrawal can be executed anytime by contacting us at contact@gamutmarketing.io. Such withdrawal will not compromise the legality of any processing executed by us before your withdrawal.

1. SCOPE OF THIS POLICY
The Policy clarifies:

• Information Collection: Types of data we may gather about you.
• Usage: How we may utilize the information we collect.
• Disclosure: If we share your information with third parties.
• Collection Justification: The reasons behind our data collection.
• Security Measures: How we safeguard your information.
• User Rights: Your entitlements concerning your data.

Our Website may include links to external sites, which are beyond our governance. We do not endorse the privacy practices of these external websites. We suggest reviewing their privacy policies for insights into their data handling.

We are not in charge of the data practices of third-party Ad Networks and their privacy notices and opt-out options.

2. DATA COLLECTION/PROCESSING
We may collect/process the following data during your visit to our Website: 

• Identifying information: Such as name, address, email address, telephone number, and government-issued identification numbers.  
• Demographic information: Such as age, marital status, gender, and nationality.
• Account credentials: Such as usernames and passwords for accessing our services.
• Financial information: Such as payment details and transaction history.
• Usage and browsing data: Such as IP address, device information, cookies, and website analytics.

If you purchase Gamut Ascent’s products/services, we collect billing and credit card information. This information is used to complete the purchase transaction. 

We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain services. These may include: (a) registering for an account; (b) entering a sweepstakes or contest sponsored by us or one of our partners; (c) signing up for special offers from selected third parties; (d) sending us an email message; (e) submitting your credit card or other payment information when ordering and purchasing services. 

To wit, we will use your information for, but not limited to, communicating with you in relation to services you have requested from us. We also may gather additional personal or non-personal information in the future. 

3. PURPOSE OF DATA COLLECTION 
We collect information for the following reasons:  

• To offer and deliver timely, reliable, and valuable products/services to our clients;
• To oversee and promote our products/services effectively; 
• To process and complete transactions, and send you related information, including invoices;
• To create, manage, and implement products/services tailored for you;
• To send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
• To notify you about changes to our Website or any services we offer or provide through it;
• To investigate and prevent unauthorized access to the Products/Services, and other illegal activities;
• To use for marketing purposes; 
• To fulfill legal obligations; and
• For other purposes directly associated with the above. 

4. DISCLOSURE OF INFORMATION
We do not sell, rent, or lease our customer lists to third parties. The information we gather on the Website may be shared within any of our affiliated and/or client companies in order to deliver and provide our services. In particular:

1. We disclose your information to our partners and service providers;
2. We may share your information to companies and individuals we employ to perform functions on our behalf;
3. We may share your information to third parties who leverage the Website’s services;
4. We may disclose such information to third parties if you consent to such disclosure. 

Your personal data will be treated as confidential but, subject to the provisions of any applicable law. We will only share information with our clients and/or third parties where we have your permission to do so in accordance with this Policy, and where we believe it is necessary for a legitimate reason. In addition, we will only share information with a third party if we are satisfied that such third party will keep that information secure.

We may disclose your personal information if:
1. We are legally obligated to do so (e.g., due to legal or regulatory requirements).
2. We need to enforce our terms of use or investigate potential breaches.
3. It is necessary to protect our rights, property, or safety, including that of our users.

We may also, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (email, name, address, phone number) is not transferred to the third party.   

5. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
We primarily store personal information about Website Visitors and Subscribers within the European Economic Area (EEA) and in the United States. However, to facilitate our global operations, we may transfer and access such personal information from around the world, including other countries where Gamut Ascent operates.

When transferring your personal data from the EEA, United Kingdom, or Switzerland, or via an onward transfer, we rely on the Standard Contractual Clauses adopted by the relevant authority. These clauses serve as appropriate safeguards for protecting your information during international transfers.

Regardless of the location where your personal information is processed, we take appropriate contractual or other steps to protect it in accordance with applicable laws. This policy is also in compliance with General Data Protection Regulation (EU GDPR). 

We contractually obligate recipients of your personal information to adhere to at least the same level of privacy safeguards required under applicable data protection laws.

6. AUTOMATICALLY COLLECTED INFORMATION
We may automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, access times, and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding the use of the Gamut Ascent’s website. 

7. SECURITY OF YOUR PERSONAL INFORMATION
Gamut Ascent secures your personal information from unauthorized access, use, or disclosure. 

Gamut Ascent uses the following method for this purpose: 

 – SSL Protocol 
 – 2FA (Two Factor Authentication) for systems access, whenever available

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol. 

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. 

As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet that are beyond our control; and (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed. 

8. YOUR RIGHTS
We think it is important that you are able to control your personal data. Listed below are your respective rights:

• Right to Information: You have the right to be informed about whether your personal data is being processed or has been processed.

• Right to Object: You have the right to object to the processing of your personal data, including processing for direct marketing, automated processing, or profiling. You may also choose not to receive any marketing information from us.

• Right to Access: You have the right, upon written request, to reasonable access to the contents of your processed personal data. This includes information on how it was processed, its sources, recipients, reasons for disclosure (if any), details of automated processes affecting you significantly, and the dates of its last access and modification.

• Right to Rectification: You have the right to rectify any errors in your personal data and request immediate rectification, unless the request is deemed vexatious or unreasonable.

• Right to Data Portability: If your personal data is processed electronically and in a structured, commonly used format, you have the right to obtain a copy of such data in a commonly used electronic or structured format for further use.

• Right to Indemnification for Damages: You shall be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data, considering any violation of your rights and freedoms as a data subject.

• Right to File a Complaint: If you wish to complain about the processing of your personal information, please contact us first. Please note that to protect your privacy and security, we must be able to verify your identity before we can process your request to exercise any of the privacy rights that you may be entitled to under the applicable law. We may conduct the verification process by email or phone, and we may ask you to provide information such as your name, contact information, and any additional relevant information based on your relationship with us. You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so. You may have other privacy rights if you are a California Resident, see our “INFORMATION FOR CALIFORNIA RESIDENTS” section below for more information. If you choose to stop using the Website, you may do so and may also want to remove any cookies placed on any device used to access the Website.

• Right to Deletion :You have the right, based on reasonable grounds, to suspend, withdraw, or request the blocking, removal, or destruction of your personal data from our database. This right can be exercised if the data is incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes, no longer necessary for the intended purposes, consent is withdrawn, or in other specified circumstances.

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: 

• Delete your personal information from our records; and 
• Direct any service providers to delete your personal information from their records. 

Please note that we may not be able to comply with requests to delete your personal information if it is necessary to: 

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty recall conducted in accordance with federal law, and provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; 
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; 
• Debug to identify and repair errors that impair existing intended functionality; 
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; 
• Comply with the California Electronic Communications Privacy Act; 
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; 
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; 
• Comply with an existing legal obligation; or 
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. 

9.   INFORMATION FOR CALIFORNIA RESIDENTS
This information is provided to California residents in accordance with California law, including the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code 1798.100, et seq., as updated by the California Privacy Rights Act of 2020 (CPRA). The details below pertain to the Personal Information that Gamut Ascent processes as a data controller, referred to as a “business” under the CCPA. If you are a resident of California, this Section is applicable to you along with the rest of this Policy. The CCPA interprets the terms “sell” and “sale” in a broad sense to encompass the sharing of Personal Information with third parties in exchange for something of value, even if no money changes hands. We do not engage in selling users’ Personal Information in the conventional sense. We do not partake in the sale of your Personal Information as a part of our business operations.

Types of Personal Information Collected. 
Over the past 12 months, we have gathered the following types of Personal Information: identifiers (like your name and contact details); commercial information (such as details about services you have bought); internet or other electronic network activity information (like your IP address, device identifier, and other data captured by online tracking technologies); and deductions made from the information collected about you. When you buy a service from us, we may also gather the information described in Section 1798.80(e) of the California Civil Code (like signature and credit/debit card number).

Business or Commercial Reason for Collecting and Using Personal Information. We gather the categories of Personal Information outlined in this Section for the business or commercial purposes detailed in this Policy.

Types of Personal Information Disclosed and Categories of Recipients. In the past 12 months, we have disclosed the following categories of Personal Information for business or commercial purposes to the following recipients:

We may distribute identifiers to advertising networks, Internet service providers, data analytics providers, operating systems and platforms, social networks, payment processors, customer support partners, events and promotions partners, and fraud prevention partners.

We may distribute commercial information to data analytics providers, payment processors, customer support partners, and fraud prevention partners.

We may distribute internet and electronic network activity information to data analytics providers, operating systems and platforms, customer support partners, and fraud prevention partners.

We may distribute the information described in Section 1798.80(e) of the California Civil Code (like signature and credit/debit card number) to: our affiliates and subsidiaries, our business partners, financial institutions, professional services organizations such as auditors and law firms, and other service providers.

We may also distribute the above categories of information to government entities as may be necessary to comply with our legal obligations or prevent illegal or fraudulent activity.

Your Rights. 
For Personal Information collected by us during the preceding 12 months preceding your request that is not otherwise subject to an exception, California residents have the right to access and delete their Personal Information. We will not discriminate against those who exercise their rights. You have the following rights:

1. Opt out of the sale of Personal Information: If you are a California resident, you have the right to “opt out” of the “sale” of your “Personal Information” to “third parties” (as those terms are defined in the CCPA/CPRA).
2. Opt out of sharing of Personal Information: If you are a California resident, you have the right to “opt out” of the “sharing” of your “Personal Information” to “third parties” (as those terms are defined in the CCPA/CPRA).
3. Correct Personal Information: If you are a California resident, you have the right to rectify (correct, update or modify) Personal Information that we hold about you.
4. Deletion of Personal Information: You can request that we delete the Personal Information that we have collected from your use of our Services. You will need to make your request from the email with which you have signed up for our services so we can provide a response when we have completed your request. We will delete your information unless it is necessary for purposes permitted by CCPA/CPRA.
5. Data Retention: We will retain your Personal Information for no longer than is necessary for the purposes stated in this Privacy Policy and our data retention policy unless otherwise extending the retention period is required or permitted by law or subject to our retention policies as may be in place from time to time.
6. Use of Authorized Agent: You can designate an authorized agent to make a request under the CCPA/CPRA on your behalf provided that (1) it is a natural person or a business entity registered with the Secretary of State of California; and (2) you have authorized the authorized agent to act on your behalf in this regard. Authorized agents may email contact@gamutmarketing.io to carry out requests on behalf of the party(ies) they represent. To protect your information, please note that we may take steps to verify your identity and we will also ask for signed permission from you authorizing the authorized agent to submit a request on your behalf.

We do not offer financial incentives to consumers based upon the retention or sale of a consumer’s Personal Information. As of the date of the last update and review of this Privacy Policy, we have no reason to believe that we have collected, disclosed, sold, or otherwise processed the Personal Information of more than 4 million California Consumers.

We do not perform Automated Decision Making on Personal Information collected from your use of our services.

If you are a California resident and you would like to exercise your rights described in this Policy, you can submit your request by emailing us at: contact@gamutmarketing.io with the subject line “CCPA/CPRA Rights.” Except where we are required by law to maintain such information for record-keeping purposes, we will take steps to delete or anonymize any new Personal Information collected for the purpose of verification as soon as practical after processing your request. Please also be aware that making any such request does not ensure the complete or comprehensive removal or deletion of Personal Information or content you may have posted, and there may be circumstances in which the law does not require or allow us to fulfill your request, including for example, where fulfilling your request may infringe upon the rights and freedoms of other consumers.

10. CHILDREN UNDER THIRTEEN 
We do not knowingly collect personally identifiable information from children under the age of 13. If you are under the age of 13, you must ask your parent or guardian for permission to use this Website. 

11. TERMS OF USE
We urge you to review our Terms of Use section for additional information regarding the website usage, disclaimers, and limitations of liability.

12. COOKIES
We may store your data on servers provided by third-party hosting vendors with whom we have contracted. Our website uses cookies, which are text files placed on your computer. These cookies collect standard Internet log information and visitor behavior data. Cookies help us distinguish you from other users, enhance your browsing experience, and track visitor activity to determine which services are the most popular. This data is used to deliver customized content and advertising within Gamut Ascent to customers whose behavior indicates that they are interested in a particular subject area.

Most browsers are initially set to accept cookies. You can modify your browser settings to refuse cookies or receive notifications when they are set. Note that disabling cookies may affect certain website features.

13. MARKETING COMMUNICATIONS 
From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our services, we may receive a notification when you open an email from Gamut Ascent or click on a link therein.  Your submission/participation in getting these free leads or purchasing one of our Products, grant us the ability to market and add you to our newsletter and any marketing materials.

If you would like to stop receiving marketing or promotional communications via email from us, you may opt out of such communications by contacting us at contact@gamutmarketing.io. 

14. CHANGES TO OUR POLICY
We reserve the right to change this Policy from time to time. When changes to this Policy are significant and material, we will notify you of the changes via email or in any other appropriate manner such as when you next interact with the Website. 

Your continued use of the Website and/or services available after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by that Policy. 

This Policy shall be effective as of August 16, 2024.