Legal

Privacy Policy

Effective date: [to be set at publication]

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.

SourcePersonal data collectedPurposeLawful basis (EU/UK GDPR)
Advisory introduction formName; email; your free-text description of who you are and why you believe you belongTo review your private introduction and decide whether to begin a conversation; held in confidenceConsent — Art. 6(1)(a)
Perspectives newsletter signupEmail (and name, if provided)To send you the Perspectives newsletter and related updatesConsent — Art. 6(1)(a)
Server logs (hosting)IP address, browser type, timestampsSecurity, site operation, abuse preventionLegitimate interests — Art. 6(1)(f)

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

Form submissions are delivered by a script on our hosting platform to our email 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. (newsletter delivery, if you subscribe; Substack's own privacy terms also 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. Newsletter data is retained until you unsubscribe, after which we keep a minimal suppression record so we do not email you again. 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. EU/UK representative

Where required under GDPR Art. 27 / UK GDPR, our EU and UK representatives will be named here. If the occasional-processing exemption applies, this section may be omitted. [pending counsel determination]

12. Contact

Questions or requests: info@borisblum.com, or Private Client Solutions, LLC, PO Box 777262, Henderson, NV 89077.

Draft for review. Not yet published; pending licensed-attorney review and the items marked [pending].