Cutwater Privacy Policy

Last updated on 06/29/26

We at Cutwater, LLC respect your concerns about privacy. This Privacy Policy (the “Policy”) applies to Cutwater, LLC (referred to herein as “Cutwater,” we,” or “our”). This Policy governs our practices regarding the collection, use and disclosure of personal information that we collect offline and online, including via our website at https://www.cutwateragency.com (the “Website”), by email, marketing communications, social media, mail, telephone, chat or other means.

This Privacy Policy is subject to our Terms and Conditions. We may update this Policy from time to time, as specified in the “Changes to This Privacy Policy” section below.

Your Consent

Please review this Policy periodically. You should read this entire Policy before submitting information, including personal information, to us in any form or using our Website. Whenever you submit personal information to us, you consent to the collection, use, disclosure, transfer, and storage of that information in accordance with this Policy.

All personal information may be used for the purposes stated in this Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form.

Collection of Personal Information

We collect Personal Information using the following methods: 1) from you, when you voluntarily provide it, including online when you visit our website, when you attend in person events, or when you interact with us in any other manner; 2) using automated technology, including when you visit our website or interact with our electronic advertisements or communications; and 3) using third party sources including but not limited to service providers and entities providing data analysis and analytics. To see a complete list of what we collect, how we use this data, please see Annex 1 below.

Cutwater collects Personal Information, including your contact information, such as your name, mailing address, email address, phone number; employment information, education information and any other information you choose to provide to us.

In addition, when you visit our website, we also collect Internet and Network Activity through your browser, computer hardware and software. We may collect and analyze information such as (a) IP addresses, location information, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the Website; and (b) information related to the ways in which you interact with the Website, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Website, the amount of time spent on particular pages, the date and time you used the Website, the frequency of your use of the Website, error logs, and other similar information.

How We Use the Information We Collect

We may use the data we collect as follows:

for the purposes for which you provided it;
to recognize and authenticate you on the Website;
to initiate or to provide the features available through the Website or to provide our services;
to send you information about your relationship or transactions with us or other communications, such as newsletters, if any, to which you have subscribed;
to process and respond to your inquiries or to request your feedback;
for internal research and reporting;
to improve the content and features of the Website or our services or develop new services;
to enforce the legal terms that govern your use of the Website or our services;
to administer and troubleshoot the Website or our services;
to send you communications required by law or which are necessary to inform you about changes to the services we provide and this Policy; and
as otherwise specified at the point of Personal Information collection.

How We Disclose Your Information

We may disclose your information as follows:

To our parents, affiliates, subsidiaries, and other companies under common control and ownership.
To consultants, service providers, and contractors that we use to support our business and operations who have agreed to keep the information confidential and use it only to provide the applicable service(s) such as vendors that help us communicate with you, vendors that host and support our website and data, security and fraud detection vendors.
To third parties who help us gather information from you and communicate with you including for email communications and/or perform services on our behalf, including without limitation marketing, market research, customer support, data storage, data analytics, analysis and processing, and legal services.
Where required to do so by law or in a good faith belief that such access, preservation, or disclosure is permitted by this Policy or reasonably necessary or appropriate for any of the following reasons:
- (a) to comply with legal process, i.e., if we are required to respond to subpoenas, court orders or are asked to respond to legitimate requests for your personal information from law enforcement or government agencies. In such situations, we will release your information to these organizations as we reasonably believe appropriate for us to comply with the law and to prevent against fraud. We will not provide you with these requests for information made by law enforcement or government agencies;
- (b) to enforce this Policy or other contracts with you, including investigation of potential violations thereof;
- (c) to respond to claims that any content violates the rights of third parties;
- (d) to respond to your requests for customer service; and/or
- (e) to protect our rights, property, or personal safety and those of our agents and affiliates, its users, and the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
As part of business transactions (including in contemplation of such transactions, e.g., due diligence), such as buying, merging with, or partnering with other businesses or as part of an asset sale.

“Cookies” and Other Technology

As you enter the Website, our server may record and monitor your IP address and use it to develop statistical analysis. These analyses assist us in refining and adapting the content and design of our site. The use of IP addresses also enables us to prevent malicious Internet users from masquerading as other users. Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology. A cookie is a small piece of information sent by a website that is saved on your hard drive by your computer’s browser. A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags.

As you access or use our Site, we and/or third parties may collect information using cookies, web beacons, pixels, and navigational and location data collection (clickstream, log files, server logs) for the purposes described in this Policy. Such automated technologies further help us to keep track of your interactions with our Website.

To find more information about cookies please visit www.allaboutcookies.org. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won't be able to enjoy the convenience provided by our customization.

Please Note:

Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.
Opt-outs maybe stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
We may still share your information with our service providers that help us perform functions that are necessary for our business such as vendors that host our Site, analytics processors, etc. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.

Third Party Advertising and Analytics Disclaimer

We and/or third parties including service providers on our behalf, may use cookies, web beacons and other similar technology, to collect information from you such as your activities on the Website for the purposes described in this Policy including analytics, monitoring performance, and improvement of our Site (traffic, errors, page load time, popular pages, etc.)

Examples of our third-party service providers to help deliver our services or to connect to our services include:

Google Ads: We use Google Ads. You can opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated. To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy.
Crazy Egg: We use Crazy Egg for website analytics and to better understand how users interact with our website, including through heatmaps, scroll maps, and other usage analytics. To learn more about how Crazy Egg collects and processes data, please visit https://www.crazyegg.com/privacy. To manage Crazy Egg’s use of your data or opt out, please visit https://www.crazyegg.com/opt-out.
Squarespace: Our website is hosted and/or supported by Squarespace, which may use cookies and similar technologies to provide website functionality, security, analytics, and performance measurement. To learn more about how Squarespace processes data, please visit https://www.squarespace.com/privacy. For more information about Squarespace cookies, please visit https://www.squarespace.com/cookie-policy.

Security and Data Retention

We have implemented reasonable administrative, technical, and physical security measures designed to protect against the loss, misuse, and/or alteration of your information. While we strive to protect your information, we cannot and do not guarantee that our efforts will prevent every unauthorized attempt to access, use, or disclose your information because no Internet and/or other electronic transmissions can be completely secure.

Whenever we collect your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected unless a longer retention period is required or permitted by applicable law. At the end of that retention period, we will either delete your data or anonymize it, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning purposes.

Data Transfers

If you are located outside of the United States, please be aware that the information we collect may be transferred to and processed in the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.

Your Choices and Rights

We offer you certain choices in connection with the information we collect and in particular to update or correct your information or submit a request, you can contact us as described below in the How to Contact Us section.

If you shared your email address with us and receive our electronic communications, you can unsubscribe from such communications by clicking the “unsubscribe” link they contain.

Links to Other Sites

Our Website may contain links to other websites (e.g. Instagram, LinkedIn, Facebook) that may collect personal information from you. Our Policy does not extend to those third-party websites and We are not responsible for these parties’ policies in particular in connection with their data protection practices. This applies to any information you submit to third parties such as BambooHR through the Website. To have further information on such policies, please consult said third party’s website.

Do Not Track Notice

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track feature or setting you can activate to signal your preference that your on-line browsing activity data are not monitored and collected. There is no uniform technology standard for recognizing and implementing Do-Not-Track signals. This application does not support Do-Not-Track signals.

Children’s Privacy

Our Website is not intended for children under the age of 18. If we become aware that we have collected personal information from children under the age of 18, we will take reasonable steps to delete it as soon as practical. If you believe that a child under the age of 18 has provided us with personal information, please contact us as specified in the How to Contact Us section below.

California Privacy Rights

Residents of the State of California have the right to request from companies conducting business in California, a list of all third parties to which the company has disclosed Personal Information during the preceding year for direct marketing purposes.

If you are a California resident and would like information about how to exercise your third party disclosure choices, you must send a request with a preference on how our response to your request should be sent via email to: info@cutwatersf.com.

California Shine the Light Disclosure Information

Although we do not disclose to any third parties for their marketing purposes any personal information, California residents are entitled to receive the following disclosure information under California law:

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. We will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are required to respond to each customer only once per calendar year.

How to Contact Us

If you have any questions regarding our privacy practices, you may contact us by email at info@cutwatersf.com; by mail at Cutwater, LLC, 950 Battery St. Floor 4, San Francisco, CA 94111.

Change of Policy

We reserve the right to make changes to this Policy at any time; in which case, we will post such changes on the Website. Your continued use of the Site following the posting of any changes to this Policy means you accept such changes.

Annex 1

Categories of Personal Information
Category	Examples	Collected From	Purposes	Disclosed to	Retention Period
Personal Identifiers	Contact information, including name, phone number and email address.	You, when you provide your information in person or via our website for our newsletter, contact us, or communicate with us in person at events, via phone or email or other methods.	To send promotional communications or offers regarding our services (unless you have requested that we not send such communications); For marketing, research, legal, and other business purposes; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.	Consultants, service providers, and contractors that we use to support our business and operations (e.g., hosting or operating our website, data collection, reporting, ad response measurement, website metrics and analytics, data analysis, delivering marketing messages and advertisements) who have agreed to keep the information confidential and use it only to provide the applicable services; Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics; Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; and An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of our company or its affiliates including any negotiation thereof. * No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Sharing of Personal Information with third party partners excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Internet / Network Activity	IP address, your device information, domain name, browsers you used to access our Site and services, webpages viewed, time spent on webpages, links clicks, transactions entered into and site-navigation patterns.	Your computer or mobile device, through your online activities and interactions with us, including, without limitation, your use of our services, your online activity on our Site, and on our social media channels or through our third-party sources. Third-party sources include third-party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.	Analyze and track usage of our services and products including our Site and social media accounts; Improve our Site, services, and products; Provide you with a customized user experience; For other marketing, research, legal, and other business purposes; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.	Consultants, service providers, and contractors that we use to support our business and operations; Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; and An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of our company or its affiliates including any negotiation thereof.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Business-to-Business (“B2B”) Information	Name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating the business relationship.	You, if you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship.	For internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.	We do not disclose B2B Information outside our business relationship without your consent.	We will retain your B2B Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.