Privacy
Privacy Policy
Effective August 13, 2026.
Your use of the Site, Services and/or Referral Program is governed by Section 5 of the Website Terms of Use (this "Policy" or the "Privacy Policy"). The Company reserves the right, and you authorize us, to use and assign all information provided by or collected from you in any manner consistent with the Privacy Policy.
(a) Information Collected
To provide the Services and administer the Referral Program, the Company may collect, use, process, and under certain conditions disclose information you provide through the Site, including Business Data, Client Personal Information, Incidental Personal Information, Referral Partner Information, and Retailer Referral Information, as defined herein.
(b) Rights and Duties
Your rights and duties and those of the Company with respect to the Services, Referral Program, Business Data, and Personal Information may be governed by applicable laws and regulations of the United States and the state where a Client or Referral Partner is incorporated, organized, registered, has its principal place of business, or makes use of the Services (collectively, the "Data Protection Laws"). At a minimum, the Company maintains policies and controls consistent with the Virginia Consumer Data Protection Act, the District of Columbia Consumer Protection Procedures Act, the District of Columbia Consumer Personal Information Security Breach Notification Act, and Section 5 of the Federal Trade Commission Act.
(c) Personal Information Use
The Services use proprietary analytics and artificial intelligence ("AI") tools to analyze sales, inventory, supply chain, and related operational data ("Business Data") to generate insights and recommendations designed to improve revenue, operational efficiency, and profit margins. The Company will make commercially reasonable efforts to promptly remove any Personal Information of Clients' customers incidentally provided to the Company within Business Data ("Incidental Personal Information") before applying the Company's proprietary data analytics and AI tools to the Business Data. The Company will collect, use, and process Personal Information pertaining directly to the Client ("Client Personal Information") in the registration process and in the course of providing the Services. The Company will also collect, use, and process Personal Information pertaining to Referral Partners ("Referral Partner Information") and Personal Information pertaining to Clients referred by a Referral Partner ("Retailer Referral Information") in the registration process for and in the course of providing the Referral Program. The Company will never disclose any data or information except as provided in this Privacy Policy or as may be required by law. We use Referral Partner Information to review applications, onboard and authenticate referral partners, issue and administer referral IDs and dashboard access, attribute referrals, communicate about referral status, determine eligibility for payouts, process ACH payments, prevent fraud and duplicate submissions, enforce program terms, comply with tax reporting and withholding obligations, maintain business records, and protect our legal rights. We use Retailer Referral Information to evaluate and respond to referrals, contact prospective retailer clients, determine referral attribution and qualification, provide services, administer the referral program, and maintain internal records regarding referral source, status, and payouts.
(d) Types of Information
Specific data the Company may request or otherwise obtain includes but is not limited to: Contact information; inventory management, POS and e-commerce reports; login information; other account information; customer service information; user preferences; device information; website navigation information; cookies; tax identification information provided on IRS Form W-9; payment and bank account information needed to process payments; account credentials; Referral Program application information; referral submission data; dashboard activity; records relating to approvals, payouts, reversals, and tax reporting; and non-personal data, such as aggregated or de-identified demographic/profile data, from third-party sources including selected partners and companies that specialize in providing enterprise data, analytics, and software as a service.
(e) Legal Bases
We do not collect data to build individualized marketing profiles of Clients or Referral Partners. We collect specific Personal Information and financial artifacts solely to execute the Services, administer the Referral Program, and related activities including general communication; product support and improvement; security; research and development; billing and payments; tax reporting; referral attribution; and payout administration. Legal bases for our collection and use of data include without limitation: (i) Our performance and exercise of contractual rights and duties; (ii) Our compliance with laws, lawful requests, court orders, and legal processes; (iii) Our legitimate interest in conducting the Company's business.
(f) Artificial Intelligence, Infrastructure, and Data Aggregation
The Company uses advanced technologies to analyze businesses.
(i) APIs and AI
We use enterprise-grade AI environments, such as OpenAI API, to process logic and generate reports. We utilize Zero Data Retention API Settings, as defined herein, where available.
(ii) Third-Party Processors
Your data may pass through secure third-party processors including without limitation Shopify (Source), Google Cloud (Storage), and Postmark (Delivery). We maintain administrative, technical, and physical safeguards designed to protect Personal Information appropriate to its nature and the risks presented, including information used for payment processing and tax reporting.
(iii) Anonymized Data
The Company reserves the irrevocable right to create and use de-identified, aggregated data sets assembled to include Business Data pertaining to Clients and Referral Partners ("Anonymized Data") (for example, "average apparel margins in the Southeast" or "sector-wide dead stock trends"). We create Anonymized Data by removing or modifying data points that could be used to associate Business Data or Personal Information to a Client, Referral Partner or individual, and by applying technical and organizational safeguards designed to prevent the data from being re-associated with any Client, Referral Partner or individual. The Company owns all rights to such Anonymized Data in perpetuity.
(iv) Use of Anonymized Data
We may use, share, or monetize Anonymized Data (i) through the sale or licensing of industry reports, benchmarks, market research, or bulk data; and (ii) for any other lawful purpose. Your data will never be singled out. It will only ever be used as de-identified data points in broader market analyses. When we disclose Anonymized Data to third-party service providers or AI platforms, we will make commercially reasonable efforts to ensure, and where required by law will contractually require, that such providers or AI platforms: (i) Not attempt to re-identify the data; (ii) Not combine the data with other information to identify a Client or individual; and (iii) Use the data only for the purposes we specify.
(g) Change of Ownership
We may disclose your Business Data and Personal Information in connection with the re-organization or merger of the Company with another entity or a sale of all or a substantial portion of our assets or ownership, including any due diligence carried out in relation to the same, provided that the information disclosed continues to be used in accordance with these Terms by the entity acquiring the information.
(h) Data Retention
The Company will make commercially reasonable efforts to promptly remove Incidental Personal Information received within Business Data provided by the Client before applying the Company's proprietary data analytics and AI tools to the Business Data. We retain your Business Data only for as long as necessary to fulfill the purposes for which it was collected or as required by Data Protection Laws. We retain Referral Partner Information and Retailer Referral Information for as long as reasonably necessary to administer the Referral Program, maintain payment and tax records, resolve disputes, enforce our agreements, comply with legal obligations, and protect our business interests.
(i) Diagnostic Clients
Once your Cash Unlock Report is generated and delivered, the Company will take commercially reasonable steps to purge your Business Data from our systems within two (2) business days.
(ii) Retainer Clients
Your Business Data is stored in a secure, encrypted database to allow for year-over-year tracking. You may request a full deletion at any time upon contract termination.
(i) Children's Privacy
The Services are only intended for use by business users. Accordingly, we do not intentionally gather Personal Information from persons who are under the age of 18. If we learn that any Personal Information is the information of a person under the age of 18, we will use reasonable efforts to delete the information in a timely manner.
(j) Client Access and Inquiries
You own your business. If you want to know what data we have in our systems, or if you want us to promptly delete your Business Data, Client Personal Information, Referral Partner Information, and/or Retailer Referral Information, please email team@cashmarginpartners.co. When the Company is acting as a Data Controller, we will process your request in accordance with this Privacy Policy and respond within two (2) business days. If the Company is acting as a Data Processor, we will direct you to the relevant Data Controller that can process your request. If you believe that your Business Data or Client Personal Information is being used in a way that violates or infringes upon Data Protection Laws, you may be entitled to lodge a complaint with relevant authorities.
(k) Disclosure
Subject to legal obligations and narrowly-defined, legitimate business reasons described in this Privacy Policy, we will never disclose your Business Data or Client Confidential Information.
(i) Third-Party Service Providers
From time to time, we may engage third-party service providers. Such providers may have limited access to Business Data and Client Personal Information for the sole purpose of helping manage or improve the Site, Services and/or Referral Program, subject to contractual restrictions on their access to and use of such data no less restrictive than our obligations under this Privacy Policy and Data Protection Laws. We may share Referral Partner Information with payment processors, banking and ACH service providers, tax reporting vendors, customer relationship management providers, analytics providers, hosting providers, and other service providers that process information on our behalf for the purposes described in this Privacy Policy.
(ii) Cross-border Processing
Business Data, Client Personal Information, Referral Partner Information, and Retailer Referral Information may be collected, transferred to, stored and processed by us and/or third parties described above in the United States or countries outside the United States. We will take all necessary steps to ensure that such recipients of such data adhere to commercially reasonable data security practices and comply with all relevant Data Protection Laws.
(iii) Referral Program Disclosures
We may disclose limited information about a referred retailer to the applicable referring Referral Partner for Referral Program administration purposes, including confirmation that a referral was received, whether the referral was accepted or rejected, whether the retailer became a customer, whether a qualifying action occurred, and whether a payout was approved, paid, adjusted, or reversed. We may also disclose limited identifying information reasonably necessary to confirm which referral is being referenced. We do not disclose more information than is reasonably necessary for referral tracking, payment administration, fraud prevention, or compliance.
(l) Law Enforcement; Subpoenas
If the law requires us to, we may need to collect and/or process Business Data or Personal Information to comply with the valid order or request of a court, regulator, or law enforcement agency. Furthermore, we may disclose such information at our sole discretion where we deem it necessary to protect the safety of any individual or the public, or to prevent violation of rights of the Company or any third party.