This Privacy Policy explains how Private Client Solutions, LLC ("we," "us," or "our") collects, uses, and protects personal information when you visit borisblum.com (the "Site") or submit information through it. We are committed to handling your information responsibly and transparently.
1. Who we are (Data Controller)
The data controller responsible for your personal information is:
Private Client Solutions, LLC
PO Box 777262, Henderson, NV 89077
Email: info@borisblum.com
2. What we collect and why
We collect only the information you choose to give us through our forms. We do not run advertising networks or third-party tracking on the Site.
| Source | Personal data collected | Purpose | Lawful basis (EU/UK GDPR) |
|---|---|---|---|
| Advisory introduction form | Name; email; your free-text description of who you are and what brings you here; your consent; and the date, time, and IP address of the submission | To review your private introduction and decide whether to begin a conversation; held in confidence | Consent — Art. 6(1)(a) |
| Server logs (hosting) | IP address, browser type, timestamps | Security, site operation, abuse prevention | Legitimate interests — Art. 6(1)(f) |
Newsletters. We do not collect newsletter sign-ups on this Site. Boris’s publications, Perspectives and The Human Edge, are subscribed to directly on Substack, which processes your subscription under its own privacy policy.
We do not sell, rent, or share your personal information with third parties for their own marketing.
3. How your information is handled and who processes it
Advisory form submissions are stored securely on our hosting platform, outside the public website, and delivered to our inbox. We use the following service providers ("processors"), who act on our instructions: StackCP / ClientCP (website hosting and form-to-email delivery), StackMail (email handling), and Substack, Inc. (our newsletters, if you subscribe there; Substack's own privacy terms apply).
4. International data transfers
We are based in the United States, and some of our service providers (including our host and Substack) are located in the United States. When we transfer personal data from the EEA or UK to the United States, we rely on appropriate safeguards, which may include Standard Contractual Clauses, the EU-U.S. Data Privacy Framework where a provider is certified, and/or your explicit consent for the specific transfer. You may request a copy of the relevant safeguards by contacting us at info@borisblum.com.
5. How long we keep your information
Advisory introductions are retained for up to 24 months after our last contact, then deleted, unless an ongoing relationship requires otherwise. Server logs are retained for the period set by our hosting provider.
6. Your rights
EEA/UK individuals (GDPR / UK GDPR): You have the right to access, correct, delete, restrict, or object to processing of your personal data; the right to data portability; and the right to withdraw consent at any time. You also have the right to lodge a complaint with your supervisory authority (in the UK, the Information Commissioner's Office; in the EU, your national data-protection authority).
California residents (CCPA/CPRA): Although we believe we are not a "business" subject to the CCPA, as a courtesy California residents may request to know what personal information we hold, request its deletion, and correct it. We do not "sell" or "share" your personal information as those terms are defined under California law, and we do not use it for cross-context behavioral advertising. We will not discriminate against you for exercising these rights.
To exercise any right, email info@borisblum.com. We will verify your request and respond within the timeframe required by applicable law.
7. Cookies and tracking
We do not use advertising or analytics tracking cookies. The Site uses only strictly necessary technical functionality. We self-host our fonts and serve our own images, so visiting the Site does not transmit your data to third-party content networks. See our Cookie Notice. If we add analytics in the future, we will update this Policy and obtain consent where required.
8. Children
The Site is intended for business professionals and is not directed to children under 16 (under 13 in the United States). We do not knowingly collect personal information from children.
9. Security
We use reasonable technical and organizational measures (including HTTPS/TLS encryption in transit) to protect your information. No method of transmission over the internet is 100% secure.
10. Changes to this Policy
We may update this Policy from time to time. The "Effective date" above shows the latest version. Material changes will be posted on this page.
11. Visitors in the EEA and UK
If you are in the European Economic Area or the United Kingdom, you may contact us directly at info@borisblum.com about any matter concerning your personal data, and we will respond within the time required by law.
12. Contact
Questions or requests: info@borisblum.com, or Private Client Solutions, LLC, PO Box 777262, Henderson, NV 89077.