This Privacy Policy ("Policy") describes how Romero NYC Marketing Agency LLC ("Romero NYC," "we," "us," or "our") collects, uses, discloses, and protects your personal information when you visit romero.nyc, use our web applications, Free Tools, or engage with any of our services. This Policy is incorporated by reference into our Terms of Service.
Information We Collect
1.1 Information You Provide Directly
We collect personal information you voluntarily provide when you complete a form, subscribe to our email list, use a Free Tool, purchase a service, or communicate with us. Categories include:
- Identifiers: First name, last name, business email address, phone number (if provided)
- Professional information: Job title, company name, industry, company size
- Commercial information: Service inquiries, purchase history, billing information
- Communications: Messages, questions, and feedback you submit
1.2 Information Collected Automatically
When you visit our website or use our tools, we and our third-party partners automatically collect:
- Device and browser data: IP address, browser type and version, operating system, device type
- Usage data: Pages visited, time spent per page, scroll depth, click-through rates, session duration, content engagement metrics
- Referral data: The URL or platform that directed you to our website
- Cookie and tracking data: As described in Section 5
- Pixel data: Conversion events and behavioral signals captured by Google Ads and LinkedIn Insight Tag pixels
1.3 Information from Third Parties
We may receive data from advertising platforms (Google, LinkedIn) providing audience insights, data enrichment services that supplement contact records with professional information, and analytics providers aggregating behavioral data across sessions.
1.4 Sensitive Data
Romero NYC does not intentionally collect sensitive personal information such as government ID numbers, health data, racial or ethnic origin, or financial account numbers. Please do not submit such information through our forms or tools.
How We Collect Your Information
2.1 Forms and Direct Submissions
Collected when you actively complete and submit a form, including contact forms, newsletter sign-ups, tool interfaces, and service inquiry forms.
2.2 Cookies and Tracking Technologies
We use cookies, web beacons, pixel tags, and local storage. See Section 5 for full details.
2.3 Google Analytics
We use Google Analytics to collect behavioral data about how visitors interact with our website, including session data, page views, and engagement metrics.
2.4 Advertising Pixels
Our website deploys advertising pixels operated by Google and LinkedIn. These pixels collect visit data and may serve you retargeted advertisements on those platforms. Each platform's privacy policy applies in addition to ours.
2.5 HubSpot CRM Integration
We use HubSpot as our CRM platform. When you submit a form on our website, your information is transmitted to and stored in HubSpot. HubSpot may also track your interactions with our emails and website using its own tracking technology. See: HubSpot Privacy Policy.
2.6 Automatic Server Logs
Our web hosting infrastructure automatically records IP addresses, request timestamps, requested URLs, HTTP status codes, and referrer information for security and diagnostics.
How We Use Your Information
| Purpose | Data Used | Legal Basis (GDPR) | Applies To |
|---|---|---|---|
| Delivering contracted services | Name, email, company, billing | Performance of contract | Service clients |
| Responding to inquiries | Name, email, message content | Legitimate interests | Form submitters |
| Email marketing (our services) | Email, name, engagement data | Consent / Legitimate interests | Subscribers & leads |
| Outreach for future products | Email, job title, company | Consent / Legitimate interests | Tool users, leads |
| Affiliate marketing | Email, behavioral data | Consent | Website visitors |
| Advertising & retargeting | IP, cookies, pixel data | Consent | Website visitors |
| Analytics & performance | Usage data, click data | Legitimate interests | All visitors |
| CRM & lead management | All contact data | Legitimate interests | Leads & clients |
| Legal compliance | Any relevant data | Legal obligation | As required |
| Security & fraud prevention | IP, device, usage logs | Legitimate interests | All visitors |
3.1 Marketing and Outreach — Important Disclosure
By submitting any form, using any Free Tool, or otherwise providing your contact information, you expressly consent to Romero NYC using your information to:
- Send commercial email communications about our outbound marketing services
- Contact you regarding consulting, advisory, or retainer services
- Reach out about digital products, templates, courses, or other resources we develop
- Enroll you in marketing sequences managed through HubSpot or similar platforms
You may opt out of marketing communications at any time as described in Section 8.
How We Share Your Information
4.1 Service Providers
| Provider | Category | Data Shared | Purpose |
|---|---|---|---|
| HubSpot | CRM / Marketing | Name, email, company, activity | Contact management & email |
| Google Analytics | Analytics | IP (anonymized), behavior, device | Website performance |
| Google Ads | Advertising | Pixel/cookie data, conversions | Ad targeting & measurement |
| LinkedIn Insight Tag | Advertising | Pixel/cookie data, page visits | B2B ad targeting |
| Web hosting provider | Infrastructure | Server logs, IP addresses | Hosting & security |
| Email delivery (ESP) | Communications | Email address, name | Sending emails |
| Payment processor | Payments | Billing info (not stored by us) | Processing transactions |
4.2 No Sale of Personal Data — CCPA Disclosure
4.3 Business Transfers
In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity. You will be notified if the transfer results in a materially different privacy policy.
4.4 Legal Requirements
We may disclose personal data if required by law, subpoena, or court order, or if necessary to protect the rights, property, or safety of Romero NYC, our clients, or the public.
Cookie Policy
5.1 What Are Cookies?
Cookies are small text files placed on your device by a website. They allow the website to recognize your device, remember your preferences, and collect usage data across sessions. We also use web beacons, local storage, and session identifiers.
5.2 Cookies We Use
| Cookie Type | Provider | Purpose | Duration |
|---|---|---|---|
| Strictly Necessary | Romero NYC / Hosting | Site functionality, security, load balancing | Session |
| Analytics | Google Analytics | Traffic measurement, behavior tracking | Up to 2 years |
| Performance | HubSpot | Page visit tracking, email link tracking | Up to 13 months |
| Advertising | Google Ads | Conversion tracking, retargeting | Up to 90 days |
| Advertising | LinkedIn Insight Tag | B2B audience targeting, retargeting | Up to 90 days |
| Preferences | Romero NYC | Cookie consent state, preferences | Up to 1 year |
5.3 Your Cookie Choices
- Cookie consent banner: Upon first visit, you will be presented with options to accept or decline non-essential cookies
- Browser settings: Most browsers allow you to block or delete cookies in their settings
- Google Analytics opt-out: Install the Google Analytics Opt-Out Add-On
- LinkedIn opt-out: Manage LinkedIn ad preferences
- Google Ads opt-out: Manage Google ad personalization
- Do Not Track: We honor browser-level DNT signals where technically feasible
Data Retention
We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.
| Data Category | Retention Period | Deletion Trigger |
|---|---|---|
| Active client records | Duration of relationship + 3 years | Contract end + 3 years |
| Lead and prospect data (CRM) | Up to 3 years from last contact | Opt-out or 3-year inactivity |
| Email marketing engagement | Duration of subscription | Unsubscribe or deletion request |
| Form submission data | Up to 3 years | Opt-out or deletion request |
| Website analytics data | 26 months (Google default) | Rolling deletion per GA settings |
| Server / access logs | 90 days | Automated rolling deletion |
| Cookie / pixel data | Per cookie lifespan (see §5.2) | Browser deletion or opt-out |
| Billing and payment records | 7 years | Required by tax/financial law |
| Legal correspondence | 7 years | Legal hold expiration |
Following the applicable retention period, we will securely delete or anonymize your personal data. Anonymized data may be retained indefinitely for analytical purposes.
Your Privacy Rights
7.1 Rights Available to All Users
7.2 Additional Rights — California Residents (CCPA/CPRA)
7.3 Additional Rights — EEA, UK & Swiss Residents (GDPR)
If you are located in the EEA or UK, you also have the right to lodge a complaint with your local data protection authority: Find your EU authority | UK ICO.
International Transfers: Romero NYC is based in the United States. If you are in the EEA or UK, your data is processed in the US under Standard Contractual Clauses (SCCs) or other appropriate safeguards. Contact us to request a copy.
7.4 How to Submit a Privacy Request
Email kristian@romero.nyc with subject line "Privacy Request – [Your Name]". We will acknowledge receipt within 10 business days and respond within 45 calendar days. We will need to verify your identity before processing your request. No fees will be charged.
Opt-Out & Communication Preferences
8.1 Email Marketing Opt-Out
Opt out of all marketing emails at any time by: (a) clicking "Unsubscribe" in any marketing email; or (b) emailing kristian@romero.nyc with "Unsubscribe" in the subject line. We process opt-out requests within 10 business days. Transactional and service emails are unaffected.
8.2 CCPA Opt-Out of Sale/Sharing
California residents may opt out of sharing data with advertising platforms for cross-context behavioral advertising. Email kristian@romero.nyc with subject line "CCPA Opt-Out" or use the cookie opt-out mechanisms in Section 5.3. We will process your request within 15 business days.
8.3 GDPR Withdrawal of Consent
Where our processing is based on your consent, you may withdraw consent at any time by contacting kristian@romero.nyc. Withdrawal does not affect the lawfulness of processing that occurred prior to withdrawal.
Data Security
We implement commercially reasonable technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, and destruction:
- Encryption: Data in transit is encrypted via TLS. Data stored in our systems and HubSpot is encrypted at rest.
- Access controls: Personal data access is restricted to personnel who require it for their role, using role-based access controls and authentication requirements.
- Third-party security: Key providers (HubSpot, Google Cloud infrastructure) maintain SOC 2 compliance and industry-standard security certifications.
- Monitoring: We monitor for unauthorized access and anomalous activity.
- Vendor assessment: We evaluate third-party service providers for security practices before sharing personal data.
No method of electronic transmission or storage is 100% secure. In the event of a data breach affecting your rights and freedoms, we will notify affected individuals and relevant authorities as required by applicable law (within 72 hours under GDPR where applicable).
Children's Privacy (COPPA)
Our Services are intended solely for adults (18+) in a B2B context. We do not knowingly collect personal information from children under the age of 13, consistent with COPPA.
While Romero NYC does not target minors and does not create content designed to attract users under 13, we acknowledge that we cannot technically prevent minors from visiting our website and we do not have age-gating in place at this time.
If we become aware that we have inadvertently collected personal information from a child under 13 without verifiable parental consent, we will take prompt steps to delete that information. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at kristian@romero.nyc.
Third-Party Websites & Links
Our website may contain links to third-party websites not owned or controlled by Romero NYC. This Policy does not apply to those websites. We encourage you to review the privacy policies of any third-party sites you visit. Romero NYC is not responsible for the content, privacy practices, or data handling of third-party websites.
Changes to This Policy
We reserve the right to update this Privacy Policy at any time. When we make material changes, we will: (a) update the "Effective Date" at the top; (b) notify registered users and email subscribers; and (c) post a prominent notice on our website for at least 30 days.
Your continued use of our Services following the effective date of any updated Policy constitutes your acceptance of the changes.
Contact Information
For any privacy-related questions, requests, or complaints, please contact:
For GDPR purposes, Romero NYC Marketing Agency LLC is the data controller for personal data collected through this website. If you have unresolved concerns, you may contact your local supervisory authority.