Privacy Policy

Effective: May 30, 2026 Last updated: July 28, 2026

This Privacy Policy explains how Clarion Growth Intelligence ("Clarion," "we," "us," or "our") collects, uses, and discloses information when you visit clariongrowth.com (the "Site"), engage our services as a client, or interact with our private internal applications described below.

If you have any questions about this policy, please contact us at gonzalo@clariongrowth.com.

1. Who we are

Clarion Growth Intelligence is a digital marketing agency based in the Florida Keys, United States. We provide paid-media management, search-engine marketing, web design, and related digital services to small and mid-sized businesses, primarily in the Florida Keys tourism economy.

For purposes of data-protection law, Clarion acts as:

• A data controller for visitors to clariongrowth.com and for our direct business contacts.
• A data processor / service provider when handling marketing data on behalf of our clients (for example, when we manage a client's Google Ads or Meta Ads account on their behalf).

2. The Clarion Growth App (Meta App ID 1251499649906754)

Clarion operates a private internal application (the "Clarion Growth App", registered with Meta as App ID 1251499649906754) that uses Meta's Marketing API and related Meta Platform APIs to manage advertising on behalf of clients who have explicitly granted us access. The Clarion Growth App is not available to the general public, does not host any consumer-facing login flow, does not offer a sign-up surface, and is operated solely by authorized Clarion personnel.

2.1 What the app accesses, and under which permissions

Under permissions explicitly granted by each client via Meta Business Manager (or, in the case of Page-level access, via the client's Page admin), the Clarion Growth App accesses:

• Ad account data — campaigns, ad sets, ads, audiences, creatives, and performance metrics — under the ads_management and ads_read permissions.
• Business Manager metadata — assets, system users, agency relationships, and partnerships — under business_management.
• Page content and insights — Page posts, ads tied to a Page, engagement and reach metrics — under pages_manage_ads, pages_manage_posts, pages_read_engagement, pages_show_list, and related Page permissions.
• Instagram business account data — Instagram business posts, Instagram ads, and Instagram insights — under instagram_basic, instagram_content_publish, instagram_manage_insights, and related Instagram permissions.

2.2 How the app uses what it accesses

The Clarion Growth App uses this access exclusively to deliver the advertising-management services contracted with each client. Specifically:

• Read campaign and ad-set performance to produce reports and inform optimization decisions.
• Create, update, or pause campaigns, ad sets, and ads on the client's behalf according to the agreed-upon scope of work.
• Read Page and Instagram insights to support creative and audience decisions tied to client campaigns.

The Clarion Growth App does not:

• Make the data available to any party outside Clarion's authorized personnel.
• Resell, rent, or trade the data.
• Repurpose the data for advertising on Clarion's own behalf or for unrelated clients.
• Collect, store, or process personal information about end-users of the client's Pages or ads beyond what Meta's APIs return as aggregated metrics.

2.3 Storage and retention of app-accessed data

Data fetched via Meta's APIs is processed in memory during the operation that requested it and is cached only for the short windows required to produce reports or complete optimization tasks. We do not maintain a long-term shadow copy of a client's Meta-platform data. Aggregated reports may be retained for the duration of the engagement (and as required by the client agreement) for historical comparison.

2.4 Access revocation

Clients may revoke the Clarion Growth App's access to their assets at any time via:

• Meta Business Manager → Business Settings → Integrations / Connected Apps → remove the Clarion Growth App, or
• Page Settings → Business Integrations → remove the app, or
• by contacting us at gonzalo@clariongrowth.com and we will remove the access on the client's behalf.

Revocation takes effect immediately at the Meta-platform level. Any aggregated reports already produced and shared with the client prior to revocation remain the client's property.

3. Information we collect

We collect information in three additional categories beyond what is described in Section 2:

3.1 Information you give us directly

• Contact information when you reach out via email, our contact form, or other channels (name, email address, company, phone number, message contents).
• Client onboarding information when you become a Clarion client (legal entity details, billing contacts, signed agreements, payment method via our payment processor).
• Communications including emails and message threads with our team.

3.2 Information collected automatically when you visit the Site

• Server log data including IP address, browser type, device type, pages viewed, and timestamps. This is collected by our hosting provider as part of standard server operation.
• Analytics data (if and when we enable analytics on the Site): page views, referrer, approximate location derived from IP, device type, session duration. We will use a privacy-respecting analytics solution and update this policy before enabling it.
• Cookies and similar technologies: as of the effective date above, clariongrowth.com does not set its own tracking cookies beyond what is strictly necessary to display the Site. Any future use of cookies will be disclosed in a separate Cookie Policy and consent flow.

3.3 Information we access on behalf of clients (other platforms)

In addition to the Meta-platform access described in Section 2, when we manage other advertising or marketing assets for a client, we access information held by third-party platforms — primarily Google Ads, Google Search Console, Google Analytics, and similar — under permissions granted by the client. This information remains the property of the client and the respective platform; Clarion accesses it solely to deliver the services contracted with the client and in accordance with each platform's terms.

We do not download, retain, or repurpose this information beyond what is necessary to manage and report on the client's campaigns.

4. How we use information

We use the information described above for the following purposes:

• Respond to inquiries received via the Site or other channels.
• Provide our services to clients, including campaign management, reporting, and consultations.
• Communicate with prospective and current clients about projects, proposals, invoices, and operational matters.
• Improve the Site and our services through analysis of usage patterns and feedback.
• Comply with legal obligations, including tax, billing, and contract retention requirements.
• Protect rights and safety, including detecting fraud, abuse, or unauthorized access.

We do not sell personal information. We do not use personal information for behavioral advertising on the Site.

5. Legal bases (where applicable)

Where the General Data Protection Regulation (GDPR) or comparable laws apply, we process personal information on the following legal bases:

• Performance of a contract: when handling client billing, onboarding, and service delivery.
• Legitimate interests: when responding to inquiries, operating the Site, and maintaining our records — balanced against your rights.
• Consent: when you explicitly opt in to communications or analytics that require consent.
• Legal obligation: when retention or disclosure is required by law.

6. Sharing and disclosure

We share information only as needed to operate the agency and serve our clients:

• Service providers we rely on, including our hosting provider (Hostinger), payment processor (Converge, by Elavon), email/communications tools, and cloud infrastructure (Google Cloud). These providers process information only under our instructions and their own published privacy practices.
• Advertising and analytics platforms where applicable to client campaigns (Meta, Google), under the client's authorization and the platforms' own terms.
• Professional advisors (lawyers, accountants) where engagement requires it.
• Authorities and law enforcement when required by valid legal process.
• Business transfers: if Clarion undergoes a merger, acquisition, or asset sale, information may be transferred as part of that transaction, subject to this Policy.

We do not sell, rent, or trade personal information to third parties for their independent marketing use.

7. How long we keep information

We retain information only as long as needed to fulfill the purposes described above:

• Contact-form submissions and inquiries: typically up to 24 months unless an ongoing relationship continues.
• Client records (contracts, invoices, signed agreements): for the duration of the engagement and as required by tax and contract law thereafter — generally seven (7) years.
• Server logs and analytics: short-term operational windows, typically 30–90 days at the provider level.
• Data fetched by the Clarion Growth App: processed in memory and cached only briefly per Section 2.3.

When we no longer need information, we delete or anonymize it.

8. Security

We use commercially reasonable safeguards to protect information from unauthorized access, alteration, and disclosure, including: encrypted transport (HTTPS) for the Site; access controls and least-privilege practices for internal systems; secrets stored in managed secret-management services (not in source code); short-lived service-account tokens and impersonation patterns for automated systems; and routine review of vendor security postures. No method of transmission or storage is perfectly secure; we encourage you to use strong, unique passwords and to alert us promptly if you suspect unauthorized access.

9. Your rights

Depending on your jurisdiction, you may have rights to:

• Access the personal information we hold about you.
• Correct inaccurate information.
• Delete information, subject to limited legal exceptions.
• Object to or restrict certain processing.
• Receive a portable copy of information you provided to us.
• Withdraw consent at any time where processing is based on consent.
• Lodge a complaint with a supervisory authority (for EU/UK residents).

To exercise these rights, contact us at gonzalo@clariongrowth.com. We will respond within a reasonable period and within any time frames required by applicable law.

If you are a resident of California (CCPA/CPRA), you have additional rights including the right to know what categories of personal information we collect and our purposes for doing so, and the right not to be discriminated against for exercising your rights. Clarion does not sell or "share" personal information for cross-context behavioral advertising as defined under California law.

10. International transfers

Clarion is based in the United States. If you are located outside the United States, information you provide may be transferred to, stored in, or processed in the United States or other countries where our service providers operate. Where required, we rely on appropriate safeguards (such as standard contractual clauses) to protect international transfers.

11. Children's privacy

The Site is not directed to children under 13 (or the equivalent minimum age in your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will delete it.

12. Third-party links

The Site may contain links to third-party websites or services that we do not control. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any site you visit.

13. Changes to this Policy

We may update this Policy from time to time to reflect changes in our practices, the services we offer, or applicable law. When we do, we will update the "Last updated" date at the top of this page. If the changes are material, we will provide more prominent notice (such as a banner on the Site or, where required, direct notice to you).

14. Contact us

For questions about this Privacy Policy, requests regarding your rights, or any other privacy matter, please reach us at:

Clarion Growth Intelligence
Email: gonzalo@clariongrowth.com
Web: https://clariongrowth.com

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This Privacy Policy was last updated on May 30, 2026.