Effective Date:01 January, 2020
Last Updated: 31 July 2026
Collective 54,LLC. (referred to herein as “Collective 54”, “we”, “our” or “us”) recognize theimportance of protecting personal data we may collect from visitors, accountholders, and any other individual or entity (“Users”, “you”, or “your”) whovisit our web sites. This Privacy Policy applies to data collection byCollective 54 and shall apply to your use of the website, www.collective54.com,and other Collective 54-related sites, apps, communications, capabilities andservices (“Services”) accessible on or by any top-level Collective 54 domainowned by us (each, a “Site” and collectively the “Sites”), but excludingservices that state that they are offered under a different privacy policy.
Our PrivacyPolicy explains: (1) what information we collect; (2) why we collect it; (3)how we use that information; (4) how we may share it; and (5) the choices weoffer, including how to access and update information. Specifically, ourPrivacy Policy covers the following topics:
1. When This Privacy Policy Applies
2. Information We Collect
3. How We Use Information We Collect
4. Our Legal Basis for Collecting Personal Data
5. Information We Share
6. Your Failure to Provide Personal Data
7. Our Retention of Your Personal Data
8. Your Choices and Accessing, Updating orDeleting Your Personal Data
9. Our Opt-in/Opt-out Policy
10. Third Party Links
11. International Transfer
12. How We Protect Personal Data
13. Children
14. Direct Marketing and “Do Not Track” Signals
15. Changes to this Privacy Policy
16. Code of Conduct
17. How to Contact Us
Pleasefamiliarize yourself with our privacy practices and let us know if you have anyquestions. By using the Sites, you signify your acceptance of this PrivacyPolicy. If you do not agree to this Privacy Policy, please do not use theSites.
Regardless ofthe country you live in, you authorize us to transfer, store, and use yourinformation in the United States, and any other country where we operate. Insome of these countries, the privacy and data protection laws and rulesregarding when government authorities may access data may vary from those inthe country where you live. Learn more about our data transfer operations inthe “International Transfer” section below. If you do not agree to thetransfer, storage and use of your information in the United States, and anyother country where we operate, please do not use the Sites or Services.
If you have anyquestions or comments about this Privacy Policy, please submit a request toprivacy@collective54.com.
Our PrivacyPolicy applies to all of the services offered by Collective 54 but excludesservices that have separate privacy policies that do not incorporate thisPrivacy Policy.
Our PrivacyPolicy does not apply to services offered by other companies or individuals,including products or sites that may be displayed to you, or other sites linkedfrom our services. Our Privacy Policy does not cover the information practicesof other companies and organizations who advertise our services, and who mayuse cookies, pixel tags and other technologies to serve and offer relevant ads.
We collectinformation, including personal data, to provide better services to all ourUsers. We use the term “Personal Data” to refer to any information thatidentifies or can be used to identify you. Common examples of personal datainclude: digital identity, such as a login name or handle, information aboutyour device, and certain metadata.
We collectPersonal Data in the following ways:
You may choose to provide us with personal data about yourself, including your name, organization, phone number and email address, such as when you request information about our Services, book a call or meeting with us, subscribe to our publications, or register on our mobile application. In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Data about yourself when you report a problem or have a question about our Services.
Business and financial information you submit to our tools. Certain features on our Sites, including our Firm Estimator, ask you to provide information about your firm and about yourself in exchange for a result. Depending on the tool, this may include your email address together with your firm's annual pre-tax profit, annual growth rate, pre-tax profit margin, percentage of recurring revenue, percentage of revenue concentrated in your largest clients, average client retention, average employee retention, the role of the founder in selling and delivering work, and the age of the founder or chief executive. This information is submitted voluntarily, is associated with the contact record we hold for you, and is retained in our customer relationship management system.
Information you volunteer in free-text fields. Some features of our Sites, including message boxes, comment fields and our website assistant, accept open text. Anything you type into those fields is submitted to us and stored, including information about you, your firm, or third parties that we did not ask for. Please do not enter information into free-text fields that you would not want us to hold.
The Sites may offer interactive and social features that permit you to submit content and communicate with other users. You may provide personal data to us when you post information in these interactive and social features.
Please note that your postings in these areas of the Sites may be accessible to other users. Please note that if you do not provide us with Personal Data, your ability to use certain aspects of our Services may be limited.
We collectcertain information automatically, such as your operating system version,browser type, and internet service provider. When you use our Site, weautomatically collect and store this information in service logs. Thisincludes: details of how you used our Site; Internet protocol address; andcookies that uniquely identify your browser. The information we collectautomatically is statistical data and may or may not include Personal Data, butwe may maintain it or associate it with Personal Data we collect in other waysor receive from third parties.
Others engagingour services for your use, such as your employer, provide us with personal dataand your eligibility to use the Services that they purchase for use by theiremployees. The information provided by your employer may include your name andphone number.
We and ourpartners use various technologies to collect and store information when youvisit one of our services, and this may include using cookies or similartechnologies to identify your browser or device.
Thetechnologies we use for this automatic data collection may include:
Cookies. Acookie is a small file placed on the hard drive of your computer. You mayrefuse to accept browser cookies by activating the appropriate setting on yourbrowser. However, if you select this setting you may be unable to accesscertain parts of our services. Unless you have adjusted your browser setting sothat it will refuse cookies, our system will issue cookies when you direct yourbrowser to our services.
Web Beacons.Pages of our services or our e-mails may contain small electronic filesknown as web beacons (also referred to as clear gifs, pixel tags andsingle-pixel gifs) that permit us, for example, to count users who have visitedthose pages or opened an e-mail and for other related website statistics (forexample, recording the popularity of certain website content and verifyingsystem and server integrity).
Theproviders we use. So that you know who is involved, the followingcategories of provider currently operate these technologies on our Sites:
• Website analytics — Google Analytics, and theanalytics functionality of HubSpot, our customer relationship managementplatform. These tell us which pages are viewed, how visitors move through theSites, and which sources referred them.
• Advertising and measurement — Google Ads, Meta,LinkedIn, and the advertising functionality of HubSpot. These allow us tomeasure the performance of our advertising and to present our advertising toyou on other platforms after you have visited our Sites.
• Website visitor identification — described insection 2.5 below.
• Website functionality — including our customerrelationship management platform’s forms and meeting-scheduling tools, hostedweb fonts, payment provider scripts, and the website assistant described insection 2.6 below.
The specificproviders we use may change. We maintain this list on a good-faith basis andupdate it when our providers change materially.
We usethird-party website visitor identification services. These services analyzeinformation available about visits to our Sites — including network informationsuch as your Internet protocol address, and information from their owndatabases — in order to identify the company or organization a visitor islikely to be associated with, and in some configurations to identify individualvisitors by name, job title, or business contact details.
We use theseservices to understand which organizations are interested in Collective 54, toprioritize our outreach, and to inform our marketing and membershipdevelopment. Information produced by these services may be added to the contactand company records we hold in our customer relationship management system, andmay be combined with the information described elsewhere in section 2.
The providerswe currently use for this purpose are ZoomInfo (WebSights) and Clay.Each operates under its own privacy policy, which we encourage you to review.Section 9 describes the choices available to you.
This means thatinformation may be associated with you or your organization even if you havenot submitted a form, created an account, or otherwise identified yourself tous.
Our Sites mayoffer an artificial intelligence assistant that answers questions aboutCollective 54. If you use it, we collect and store the full text of theconversation — both the messages you send and the responses generated —together with a randomly generated session identifier and the date and time ofeach message.
What we donot collect through the assistant. The assistant does not ask you for, andwe do not automatically attach, your name, your email address or your Internetprotocol address. Conversations are stored without those identifiers.
What you mayreveal. The message box accepts free text. If you type your name, yourcontact details, information about your firm’s finances, your plans for yourbusiness, or information about other people, that content is stored along withthe rest of the conversation. Please see the guidance in section 2.1.
Howconversations are processed. To generate responses, the content of yourmessages is transmitted to and processed by our artificial intelligence serviceprovider. Conversations are stored in a hosted database operated by ourdatabase provider, and the service that receives them runs on our hostingprovider’s infrastructure. All three act as service providers to us undercontract. Section 3 describes how we use conversations after they are stored,and section 5 describes with whom they are shared.
In addition toforms that we operate directly, our customer relationship management platformprovides a feature that captures information submitted through other formspresent on our Sites, including forms that were not built on that platform.Where this feature is active, the values you enter into a form on our Sites —such as your name, email address and any other fields the form contains — maybe recorded and associated with the contact record we hold for you at the pointyou submit the form.
We use yourpersonal data in ways that are compatible with the purposes for which it wascollected or authorized by you, including for the following purposes:
1. To inform you about services available fromCollective 54.
2. To authorize access to our Sites andServices.
3. To provide you with Services.
4. To offer and administer programs.
5. To administer content, promotion, survey orother Site features.
6. To communicate about, and administer yourparticipation in, special programs, online campaigns, online programs, and todeliver pertinent emails.
7. To improve our customer service.
8. To respond to and support users regardingtheir use of the Sites and Services.
9. To comply with all applicable legalrequirements.
10. To investigate possible fraud or otherviolations of our Terms of Use or this Privacy Policy and/or attempts to harmour Users.
11. To identify organizations and individuals whohave shown interest in Collective 54, and to prioritize and personalize ourmarketing and membership outreach accordingly.
12. To measure the effectiveness of ouradvertising and to present our advertising to you on third-party platforms.
We use theinformation we collect from our Sites to provide, maintain, and improve them,to develop new services, and to protect our Company and our users. We useinformation collected from cookies and other technologies, to improve your userexperience and the overall quality of our services. We may use your personalinformation to see which web pages you visit at our Site, which web site youvisited before coming to our Site, and where you go after you leave our Site.We can then develop statistics that help us understand how our visitors use ourSite and how to improve it. We may also use the information we obtain about youin other ways for which we provide specific notice at the time of collection.
We will alwaysask for your consent before using information for a purpose other than thoseset out in this Privacy Policy.
Our use ofartificial intelligence. Collective 54 uses artificial intelligencetechnologies in various aspects of its operations, including data analysis,support, product development, and internal processes. The use of AI may involvenatural language processing, machine learning, and other AI techniques toenhance efficiency, accuracy, effectiveness, and overall performance.Collective 54 reserves the right to modify, update, or discontinue the use ofAI in its operations without prior notice.
Automatedsummaries of website conversations. Conversations with our websiteassistant are processed automatically. In addition to generating responses toyou, we use artificial intelligence to produce a short written summary of eachconversation — for example, the apparent interest or need expressed, and anyindication of the type of firm involved. That summary is stored alongside theconversation and is circulated internally as described in section 5. Thesesummaries are used to inform our follow-up and our understanding of whatvisitors are looking for. They are not used to make any decision that producesa legal effect concerning you.
Whenever wecollect Personal Data from you, we may do so on the following legal bases:
Your consent tosuch collection and use;
Out ofnecessity for the performance of an agreement between us and you, such as youragreement to use our Services;
Our legitimatebusiness interest, including but not limited to the following circumstanceswhere collecting or using Personal Data is necessary for:
• Intra-organization transfers for client data foradministrative purposes;
• Product development and enhancement, where theprocessing enables Collective 54 to enhance, modify, personalize, or otherwiseimprove our services and communications for the benefit of our users, and tobetter understand how people interact with our Sites;
• Fraud detection and prevention;
• Enhancement of our cybersecurity, including improvingthe security of our network and information systems; and
• General business operations and diligence;
Provided that,in each circumstance, we will weigh the necessity of our processing for thepurpose against your privacy and confidentiality interests, including takinginto account your reasonable expectations, the impact of processing, and anysafeguards which are or could be put in place. In all circumstances, we willlimit such processing for our legitimate business interest to what is necessaryfor its purposes.
We do not sharepersonal information with companies, organizations, entities and individualsoutside of Collective 54 unless one of the following circumstances applies:
• With your consent. We will share personal datawith companies, organizations or individuals outside of Collective 54 when wehave your consent to do so.
• Enterprise accounts. We may share personal datawith your employer for the purpose of invoicing.
• For external processing. We may provide personalinformation to our affiliates or other trusted businesses or partners toprocess it for us, based on our instructions and in compliance with our PrivacyPolicy and any other appropriate confidentiality and security measures. It isour policy to only share Personal Data with contractors, service providers andother third parties who are bound by contractual obligations to keep PersonalData confidential and use it only for the purposes for which we disclose it tothem. Under certain circumstances, you may avoid having us share yourinformation with our business partners and vendors by not granting uspermission to share your information. Not granting us permission to share yourinformation with our business partners or vendors may limit your access totheir services through the Sites. We do not share personal information withthird parties for their own marketing purposes.
• With the providers who operate our Sites andmarketing. We rely on third-party providers to operate our Sites and ourmarketing, and information described in section 2 is disclosed to them for thatpurpose. These include: our customer relationship management and marketingplatform; our website analytics providers; our advertising platforms; ourwebsite visitor identification providers; our website hosting, database andartificial intelligence providers, which together operate the websiteassistant; our payment processor; and our internal communications and emailproviders. Each of these providers handles information in accordance with itsown privacy policy and terms, over which we do not have control. We encourageyou to review those policies.
• For legal reasons. We will share Personal Datawith companies, organizations or individuals outside of Collective 54 if wehave a good-faith belief that access, use, preservation or disclosure of theinformation is reasonably necessary to:
◦ meet any applicable law, regulation, legal process orenforceable governmental request.
◦ enforce applicable Terms of Use, includinginvestigation of potential violations.
◦ detect, prevent, or otherwise address fraud, securityor technical issues.
◦ protect against harm to the rights, property or safetyof Collective 54, our Users or the public as required or permitted by law.
We attempt tonotify Users about legal demands for their personal data when appropriate inour judgment, unless prohibited by law or court order or when the request is anemergency. We may dispute such demands when we believe, in our discretion, thatthe requests are over-broad, vague or lack proper authority, but we do notpromise to challenge every demand.
• Business transfers. If we establish a newrelated entity, are acquired by or merged with another organization, or ifsubstantially all of our assets are transferred to another organization,Personal Data about our users is often a transferred business asset. In theevent that Collective 54 itself or substantially all of our assets areacquired, Personal Data about our users may be one of the transferred assets.
• Aggregate site use information. We may shareaggregate and anonymized/pseudonymized Personal Data to third parties in orderto promote or describe use of the Sites, for research, marketing, advertising,or similar purposes.
Internaldistribution. Conversations with our website assistant, and the automatedsummaries described in section 3, are distributed internally to Collective 54personnel by email and through our internal messaging platform, so that we canrespond to enquiries and understand what visitors are asking about.
Your provisionof Personal Data is required in order to use certain parts of our services andour programs. If you fail to provide such Personal Data, you may not be able toaccess and use our Services and/or our programs, or parts of our Servicesand/or our programs.
We may retainyour Personal Data for a period of time consistent with the original purposefor collection. For example, we keep your Personal Data for no longer thanreasonably necessary for your use of our programs and Services and for areasonable period of time afterward. We also may retain your Personal Dataduring the period of time needed for us to pursue our legitimate businessinterests, conduct audits, comply with our legal obligations, resolve disputesand enforce our agreements.
If you chooseto end your business relationship with us, we generally will delete yourpersonal data according to our data retention policy. We may retain yourPersonal Data even after you have ended your relationship with us if reasonablynecessary to comply with our legal obligations (including law enforcementrequests), meet regulatory requirements, resolve disputes, maintain security,prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to“unsubscribe” from further messages from us. We will retain depersonalizedinformation after your account has been closed.
Websiteconversations. Conversations with our website assistant, and the automatedsummaries of them, are retained for no longer than reasonably necessary for thepurposes described in section 3 — principally responding to enquiries andimproving the assistant — and for a reasonable period afterward. Because theseconversations are stored without your name, email address or Internet protocoladdress, we may be unable to locate a particular conversation in response to arequest unless you can supply information that identifies it.
Informationsubmitted to our tools. Information you submit through our forms and tools,including the business and financial information described in section 2.1, isretained on your contact record for as long as reasonably necessary for thepurposes described in section 3, and thereafter in accordance with theparagraphs above.
Whenever youuse our services, we aim to provide you with choices about how we use yourpersonal data. We also aim to provide you with access to your Personal Data. Ifthat information is wrong, we strive to give you ways to update it quickly orto delete it – unless we have to keep that information for legitimate businessor legal purposes. Subject to applicable law, you may obtain a copy of personalinformation we maintain about you or you may update or correct inaccuracies inthat information by contacting us at privacy@collective54.com. To help protectyour privacy and maintain security, we will take steps to verify your identitybefore granting you access to the information. In addition, if you believe thatpersonal information we maintain about you is inaccurate, subject to applicablelaw, you may have the right to request that we correct or amend the informationby contacting us as indicated in the How to Contact Us section below.
Informationobtained about you from third parties. If you believe we hold informationabout you that was obtained through the visitor identification servicesdescribed in section 2.5, you may contact us at privacy@collective54.com torequest access to it, to ask us to correct it, or to ask us to delete it.Because that information originates with the provider rather than with us,deleting it from our records will not remove it from the provider’s owndatabase; you would need to contact the provider directly for that.
Some dataprotection laws, including the European Union’s General Data ProtectionRegulation (“GDPR”), provide you with certain rights in connection withPersonal Data you have shared with us. If you are resident in the EuropeanEconomic Area, you may have the following rights:
1. The right to be informed. You areentitled to be informed of the use of your Personal Data. This Privacy Policyprovides such information to you.
2. The right of access. You have theright to request a copy of your Personal Data which we hold about you.
3. The right of correction: You have theright to request correction or changes of your Personal Data if it is found tobe inaccurate or out of date.
4. The right to be forgotten: You havethe right to request us, at any time, to delete your Personal Data from ourservers and to erase your Personal Data when it is no longer necessary for usto retain such data. Note, however, that deletion of your Personal Data willlikely impact your ability to use our services.
5. The right to object (opt-out): Youhave the right to opt-out of certain uses of your Personal Data, such as directmarketing, at any time.
6. The right to data portability: Youhave the right to a “portable” copy of your Personal Data that you havesubmitted to us. Generally, this means your right to request that we move, copyor transmit your Personal Data stored on our servers / IT environment toanother service provider’s servers / IT environment.
7. The right to refuse to be subjected toautomated decision making, including profiling: You have the right not tobe subject to a decision and insist on human intervention if the decision isbased on automated processing and produces a legal effect or a similarlysignificant effect on you.
8. The right to lodge a complaint with asupervisory authority.
You may alsocontact us using the contact information below to make your request and we willconsider your request in accordance with applicable laws.
You may updateor correct information about yourself by emailing us atprivacy@collective54.com. If you completely delete all such information, thenyour account may become deactivated. We may retain an archived copy of yourrecords as required by law, to comply with our legal obligations, to resolvedisputes, to enforce our agreements or for other legitimate business purposes.
We may contactyou to request that you update your Personal Data on a regular basis to ensureits integrity for the purposes of ongoing data management.
By providing anemail address on the Collective 54 Sites, you agree that we may contact you inthe event of a change in this Privacy Policy, to provide you with any servicerelated notices, or to provide you with information about our events,invitations, or related educational information.
For purposes ofthis Privacy Policy, “opt-in” is generally defined as any affirmative action bya user to submit or receive information, as the case may be. We currentlyprovide the following opt-out opportunities:
1. At any time, you can follow a link providedin offers, newsletters or other email messages (except for e-commerceconfirmation or service notice emails) received from us to unsubscribe from theservice.
2. At any time, you can contact us throughemail at privacy@collective54.com to unsubscribe from the service and opt-outof your consent, under the terms of this Privacy Policy, to share your PersonalData.
3. Browser and device controls. Mostbrowsers allow you to block or delete cookies, and most mobile operatingsystems allow you to limit ad tracking. Blocking cookies may prevent parts ofour Sites from functioning.
4. Provider-level controls. Several ofthe providers described in sections 2.4 and 2.5 offer their own opt-out orsuppression mechanisms, including the advertising platforms, our analyticsprovider, and our visitor identification providers. Those controls are operatedby the providers, not by us, and are available through their respectivewebsites and privacy policies. You may also contact us atprivacy@collective54.com and we will assist where we are able to.
Notwithstandinganything else in this Privacy Policy, please note that we always reserve theright to contact you in the event of a change in this Privacy Policy, or toprovide you with any service related notices.
The Sites maycontain links to webpages operated by parties other than Collective 54. We donot control such websites and are not responsible for their contents or theprivacy policies or other practices of such websites. Our inclusion of links tosuch websites does not imply any endorsement of the material on such websitesor any association with their operators. Further, it is up to the User to takeprecautions to ensure that whatever links the User selects or software the Userdownloads (whether from this Site or other websites) is free of such items asviruses, worms, trojan horses, defects and other items of a destructive nature.These websites and services may have their own privacy policies, which the Userwill be subject to upon linking to the third party’s website. Collective 54strongly recommends that each User review the third party’s terms and policies.
We arecommitted to complying with applicable laws, regulations and mandatorygovernment standards regarding the protection of Personal Data, Personal Dataand any additional information submitted may be used nationally in connectionwith employment, business processes within Collective 54, or communicating withour clients.
In the eventthat we transfer your Personal Data out of your jurisdiction, we will implementsuitable safeguards and may rely on legally-provided mechanisms to lawfullytransfer data across borders to ensure that your Personal Data is protected.
Collective 54maintains administrative, technical and physical safeguards designed to protectthe User’s Personal Data and information against accidental, unlawful orunauthorized destruction, loss, alteration, access, disclosure or use. Weimplement appropriate technical and organizational measures to ensure a levelof security appropriate to the risk, taking into account technological reality,cost, the scope, context and purposes of processing weighted against theseverity and likelihood that the processing could threaten individual rightsand freedoms. For example, we use commercially reasonable security measuressuch as encryption, firewalls, and transport layer security (TLS) or hypertexttransfer protocol secure (HTTPS) to protect Personal Data.
If Collective54 collects account information for payment or credit, Collective 54 will usethe information only to complete the task for which the account information wasoffered.
The Site is notintended for use by children. We do not intentionally gather Personal Dataabout visitors who are under the age of 18. If a child has provided us withPersonal Data, a parent or guardian of that child may contact us to have theinformation deleted from our records. If you believe that we might have anyinformation from a child under age 18, please contact us atprivacy@collective54.com. If we learn that we have inadvertently collected thepersonal information of a child under 18, or equivalent minimum age dependingon jurisdiction, we will take steps to delete the information as soon aspossible.
Your webbrowser may have a “do not track” setting which, when enabled, causes yourbrowser to send a do not track HTTP header file or “signal” to each site youvisit. At present, the Collective 54 website does not respond to this type ofsignal.
Californiaresidents are entitled to contact us to request information about whether wehave disclosed personal information to third parties for the third parties’direct marketing purposes. We do not disclose personal information to thirdparties for the third parties’ direct marketing purposes. California users mayrequest further information about our compliance with this law by e-mailing usat the address listed in the “How to Contact Us” section.
Our PrivacyPolicy may change from time to time. We will not reduce your rights under thisPrivacy Policy without your explicit consent. We will post any privacy policychanges on this page and, if the changes are significant, we will provide amore prominent notice (including, for certain services or programs, emailnotification or privacy policy changes). We will also keep prior versions ofthis Privacy Policy in an archive for your review.
By accessing orusing Collective 54, I agree to be bound by this Code of Conduct which appliesto all members accessing and participating in our community. I acknowledge thatmy access to and use of Collective 54 is conditioned on my acceptance of and compliancewith the Code of Conduct of Collective 54.
View the Codeof Conduct at members.collective54.com/code-of-conduct.
If you have anyspecific questions about this Privacy Policy, you can contact us via email orwriting to us at the address below:
Send an e-mailto: privacy@collective54.com