This Privacy Policy (“Policy”) explains how CFX-Systems (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes personal data in connection with your use of our website, products, or services (“Services”). By accessing or using our Services, you agree to the collection and use of your personal data in accordance with this Policy.

 

 

1. Scope of This Policy

 

1.1 Geographical Scope

This Policy is intended to address the global privacy requirements and laws applicable to our operations, including, but not limited to:

• EU General Data Protection Regulation (GDPR)
• California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA) and other U.S. state laws, as applicable
• Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada
• Australian Privacy Principles (APPs) in Australia

 

1.2 Applicability

This Policy applies to the personal data we collect from individuals who visit our website, communicate with us, or use our Services. It also applies to the personal data we collect from prospective, current, and former customers, vendors, suppliers, and other partners.

 

 

2. Data We Collect

 

2.1 Personal Data You Provide

We may collect personal data that you voluntarily provide to us, such as:

 

• Contact Information: Name, email address, phone number, business address, and/or job title.

 

• Account Information: Username, password, or other credentials when you create an account for our Services.

 

• Payment Information: Billing address, payment methods, and transaction details (though payment processing may be handled by third-party processors).

 

• Communications: Any information you provide in messages, support tickets, or inquiries you send us.

 

 

2.2 Data Collected Automatically

When you visit our website or use our Services, we may collect certain data automatically, such as:

 

• Log Data: IP addresses, browser type, operating system, referring/exit pages, and timestamps.

 

• Cookies and Similar Technologies: Small files placed on your device to analyze website usage, remember your preferences, or deliver targeted ads. You can manage or disable cookies through your browser settings, though some features of the website may not function properly without them.

 

• Usage Data: Information about how you navigate and use our website or Services, including clicks, scrolls, pages viewed, and session duration.

 

 

2.3 Data from Third Parties

We may receive personal data from third parties, such as:

 

• Service Providers: Analytics or advertising networks that provide us with aggregated user data.

•Business Partners and Referrals: Entities that have recommended or referred you to our Services.

 

 

3. Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data under one or more of the following legal bases:

 

• Consent: Where you have given consent to the processing of your personal data.

 

• Contract: Where processing is necessary for the performance of a contract or to take steps prior to entering into a contract.

 

• Legal Obligation: Where processing is necessary to comply with a legal obligation.

 

• Legitimate Interests: Where processing is necessary for our legitimate interests, provided those interests are not overridden by your fundamental rights and freedoms.

 

 

4. How We Use Your Data

 

We may use your personal data for the following purposes:

 

• To Provide Services: Setting up and managing user accounts, processing payments, and delivering the functionality of our self-hosted AI solutions (e.g., K.I.R.A.).

 

• Customer Support: Responding to inquiries, troubleshooting issues, and providing technical or customer support.

 

• Communication: Sending you administrative information, updates, security alerts, or marketing communications (where permitted by law).

 

• Personalization: Tailoring our website, content, and user experience to your preferences or interests.

 

• Analytics and Improvement: Monitoring and analyzing usage and trends to improve our Services and develop new features.

 

• Legal and Compliance: Preventing fraud, enforcing our Terms of Use, complying with legal obligations, or protecting our rights and interests.

 

 

5. Disclosure of Your Data

 

We do not sell or rent your personal data to third parties. However, we may share your data under the following circumstances:

 

• Service Providers: We engage third-party service providers to perform certain functions on our behalf (e.g., payment processing, analytics, hosting). These service providers have access to personal data only to the extent necessary to perform their duties.

 

• Business Transactions: In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction.

 

• Legal Requirements: We may disclose your data if required to do so by law or in response to valid requests by public authorities (e.g., courts, law enforcement).

 

• Protection of Rights: We may disclose information to enforce our agreements, prevent fraud, or protect the security of our Services or the safety of others.

 

 

6. International Data Transfers

 

Your personal data may be transferred to, and processed in, countries other than the one you reside in, including the United States, Canada, and Australia. If you are located in the EEA, the UK, or Switzerland, we will ensure appropriate safeguards (such as Standard Contractual Clauses or other lawful mechanisms) are in place to protect your personal data in accordance with applicable laws.

 

 

7. Retention of Data

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting obligations, or to resolve disputes. When we no longer require your personal data, we will securely destroy or de-identify it.

 

 

8. Your Privacy Rights

 

8.1 European Economic Area (EEA) and UK Residents

Under the GDPR, you have the right to:

 

• Access: Request a copy of the personal data we hold about you.

 

• Rectification: Request correction of inaccurate or incomplete data.

 

• Erasure (“Right to be Forgotten”): Request deletion of your personal data under certain circumstances.

 

• Restriction of Processing: Request that we limit processing of your data in certain cases.

 

• Data Portability: Receive your personal data in a structured, commonly used, and machine-readable format.

 

• Objection: Object to certain processing activities based on legitimate interests or direct marketing.

 

• Withdraw Consent: If processing is based on consent, you can withdraw your consent at any time.

 

 

8.2 California Residents (CCPA/CPRA)

 

 

If you are a California resident, you have the right to:

 

• Know the categories and specific pieces of personal information we collect, use, and disclose.

 

• Request Deletion of your personal information.

 

• Opt-Out of the sale or sharing of personal information (we do not sell personal information).

 

• Non-Discrimination for exercising any of these rights.

 

 

8.3 Canadian Residents (PIPEDA)

You have the right to access, correct, or update your personal data that we hold. You also have the right to challenge our compliance with PIPEDA by filing a complaint with the appropriate privacy commissioner.

 

 

8.4 Australian Residents (APPs)

You have the right to request access to the personal data we hold about you and request corrections if it is inaccurate, out-of-date, or incomplete. You may also lodge a complaint about any breach of the Australian Privacy Principles.

 

 

8.5 How to Exercise Your Rights

To submit a request or exercise any of your rights, please contact us using the details provided in the

“Contact Us”

section. We will respond to your request in accordance with applicable laws.

 

 

9. Security Measures

We implement technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. These measures include, but are not limited to, encryption, secure hosting environments, access controls, and regular security assessments. However, no security system is impenetrable, and we cannot guarantee the absolute security of your data.

 

 

10. Cookies and Tracking Technologies

 

We use cookies and similar tracking technologies to enhance user experience, analyze website performance, and deliver personalized ads or content, as permitted by law. You can control cookies through your browser settings and other tools. For more details on our use of cookies:

 

COOKIE POLICY

 

Last Updated: [22.02.2025]

 

 

This Cookie Policy (“Policy”) explains how [CFX Systems] (“Company,” “we,” “us,” or “our”) uses cookies and similar tracking technologies when you visit our website or use our online services (“Services”). This Policy should be read together with our [Privacy Policy](insert link) and Terms of Use (insert link), which provide further information on how we use your personal data. By continuing to browse or use our website, you agree to our use of cookies under this Policy.

 

 

10.1. What Are Cookies?

Cookies are small text files placed on your device (computer, smartphone, tablet, etc.) when you visit a website. They store certain information about your browsing activity and can help recognize you and remember information about your preferences or past actions.

 

 

10.2. Why We Use Cookies

 

We use cookies and similar technologies to:

 

A. Enable core functionalities of our website (e.g., maintaining session state, logging in, and navigating pages).

 

B. Analyze how our website is performing and how users interact with it.

 

C. Personalize your experience, such as remembering your preferences or settings.

 

D. Measure and improve the performance of our Services.

 

E. Provide relevant advertising or content (where applicable).

 

 

10.3. Types of Cookies We Use

We categorize cookies based on their duration, purpose, and ownership:

 

 

10.3.1 Duration

• Session Cookies:

These cookies are temporary and expire once you close your browser.

 

• Persistent Cookies:

These cookies remain on your device for a set period or until you delete them, helping us recognize you on subsequent visits.

 

 

10.3.2 Purpose

• Strictly Necessary Cookies:

Essential for our website to function properly (e.g., enabling you to log in or navigate secure areas). These cookies cannot be opted out.

 

• Functional Cookies:

Allow the website to remember choices you make (such as language or region) and provide enhanced features. Disabling these may affect functionality.

 

• Analytics/Performance Cookies:

Collect information about how visitors use our website (e.g., pages visited, errors encountered) so we can improve site performance and better understand user interests.

 

• Advertising/Targeting Cookies:

Track your browsing habits and are used to deliver relevant ads or limit the number of times you see an advertisement. These may be placed by third parties.

10.3.3 Ownership

•First-Party Cookies:

Placed by us directly (the domain you are visiting or your custom-mapped domain when using our website builder).

 

•Third-Party Cookies:

Placed by third parties (e.g., analytics providers, advertisers) to collect information about your device and usage patterns.

 

 

10.4. Specific Cookies We Use

 

When you create and publish a website using our HighLevel website builder, our platform automatically implements a standard set of cookies for tracking and functionality. If you map your website to a custom domain, the cookies’ domain attribute may appear as your domain rather than gohighlevel.com, but the names, vendors, and purposes remain the same. Additionally, any marketing integrations (e.g., Facebook Pixel, Google Tag Manager) that you add via our advanced settings may set additional cookies for which you are responsible to document.

 

 

 

Below is the list of cookies typically set by our platform:

 

 

 

Note: The durations provided above are typical; actual durations may vary based on implementation details.

 

 

 

10.5. Consent and Cookie Control

 

 

10.5.1 Consent in the EU (GDPR/ePrivacy)

 

If you are located in a jurisdiction that requires opt-in consent (e.g., certain EU member states), our website will display a cookie banner or pop-up (integrated via our website builder) to obtain your consent before placing non-essential cookies on your device. You may withdraw your consent at any time by adjusting your cookie preferences.

 

 

 

10.5.2 Browser Controls

 

 

You can control or disable cookies via your browser settings. For instructions on popular browsers, please see:

 

• Google Chrome Cookie Settings

• Mozilla Firefox Cookie Settings

• Safari Cookie Settings (Desktop)

• Safari Cookie Settings (iOS)

• Microsoft Edge Cookie Settings

• Internet Explorer Cookie Settings

• Opera Cookie Settings

 

 

 

Please note that blocking or deleting cookies may affect your user experience and some website functionality may become limited.

 

 

 

10.5.3 Third-Party Opt-Out

 

 

If third-party cookies (e.g., from advertising or analytics providers) are set, you may be able to opt out directly through those third parties:

 

• Network Advertising Initiative (NAI) Opt-Out

 

• Digital Advertising Alliance (DAA) Opt-Out

 

• European Interactive Digital Advertising Alliance (EDAA) Opt-Out

 

 

 

10.6. Updates to This Cookie Policy

 

 

We may update this Policy to reflect changes in our practices, legal requirements, or for other operational reasons. The “Last Updated” date at the top of this Policy indicates when it was last revised. We will notify you of any material changes by posting the new version on our website or as required by law.

 

 

 

10.7. Contact Us

 

 

If you have any questions or concerns about our use of cookies, please contact us at:

 

CFX Systems Ltd.

 

Email: hello@cfx-systems.eu

 

Data Protection Officer: Philipp Pagels

 

 

 

By continuing to browse or use our Services, you acknowledge that you have read, understood, and agreed to our Cookie Policy.

 

 

 

 

11. Third-Party Links

 

Our website or Services may contain links to third-party websites, plug-ins, or applications. We do not control these third-party sites and are not responsible for their privacy practices. We encourage you to review the privacy policies of any site you visit.

 

 

12. Children’s Privacy

 

Our Services are intended for business and professional use and are not directed at children. We do not knowingly collect personal data from individuals under the age of 13 (or older if required by applicable law). If you believe we have inadvertently collected data from a child, please contact us so we can delete such data.

 

 

13. Updates to This Policy

 

We may revise this Policy from time to time. Any changes will be reflected by the “Last Updated” date at the top. If we make significant changes, we will provide a more prominent notice (e.g., via email or a pop-up on our website). Your continued use of our Services after any changes indicates your acceptance of the updated Policy.

 

 

14. Contact Us

 

If you have any questions, concerns, or requests regarding this Policy or our data processing activities, please contact us at:

 

 

 

CFX Systems Ltd.

 

Email: hello@cfx-systems.eu

 

 

If you are not satisfied with our response, you have the right to contact or lodge a complaint with the relevant data protection authority, including but not limited to:

 

• The European Data Protection Supervisor (EU)

 

• ICO (UK)

 

• The California Attorney General’s Office (U.S.)

 

• The Office of the Privacy Commissioner of Canada (Canada)

 

• The Office of the Australian Information Commissioner (Australia) By using our website or Services, you acknowledge that you have read and understood this Privacy Policy. Disclaimer