Flowing River Conflict Solutions LLC ("Flowing River," "we," "us," or "our" respects your privacy. This  Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you visit www.flowingrivercs.com, use our Pathways Questionnaire or Conflict Cost Calculator, submit forms, book meetings, sign up for emails, or otherwise interact with us online.

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This Privacy Policy is intended to provide transparent notice of our data practices and to support compliance with applicable privacy laws, including, where applicable, the General Data Protection Regulation ("GDPR"), UK GDPR, and U.S. state privacy laws such as the California Consumer Privacy Act, as amended ("CCPA/CPRA").

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1. Who We Are

Controller/Business:

Flowing River Conflict Solutions LLC

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Contact email:

vpolunas@flowingrivercs.com

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Website:

www.flowingrivercs.com

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Mailing address:

PO Box 391094, Solon, Ohio, 44139, United States of America

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2. Information We Collect

We may collect the following categories of personal information:

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Identifiers and contact information

• Name

• Email address

• Company or organization name

• Job title

• Business contact details you provide

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Professional or employment-related information

• Employer name

• Role or department

• Information you share about your team or organization in inquiries or forms

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Calculator and form-submission information

• Employee count

• Salary range

• Turnover information

• Conflict-related estimates

• Industry

• Other inputs you provide through the calculator or forms 

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Internet or device information

• IP address

• Browser type

• Device type

• Operating system

• Referring URL

• Pages viewed

• Timestamps

• General location derived from IP

• Cookie or similar tracking data where used

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Communications

• Emails, messages, inquiries, scheduling requests, and other communications you send us

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We do not ask for or intentionally collect highly sensitive data such as government ID numbers, financial account numbers, health information, or precise geolocation through the calculator.

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3. Sources of Information

We collect personal information:

• Directly from you

• Automatically from your browser or device when you use the site

• From service providers that support our website, scheduling, analytics, communications, or hosting

• From booking or email tools when you interact with them through our site

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4. Why We Use Personal Information and Our Legal Bases

We use personal information for the following purposes.

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To provide requested services or information

• Deliver calculator and questionnaire results

• Respond to inquiries

• Schedule discovery calls

• Send requested resources or follow-up communications

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To operate and improve our website and business

• Maintain site functionality

• Troubleshoot issues

• Improve user experience

• Understand site usage and engagement

• Maintain records of inquiries and leads

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To protect our site and business

• Prevent fraud or misuse

• Monitor security

• Enforce our terms

• Comply with legal obligations

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Where GDPR, UK GDPR, or similar laws apply, we rely on one ore more of the following legal bases:

• Consent, such as where you opt in to marketing emails or non-essential cookies

• Performance of a contract or taking steps at your request before entering into a contract, such as when you request a calculator or questionnaire result or book a call

• Legitimate interests, such as operating, securing, and improving our website and communicating with business contacts in a proportionate way

• Legal obligation, where processing is required by law

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GDPR requires a lawful basis for processing, and direct marketing commonly relies on consent or legitimate interests depending on the context.

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5. Notice at Collection and Data Minimization

We collect, use, retain, and share personal information only as reasonably necessary and proportionate for the purposes described in this Privacy Policy or otherwise disclosed at the point of collection.

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At or before collection, we aim to inform you about:

• The categories of personal information collected

• The purposes for which it is collected and used

• Whether it is sold or shared

• How to review this Privacy Policy and exercise applicable rights

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California law requires notice at or before the point of collection, and states that collection, use, retention, and sharing should be reasonably necessary and proportionate to the disclosed purposes.

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6. Cookies and Similar Technologies

We and our service providers may use cookies, pixels, local storage, and similar technologies to:

• Keep the site working

• Remember preferences

• Measure traffic and usage

• Improve performance

• Support embedded services or communication tools

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Where required by law, we will ask for consent before using non-essential cookies or similar technologies.

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You can manage cookie preferences through our cookie banner or your browser settings, where applicable.

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GDPR-style guidance emphasizes clear cookie transparency, and regulators in Europe have taken enforcement action where consent and refusal mechanisms were inadequate.

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7. How We Disclose Personal Information

We may disclose personal information to:

• Website hosting and CMS provides, including Wix

• Scheduling and calendar providers, including Google

• Email and communication providers

• Analytics or technical service providers

• Legal, tax, insurance, or professional advisers

• Authorities or regulators where required by law

• Successors in connection with a merger, acquisition, financing, or asset transfer

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We don disclose personal information to third parties for their own independent marketing purposes.

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8. Sale, Sharing, Targeted Advertising, and Sensitive Personal Information

We do not sell personal information for money.

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We do not knowingly share personal information for purposes that would require a "Limit the Use of My Sensitive Personal Information" link under California law.

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If our practices change, we will update this Privacy Policy and any required notices.

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California guidance explains rights to opt out of sale-sharing and to limit use of sensitive personal information when those activities occur.

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9. International Transfers

We are based in the United States. If you access the site from outside the United States, your information may be transferred to and processed in the United States or other countries where our service providers operate.

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Where required by applicable law, we will use appropriate safeguards for international transfers of personal information.

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GDPR-style guidance requires privacy information about transfers to countries outside the relevant region and the transfer mechanism used where applicable.

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10. How Long We Keep Information

We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• Provide requested services or information

• Maintain business and tax records

• Resolve disputes

• Protect our legal interests

• Comply with legal obligations

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Our retention periods may vary by data type and purpose. For example:

• Inquiry and lead information: up to 24 months after last meaningful interaction, unless longer retention is needed

• Client records: according to contract, business, tax, and legal needs

• Cookie and analytics data: according to the settings of the relevant tool or our internal retention rules

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GDPR-style transparency guidance expects organizations to tell individuals their retention periods, or at least the criteria used to set them.

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11. Your Privacy Rights

Depending on where you live, you may have the right to:

• Know or access the personal information we hold about you

• Receive a portable copy of certain information

• Correct inaccurate information

• Delete certain information

• Object to certain processing

• Restrict certain processing

• Withdraw consent where processing is based on consent

• Opt out of the sale of personal information, sharing for cross-context behavioral advertising, targeted advertising, or certain profiling, where applicable

• Limit certain uses of sensitive personal information, where applicable

• Appeal a denial of your request, where applicable

• GDPR/UK GDPR rights include access, rectification, erasure, objection, and more; California rights include know, delete, correct, opt out, and limit in certain situations; Colorado and Connecticut also provide access, delete, correct, and opt-out rights, and Connecticut expressly provides an appeal process for denied requests.

 

EEA/UK/Switzerland

If GDPR, UK GDPR, or similar laws apply to you, you may also have the right to lodge a complaint with your local supervisory authority.

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12. How to Exercise Your Rights

To submit a privacy request, email us at vpolunas@flowingrivercs.com with the subject line: Privacy Request.

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Please describe your request in enough detail for us to verify and respond appropriately.

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We may need to verify your identity before completing a request. We will not discriminate against you for exercising applicable privacy rights.

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If we deny a request and an appeal right applies to you, you may appeal by replying to our response and writing Appeal Privacy Decision in the subject line within 30 days of the denial. We will review and respond as required by applicable law.

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Colorado and Connecticut privacy law materials describe consumer rights to access, delete, correct, and opt out, and Connecticut's law expressly requires an appeal path for denied rights requests.

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13. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. No method of transmission over the internet or electronic storage is completely secure, so we cannot guarantee absolute security.

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FTC guidance for businesses recommends taking stock of what personal information you hold, keeping only what you need, protecting it, disposing of it securely, and planning ahead for security incidents.

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14. Children's Privacy

Our website and services are intended for adults and business users. We do not knowingly collect personal information from children under 13 through our website. 

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15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. Material changes will be posted on this page and, where appropriate, communicated in another reasonable way.

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16. Contact Us

Flowing River Conflict Solutions LLC

Email: vpolunas@flowingrivercs.com 

Website: www.flowingrivercs.com 

Mailing address: PO Box 391094, Solon, Ohio 44139, United States of America