Privacy Policy

01 Introduction

Kelly Gray Advisory takes privacy seriously. This Policy explains what personal information we collect when you visit our website or engage us as a client, how we use it, and how we protect it.

This Privacy Policy applies to information collected through our website, client engagements, and any other interactions you have with Kelly Gray Advisory. By using our services or website, you agree to the practices described here.

02 About Kelly Gray Advisory

Kelly Gray Advisory is the registered trade name (DBA) of Dagny Enterprises LLC, a Wyoming Limited Liability Company. This Policy is governed by the laws of the State of Wyoming.

Kelly Gray Advisory is a solo practice. When you share information with us, you share it with Kelly Gray directly. Not a large team, not a data processing operation. We collect only what we need to do good work together, and we handle it with care.

03 Information We Collect

What you give us directly

When you reach out, become a client, or otherwise interact with Kelly Gray Advisory, you may share:

• Your name, email address, phone number, and company name
• Business context and project details shared during consultations or engagements
• Communications, including emails and meeting notes
• Payment and billing information, processed through our third-party payment providers

When you visit our website, we may collect basic technical information, including your IP address and browser type, pages visited and time spent on pages, and referring URLs and basic usage patterns. This information is collected through Google Analytics and is used in aggregate to understand how our site performs. You can learn more about how Google handles data at google.com/policies/privacy. When you submit a webform on our site, that information is collected through Zoho and flows directly into our CRM.

When we use AI tools and recording software

Kelly Gray Advisory uses artificial intelligence tools and call recording and transcription software while providing services to clients. Business information and communications shared during client engagements, including notes, project details, call content, and other information you share with Kelly Gray Advisory, may be processed by these tools. Kelly Gray Advisory only uses tools that are configured so that this information is not used to train the providers' models and is handled under business confidentiality terms, applies the same care and confidentiality standards to information processed by these tools as to all other client information, and does not use it for any purpose unrelated to delivering services.

Call recording is covered in the Kelly Gray Advisory Client Agreement. If you have questions about specific tools in use, contact compliance@kellygrayadvisory.com.

04 How We Use Your Information

We use what we collect to:

• Deliver, manage, and improve our B2B sales advisory services
• Communicate with you about your project and our work together
• Process payments and maintain accurate billing records
• Send relevant updates or marketing content (you can opt out at any time)
• Comply with legal obligations and protect our legal rights
• Analyze and improve our website

We do not sell your personal information. We do not use it for automated decision-making that produces legal or similarly significant effects.

05 How We Share Your Information

We share your information only in limited circumstances:

• Service Providers: Trusted vendors who support our operations (email platforms, accounting tools, scheduling software, AI tools, and call recording and transcription software) process data on our behalf and are bound by confidentiality obligations.
• Professional Advisors: We may share information with attorneys, accountants, or insurers as needed to run our business.
• Legal Requirements: We will disclose information when required by law, court order, or government authority, or to protect the rights and safety of Kelly Gray Advisory or others.
• Business Transfers: If Kelly Gray Advisory is ever sold or reorganized, your information may transfer as part of that transaction.

We do not sell, rent, or trade your information to third parties for their own marketing purposes.

06 Cookies and Tracking Technologies

Our website may use cookies (small text files stored on your device) to support basic site functionality and understand how visitors use the site. Google Analytics and Zoho's webforms each set their own cookies as part of how they function.

• Essential cookies keep the site working properly.
• Analytics cookies, including those set by Google Analytics, help us understand traffic patterns and improve the site.

You can manage or disable cookies through your browser settings. Disabling certain cookies may affect how some features work.

07 Data Retention

We keep personal information for as long as necessary to deliver our services, maintain business records, and meet legal requirements. Website analytics data is retained per the settings of our analytics provider. Client project files are typically retained for seven (7) years following the end of an engagement. You can request deletion of your data at any time. See Section 08.

08 Your Privacy Rights

For California residents (CCPA/CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• Right to Know: Request disclosure of what personal information we hold about you.
• Right to Delete: Request that we delete your personal information, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt Out: We do not sell or share personal information for behavioral advertising, but you may contact us with concerns.
• Right to Non-Discrimination: We will not treat you differently for exercising these rights.

To submit a request, email compliance@kellygrayadvisory.com. We will respond within 45 days.

For all users

Regardless of your location, you may:

• Request access to the personal information we hold about you
• Ask us to correct inaccurate information
• Opt out of marketing communications at any time by clicking "unsubscribe" or emailing us directly

09 Data Security

We take reasonable measures to protect your information, including secure communications, access controls, and confidentiality expectations with any vendors we use. That said, no system is perfectly secure. We cannot guarantee that information transmitted to us is completely safe, and we encourage you to use good security practices on your end as well. In the event of a data breach affecting your personal information, we will notify you as required by applicable law.

10 Third-Party Websites and Tools

Our website or communications may contain links to third-party sites or tools. We are not responsible for the privacy practices of those third parties. If you follow a link to an outside platform, we encourage you to read their privacy policy before sharing any information.

11 Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the effective date at the top of this document. We encourage you to review it periodically. Your continued use of our services after any update means you accept the revised Policy.

12 Contact Information

Questions about this Policy or how we handle your information? Reach out directly.