1. Introduction and scope
This Privacy Policy (hereinafter referred to as the "Policy") describes how Drew Golub, an individual (hereinafter referred to as "Drew Golub," "we," "us," or "our"), collects, uses, discloses, retains, and protects Personal Information obtained through the website located at drewgolub.com and any page, form, or email communication that links to this Policy (collectively, the "Site").
This Policy applies only to information collected through the Site. It does not apply to information that Drew Golub receives or processes on behalf of, or in the course of his work for, Pinnacle Ethos, LLC, YEC, or any other organization, which is governed by that organization's own policies and agreements. The Site is intended for use by adults.
By using the Site or submitting information through it, you acknowledge that you have read and understood this Policy. Use of the Site is also governed by our Terms of Use.
2. Definitions
For purposes of this Policy: (a) "Personal Information" means information that identifies, relates to, or could reasonably be linked with an identified or identifiable individual; (b) "Service Provider" means a person that processes Personal Information on our behalf and under our instructions; and (c) the words "include," "includes," and "including" mean include, includes, and including "without limitation."
3. Personal Information we collect
3.1 Information you provide
- Contact form. Your name, your email address, and the free-text message you submit.
- Email list. Your email address, if you sign up to receive email updates.
3.2 Information collected automatically
- Form context. Which form you used (the contact form or the email list signup).
- Technical and security information. As with any website, our hosting and security Service Provider receives your Internet Protocol (IP) address, browser user-agent, and related request metadata, such as the date and time of a request, the page requested, and the referring page, and processes that information to host, deliver, and secure the Site and to detect automated abuse. Where Cloudflare Turnstile is enabled, Cloudflare also processes signals, including a TLS fingerprint, to distinguish human visitors from bots. Turnstile loads only when you begin to use a form on the Site and runs when you submit it; it is not loaded when you merely view a page. Form submissions are received first by the Site's own server-side functions, which forward only the information you enter in the form to our customer relationship management provider; your IP address and browser information are not forwarded to that provider.
- Browser storage. The Site may store a non-identifying display preference, such as a light or dark theme setting, in your browser's local storage. Any such value remains on your device and is not transmitted to us.
3.3 Information we do not collect
The Site does not collect payment card information, government identification numbers, precise geolocation, or telephone numbers, and we do not knowingly collect sensitive personal information through the Site.
4. How we use Personal Information
We use Personal Information to: (a) read and respond to inquiries and other messages you send; (b) send email updates to those who have subscribed; (c) protect the Site and its forms against automated abuse, fraud, and security threats; (d) maintain records of our correspondence; and (e) comply with applicable law, enforce our Terms of Use, and establish, exercise, or defend legal claims.
5. Legal bases for processing
To the extent the laws of the European Economic Area, the United Kingdom, or Switzerland apply, we process Personal Information on the following bases: our legitimate interests in responding to messages sent to us (subsection 4(a)); your consent (subsection 4(b)), which you may withdraw at any time; and our legitimate interests in securing and operating the Site and in maintaining records and protecting our legal rights (subsections 4(c) through 4(e)).
6. How we disclose Personal Information
We disclose Personal Information only as follows:
- Service Providers. HighLevel, Inc. and its affiliate LeadConnector LLC, which receive form submissions and provide our customer relationship management and email services and act as our processor (see HighLevel's Privacy Policy); and Cloudflare, Inc., which hosts the Site and provides security and, where enabled, bot detection (Cloudflare Turnstile) (see Cloudflare's Privacy Policy and Turnstile Privacy Addendum). Cloudflare has stated that it also uses certain Turnstile signals, as an independent controller, to improve its bot detection.
- Legal and protective disclosures. When we believe in good faith that disclosure is required by law, subpoena, or other legal process, or is necessary to protect the rights, property, or safety of Drew Golub, users of the Site, or others.
- Transfer of the Site. In connection with a sale, assignment, or other transfer of the Site or its operation, subject to this Policy.
- With your direction or consent.
7. No sale; no targeted advertising
We do not sell Personal Information, do not share Personal Information for cross-context behavioral or targeted advertising, and do not use advertising cookies or advertising pixels on the Site.
8. Cookies and similar technologies
The Site does not use analytics, advertising, marketing, or cross-site tracking cookies. Cloudflare may set cookies that are strictly necessary for security and bot detection. As described in subsection 3.2(c), the Site may store a non-identifying display preference in your browser's local storage. The Site's fonts are served from the Site itself and not from a third-party font service.
9. Do Not Track and cross-site tracking
Some browsers transmit "Do Not Track" or Global Privacy Control signals. Because the Site does not track visitors across third-party websites over time and does not engage in targeted advertising, the Site's practices are the same whether or not such a signal is present. We do not permit third parties to collect Personal Information about your online activities over time and across different websites through the Site.
10. Email communications
We send email updates only to persons who subscribe. Each such email includes an unsubscribe mechanism and our postal address, and opt-out requests are honored within ten (10) business days. If you submit the contact form, you may also receive replies relating to your inquiry; unsubscribing from email updates does not stop those messages.
11. Retention
We retain contact form submissions for as long as reasonably necessary to respond to you and maintain records of our correspondence, and in any event no longer than three (3) years after our last communication with you, unless a longer period is required or permitted by law or you request earlier deletion under Section 13. Email list addresses are retained until you unsubscribe, after which the address is retained only on a suppression list to honor your opt-out. Security data held by Cloudflare is retained in accordance with Cloudflare's policies.
12. Security
We maintain reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, alteration, and destruction, including encrypted transmission of Site traffic and access controls on the systems that store Personal Information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a breach of the security of a system that requires notice under applicable law, including Ohio Revised Code Section 1349.19, we will provide notice as required.
13. Your choices and requests
Regardless of where you reside, you may request to access, correct, or delete Personal Information we hold about you, or to withdraw consent to email updates, by submitting a request through the contact form at https://drewgolub.com/contact or by writing to the address in Section 19. We may take reasonable steps to verify your identity before acting on a request and will respond within a reasonable time and in any event within the period required by applicable law. We may retain information where retention is required by law or necessary to establish, exercise, or defend legal claims.
14. State privacy rights
Certain state laws grant residents rights with respect to their personal information, including rights to know, access, correct, delete, and obtain a copy of personal information, and to opt out of its sale, targeted advertising, or profiling. We do not sell personal information or engage in targeted advertising or profiling. Whether or not such a law applies to us, we will honor requests described in Section 13 and will not discriminate against you for making one. If a request is denied, you may appeal by replying to our response, and we will respond to the appeal in writing.
15. International visitors
Drew Golub is located in the State of Ohio, United States, and the Site is operated from the United States and is not directed to persons in the European Economic Area, the United Kingdom, or Switzerland. Personal Information submitted through the Site is processed and stored in the United States, where data protection laws may differ from those of your jurisdiction. HighLevel states that it relies on the EU-U.S. Data Privacy Framework, its UK and Swiss extensions, and standard contractual clauses for international transfers.
16. Children
The Site is intended for adults and is not directed to children. We do not knowingly collect Personal Information from children under sixteen (16) years of age. If we learn that we have collected Personal Information from a child under thirteen (13) years of age, we will delete that information promptly.
17. No attorney-client relationship; confidential information
Although Drew Golub is a licensed attorney, the Site does not offer legal services, and Drew Golub does not provide legal services through the Site. Submitting information through the Site, subscribing to email updates, or otherwise communicating with Drew Golub through the Site does not create an attorney-client relationship, and the protections of such a relationship, including the attorney-client privilege, do not apply. Do not submit confidential, privileged, or sensitive information through the Site.
18. Changes to this Privacy Policy
We may amend this Policy from time to time. The amended Policy will be posted on the Site with a revised effective date. If an amendment materially changes how we use Personal Information previously collected, we will provide notice on the Site and, for email list subscribers, by email before the change takes effect.
19. Contact
Questions and requests regarding this Policy may be submitted through the contact form at https://drewgolub.com/contact or directed by mail to:
Drew Golub
Attention: Privacy
5195 Hampsted Village Center Way #761
New Albany, OH 43054