Privacy Policy

1. Scope

This Privacy Policy describes how Blevins Holdings LLC and the affiliates that adopt this Policy (“Blevins,” “we,” “us,” or “our”) collect, use, disclose, retain, and protect personal information in connection with public websites, forms, communications, recruiting, vendor and business relationships, events, messaging programs, and services that link to this Policy.

A specific platform, subsidiary, contract, workforce program, healthcare activity, or regulated service may provide a separate privacy notice. That more specific notice controls for the identified activity. This Policy does not replace a customer’s instructions when Blevins processes information solely on the customer’s behalf.

2. Personal Information We Collect

Depending on your relationship and activity, we may collect the following categories:

We may collect sensitive personal information when reasonably necessary, such as government identifiers, account credentials, financial information, precise location, health or accommodation information, or the contents of private communications. We do not use sensitive personal information to infer characteristics about individuals except where permitted and reasonably necessary for the applicable purpose.

3. Sources of Personal Information

We collect personal information:

• directly from you, your organization, authorized representatives, applications, forms, contracts, meetings, and communications;
• automatically from websites, devices, cookies, analytics, authentication systems, security tools, and service usage;
• from affiliates, customers, suppliers, business partners, recruiters, references, event organizers, and professional advisors;
• from service providers supporting hosting, communications, analytics, advertising, recruiting, payments, security, and administration; and
• from public records, professional networks, government sources, sanctions and compliance databases, and other lawful sources.

4. How We Use Personal Information

We may use personal information to:

• operate websites, services, platforms, accounts, communications, and business relationships;
• respond to inquiries, route requests, provide support, authenticate users, and manage preferences;
• evaluate, negotiate, administer, perform, bill, and enforce contracts, orders, procurement, and transactions;
• recruit, evaluate, communicate with, and retain records concerning applicants;
• onboard, verify, manage, pay, and monitor suppliers and other counterparties;
• analyze performance, usage, audience engagement, service quality, and operational needs;
• personalize content and measure advertising or campaigns where permitted;
• protect people, facilities, systems, information, operations, and legal rights;
• detect and prevent fraud, abuse, security incidents, prohibited activity, and legal violations;
• comply with law, regulation, government contracts, legal process, records obligations, and professional requirements; and
• support corporate transactions, governance, audit, risk management, and business continuity.

5. How We Disclose Personal Information

We may disclose personal information to:

• service providers and contractors that perform hosting, communications, analytics, advertising, recruiting, payment, professional, security, document, and administrative services;
• Blevins affiliates for shared services, governance, security, legal, operational, recruiting, and relationship-management purposes;
• customers, suppliers, partners, and counterparties as necessary to evaluate or perform a relationship;
• professional advisors including attorneys, auditors, accountants, insurers, banks, and consultants;
• government and legal recipients when required by law, legal process, contract, security requirement, or to protect rights and safety;
• transaction participants in a merger, financing, acquisition, reorganization, bankruptcy, or sale of assets, subject to appropriate safeguards; and
• advertising and analytics partners when cookies, pixels, or similar technologies are enabled and permitted.

We may also disclose information at your direction, with your consent, or as otherwise described when it is collected.

6. Cookies, Analytics, and Advertising

We use cookies and similar technologies for security, authentication, preferences, functionality, analytics, performance, and advertising. Our Cookie Policy provides additional details and available controls.

Depending on consent, location, and configuration, third parties such as Google, Meta, LinkedIn, or other analytics and advertising providers may receive device, usage, page-view, and online identifier information. This activity may constitute “sharing” for cross-context behavioral advertising under California law or targeted advertising under other state laws.

We do not sell personal information for money. Where required, you may opt out of sale, sharing, or targeted advertising through our cookie controls, a recognized browser-based opt-out signal, or the methods in Section 13.

7. Global Privacy Control and Do Not Track

Where required by applicable law, we treat a valid Global Privacy Control (GPC) signal as a request to opt out of sale or sharing for the browser or device that sends the signal. The signal may not apply across devices, browsers, accounts, or contexts if we cannot reasonably associate them.

Because there is no universally accepted standard for traditional “Do Not Track” signals, we do not respond to every DNT signal. We respond to legally recognized opt-out preference signals as required.

8. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including the duration of a relationship, and afterward as needed for legal, contractual, accounting, audit, security, dispute, records, and operational requirements.

Retention depends on the information type, sensitivity, relationship, applicable law, contract, limitation period, security need, and whether the information is contained in backups or legal holds. When retention is no longer reasonably necessary, we may delete, anonymize, or securely dispose of the information.

9. Security

We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. Safeguards may include access controls, authentication, encryption, monitoring, vendor controls, training, incident response, and data-minimization practices.

No system or transmission is completely secure. You are responsible for protecting your credentials and devices and for using approved channels. Do not submit classified information, controlled unclassified information, export-controlled technical data, protected health information, financial credentials, or other restricted information through public forms or ordinary email.

10. Children

Our public websites and services are intended for business and professional audiences and are not directed to children under thirteen (13). We do not knowingly collect personal information online from children under thirteen without legally required authorization.

If you believe a child provided personal information improperly, contact us so we can review and take appropriate action.

11. International Users and Transfers

Blevins is based in the United States. Personal information may be processed in the United States and other countries where Blevins, affiliates, or service providers operate. Those countries may have different data-protection laws.

Where required, we use appropriate transfer mechanisms and safeguards. EEA, UK, and similar-law users may have rights to access, correct, erase, restrict, object, port data, withdraw consent, and lodge a complaint with a supervisory authority, subject to applicable conditions and exceptions.

Legal bases may include performance of a contract, legitimate interests, compliance with legal obligations, protection of vital interests, and consent. You may withdraw consent prospectively where processing depends on consent.

12. Applicants, Workforce, and Business Contacts

Applicant information may be used to evaluate qualifications, communicate, schedule interviews, verify information, conduct lawful checks, make hiring decisions, maintain recruiting records, improve recruiting, and comply with employment law. Application materials may be shared with recruiters, interviewers, service providers, affiliates, and advisors involved in the process.

Business-to-business and workforce information may be subject to additional notices. This Policy does not replace an employee, contractor, benefits, background-check, or workplace-specific notice.

13. Privacy Rights and Choices

Depending on your jurisdiction and our relationship, you may have the right to:

• confirm whether we process your personal information;
• access categories or specific pieces of personal information;
• correct inaccurate information;
• delete personal information, subject to exceptions;
• obtain a portable copy of certain information;
• opt out of sale, sharing, targeted advertising, or certain profiling;
• limit certain uses of sensitive personal information;
• withdraw consent where processing relies on consent;
• appeal a denied request where applicable; and
• receive equal service and pricing without unlawful discrimination for exercising rights.

Submit a request by emailing privacy@blevinsholdings.com, calling (858) 319-0217, or using the contact page with “Privacy Request” in the subject. We may verify your identity and authority before acting. An authorized agent may submit a request where permitted, subject to proof of authorization.

To opt out of sale or sharing for advertising, use the cookie controls, enable GPC, or email us. We will not require account creation solely to submit an opt-out.

14. California Privacy Notice

This section supplements the Policy for California residents where the California Consumer Privacy Act, as amended (CCPA), applies.

We may disclose these categories to the recipients described in Section 5. We do not sell personal information for money. Online advertising activities may constitute “sharing” under the CCPA. We do not knowingly sell or share personal information of individuals under sixteen (16).

We do not use or disclose sensitive personal information for purposes that require a right to limit, except where disclosed through a specific notice or legally required.

15. Other U.S. State Privacy Rights

Residents of certain states may have rights similar to those described in Section 13, including opt-out rights for targeted advertising, sale, or profiling in furtherance of decisions producing legal or similarly significant effects. Where applicable, you may appeal a denied request by replying to our decision or emailing privacy@blevinsholdings.com with “Privacy Appeal.”

Rights, exceptions, definitions, verification standards, and response periods vary by state. We will respond according to the law that applies to the request.

16. Email and Mobile Messaging Choices

You may unsubscribe from marketing email using the link in the message. Transactional, security, account, legal, and relationship messages may continue where permitted.

For text messages, follow the instructions in the Messaging Terms. Reply STOP or use another reasonable revocation method. We retain consent and opt-out records as needed for compliance.

17. Third-Party Links and Services

Our websites may link to or integrate third-party websites, social networks, document services, maps, payment systems, authentication tools, and other services. Their privacy practices are governed by their own notices. Review those notices before providing information.

18. Changes to This Policy

We may update this Policy to reflect changes in our practices, technologies, services, law, or organization. We will revise the “Last Updated” date and provide additional notice when required for a material change.

If consent is legally required for a new use, we will request consent before applying that use to affected information.

19. Contact Us

Privacy questions and requests may be directed to:

Blevins Holdings LLC
Privacy Office
3611 Valley Centre Drive, Suite 200
San Diego, California 92130
Email: privacy@blevinsholdings.com
Telephone: (858) 319-0217

Do not send sensitive records with an initial request. We will provide a secure method if additional information is needed.