Privacy Policy

1. INTRODUCTION

This Privacy Policy ("Policy") describes how True North Marketing INC d/b/a KLYR MEDIA ("KLYR MEDIA," "Company," "we," "us," or "our") collects, uses, discloses, stores, and otherwise processes information in connection with our websites, digital properties, marketing services, communications, software platforms, and related business operations (collectively, the "Services").

This Policy applies to information collected from or about individuals who access or use the Services, communicate with us, or otherwise interact with KLYR MEDIA in a business or consumer capacity ("you" or "your"). By accessing or using the Services, you acknowledge that you have read, understood, and agreed to the practices described in this Policy.

2. INFORMATION WE COLLECT

We may collect information to the extent reasonably necessary or appropriate to operate, maintain, enhance, secure, market, and support the Services; comply with legal and regulatory obligations; enforce contractual rights; and protect the rights, property, and safety of KLYR MEDIA, our clients, and others.

2.1 Information You Provide Voluntarily

We may collect information you choose to provide, including, without limitation:

• Identifiers and contact information, such as name, email address, telephone number, business name, job title, and mailing address;
• Lead, inquiry, and project information, including details regarding your business, objectives, services requested, budget ranges, and related communications;
• Communications, including emails, messages, form submissions, chat interactions, SMS messages, and other correspondence;
• Billing and transactional information, including invoices, payment confirmations, subscription status, and related records (payment card information is generally processed by third party payment processors and not stored by us in full);
• Any other information you elect to provide in connection with your use of the Services.

You are not required to provide optional information; however, certain Services may not be available without it.

2.2 Voice, Call, and Messaging Data

If you contact us by telephone, SMS, or other voice enabled systems, we may collect:

• Call metadata, including date, time, duration, routing, and status;
• Call content, including recordings and/or transcriptions, where enabled;
• AI generated data, such as summaries, tags, classifications, and routing decisions generated by automated or artificial intelligence based systems.

By providing a telephone number or engaging in voice or SMS communications with us, you expressly consent to receive communications from us, including via automated systems or artificial intelligence technologies, to the fullest extent permitted by applicable law.

2.3 Information Collected Automatically

When you access or use the Services, we may automatically collect:

• Device and log information, including IP address, browser type, operating system, device identifiers, referral URLs, pages viewed, and timestamps;
• Usage and performance data, including interactions with the Services and system activity logs;
• Analytics and advertising data, including conversion events and engagement metrics collected through cookies, pixels, SDKs, and similar technologies.

2.4 Information From Third Parties

We may receive information from third parties, including, without limitation:

• Advertising and analytics platforms (e.g., performance and conversion data);
• Payment processors (e.g., transaction confirmations and dispute notices);
• CRM and marketing automation platforms used to operate the Services;
• Publicly available sources and business partners.

3. TECHNOLOGIES AND SERVICE PROVIDERS

We may engage third party service providers, processors, and platforms to support the Services, including, without limitation:

• Customer relationship management and marketing automation platforms (including GoHighLevel and LeadConnector);
• Analytics and measurement services (including Google Analytics and Google Search Console);
• Advertising and remarketing platforms (including Meta Pixel);
• Payment processing services (including Stripe);
• Voice, telephony, and artificial intelligence–enabled communication tools.

Such providers process information in accordance with their own privacy policies and contractual obligations. We may add, remove, or replace service providers at our discretion.

4. HOW WE USE INFORMATION

We may use information for purposes including, without limitation:

• Providing, operating, and maintaining the Services;
• Responding to inquiries and delivering requested services;
• Communicating with you regarding accounts, services, updates, and offers;
• Marketing, advertising, and measuring campaign effectiveness;
• Improving functionality, performance, and user experience;
• Processing payments and managing billing;
• Detecting, preventing, and responding to fraud, abuse, and security incidents;
• Complying with legal and regulatory obligations;
• Enforcing agreements and protecting legal rights.

5. DISCLOSURE OF INFORMATION

We may disclose information under the following circumstances:

5.1 Service Providers and Vendors

To third parties that perform services on our behalf, subject to contractual confidentiality and data protection obligations.

5.2 Legal and Regulatory Requirements

To comply with applicable laws, regulations, subpoenas, court orders, or governmental requests.

5.3 Protection of Rights and Interests

Where we believe disclosure is reasonably necessary to protect the rights, property, or safety of KLYR MEDIA, our clients, or others.

5.4 Business Transactions

In connection with a merger, acquisition, sale of assets, financing, or similar transaction.

5.5 With Consent

Where you have provided consent or direction to do so.

5.6 Aggregated or De-Identified Data

Information that does not reasonably identify an individual may be used or disclosed for any lawful purpose.

6. COOKIES, TRACKING, AND TARGETED ADVERTISING

We and our partners may use cookies and similar technologies for functionality, analytics, and advertising. Depending on your jurisdiction, certain sharing of information for advertising purposes may constitute a "sale" or "share" under applicable law. You may control cookie preferences through browser settings and, where available, consent management tools.

7. DATA RETENTION

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, including legal, regulatory, accounting, dispute resolution, security, and business continuity purposes, unless a longer retention period is required or permitted by law.

8. DATA SECURITY

We implement reasonable administrative, technical, and organizational safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction. However, no system is completely secure, and we cannot guarantee absolute security.

9. YOUR RIGHTS AND CHOICES

Depending on your jurisdiction, you may have rights regarding your personal information, including rights to access, correct, delete, restrict processing, or opt out of certain data uses. Requests may be submitted using the contact information below. We reserve the right to verify your identity before responding.

10. CHILDREN'S INFORMATION

The Services are not directed to children under 13 (or under 16 where applicable), and we do not knowingly collect personal information from children.

11. INTERNATIONAL DATA TRANSFERS

Your information may be processed and stored in the United States and other jurisdictions where we or our service providers operate, which may have different data protection laws than your jurisdiction.

12. GOVERNING LAW

This Policy shall be governed by and construed in accordance with the laws of the State of New York, without regard to conflict of laws principles.

13. CHANGES TO THIS POLICY

We may update this Policy from time to time. Changes will be effective upon posting of the revised Policy. Continued use of the Services constitutes acceptance of the updated Policy.

14. CONTACT INFORMATION