PRIVACY POLICY AGREEMENT
This Privacy Policy Agreement (“Agreement”) is entered into by and between Diaz-Murphy and Associates CES, LLC, a Florida limited liability company, with its principal place of business at 12318 SW 13nd Ct, Miami, FL 33186, United States (“Company”), and any individual or entity providing Personal Data to the Company (“Data Subject” or “You”), collectively referred to herein as the “Parties.”
Effective Date: August 18th, 2025
RECITALS
WHEREAS, the Company is committed to protecting the privacy and confidentiality of Personal Data collected from Data Subjects;
WHEREAS, the Company collects, stores, processes, and shares Personal Data for legitimate business purposes, including marketing, analytics, service improvements, recruitment, internal operations, and employee management
WHEREAS, the Company seeks to comply with applicable data protection laws, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other relevant U.S. and international regulations;
NOW, THEREFORE, in consideration of the mutual promises contained herein, the Parties agree as follows:
1. DEFINITIONS
1.1 “Personal Data” means any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, IP address, employment information, and usage data collected through the Company’s website, internal systems, or third-party services.
1.2 “Processing” means any operation performed on Personal Data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, or destruction.
1.3 “Third-Party Service Providers” means external companies engaged by the Company to provide services that may involve Processing Personal Data, including HubSpot, Google Analytics, Google Ads, LinkedIn, JotForms, and YouTube.
1.4 “Employee Account” means any account created by a Company employee to access internal systems or services.
1.5 “Blog User” means any individual who accesses, comments, or interacts with content on the Company’s blog-style platform.
2. COLLECTION OF PERSONAL DATA
2.1: The Company shall collect Personal Data directly from Data Subjects, automatically via website interactions, or indirectly through Third-Party Service Providers.
2.2: The types of Personal Data collected shall include, without limitation:
(a) Contact information;
(b) Technical and usage information;
(c) Employment and application-related information;
(d) Interaction data with Company content, blogs, or services;
(e) Employee account access information.
2.3: Personal Data may be collected when:
(a) Data Subjects submit inquiries, forms, or applications;
(b) Blog Users comment, like, or share content;
(c) Employees sign into internal systems;
(d) Data Subjects interact with marketing, analytics, or service improvement tools.
3. PURPOSE OF PROCESSING
3.1: The Company shall Process Personal Data solely for the following purposes:
(a) Marketing and communications, including email campaigns and newsletters;
(b) Analytics, reporting, and improvement of services;
(c) Recruitment, hiring, and employee management;
(d) Internal business operations;
(e) Compliance with legal obligations;
(f) Facilitating secure employee access and management of internal systems;
(g) Managing user interactions with Company content, including blogs.
4. DATA SHARING AND THIRD-PARTY PROCESSORS
4.1: The Company shall not sell, lease, or rent Personal Data to third parties.
4.2: The Company may share Personal Data with Third-Party Service Providers for legitimate business purposes, provided that such Third Parties:
(a) Act solely on the Company’s instructions;
(b) Implement adequate technical and organizational measures; and
(c) Comply with applicable data protection laws
4.3: Data Subjects’ Personal Data collected via blogs or employee accounts shall not be shared outside the Company except where required by law or with the express consent of the Data Subject.
5. COOKIES AND TRACKING TECHNOLOGIES
5.1: The Company shall use cookies and similar tracking technologies to improve website functionality and user experience, subject to the Data Subject’s consent where required by law.
5.2: The Company shall provide a cookie banner for Data Subjects to manage their consent preferences.
6. DATA RETENTION
6.1: Personal Data shall be retained only as long as necessary to fulfill the purposes set forth in this Agreement or as required by law.
6.2: Retention periods:
(a) Active clients: For the duration of the client relationship and as required by law;
(b) Inactive or non-fit contacts: Two (2) years from last interaction;
(c) Job applicants: For the period necessary to complete recruitment and comply with legal obligations;
(d) Blog Users: Until deletion is requested by the Data Subject or as necessary for platform functionality and legal compliance;
(e) Employee accounts: For the duration of employment and up to legal retention requirements thereafter.
6.3: Personal Data shall be securely deleted or anonymized when no longer required.
7. DATA SECURITY
7.1: The Company shall implement reasonable technical and organizational measures to protect Personal Data against unauthorized access, disclosure, alteration, or destruction.
7.2: Personal Data shall be stored on secure U.S.-based servers and Third-Party Service Provider platforms in accordance with applicable law.
8. RIGHTS OF DATA SUBJECTS
8.1: Data Subjects shall have the right to:
(a) Access, correct, or delete their Personal Data;
(b) Restrict or object to processing;
(c) Request data portability;
(d) Withdraw consent where applicable.
8.2: California residents may exercise additional rights under the CCPA, including the right to opt-out of the sale of Personal Information and to request disclosure of data collected.
8.3: Blog Users may manage or request deletion of their comments or interactions.
8.4: Employees may request access to or correction of Personal Data processed in connection with their employment.
8.5: Requests shall be submitted to the Company via email to legal@dma-ces.com.
9. INTERNATIONAL DATA TRANSFERS
9.1: Personal Data may be transferred to, stored, and processed in the United States.
9.2: The Company shall implement appropriate safeguards to ensure compliance with applicable data protection laws, including GDPR.
10. GOVERNING LAW AND JURISDICTION
10.1: This Agreement shall be governed by and construed in accordance with the laws of the State of Florida, United States, without regard to its conflict of law principles.
10.2: Any disputes arising under or in connection with this Agreement shall be subject to the exclusive jurisdiction of the courts located in Miami-Dade County, Florida.
11. AMENDMENTS
11.1: The Company may update or amend this Agreement from time to time to reflect changes in legal requirements or business practices.
11.2: The updated Agreement shall be effective upon posting on the Company website, and the “Effective Date” shall be revised accordingly.
12. CONTACT INFORMATION
Diaz-Murphy and Associates CES, LLC
12318 SW 13nd Ct, Miami, FL 33186, USA
Email: contact@dma-ces.com
Phone: +1 (786) 701-8639