Privacy Policy

Last Updated: May 2026

1. Introduction

Project I.C.O.N, LLC ("Project ICON," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains what we collect, why we collect it, how we use and share it, and the rights you have over your information.

This policy applies to our website [insert website URL] and the services we provide. It is a privacy policy and is separate from any Terms of Service or Terms and Conditions governing use of our services.

By using our website or services, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

We collect personal information that you provide directly, information collected automatically as you use our site, and information we receive from third parties.

Information you provide:

- Personal identifiers: name, email address, phone number, and mailing address.

- Payment information: credit or debit card details and other financial information needed to process payments (typically handled by our payment processors, not stored by us).

- Professional information: company name, job title, and industry.

- Financial prequalification data: where you apply for financing or prequalification, information such as income and credit-related data (see Section 6).

Information collected automatically:

- Device and usage data, IP address, browser type, pages visited, and similar analytics data collected through cookies and comparable technologies. [Confirm what your site actually collects.]

Information from third parties:

- Data from payment processors, financing partners, and credit reporting agencies used for prequalification. [List these partners; see Section 7.]

3. How We Use Your Information

We use the information we collect to:


- Provide, operate, and maintain our services.

- Process transactions and send purchase confirmations, invoices, and related information.

- Communicate with you, including responding to inquiries and, where permitted, sending promotional materials.

- Prequalify applicants for financial products, including through soft credit checks (see Section 6).

- Improve our website, services, and customer experience.

- Comply with legal obligations and enforce our agreements.


Applicable to FTC, GDPR, CCPA, and FCRA.

4. Legal Bases for Processing (GDPR)

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

- Consent — where you have given clear consent (for example, marketing emails).

- Performance of a contract — to deliver the services you have requested.

- Legal obligation — where processing is required by law.

- Legitimate interests — to operate and improve our business, provided your rights do not override those interests.

- Vital interests / public task — where applicable.

You may withdraw consent at any time where consent is the legal basis (see Section 11).

Specific to GDPR.

5. Data Security

We use administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. For consumer credit data, we apply security controls consistent with FCRA standards during transmission and storage.

No method of transmission over the Internet or electronic storage is fully secure, so we cannot guarantee absolute security.


Applicable to FTC, GDPR, CCPA, and FCRA.

6. Prequalification and Financial Data (FCRA)

Where you apply for financing or prequalification through our site, we collect and process financial data such as credit information and, where relevant, income.

We conduct soft credit checks (pre-screening) solely for legitimate business purposes in compliance with the Fair Credit Reporting Act (FCRA). Soft credit checks used for prequalification do not affect your credit score.


We share the information needed to complete prequalification with the credit reporting agencies and financing partners identified in Section 7, each of which is expected to handle your data in accordance with FCRA requirements.

You have the right to dispute inaccuracies in your credit information and to request access to your credit report (see Sections 9 and 12).

Specific to FCRA.

7. How We Share and Disclose Information

We do not sell your personal information. We share it only as described below:


- Service providers: third-party vendors who help operate our website, run our business, or serve you (for example, payment processors, financing partners, CRM, email, and analytics providers), under obligations of confidentiality. [Identify your key vendors here, e.g., payment/BNPL providers, CRM, email platform.]

- Financing and credit partners (FCRA): credit reporting agencies and financing partners used for prequalification. [Name the specific bureaus and BNPL/financing partners, e.g., ClarityPay, Splitit, Klarna — confirm the full list.] These partners are expected to adhere to FCRA guidelines.

- Legal and safety: where required by law, subpoena, or to protect our rights, users, or the public.

California residents (CCPA): [If you do not sell personal information, state that plainly. If you do sell or "share" it as defined by the CCPA, you must include a "Do Not Sell or Share My Personal Information" link here and honor opt-out requests.]

Applicable to FTC, GDPR, CCPA, and FCRA.

8. Data Retention

We retain personal information only as long as necessary for the purposes described in this policy, or as required to meet legal, accounting, or reporting obligations. When data is no longer needed, we securely delete or anonymize it.

Financial and credit-related data is retained only as long as necessary for the prequalification or transaction purpose for which it was collected, then securely disposed of. [State your actual retention periods or the criteria you use.]

Specific to GDPR, CCPA, and FCRA.

9. Your Privacy Rights

If you are in the EEA or UK (GDPR), you have the right to:

- Access the personal data we hold about you.

- Request correction (rectification) of inaccurate data.

- Request erasure of your data.

- Restrict or object to processing.

- Data portability.

- Withdraw consent at any time.

If you are a California resident (CCPA), you have the right to:

- Know what personal information we collect and how we use it.

- Request deletion of your personal information.

- Opt out of the sale or sharing of your personal information.

- Non-discrimination for exercising your privacy rights.

Under the FCRA, you have the right to:

- Dispute inaccuracies in your credit information.

- Request access to your credit report.

To exercise any of these rights, contact us using the details in Section 12. We will respond within the timeframes required by applicable law.


Specific to GDPR, CCPA, and FCRA.

10. Your Choices

You can limit the collection or use of your personal information by contacting us directly. You can opt out of promotional emails at any time by following the unsubscribe instructions in each message. Opting out of promotional messages does not stop transactional messages such as invoices or service notices.

11. International Data Transfers (GDPR)

If we transfer personal data outside the EEA or UK, we use appropriate safeguards such as Standard Contractual Clauses or transfers to countries covered by an adequacy decision. [Confirm whether you transfer data internationally and which safeguards apply.]

Specific to GDPR.

12. Third-Party Links

Our website may contain links to third-party sites. We are not responsible for the privacy practices or content of those sites. Review their privacy policies before providing personal information.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will post any changes on this page with a revised "Last Updated" date and, where required by law, provide additional notice. Your continued use of our services after changes take effect constitutes acceptance of the updated policy.


Applicable to FTC, GDPR, and CCPA.

14. Contact Us

For questions about this Privacy Policy, to exercise your privacy rights, or to dispute credit information under the FCRA, contact us at:

Project I.C.O.N, LLC [Mailing address] Email: [email protected]

For FCRA disputes, include the specific information you believe is inaccurate. For GDPR or CCPA requests, tell us which right you are exercising and provide enough detail for us to verify your identity.

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