1. Data Controller
Fettinger Digital (operated by Jonathan D. Fettinger)
314 Van Rensselaer St #5
Syracuse, NY 13204-2240
United States
Email: [email protected]
Phone: +1 (315) 926-4073
2. Information We Collect
2.1 Information You Provide Directly
- Contact Information: Name, email address, phone number when you submit forms or contact us.
- Business Details: Website URL, ad spend, business goals, industry, campaign details shared via forms or communications.
- Communication Records: Emails, call notes, messages, and other correspondence.
- Account Access: Google Ads, Analytics, and Tag Manager access credentials you provide for campaign management (handled securely per Google's partner requirements).
2.2 Information Collected Automatically
- Device Information: Browser type, operating system, device type, screen resolution.
- Usage Data: Pages visited, time on pages, click patterns, referring URLs, navigation paths.
- Network Data: IP address, approximate geographic location (city/region), ISP.
- Cookie Data: As described in our Cookie Policy.
3. Legal Bases for Processing (GDPR)
| Processing Activity | Legal Basis |
|---|
| Responding to audit requests and contact forms | Pre-contractual measures (Art. 6(1)(b)) |
| Managing ad campaigns and client accounts | Performance of a contract (Art. 6(1)(b)) |
| Sending project updates and reports | Legitimate interest (Art. 6(1)(f)) |
| Website analytics and performance monitoring | Consent (Art. 6(1)(a)) |
| Marketing communications | Consent (Art. 6(1)(a)) |
| Legal compliance and dispute resolution | Legal obligation (Art. 6(1)(c)) |
4. Purpose of Processing
- Service Delivery: To perform PPC audits, build and manage Google Ads campaigns, and deliver reports.
- Communication: To respond to inquiries, send campaign updates, and maintain business relationships.
- Website Improvement: To analyze site usage and optimize content and user experience.
- Legal Compliance: To comply with applicable federal, state, and international laws.
- Security: To detect, prevent, and address fraud, security incidents, and technical issues.
- Marketing: To send promotional materials — only with your explicit consent.
5. Data Retention
Data is retained only as long as necessary for stated purposes or required by law.
| Data Category | Retention Period |
|---|
| Contact form / audit requests | 24 months from last communication |
| Client campaign and account data | Duration of contract + 5 years |
| Communication records | 3 years from last communication |
| Invoices and financial records | 7 years (IRS requirements) |
| Website analytics | 26 months (anonymized after 14 months) |
| Marketing consent records | Duration of consent + 3 years |
6. International Data Transfers
Data is primarily stored and processed in the United States. For transfers outside the US to countries without adequate protection (or if you are located in the EEA), we implement:
- Standard Contractual Clauses (SCCs)
- Data Processing Agreements with all third-party processors
- Adequacy Decisions where applicable
7. Third-Party Sharing
We do not sell personal data. We do not share data for advertising purposes.
We may share data with:
- Service Providers: Hosting, email platforms, CRM, analytics (Google LLC, etc.).
- Google: As required for managing your Google Ads account under Google's Partner terms.
- Professional Advisors: Attorneys and accountants where necessary.
- Legal Authorities: When required by law or governmental request.
8. Your Rights Under GDPR
If you are in the EEA, UK, or Switzerland:
- Right of Access (Art. 15): Obtain confirmation of processing and a copy of your data.
- Right to Rectification (Art. 16): Request correction of inaccurate data.
- Right to Erasure (Art. 17): Request deletion when data is no longer necessary.
- Right to Restriction (Art. 18): Request restriction of processing.
- Right to Data Portability (Art. 20): Receive data in structured, machine-readable format.
- Right to Object (Art. 21): Object to processing based on legitimate interests.
- Right to Withdraw Consent (Art. 7(3)): Withdraw at any time without affecting prior processing.
- Right to Lodge a Complaint (Art. 77): Lodge a complaint with a supervisory authority.
9. Your Rights Under CCPA
California residents have the right to:
- Know: Request disclosure of categories and specific data collected.
- Delete: Request deletion, subject to exceptions.
- Opt-Out: We do not sell personal data.
- Non-Discrimination: No penalty for exercising rights.
- Correct: Request correction of inaccurate data.
- Limit Sensitive Data Use.
10. Data Security
- Encryption in transit (TLS/SSL) and at rest (AES-256)
- Regular security assessments
- Access controls and role-based permissions
- Two-factor authentication for all account access
- Incident response and breach notification protocols
- Secure backup and disaster recovery
Disclaimer: No method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security but commit to prompt notification of affected individuals and authorities in the event of a breach.
11. Children's Privacy
Our services are not directed at individuals under 16. We do not knowingly collect data from children.
12. Changes
We may update this Policy periodically. Material changes will be posted with an updated date.
13. Contact
Fettinger Digital
314 Van Rensselaer St #5, Syracuse, NY 13204
Email: [email protected]
Phone: +1 (315) 926-4073