Effective Date: October 13, 2026

This Privacy Policy explains how CQ Fluency (“we,” “us,” or “our”) collects, uses, discloses, and otherwise processes personal information when you visit www.cqfluency.com or communicate with us through the website. This policy describes our website privacy practices, not the handling of information under a separate client services agreement.

Please read this Privacy Policy carefully to understand our website privacy practices. This policy provides information about how we process personal information; it does not itself obtain your consent. Where consent is required by applicable law, it must be obtained separately for the relevant processing. You may contact us about this policy at compliance@cqfluency.com.

What information do we collect about you?

We collect personal information that you provide through the website, including the categories listed below. Please do not include sensitive personal information in website messages.

The personal information you may provide includes:

• Email address
• Name
• Information included in your messages

How do we collect such information?

We may use any of the following three ways to get information about you.

1. The information that you give us
2. The information that we automatically collect from you
3. Information that we collect from third parties

Before going into the reasons why we collect the information that we do, we want you to understand what the above three terms mean.

a. The information that you give us

When you communicate with us through the website, you provide personal information such as your name, email address, and the information included in your messages.

b. The information that we automatically collect from you

When you visit the website, we may automatically collect information from your device through cookies and similar technologies. Our Cookie Policy provides further information about these technologies and your choices.

c. Information that we collect from third parties

We may obtain personal information about you from third-party sources, including data aggregators, online directories, and data marketplaces or exchanges.

Cookies and similar technologies

Cookies are small files placed on your device that can store information about your interactions with a website and your preferences. Cookies and similar technologies may collect personal information.

For more information about cookies and similar technologies, please visit our cookie policy.

Do not track requests

We respond to “do not track” requests in the following manner:

CQ Fluency honors Do Not Track (DNT) browser signals and does not use non-essential tracking cookies when these signals are enabled. Visitors can also manage their cookie preferences through our cookie consent tool.

DNT is distinct from Global Privacy Control (GPC) and other legally recognized opt-out preference signals. Where applicable law requires recognition of an opt-out preference signal, that signal must be treated as a request to opt out of the covered processing.

Why do we collect information about you?

We use the personal information described in this policy for the following purposes:

• To send marketing and promotional communications
• To contact you and respond to your messages

You may opt out of marketing and promotional communications by contacting compliance@cqfluency.com. Where we process your personal information for direct marketing, you may object to that processing at any time.

How long do we retain your information?

We retain your personal information for 12 months, unless a longer retention period is required or permitted by law, such as for tax, accounting, or other legal requirements.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Do we share your information?

We may share your information with third parties in the following ways:

1. Sharing with your consent: When you give consent, we may share your information with third parties for the purposes that are mentioned in the consent notification.
2. Legal Obligations: We may disclose information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
3. For business transfers: We may share your personal information in connection with, or during the course of negotiations regarding merger, sale of business assets, financing or acquisition of all or a part of our business by another entity.

Sale/sharing of information

We do not sell personal information or share personal information for cross-context behavioral advertising, as those terms are defined under applicable California privacy law. This statement does not prevent the disclosures described in the preceding section.

U.S. state privacy rights

California residents. Where the California Consumer Privacy Act applies, you may, subject to applicable exceptions, request access to specific pieces of personal information and information about the categories collected, their sources, the purposes of collection, and disclosures; request correction of inaccurate information; and request deletion. You may also have rights to opt out of sale or sharing and to limit certain uses and disclosures of sensitive personal information. We will not unlawfully discriminate against you for exercising these rights.

Other U.S. residents, including New Jersey residents. Depending on your residence and the applicability of state law, you may have rights to confirm whether we process your personal information; access it and obtain a portable copy; correct inaccuracies; delete it; and opt out of sale, targeted advertising, or profiling in furtherance of decisions producing legal or similarly significant effects. These rights are subject to applicable conditions and exceptions.

Submitting requests. Contact compliance@cqfluency.com to exercise an applicable right. We may request information reasonably necessary to verify your identity and, where applicable, an authorized agent’s authority, as permitted by law. You do not need to create an account to submit a request. We will respond within the period required by applicable law and explain any applicable extension or denial. Where an appeal right applies, you may appeal a denied request by emailing compliance@cqfluency.com with the subject “Privacy Request Appeal.” If an appeal is denied, we will provide information about further complaint options required by applicable law.

GDPR Disclosures

Automatic processing of data

We use automated processing of personal information to personalize our website services. Automated personalization is not necessarily automated decision-making that produces legal or similarly significant effects. Where applicable, the rights and safeguards relating to such significant decisions are described below.

Legal basis for the collection

Where the General Data Protection Regulation applies, processing must have an applicable lawful basis. The legal basis identified for the processing described in this policy is:

Consent: Where we rely on your consent to process personal information, you may withdraw that consent at any time by contacting compliance@cqfluency.com. You may also manage cookie preferences through our cookie consent tool. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

Your rights

Where the General Data Protection Regulation applies to our processing of your personal information, you have the following rights, subject to the conditions and exceptions established by that Regulation:

1. Right to object to the processing of personal data in certain circumstances. See here for details.
2. Right to request access to the data we have collected about you and to receive a copy of it in an accessible format.
3. Right to restrict the processing of your personal data for a limited period, under certain circumstances. See here for details.
4. Right to rectify or modify personal information that you consider obsolete, incomplete, or inaccurate.
5. Right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you, subject to the exceptions and safeguards in Article 22 of the General Data Protection Regulation.
6. Right to erasure of your personal information, also known as the right to be forgotten.

You may also have the right to receive personal information you provided to us in a structured, commonly used, machine-readable format and transmit it to another controller, subject to Article 20. To exercise your rights, contact compliance@cqfluency.com. You may lodge a complaint with a competent supervisory authority, including in the country of your habitual residence, place of work, or the alleged infringement.

Consequences of non-consent

Where processing depends on your consent, you may refuse or withdraw that consent. Any resulting limitation relates to the feature or activity that requires the relevant processing; refusing optional processing does not by itself prevent access to unrelated website features.

Privacy of children

Our website is not directed to children under 16, and we do not knowingly collect personal information from children under 16 through the website. If you are a parent or legal guardian and believe your child has provided personal information through the website, contact compliance@cqfluency.com. If we determine that personal information was collected in violation of applicable children’s privacy law, we will delete it.

Security of your personal information

We use commercially reasonable and appropriate security measures to protect the personal information we collect, including during storage. However, no method of internet transmission or digital storage is completely secure, and we cannot guarantee absolute security.

Links to other websites or apps

On our website, we may provide links to external websites, apps, or services. These are not operated by us and therefore are not governed by our Privacy Policy or practices. We strongly recommend that you review the privacy policies of such websites or services before engaging with them to ensure that you do not provide personal information that you do not wish to share.

Changes to this privacy policy

We may update this Privacy Policy to reflect changes in the law or our privacy practices. We will post the revised policy on this page and update its effective date. Where applicable law requires additional notice of a material change or consent to new processing, we will provide that notice or obtain consent before implementing the relevant change. Please review this policy periodically to stay informed.

This Privacy Policy takes effect on the effective date shown at the beginning of this policy.

Contact us

For any questions or concerns regarding your privacy, or to exercise any of your rights, you may contact us using the following details:

Privacy contact: CQ Fluency; telephone: +1 (201) 487-8007. Use the address or email below for privacy inquiries and requests.

Address: CQ Fluency, 2 University Plaza Drive, Hackensack, NJ 07601, United States

Email address: compliance@cqfluency.com