Lower Cross LLC

Privacy Policy

Last Updated: July 8, 2026
Effective Date: July 8, 2026

1. INTRODUCTION

Lower Cross LLC ("Lower Cross," "we," "us," or "our") is a digital growth and strategy firm based in Greenwich, Connecticut. This Privacy Policy explains how we collect, use, disclose, and protect information about you when you visit lowercross.com and any related pages, subdomains, or forms we operate (collectively, the "Site"), contact us, subscribe to our communications, or otherwise interact with us.

By using the Site or submitting information to us, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Site or submit information to us.

This Policy applies to information we collect through the Site and in the course of our marketing and business-development activities. It does not govern the separate confidentiality and data-handling terms of any services agreement we enter into with a client, which are addressed in the applicable engagement contract.

2. INFORMATION WE COLLECT

We collect information in three ways: (a) information you provide directly, (b) information collected automatically, and (c) information from third parties.

2.1 Information You Provide Directly

When you complete a form on the Site, request a strategy call, subscribe to our newsletter, or email or call us, you may provide:

• Full name
• Business email address
• Company name
• Company website
• Monthly marketing budget range
• The content of your message or inquiry
• Any other information you choose to include in your communications with us

Our contact and "Request a Strategy Call" forms ask for name, email, company, website, monthly marketing budget, and a free-text description of how we can help. Our newsletter sign-up collects your email address and your acceptance of this Privacy Policy and our Terms of Service.

2.2 Information Collected Automatically

When you visit the Site, we and our service providers automatically collect certain technical and usage information through cookies, tags, pixels, and similar technologies, including:

• IP address and approximate location derived from it
• Browser type and version, device type, and operating system
• Referring and exit pages, and pages viewed on the Site
• Date, time, and duration of your visit
• Clickstream data and interactions with Site content
• Unique device or cookie identifiers

We use Google Tag Manager to deploy these technologies and Google Analytics to understand Site traffic and usage. We also use advertising and measurement technologies from platforms including Meta (Facebook and Instagram) and Google to measure the performance of our marketing and to reach relevant audiences.

2.3 Information from Third Parties

We may receive information about you or your company from analytics providers, advertising platforms, data-enrichment and lead-intelligence providers, and publicly available sources (such as company websites and professional networking profiles). We may combine this information with the information you provide to us.

2.4 Sensitive Information

We do not intentionally collect sensitive personal information (such as government identifiers, health information, or financial account numbers) through the Site, and we ask that you not submit such information to us through Site forms.

3. HOW WE USE INFORMATION

We use the information described above for the following purposes:

• To respond to your inquiries and requests, including scheduling strategy calls and providing information about our services;
• To send you newsletters, insights, market intelligence, and other marketing communications you have requested or that are permitted by law;
• To operate, maintain, secure, and improve the Site and our services;
• To analyze Site usage and measure and optimize the performance of our marketing campaigns;
• To evaluate potential business relationships and conduct business-development activities;
• To personalize your experience and the content and advertising you see;
• To detect, prevent, and address fraud, abuse, security incidents, and technical issues;
• To comply with legal obligations and enforce our Terms of Service and other agreements; and
• For any other purpose disclosed to you at the time of collection or to which you consent.

4. LEGAL BASES FOR PROCESSING (EEA/UK VISITORS)

If you are located in the European Economic Area or the United Kingdom, we process your personal data on one or more of the following legal bases:

• Your consent (for example, to send marketing communications or set non-essential cookies), which you may withdraw at any time;
• Our legitimate interests in operating and promoting our business, provided those interests are not overridden by your rights;
• The performance of a contract or steps taken at your request prior to entering into a contract; and
• Compliance with our legal obligations.

5. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to operate the Site, remember your preferences, analyze traffic, and support advertising and measurement. Cookies we use generally fall into these categories:

• Strictly Necessary: required for the Site to function;
• Analytics/Performance: help us understand how visitors use the Site (for example, Google Analytics);
• Advertising/Targeting: used by us and platforms such as Meta and Google to measure and deliver relevant advertising.

You can control cookies through your browser settings and, where offered, through a cookie banner or preference tool on the Site. Disabling certain cookies may affect Site functionality. Because standards for responding to browser "Do Not Track" signals are not yet uniform, the Site may not respond to such signals; however, we honor recognized opt-out preference signals (such as Global Privacy Control) where required by law.

6. HOW WE SHARE INFORMATION

We do not sell your personal information for money. We may share information as follows:

• Service Providers: with vendors who perform services on our behalf, such as website hosting, form processing, email and CRM platforms, analytics providers, and advertising and measurement partners, who are permitted to use the information only to provide services to us;
• Advertising and Analytics Platforms: with platforms such as Google and Meta that provide analytics and advertising services, which may constitute a "sale" or "sharing" of personal information under certain U.S. state laws (see Section 9);
• Business Transfers: in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business or assets;
• Legal and Safety: when we believe disclosure is necessary to comply with applicable law, legal process, or governmental request, to enforce our agreements, or to protect the rights, property, or safety of Lower Cross, our clients, or others; and
• With Your Direction or Consent: when you ask us to share information or otherwise consent to sharing.

7. DATA RETENTION

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including to respond to inquiries, provide and improve our services, maintain business records, and comply with our legal obligations, resolve disputes, and enforce our agreements. When information is no longer needed, we take reasonable steps to delete, anonymize, or securely store it.

8. DATA SECURITY

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping any credentials you use in connection with the Site confidential.

9. YOUR PRIVACY RIGHTS

9.1 U.S. State Privacy Rights (Including Connecticut and California)

Depending on your state of residence, you may have some or all of the following rights, subject to legal exceptions:

• The right to know or access the personal information we have collected about you;
• The right to correct inaccurate personal information;
• The right to delete personal information;
• The right to obtain a portable copy of your personal information;
• The right to opt out of "sale" or "sharing" of personal information and of targeted advertising; and
• The right not to be discriminated against for exercising your rights.

Connecticut residents may exercise these rights under the Connecticut Data Privacy Act, and California residents may exercise rights under the California Consumer Privacy Act, as amended. To exercise any of these rights, contact us using the details in Section 13. We will verify your request as required by law. You may use an authorized agent to submit a request on your behalf where permitted. If we decline your request, you may have the right to appeal by replying to our decision; we will respond to appeals as required by applicable law.

9.2 EEA/UK Rights

If you are in the EEA or UK, you may have rights to access, correct, delete, restrict, or object to the processing of your personal data, to data portability, and to withdraw consent. You also have the right to lodge a complaint with your local data protection authority.

9.3 Marketing Opt-Out

You may opt out of our marketing emails at any time by using the unsubscribe link in any such email or by contacting us. Even if you opt out of marketing messages, we may still send you non-promotional communications, such as responses to your inquiries. 10. THIRD-PARTY LINKS AND SERVICES

The Site may contain links to third-party websites, platforms, and services (for example, LinkedIn, Facebook, Instagram, X, YouTube, and case-study or press resources) that we do not control. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party sites or services you visit.

11. INTERNATIONAL DATA TRANSFERS

Lower Cross is based in the United States, and the information we collect is processed in the United States and may be processed in other countries where we or our service providers operate. These countries may have data-protection laws that differ from those in your jurisdiction. Where required, we implement appropriate safeguards for cross-border transfers.

12. CHILDREN'S PRIVACY

The Site is intended for businesses and professionals and is not directed to children under 16. We do not knowingly collect personal information from children under 16. If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to delete it.

13. HOW TO CONTACT US

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us at:

Lower Cross LLC Attn: Privacy Greenwich, Connecticut Email: hello@lowercross.com Phone: 203-990-2888

14. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date above. If we make material changes, we will provide additional notice as required by law. Your continued use of the Site after the effective date of an updated Policy constitutes your acceptance of the changes.

15. GOVERNING LAW

This Privacy Policy and any dispute arising out of or relating to it are governed by the laws of the State of Connecticut, without regard to its conflict-of-laws principles, except to the extent that mandatory data-protection laws of another jurisdiction apply to you.