Privacy Policy
This Privacy Policy describes how AVERION DIGITAL LLC, doing business as CtrlFlow ("CtrlFlow", "we", "us", or "our"), collects, uses, discloses, and protects personal information when you visit ctrlflow.site, contact us, or use our marketing services.
By using our website or services, you acknowledge the practices described in this Policy. If you do not agree, please do not use our website or services.
1. Who We Are
AVERION DIGITAL LLC
Wyoming limited liability company
Federal Tax ID (EIN): 98-1939020
Registered and mailing address: 30 N Gould St, Suite N, Sheridan, WY 82801, United States
Email: [email protected]
Phone: +1 917 695 7814
2. Information We Collect
2.1 Information you provide
- Contact information: name, email address, company name, phone number (optional).
- Project information: details you share about your brand, goals, budget, and marketing needs via forms or email.
- Billing information: payment details processed by our payment processor (we do not store full card numbers).
2.2 Information collected automatically
- Usage data: pages visited, time on site, referring URL, device/browser type, IP address.
- Cookies and similar technologies: see our Cookie Policy.
- Analytics and advertising data: information generated by analytics or advertising technologies, such as Google Analytics, Google Ads, Meta Pixel, TikTok Pixel, or similar tools, when those tools are enabled and subject to applicable consent requirements.
3. How We Use Your Information
- To respond to inquiries and provide requested services.
- To deliver, maintain, and improve our marketing services.
- To communicate updates, proposals, invoices, and service-related messages.
- To send marketing communications (only with your consent where required).
- To comply with legal obligations and enforce our Terms of Service.
- To detect, prevent, and address fraud or security issues.
4. Legal Bases for Processing (EEA and UK)
Where the EU General Data Protection Regulation or UK GDPR applies, we rely on the following legal bases:
- Contract: to provide services you requested.
- Consent: for marketing emails, analytics, and non-essential cookies.
- Legitimate interests: to operate, secure, and improve our website and services.
- Legal obligation: to comply with applicable laws.
5. Sharing Your Information
We do not sell personal information for money. We disclose personal information only as reasonably necessary to:
- Service providers: hosting, email delivery, analytics, payment processing, CRM.
- Advertising platforms: Google Ads, Meta, TikTok, Microsoft Ads, and similar providers when advertising tools are enabled. We do not upload client-owned audience or customer data without authorization.
- Legal authorities: when required by law, subpoena, or to protect rights and safety.
- Business transfers: in connection with a merger, acquisition, or sale of assets.
6. International Data Transfers
We are based in the United States. Your information may be transferred to, stored, and processed in the United States and other countries where our service providers operate. Those countries may have different data-protection laws than your country. Where required, we use approved safeguards such as Standard Contractual Clauses, the UK International Data Transfer Addendum, or another lawful transfer mechanism.
7. Data Retention
We retain personal information only as long as necessary for the purposes described in this Policy, to comply with legal obligations, resolve disputes, and enforce agreements. Typical retention periods: inquiry data — 24 months; client records — 7 years post-engagement for tax/legal purposes.
8. Your Privacy Rights
Depending on your location, you may have the right to:
- Access, correct, or delete your personal information.
- Object to or restrict certain processing.
- Withdraw consent at any time (without affecting prior lawful processing).
- Port your data to another provider.
- Lodge a complaint with a supervisory authority.
United States residents: depending on your state and whether the applicable law applies to us, you may have rights to confirm processing; access, correct, delete, or obtain a copy of personal information; and opt out of targeted advertising, the sale of personal information, or certain profiling. We do not sell personal information for money. Some advertising-cookie activity may be treated as "sharing," "sale," or targeted advertising under certain state laws.
EEA and UK residents: where applicable, you may also lodge a complaint with your local data-protection authority.
To exercise a right or appeal a decision concerning a request, email [email protected] or call +1 917 695 7814. We may need to verify your identity before completing a request. Authorized agents may submit requests where permitted by law.
9. Children's Privacy
Our website and services are intended for businesses and adults and are not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe we have collected such information, please contact us so we can delete it.
10. Security
We use reasonable administrative, technical, and physical safeguards to protect your information. However, no method of transmission over the Internet is 100% secure.
11. Third-Party Links
Our website may link to third-party sites. We are not responsible for their privacy practices — please review their policies separately.
12. Changes to This Policy
We may update this Policy from time to time. The "Last updated" date above reflects the latest revision. Material changes will be announced on our website.
13. Contact Us
For any privacy-related questions or requests, contact:
[email protected]
Phone: +1 917 695 7814
AVERION DIGITAL LLC, 30 N Gould St, Suite N, Sheridan, WY 82801, United States.