New Breed Privacy Policy

Effective Date: 11/20/2025
Last Updated: 11/20/2025 

1. Introduction

New Breed Marketing LLC ("New Breed," "we," "us," or "our") is a HubSpot Elite Partner providing revenue operations consulting and implementation services. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit our website (newbreedrevenue.com), engage our services, or interact with us.

This policy applies to personal information we collect through our website, client engagements, and business operations.

2. Information We Collect

2.1 Information You Provide Directly

We collect personal information you voluntarily submit through:

Website Forms: When you complete contact forms, download gated content, or subscribe to our newsletter, we collect:

• First and last name
• Business email address
• Company name and website URL
• Job title
• Company size and industry
• Marketing automation platform in use
• Blog subscription preferences (daily, weekly, monthly)
• Business challenges and requirements (free-text responses)

Client Engagements: When you engage our services, we collect:

• Contact and billing information
• Project requirements and business objectives
• Access credentials for platforms we manage on your behalf
• Communications and work product throughout the engagement

Communications: Information in emails, phone calls, video meetings, and other correspondence with our team.

2.2 Information Collected Automatically

When you visit our website, we automatically collect:

Technical Information:

• IP address and approximate geographic location
• Browser type, version, and language settings
• Device type and operating system
• Referring website and pages visited
• Date, time, and duration of visits

Cookies and Tracking Technologies: We use cookies and similar technologies to:

• Maintain website functionality
• Analyze site usage and performance
• Track marketing campaign effectiveness
• Remember your preferences and consent choices

Cookie Categories:

• Necessary cookies: Required for website operation (e.g., security, load balancing)
• Analytics cookies: Measure site performance and visitor behavior
• Marketing cookies: Track engagement with our content and campaigns

You can manage cookie preferences through our cookie consent banner when you first visit our site. You can change your preferences at any time by accessing the cookie settings in your browser or through our cookie preference center.

2.3 Information From Third-Party Sources

We may receive information about you from:

• HubSpot CRM and marketing automation platform
• Professional networking platforms (LinkedIn)
• Business data enrichment services
• Marketing analytics and advertising platforms
• Referral partners and business associates

3. How We Use Your Information

We process personal information for the following purposes:

3.1 Service Delivery

• Providing consulting, implementation, and support services
• Managing client projects through our project management systems
• Communicating about service delivery and project status
• Creating deliverables and strategic recommendations
• Providing access to client portals and collaboration platforms

3.2 Business Operations

• Responding to inquiries and support requests
• Processing transactions and maintaining business records
• Managing vendor and partner relationships
• Conducting internal research and business analysis

3.3 Marketing and Communications

• Sending newsletters, blog updates, and educational content
• Distributing information about our services and events
• Conducting market research and analyzing engagement
• Personalizing content and recommendations based on interests

3.4 Analytics and Improvement

• Analyzing website traffic and user behavior
• Measuring marketing campaign performance
• Improving our services, website, and content
• Conducting business intelligence and strategic planning

3.5 AI-Assisted Services

For certain engagements, we use artificial intelligence platforms (OpenAI's ChatGPT Enterprise and Anthropic's Claude) to enhance service delivery, including content creation, data analysis, and strategic recommendations. We use enterprise versions of these platforms with appropriate data processing agreements that prohibit the use of client data for AI model training. Client data processed through AI services is subject to the same confidentiality and security standards as all other data we process.

3.6 Legal and Security

• Complying with legal obligations and responding to lawful requests
• Enforcing our terms of service and client agreements
• Detecting, preventing, and responding to security incidents
• Protecting our rights, property, and safety, and those of others

4. Legal Basis for Processing (GDPR)

For individuals in the European Economic Area (EEA), United Kingdom, and Switzerland, we process personal information based on the following legal grounds:

• Consent: Where you have provided explicit consent (e.g., marketing communications, cookie placement)
• Contract performance: Where processing is necessary to deliver services you have engaged
• Legitimate interests: Where we have legitimate business interests that do not override your rights (e.g., business analytics, fraud prevention)
• Legal obligation: Where we must process information to comply with applicable laws

You have the right to withdraw consent at any time where processing is based on consent.

5. How We Share Your Information

We do not sell personal information. We share personal information in the following circumstances:

5.1 Service Providers and Subprocessors

We engage third-party vendors to support our business operations and service delivery. These providers process personal information on our behalf and are contractually obligated to protect it. Our current subprocessors include:

Core Service Delivery:

• HubSpot (CRM and marketing automation)
• Kantata (project management - clients may access this system to view project status)
• Google Workspace (email and document collaboration)
• Slack (team communication and client collaboration)
• Zoom (video conferencing, including recordings if enabled)

Analytics and Marketing:

• Semrush (SEO and marketing analytics)
• Vidyard (video hosting and analytics)
• Databox (business analytics and reporting)
• Scrunch (LLM keyword analytics)

Content and Development:

• Adobe Creative Cloud (design and content creation)
• Figma and Sketch (collaborative design)
• GitHub (code repository and version control)
• Shutterstock (licensed media, no customer data processed)

Business Operations:

• PandaDoc (document management and e-signatures)
• 1Password (credential management)
• Fathom (meeting transcription)

AI Services (Engagement-Specific):

• OpenAI (ChatGPT Enterprise)
• Anthropic (Claude)

A complete, current list of subprocessors with hosting locations and security certifications is available upon request by contacting security@newbreedrevenue.com.

5.2 Business Transfers

If New Breed is involved in a merger, acquisition, asset sale, or bankruptcy, personal information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on our website of any change in ownership or use of your personal information.

5.3 Legal Requirements

We may disclose personal information when required by law, regulation, legal process, or governmental request, including to:

• Comply with subpoenas, court orders, or other legal obligations
• Respond to lawful requests from public authorities (including national security or law enforcement)
• Enforce our agreements and policies
• Protect our rights, property, safety, or that of others
• Investigate suspected fraud, security breaches, or policy violations

5.4 With Your Consent

We may share information for other purposes with your explicit consent or at your direction.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required or permitted by law.

General Retention Practices:

• Marketing contacts: Retained until you unsubscribe or request deletion, or after extended periods of inactivity
• Client engagement data: Retained for the duration of the client relationship and for a reasonable period thereafter to support ongoing service needs and legal obligations
• Website analytics: Aggregated analytics data is retained indefinitely; individual session data is retained for operational purposes
• Communications: Business communications retained in accordance with our records management practices
• Credentials: Deleted upon engagement termination or employee departure

We are implementing formal data retention schedules with specific timeframes by category. Upon request, we will provide information about how long we retain specific categories of data.

When personal information is no longer needed, we securely delete or anonymize it in accordance with our data disposal procedures.

7. Data Security

We implement technical, administrative, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction.

Security Measures Include:

• Encryption of data in transit (TLS/SSL) and at rest where applicable
• Access controls and authentication requirements
• Regular security assessments and vulnerability testing
• Employee training on data protection practices
• Vendor security requirements and due diligence
• Incident response and breach notification procedures

We maintain SOC 2 compliance practices and are working toward formal SOC 2 Type II certification.

Despite our efforts, no security measures are perfect or impenetrable. We cannot guarantee the absolute security of personal information.

8. Your Rights and Choices

8.1 All Users

Access and Portability: You may request access to the personal information we hold about you and, where applicable, receive a copy in a structured, machine-readable format.

Correction: You may request correction of inaccurate or incomplete personal information.

Deletion: You may request deletion of your personal information, subject to legal retention requirements and legitimate business needs.

Opt-Out of Marketing: You may unsubscribe from marketing emails using the unsubscribe link in any marketing message or by contacting us directly. You will continue to receive transactional communications related to services you have engaged.

Cookie Management: You can manage cookie preferences through our cookie consent banner or your browser settings. Note that disabling certain cookies may limit website functionality.

8.2 Additional Rights for EEA, UK, and Swiss Residents

Restriction: You may request that we restrict processing of your personal information in certain circumstances.

Objection: You may object to processing based on legitimate interests or for direct marketing purposes.

Withdrawal of Consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

Data Portability: You have the right to receive personal information you provided in a portable format and to transmit it to another controller.

Complaint: You have the right to lodge a complaint with a supervisory authority in your jurisdiction.

8.3 California Residents (CCPA/CPRA)

California residents have specific rights under the California Consumer Privacy Act:

Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected, the categories of sources, business purposes for collection, and categories of third parties with whom we share information.

Right to Delete: You may request deletion of personal information we have collected, subject to certain exceptions.

Right to Opt-Out: We do not sell personal information. If our practices change, we will update this policy and provide an opt-out mechanism.

Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

Authorized Agent: You may designate an authorized agent to submit requests on your behalf.

Shine the Light: California residents may request information about our disclosure of personal information to third parties for direct marketing purposes.

8.4 Exercising Your Rights

To exercise any of these rights, contact us at:

• Email: security@newbreedrevenue.com
• Phone: 802-655-0800
• Mail: New Breed Marketing LLC, 44 Lakeside Ave, PMB 11 Burlington VT 05401

We will respond to verified requests within the timeframes required by applicable law (typically 30-45 days). We may request additional information to verify your identity before processing requests.

9. International Data Transfers

New Breed is based in the United States. If you are located outside the United States, your personal information will be transferred to and processed in the United States.

Many of our subprocessors utilize cloud infrastructure (primarily Amazon Web Services and Google Cloud Platform) with multi-region hosting capabilities. Where required by law, we implement appropriate safeguards for international transfers, including:

• Standard Contractual Clauses approved by the European Commission
• Data Processing Agreements with GDPR-compliant terms
• Adherence to EU-U.S. Data Privacy Framework principles by relevant vendors

10. Children's Privacy

Our services are directed to businesses and professionals. We do not knowingly collect personal information from individuals under 18 years of age. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information.

11. Third-Party Websites and Services

Our website may contain links to third-party websites, services, or resources. This Privacy Policy does not apply to those third parties. We are not responsible for the privacy practices of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technologies, legal requirements, or other factors. We will post the updated policy on this page with a revised "Last Updated" date.

For material changes that significantly affect your rights, we will provide prominent notice on our website or contact you directly via email. Your continued use of our services after changes become effective constitutes acceptance of the revised policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

New Breed Marketing LLC
Attention: Data Privacy
Email: security@newbreedrevenue.com
Phone: 802-655-0800
Address: 44 Lakeside Ave PMB 11, Burlington VT 05401

For data protection inquiries from EEA, UK, or Swiss residents, you may also contact our data protection representative at the above contact information.

14. Supervisory Authority Contact Information

EEA, UK, and Swiss residents have the right to lodge complaints with their local data protection authority:

• EEA: Contact information for EU supervisory authorities: https://edpb.europa.eu/about-edpb/board/members_en
• UK: Information Commissioner's Office (ICO): https://ico.org.uk/
• Switzerland: Federal Data Protection and Information Commissioner (FDPIC): https://www.edoeb.admin.ch/

Version: 2.1
Effective Date: 11/20/2025
Policy Owner: Will Broughton, Security & Infrastructure
Review Cycle: Annual