Privacy Policy

EFFECTIVE DATE: JULY 15, 2026

1. Scope and Purpose

This Privacy Policy explains how Delmion Advisory ("Delmion Advisory," "we," "us," or "our") collects, uses, stores, discloses, and protects personal information in connection with our website, business inquiries, consultations, proposals, client engagements, and related communications. It also describes the choices and rights that may be available to individuals under applicable privacy laws.

This Policy applies to information collected through this website and through ordinary business communications associated with our remote business consulting and strategic advisory services. It does not govern the independent privacy practices of third-party websites, payment processors, communications providers, analytics services, or other external services that may be referenced or used in connection with our operations.

By using this website, submitting information to us, or communicating with us, you acknowledge the practices described in this Policy. Where consent is required by applicable law, we will request it separately or provide an appropriate choice at the time of collection.

2. Information We Collect

The information we collect depends on how you interact with us. We may collect information that you provide directly, information generated through your use of the website, and information received from legitimate business sources.

Information you provide directly

• Identity and contact information: your name, business name, job title, postal address, email address, telephone number, and preferred contact method.
• Inquiry and engagement information: the subject of your inquiry, business objectives, operational concerns, project requirements, desired timelines, budget expectations, and other information you choose to provide.
• Client materials: business records, process descriptions, organizational materials, planning documents, performance information, written instructions, and other content supplied for an engagement.
• Transaction information: invoice details, billing contact information, payment status, transaction references, and limited payment-related information. Full payment-card details are generally processed by third-party payment providers and are not intended to be stored by us.
• Communications: correspondence, meeting notes, feedback, support requests, and records of communications with you.
• Preference information: communication preferences, meeting availability, and choices relating to cookies or marketing communications.

Information collected automatically

When you visit the website, certain technical information may be collected automatically by our website platform, hosting providers, analytics tools, security services, or similar technologies. This may include internet protocol address, browser type, device type, operating system, referring page, pages viewed, approximate location derived from an internet protocol address, timestamps, session information, and interactions with website features.

We do not intentionally use the website to collect sensitive personal data such as government identification numbers, precise geolocation, biometric identifiers, health information, or financial account credentials. Please do not submit such information unless we specifically request it for a legitimate engagement purpose and provide appropriate instructions.

3. Sources of Personal Information

We may obtain personal information directly from you; from your employer, business, authorized representative, or colleagues; through website technologies; from service providers that support our operations; from public business sources such as professional websites and company directories; and from referral partners or other persons who reasonably believe you may be interested in our Services.

If you provide personal information about another person, you represent that you are authorized to provide it and that you have given any notices or obtained any permissions required by applicable law.

4. How We Use Personal Information

We may use personal information for the following business and operational purposes:

• responding to inquiries and determining whether our Services are appropriate for a prospective client;
• preparing proposals, statements of work, engagement confirmations, and related documents;
• delivering consultations, assessments, strategic planning, process improvement, growth strategy, and ongoing advisory support;
• communicating about meetings, project status, deliverables, decisions, approvals, invoices, and account administration;
• processing payments, maintaining accounting records, managing receivables, and addressing billing questions;
• operating, maintaining, securing, troubleshooting, and improving the website and our business systems;
• understanding website usage and evaluating the effectiveness of our content and service presentation;
• protecting our rights, property, systems, personnel, clients, and the public from fraud, misuse, security incidents, or unlawful activity;
• complying with legal obligations, recordkeeping requirements, court orders, lawful requests, and professional responsibilities;
• establishing, exercising, or defending legal claims; and
• sending service-related communications and, where permitted, limited business updates or marketing communications.

We will not use personal information for materially different purposes without providing additional notice or obtaining consent where required by law.

5. Legal Bases for Processing

Where a law requires us to identify a legal basis for processing, we rely on one or more of the following: performance of a contract or steps requested before entering into a contract; our legitimate interests in operating and protecting our consulting business; compliance with legal obligations; protection of vital or legal interests; and consent where consent is the appropriate basis.

Our legitimate interests may include evaluating inquiries, delivering professional services, maintaining business records, improving operations, preventing fraud, securing systems, communicating with business contacts, and protecting legal rights. We consider the nature of the information and the reasonable expectations of individuals when relying on legitimate interests.

6. How We Disclose Personal Information

We may disclose personal information only as reasonably necessary for legitimate business purposes, including to the following categories of recipients:

• Service providers: website hosting, cloud storage, communications, scheduling, document management, accounting, payment processing, analytics, cybersecurity, and professional support providers that process information on our behalf.
• Professional advisers: attorneys, accountants, insurers, auditors, and other advisers when disclosure is necessary to obtain advice or protect legal interests.
• Authorized persons: your employer, team members, representatives, or other persons you direct us to include in an engagement.
• Business transaction parties: prospective or actual purchasers, investors, successors, or advisers in connection with a merger, acquisition, financing, reorganization, or sale of all or part of the business, subject to appropriate safeguards.
• Government and legal recipients: courts, regulators, law enforcement, and other authorities where disclosure is required by law, legal process, or a good-faith effort to protect rights, safety, or security.

We do not sell personal information for money. We also do not knowingly share personal information for cross-context behavioral advertising. If our practices change in a manner that creates additional rights under applicable law, we will update this Policy and provide required choices.

7. Cookies and Similar Technologies

The website may use cookies, pixels, local storage, and comparable technologies to support essential functionality, remember preferences, improve security, measure performance, and understand website usage. Some technologies may be placed by third-party service providers.

You can learn more about the categories of cookies we may use, their purposes, retention, and available controls in our Cookie Policy. Blocking certain cookies may affect the operation or availability of website features.

8. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, perform an engagement, satisfy accounting and legal obligations, resolve disputes, enforce agreements, maintain business continuity, and protect legitimate interests. Retention periods vary according to the type of information and the context in which it was collected.

In determining a retention period, we consider the duration of the client relationship, contractual requirements, limitation periods, tax and bookkeeping rules, the sensitivity of the information, security needs, and whether continued retention is necessary for a documented business purpose. When information is no longer needed, we may delete it, anonymize it, or securely archive it where deletion is not immediately practical.

9. Data Security

We use administrative, technical, and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, loss, or misuse. These measures may include access controls, authentication practices, secure service providers, system updates, backups, confidentiality obligations, and procedures for responding to suspected incidents.

No method of transmission or storage is completely secure. Accordingly, we cannot guarantee absolute security. You are responsible for using appropriate safeguards when sending information to us and for avoiding transmission of unnecessary sensitive information through ordinary email or website forms.

10. International Data Transfers

Delmion Advisory is based in the United States, and information may be processed or stored in the United States or other jurisdictions where our service providers operate. Those jurisdictions may have privacy laws that differ from the laws of your location.

Where required, we use contractual, organizational, or other legally recognized safeguards for international transfers. By providing information in connection with our Services, you understand that it may be transferred and processed as described in this Policy, subject to applicable legal requirements.

11. Privacy Rights and Choices

Depending on your location and the nature of our relationship, you may have rights to request access to personal information, correction of inaccurate information, deletion, portability, restriction of processing, objection to certain processing, or withdrawal of consent. You may also have a right to opt out of certain targeted advertising, sale, or profiling activities if those activities are conducted and covered by applicable law.

To submit a request, contact us using the details at the end of this Policy and describe the right you wish to exercise. We may need to verify your identity and authority before completing a request. We will respond within the period required by applicable law and may deny or limit a request where an exception applies. We will explain the basis for a denial where required.

Authorized agents may submit requests where permitted by law, but we may require evidence of authorization and may verify the request directly with the individual. You will not be discriminated against for exercising a privacy right.

12. Colorado Privacy Notice

Colorado residents may have rights under the Colorado Privacy Act when the law applies to the relevant processing. These may include rights to access, correct, delete, and obtain a portable copy of certain personal data, and to opt out of certain sales, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects.

We do not currently represent that every provision of the Colorado Privacy Act applies to every interaction or business record. Eligibility depends on statutory thresholds, exemptions, the capacity in which an individual acts, and the nature of the data. If you submit a covered request and disagree with our response, you may request an appeal by replying to our decision and stating that you wish to appeal. We will process the appeal as required by applicable law.

13. California and Other U.S. State Notices

Residents of California and other states with comprehensive privacy laws may have additional rights where the relevant law applies. Those rights can differ based on statutory thresholds, exemptions, and whether information is collected in an individual, employee, business-to-business, or other capacity.

During the preceding twelve months, we may have collected the categories described in Section 2, used them for the purposes described in Section 4, and disclosed them to the categories of recipients described in Section 6. We do not knowingly sell personal information for monetary consideration and do not knowingly use sensitive personal information to infer characteristics about individuals.

14. European Economic Area, United Kingdom, and Switzerland

Individuals located in the European Economic Area, United Kingdom, or Switzerland may have rights under applicable data protection law, including access, correction, erasure, restriction, portability, objection, and withdrawal of consent. They may also lodge a complaint with a competent supervisory authority.

Where we process personal information in connection with a business inquiry or client engagement, Delmion Advisory generally acts as a controller for its own business administration and may act as an independent controller or processor for particular engagement information depending on the written scope and instructions. Any required processing terms should be addressed in the applicable Engagement Document.

15. Children’s Privacy

This website and our Services are intended for businesses and adults. We do not knowingly collect personal information from children under thirteen years of age, and we do not direct our Services to minors. If you believe a child has provided personal information to us without appropriate authorization, contact us so that we can review and, where appropriate, delete the information.

16. Third-Party Websites and Services

The website may reference third-party websites, platforms, or services. We do not control their privacy practices and are not responsible for their content, security, or handling of personal information. Review the privacy notices of those third parties before providing information to them.

17. Changes to This Privacy Policy

We may revise this Privacy Policy to reflect changes in law, technology, service providers, or business practices. The effective date shown above identifies the current version. Revised terms take effect when posted unless a later date is stated. If a change materially affects how we use information already collected, we will provide any additional notice or choice required by applicable law.

18. Contact and Privacy Requests

Questions, privacy requests, and concerns regarding this Policy may be submitted using the contact information below. Please include enough detail for us to understand the request, but do not send passwords, payment-card numbers, government identification numbers, or other unnecessary sensitive information.

We will review communications in good faith and respond as required by applicable law. This contact channel is intended for privacy matters and general business inquiries and does not create an attorney-client, fiduciary, or other regulated professional relationship.