Privacy Policy

Effective Date: September 3, 2026
Last Updated: September 3, 2026

Bold Array LLC (“Bold Array,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit our websites, communicate with us, request information, engage our services, or otherwise interact with Bold Array.

This Privacy Policy also describes privacy rights that may be available to you under applicable laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), the European Union General Data Protection Regulation (“GDPR”), the UK GDPR, and applicable U.S. state consumer privacy laws.

1. Scope of This Privacy Policy

This Privacy Policy applies to personal information collected through:

Bold Array websites and webpages;
contact, inquiry, and request forms;
email and other communications with Bold Array;
marketing communications;
business development activities;
client and prospective-client relationships;
analytics and similar website technologies; and
other online or offline interactions where this Privacy Policy is provided or referenced.

This Privacy Policy does not necessarily apply to information Bold Array processes solely on behalf of a client.

When Bold Array processes personal information on behalf of a client in connection with website development, software development, marketing, analytics, hosting, integrations, artificial intelligence, or other services, the client may be the controller or business responsible for determining how that information is processed. In those circumstances, the client's privacy policy and our agreement with that client may govern the processing.

2. Personal Information We Collect

The information we collect depends upon how you interact with Bold Array.

Information You Provide Directly

We may collect information you voluntarily provide, including:

name;
company or organization;
job title;
email address;
telephone number;
mailing or business address;
information submitted through contact forms;
project requirements;
requests for proposals or estimates;
communications and correspondence;
account information where applicable;
billing and transaction information;
files, documents, or other materials you provide to us; and
any other information you choose to provide.

Information Collected Automatically

When you access our website, we or service providers acting on our behalf may automatically collect certain technical and usage information, including:

Internet Protocol (IP) address;
browser type and version;
operating system;
device type;
referring website or URL;
pages viewed;
links clicked;
date and time of visits;
approximate geographic location derived from an IP address;
session information;
device or online identifiers;
cookie identifiers; and
information regarding how you interact with our website.

Information From Other Sources

We may receive information from:

clients;
business partners;
service providers;
analytics providers;
advertising and marketing platforms;
social media platforms;
publicly available sources;
professional networking services;
referrals; and
other third parties where permitted by law.

When required by applicable law, we will provide appropriate notice concerning personal information obtained from sources other than you.

3. Categories of Personal Information

Depending upon your interaction with Bold Array, we may process the following categories of personal information:

Identifiers: such as name, email address, telephone number, postal address, IP address, account identifiers, and online identifiers.

Customer and business information: such as company, job title, project information, services requested, client relationship information, and communications.

Commercial information: such as services purchased, considered, requested, or discussed and other business transaction information.

Internet or electronic activity: such as browsing activity, interactions with our website, referring URLs, device information, and analytics information.

Approximate geolocation information: such as location inferred from an IP address.

Professional or employment-related information: such as employer, company, job title, and professional contact information.

Audio, electronic, or similar information: when you communicate with us through technologies capable of collecting this information.

Inferences: limited inferences that may be generated from interactions with our website or services, such as potential interest in particular Bold Array services.

We do not intentionally collect sensitive personal information beyond what is reasonably necessary to provide our services or where information is voluntarily provided to us.

4. How We Use Personal Information

We may use personal information to:

provide, operate, maintain, and improve our website;
provide requested services;
respond to inquiries and requests;
communicate with clients and prospective clients;
prepare proposals, estimates, contracts, and project plans;
manage client relationships;
develop websites, applications, software, integrations, marketing programs, and other client projects;
process transactions and maintain business records;
provide customer and technical support;
analyze website traffic and performance;
understand how visitors use our website;
improve our products, services, marketing, and website;
personalize website experiences where appropriate;
conduct advertising and marketing activities;
measure marketing effectiveness;
maintain the security and integrity of our systems;
detect, investigate, and prevent fraud, abuse, security incidents, and unlawful activity;
enforce agreements and policies;
comply with legal, regulatory, tax, accounting, and contractual requirements;
establish, exercise, or defend legal claims; and
carry out other purposes disclosed when information is collected.

We may also use aggregated or deidentified information for analytics, research, business planning, and other lawful purposes.

5. Legal Bases for Processing Under GDPR

Where the GDPR, UK GDPR, or another law requiring a lawful basis applies, Bold Array processes personal information based upon one or more of the following legal grounds:

Performance of a Contract

Processing may be necessary to enter into or perform a contract with you, including providing services you have requested.

Legitimate Interests

We may process information when necessary for our legitimate business interests, including:

operating and improving our business;
responding to inquiries;
maintaining client relationships;
securing our websites and systems;
preventing fraud;
conducting business-to-business marketing; and
understanding and improving our services.

We consider the potential effect of such processing on your rights and interests.

Consent

Where required, we may process personal information based upon your consent, including certain marketing, advertising, analytics, or cookie activities.

You may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted before consent was withdrawn.

Legal Obligations

We may process personal information when necessary to comply with applicable laws, regulations, court orders, governmental requests, or other legal obligations.

6. Cookies and Similar Technologies

Bold Array and our service providers may use cookies, pixels, tags, scripts, local storage, and similar technologies.

These technologies may be used for:

essential website functionality;
security;
remembering preferences;
analytics;
measuring website performance;
understanding visitor behavior;
advertising;
measuring advertising effectiveness; and
improving our website and services.

Cookies may be classified as:

Strictly Necessary Cookies – Required for the website to operate properly.

Functional Cookies – Help remember preferences or provide enhanced functionality.

Analytics Cookies – Help us understand website traffic and usage.

Advertising Cookies – May be used to measure advertising effectiveness, create audiences, or provide advertising relevant to users.

Where required by law, non-essential cookies will not be placed until appropriate consent has been obtained.

You may manage cookies through our cookie preference controls, where available, and through your browser settings.

Disabling certain cookies may affect website functionality.

7. Analytics and Advertising

We may use third-party analytics, advertising, and marketing services to understand website usage, measure marketing performance, and promote our services.

These providers may collect information through cookies, pixels, APIs, or similar technologies.

Depending upon the technologies implemented on our website, disclosure of personal information to advertising or analytics providers may constitute “sharing,” “sale,” or processing for “targeted advertising” under certain privacy laws even when Bold Array does not receive money in exchange for the information.

Where required by applicable law, we provide mechanisms to opt out of these activities.

8. Global Privacy Control and Universal Opt-Out Mechanisms

Where required by applicable law, Bold Array recognizes qualifying browser-based opt-out preference signals, including Global Privacy Control (“GPC”), as a request to opt out of the sale or sharing of personal information or the processing of personal data for targeted advertising.

A GPC signal generally applies to the browser and device from which it is sent.

Where permitted, we may associate your preference with your account or other information if you are authenticated or otherwise provide sufficient information for us to do so.

9. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients:

Service Providers and Processors

We may provide information to vendors that perform services on our behalf, including:

website hosting;
cloud infrastructure;
data storage;
analytics;
security;
email;
communications;
customer relationship management;
payment processing;
accounting;
project management;
marketing; and
other technology services.

These providers may process information only as permitted by our agreements and applicable law.

Advertising and Analytics Partners

Subject to applicable law and your privacy choices, information may be disclosed to analytics, advertising, and marketing providers.

Professional Advisors

We may disclose information to attorneys, accountants, auditors, insurers, consultants, and other professional advisors where reasonably necessary.

Legal and Governmental Authorities

We may disclose information where we reasonably believe disclosure is required by law or necessary to:

comply with legal processes;
respond to lawful governmental requests;
protect our legal rights;
protect the safety of individuals;
investigate fraud or security incidents; or
prevent unlawful activity.

Corporate Transactions

Information may be disclosed or transferred in connection with a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar corporate transaction.

10. Sale and Sharing of Personal Information

Bold Array does not sell personal information for money in the traditional sense.

However, certain uses of advertising, analytics, or marketing technologies may constitute a “sale,” “sharing,” or use for “targeted advertising” under some U.S. state privacy laws.

Where these laws apply, you may opt out through the privacy controls provided on our website or by contacting us as described below.

We do not knowingly sell or share personal information of consumers under 16 years of age.

11. Sensitive Personal Information

Bold Array does not intentionally collect sensitive personal information through its general public website except where reasonably necessary for a requested service or voluntarily provided.

We do not use or disclose sensitive personal information for purposes that require a right to limit under the CCPA unless appropriate notice and controls are provided.

Where applicable state law requires consent before processing sensitive personal data, we will obtain the required consent.

12. Data Retention

We retain personal information only for as long as reasonably necessary to accomplish the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods may depend upon:

the nature of the information;
the purpose for which it was collected;
the duration of our relationship with you;
contractual requirements;
security requirements;
applicable statutes of limitation;
tax and accounting requirements;
regulatory requirements; and
legal obligations.

When personal information is no longer reasonably necessary, we may delete, anonymize, aggregate, or securely dispose of it.

13. Data Security

Bold Array uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, destruction, loss, alteration, disclosure, or misuse.

Security measures may include access controls, authentication mechanisms, encryption where appropriate, network security, monitoring, backups, system updates, and other security practices.

No internet transmission, network, or information storage system can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of information transmitted to or stored by us.

14. International Data Transfers

Bold Array is located in the United States.

If you access our website or services from outside the United States, your personal information may be transferred to, processed in, or stored in the United States or other jurisdictions where our service providers operate.

Where required by GDPR or similar laws, international transfers may rely upon recognized legal mechanisms such as:

adequacy decisions;
Standard Contractual Clauses;
approved data transfer frameworks; or
other legally recognized safeguards.

You may contact us for additional information regarding safeguards applicable to international transfers.

15. Your Privacy Rights

Depending upon where you reside and applicable law, you may have the right to:

confirm whether we process your personal information;
request access to your personal information;
obtain a copy of your personal information;
request correction of inaccurate information;
request deletion of personal information;
request restriction of processing;
object to certain processing;
request data portability;
opt out of the sale of personal information;
opt out of sharing personal information for cross-context behavioral advertising;
opt out of targeted advertising;
opt out of certain profiling or automated decision-making;
limit certain uses or disclosures of sensitive personal information;
withdraw consent;
appeal a decision concerning a privacy request; and
receive equal service and not be discriminated or retaliated against for exercising your privacy rights.

The specific rights available to you depend upon your jurisdiction and our relationship with you.

16. California Privacy Rights

This section applies to California residents to the extent Bold Array is subject to the CCPA with respect to the applicable processing.

California consumers may have the following rights:

Right to Know

You may request information regarding our collection, use, disclosure, sale, or sharing of personal information, including:

categories of personal information collected;
categories of sources;
business or commercial purposes for collection, use, sale, or sharing;
categories of third parties to whom information is disclosed;
categories of personal information sold or shared; and
specific pieces of personal information collected about you.

Right to Delete

You may request deletion of personal information we collected about you, subject to exceptions permitted by law.

Right to Correct

You may request correction of inaccurate personal information.

Right to Opt Out of Sale or Sharing

You may direct us not to sell or share your personal information as those terms are defined under the CCPA.

You may exercise this right using the “Your Privacy Choices” or “Do Not Sell or Share My Personal Information” mechanism provided on our website, where applicable.

We also process qualifying Global Privacy Control signals as opt-out requests where required.

Right to Limit Use of Sensitive Personal Information

Where applicable, you may have the right to limit certain uses or disclosures of sensitive personal information.

Right to Non-Discrimination

We will not discriminate against you because you exercise rights provided under the CCPA.

Authorized Agents

You may designate an authorized agent to submit certain requests on your behalf.

We may request information necessary to verify your identity, the agent's identity, and the agent's authority to act on your behalf.

17. California Notice at Collection

At or before the point of collection, California consumers have the right to receive information regarding the categories of personal information collected and the purposes for which they are used.

Bold Array may collect:

identifiers;
customer and business information;
commercial information;
internet or electronic activity;
approximate geolocation information;
professional information; and
limited inferences.

These categories are used for the business and commercial purposes described in this Privacy Policy.

We retain each category for only as long as reasonably necessary for the disclosed purposes, taking into account the criteria described in the Data Retention section.

Additional information regarding our practices is provided throughout this Privacy Policy.

18. Other U.S. State Privacy Rights

Residents of states with comprehensive consumer privacy laws may have additional rights.

Depending upon applicable law, this may include residents of states such as Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and other jurisdictions that enact comprehensive privacy legislation.

Available rights may include:

access;
confirmation of processing;
correction;
deletion;
portability;
obtaining information concerning third-party disclosures;
opting out of targeted advertising;
opting out of sale;
opting out of certain profiling;
withdrawing consent for sensitive-data processing; and
appealing a decision concerning a privacy request.

Where applicable, we recognize qualifying universal opt-out mechanisms as required by state law.

Appeals

If we deny a privacy request and applicable law provides a right to appeal, you may appeal our decision by contacting us at info@boldarray.com and identifying your communication as a Privacy Request Appeal.

We will respond to the appeal as required by applicable law and provide information regarding additional remedies where required.

19. European Economic Area, United Kingdom, and Switzerland

If GDPR, UK GDPR, or comparable European data protection law applies to our processing of your personal information, you may have the right to:

access personal information;
rectify inaccurate information;
erase personal information;
restrict processing;
object to processing;
receive portable copies of certain information;
withdraw consent;
object to direct marketing;
obtain information concerning certain automated decision-making; and
lodge a complaint with an applicable data protection supervisory authority.

Where we rely upon legitimate interests, you may object to processing based upon circumstances relating to your particular situation.

Where personal information is processed for direct marketing, you may object to such processing at any time.

You may lodge a complaint with the supervisory authority in the country where you reside, work, or where you believe an infringement occurred.

20. Automated Decision-Making and Artificial Intelligence

Bold Array provides artificial intelligence and software engineering services and may use AI-enabled tools in connection with our business operations.

Unless otherwise disclosed, we do not use personal information collected through our general public website to make solely automated decisions that produce legal or similarly significant effects concerning individuals.

If we engage in automated decision-making or profiling subject to specific disclosure, access, or opt-out requirements under applicable law, we will provide the required notices and rights.

We may use AI-assisted technologies for purposes such as:

content assistance;
software development;
data analysis;
internal productivity;
customer support assistance;
security; and
improving services.

Where third-party AI providers process personal information on our behalf, we seek to use such providers consistent with our contractual obligations and applicable privacy laws.

21. Children's Privacy

Our website and services are intended for businesses and adults and are not directed toward children under 13 years of age.

We do not knowingly collect personal information from children under 13 through our general website.

We also do not knowingly sell or share personal information of individuals under 16 for purposes subject to the CCPA's opt-in requirements.

If you believe a child has provided personal information to us, please contact us so that we can investigate and, where appropriate, delete the information.

22. Marketing Communications

You may opt out of marketing emails at any time by using the unsubscribe mechanism included in the communication or by contacting us.

Even if you opt out of marketing communications, we may continue sending non-promotional communications concerning existing projects, transactions, security, legal matters, or our business relationship with you.

23. Do Not Track

Some browsers provide a “Do Not Track” (“DNT”) setting.

Because there is not a single universally accepted standard governing DNT signals, our website may not respond to traditional DNT signals.

However, where required by applicable law, we recognize qualifying universal opt-out mechanisms such as Global Privacy Control.

24. Third-Party Websites and Services

Our website may contain links to websites, platforms, applications, or services operated by third parties.

Bold Array does not control the privacy or security practices of those third parties. Their collection and use of personal information are governed by their own privacy policies.

We encourage you to review the privacy policies of third-party services before providing personal information.

25. Client Websites and Applications

Bold Array designs, develops, integrates, maintains, or provides services for websites, applications, and systems belonging to clients.

The presence of Bold Array technology, code, hosting, analytics, development services, or other services on a client's website does not necessarily mean Bold Array controls the personal information collected by that client.

Where Bold Array acts as a processor or service provider on behalf of a client, requests concerning personal information controlled by that client should generally be directed to the client.

26. How to Exercise Your Privacy Rights

To submit a privacy request, you may contact us at:

Email: info@boldarray.com
Telephone: 949-238-8077

Please identify your request as a Privacy Request and describe the right you wish to exercise.

Where required by law, additional request mechanisms may be provided through our website.

We may need to verify your identity before completing certain requests. Verification procedures will depend upon the nature and sensitivity of the information involved.

We will use personal information submitted in connection with a privacy request only as reasonably necessary to verify and fulfill the request, prevent fraud, maintain required records, and comply with law.

We will respond within the time required by applicable law.

27. Requests Through Authorized Agents

Where permitted by applicable law, you may use an authorized agent to exercise privacy rights on your behalf.

We may require:

proof that you authorized the agent;
verification of your identity;
verification of the agent's identity; or
other information reasonably necessary to prevent fraudulent requests.

These requirements will not be applied where prohibited by law.

28. Changes to This Privacy Policy

We may periodically update this Privacy Policy to reflect:

changes to our services;
changes to our information practices;
new technologies;
legal or regulatory developments; or
other operational changes.

When we make changes, we will update the Last Updated date at the top of this Privacy Policy.

If changes materially affect how we process personal information, we may provide additional notice where required by law.

We encourage you to periodically review this Privacy Policy.

29. Contact Us

Questions, concerns, complaints, or privacy requests may be directed to:

Bold Array LLC
200 Spectrum Center Dr, #300
Irvine, CA 92618
United States

Telephone: 949-238-8077
Email: info@boldarray.com

For privacy-related correspondence, please include “Privacy Request” or “Privacy Inquiry” in the subject line.