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Privacy Policy

AK OPERATIONS, LLC

Privacy Policy

Last Updated: May 2026   |   Effective: May 2026

This policy supersedes and replaces the Privacy Policy dated April 17, 2025.

SUMMARY OF KEY POINTS

This summary provides key points. Use the Table of Contents to find more detail on any topic.

What personal information do we process? When you visit or use our Services, we may process personal information depending on how you interact with us, the choices you make, and the features you use. This includes information you provide directly, information automatically collected when you visit our site, and in some cases information about business contacts visiting our website that we receive from third-party data providers.

Do we use website visitor identification technology? Yes. We use a third-party service called Swan (Shalosh Labs LTD, Tel Aviv, Israel) to help us identify companies and business contacts who visit akoperations.com. This technology uses cookies and IP-address matching to associate website visits with B2B contact information. This applies to US-based visitors. See Section 1B and Section 15 for full details.

Do we collect any information from third parties? Yes, for purposes of website visitor identification. Swan and its data partners may provide us with enriched contact information about business contacts visiting our website. We do not purchase general consumer data lists.

Do we process any sensitive personal information? We do not intentionally process sensitive personal information as defined under applicable privacy laws. We do not seek to collect health, biometric, financial account, or similar sensitive data through our website.

How do we process your information? We process information to provide and improve our Services, communicate with you, identify potential B2B prospects, and comply with applicable law.

In what situations and with which parties do we share personal information? We may share information with service providers who help us operate our business, including Swan (visitor identification), CRM platform (CRM), website analytics tools (analytics), and others. We do not sell personal information.

What are your rights? Depending on your state of residence, you may have rights to access, correct, delete, or opt out of certain processing of your personal data. California residents have additional rights. See Section 10.

How do you exercise your rights? Submit a request to info@akoperations.com or use the contact information in Section 12.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  5. HOW LONG DO WE KEEP YOUR INFORMATION?
  6. HOW DO WE KEEP YOUR INFORMATION SAFE?
  7. DO WE COLLECT INFORMATION FROM MINORS?
  8. WHAT ARE YOUR PRIVACY RIGHTS?
  9. CONTROLS FOR DO-NOT-TRACK FEATURES AND GLOBAL PRIVACY CONTROL
  10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  11. DO WE MAKE UPDATES TO THIS NOTICE?
  12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
  14. HOW DO WE HANDLE INTERNATIONAL DATA TRANSFERS?
  15. WEBSITE VISITOR IDENTIFICATION TECHNOLOGY (SWAN)

1. WHAT INFORMATION DO WE COLLECT?

1A. Personal Information You Disclose to Us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information we collect may include:

  • Contact details: names, email addresses, phone numbers, mailing addresses, job titles
  • Communication preferences: contact preferences, opt-in/opt-out choices
  • Inquiry content: messages or questions you submit to us

 

Sensitive Information. We do not intentionally process sensitive personal information.

1B. Information Automatically Collected

In Short: Some information is collected automatically when you visit our website, including information used for visitor identification.

We automatically collect certain information when you visit, use, or navigate our Services. This may include:

  • Log and Usage Data: IP address, browser type and version, pages visited, timestamps, referring URLs, and device event information.
  • Device Data: device type, operating system, browser settings, hardware model, and internet service provider information.
  • Location Data: approximate location derived from your IP address.
  • Cookie and Tracking Data: behavioral data collected through cookies and similar technologies. See Section 4 for details.

1C. Visitor Identification and B2B Lead Intelligence Data

We use visitor identification technology to identify companies and business contacts who visit our website. Specifically:

  • We have deployed a tracking pixel from Swan on akoperations.com.
  • Swan’s pixel collects your IP address, cookie identifiers, and session behavior when you visit our site.
  • For visitors based in the United States: Swan and its B2B contact data partners may match your IP address and cookie data against business contact databases to identify your name, employer, business email address, and phone number.
  • For visitors outside the United States: Swan limits identification to company-level information only (company name, size, industry, and related firmographic data). Individual-level identification does not apply to non-US visitors.
  • This data is used exclusively for B2B sales and marketing purposes — specifically, to identify and reach out to business contacts who may benefit from our services.

You can opt out of this visitor identification at any time. See Section 15 for opt-out instructions.

1D. Information Received from Third Parties

In connection with visitor identification, we may receive enriched business contact information from third-party data providers including third-party B2B data sources Swan uses to identify and qualify website visitors. This information is limited to professional/business context data (name, business email, employer, title) and is not used for any purpose other than B2B sales and marketing outreach.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide and improve our Services, communicate with you, identify potential B2B prospects, and comply with applicable law.

We process personal information for the following purposes:

  • To deliver and facilitate our Services. We process your information to provide the services you have requested.
  • To respond to inquiries and provide support. We process your information to respond to questions and resolve issues.
  • To send administrative communications. We may send you details about our products and services or changes to our terms and policies.
  • To send marketing and promotional communications. We may process personal information for marketing purposes consistent with your preferences. You can opt out at any time.
  • To identify and qualify potential B2B prospects. We use visitor identification technology to identify business contacts who visit our website, assess whether our services may be relevant to their organization, and initiate outreach. Our lawful basis for this activity is legitimate interest — specifically, our interest in reaching business contacts who may benefit from our services, balanced against the limited privacy impact on professional contacts in a B2B context.
  • To deliver targeted advertising. We may process your information to develop and display personalized content and advertising.
  • To evaluate and improve our Services. We may process usage data to identify trends, assess our marketing effectiveness, and improve the website and services.
  • To comply with legal obligations. We may process information to comply with applicable laws, respond to legal requests, or exercise legal rights.
  • To protect our Services. We process information as part of fraud monitoring and security efforts.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations with specific categories of third parties.

Service Providers

We share personal information with third-party service providers who perform services on our behalf under written contracts that require them to protect your data. These providers include:

  • CRM and Marketing Automation: CRM and marketing automation platforms — manage contact records and email communications.
  • Website Visitor Identification: Swan — identifies companies and business contacts visiting our website. These services may use sub-processors, including US-registered B2B contact data brokers, to match visitor data against business contact databases. Swan acts as a data processor for this activity; AK Operations is the data controller.
  • Analytics: Website analytics tools — behavioral analytics, heatmaps, session recording, and performance measurement. Review your analytics provider’s privacy policies for more information on their data practices.
  • Hosting: Website hosting and infrastructure providers.
  • Scheduling: Scheduling and calendar tools.

Business Transfers

We may share or transfer your information in connection with a merger, sale, financing, or acquisition of all or a portion of our business.

Affiliates

We may share information with our affiliates for purposes consistent with this Privacy Policy.

Legal Requirements

We may disclose information if required by law, court order, or governmental request.

Sale of Personal Information

We do not sell personal information for monetary compensation. We may share certain visitor data with Swan as part of the service they provide us. Under California law, sharing data with a service provider for business purposes is not a ‘sale’; however, if you wish to opt out of any sharing of your personal information, see Section 10.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: Yes. We use cookies and similar technologies for website operation, analytics, advertising, and visitor identification.

We use the following types of cookies and tracking technologies:

  • Essential Cookies: Required for the website to function (security, session management). These cannot be disabled.
  • Analytics Cookies: Help us understand how visitors use the site (e.g., Google Analytics, CRM platform tracking).
  • Advertising Cookies: Enable personalized advertising (e.g., retargeting).
  • Visitor Identification Cookies: Set by Swan and its B2B contact data partners to associate website sessions with business contact information. These cookies are used to identify companies and individuals visiting our site for B2B sales and marketing purposes. See Section 15 for full disclosure and opt-out options.

You can manage your cookie preferences through our cookie consent tool (accessible on your first visit and at any time via the ‘Consent Preferences’ link in the footer), or by adjusting your browser settings. Disabling certain cookies may affect site functionality.

Some cookie-based data sharing may constitute ‘sharing’ under California law for targeted advertising purposes. You can opt out using our cookie consent tool or by submitting a request as described in Section 10.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

We retain personal information only as long as necessary for the purposes outlined in this policy, unless a longer period is required by law:

  • Contact information (names, email addresses): 1 year after your last interaction with our Services, unless you are an active customer.
  • Transaction data: 7 years to comply with tax and accounting obligations.
  • Usage and device data (IP addresses, analytics): 1 year for internal analytics and security.
  • Marketing preferences: Until you opt out or 1 year after your last interaction.
  • Visitor identification data received from Swan: Retained for the duration of the sales prospecting process, generally not longer than 12 months from identification, unless the contact becomes an active customer.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented industry-standard technical and organizational security measures including:

  • Encryption of data in transit (TLS/SSL) and at rest
  • Multi-factor authentication for employee system access
  • Regular security assessments
  • Access controls limiting data access to authorized personnel

In the event of a data breach affecting your personal information, we will notify you and relevant authorities as required by applicable law. No electronic system is 100% secure. You should access our Services only in a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to anyone under 18 years of age. Our Services are directed entirely to business professionals. If we learn that we have inadvertently collected data from a minor, we will take prompt steps to delete that information. Contact us at info@akoperations.com if you believe we have collected data from a minor.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your location, you may have rights to review, change, or restrict how we process your personal information.

Withdrawing consent: Where we rely on your consent to process personal information, you may withdraw that consent at any time by contacting us at info@akoperations.com. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

Opting out of marketing communications: You can unsubscribe from marketing emails at any time by clicking the unsubscribe link in any email we send, or by contacting us. You will remain on our list for essential service communications.

Opting out of visitor identification: You can opt out of Swan’s visitor identification technology at any time by visiting https://getswan.com/opt-out. You may also use our general opt-out process described in Section 10. See Section 15 for full details.

Cookies: You can manage cookies through our cookie consent tool or your browser settings. Blocking certain cookies may affect site functionality.

Challenging profiling: If you believe our use of profiling or automated decision-making has affected you unfairly, contact us at info@akoperations.com and we will respond within 30 days.

9. CONTROLS FOR DO-NOT-TRACK FEATURES AND GLOBAL PRIVACY CONTROL

Global Privacy Control (GPC): We honor Global Privacy Control signals. If your browser or browser extension sends a GPC signal to our website, we will treat it as a request to opt out of the sale and sharing of your personal information for targeted advertising purposes. This applies to California residents and residents of other states that have enacted GPC recognition requirements (currently including Colorado, Connecticut, Texas, Montana, Oregon, Delaware, New Jersey, Nebraska, New Hampshire, and Maryland). GPC applies to the browser session in which it is sent and does not affect information we have already collected.

Do Not Track (DNT): Most web browsers include a Do Not Track (‘DNT’) feature. Because no uniform technology standard for DNT has been finalized, we do not respond to DNT signals separately. If DNT becomes a recognized legal standard, we will update this policy accordingly.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Residents of California and certain other states have specific privacy rights.

Covered States

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to, correct, or delete the personal information we hold about you, and to opt out of certain data processing activities. These rights may be limited by applicable law.

Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information:

Category Examples Collected
A. Identifiers Name, email, IP address, device identifier, online identifier YES
B. Personal information (CA Records statute) Name, contact info, professional information YES
C. Commercial information Inquiry and transaction history YES
D. Internet/network activity Browsing history on our site, interactions with our pages YES
E. Geolocation data Approximate location derived from IP address YES
F. Professional/employment information Job title, employer, business contact details (received via visitor ID) YES
G. Inferences drawn from collected data Lead qualification scores, ICP fit assessments YES
H. Biometric information Fingerprints, voiceprints NO
I. Sensitive personal information Health, financial, racial/ethnic origin data NO

 

Sources of Personal Information

We collect personal information directly from you (e.g., form submissions and inquiries), automatically when you visit our website (e.g., IP addresses and cookies), and from third-party data providers in the context of visitor identification (e.g., Swan and third-party B2B contact data providers).

Sale and Sharing of Personal Information

We do not sell personal information for monetary compensation. In the context of operating our visitor identification technology, we share certain visitor data (IP addresses, cookie identifiers, and enriched contact information) with Swan as a data processor. This sharing enables Swan to perform the visitor identification service on our behalf and is not considered a sale. If you wish to opt out of this data sharing, see ‘How to Exercise Your Rights’ below.

Your Rights

Depending on your state of residence, you may have the following rights:

  • Right to know whether we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request deletion of your personal data
  • Right to obtain a portable copy of your personal data
  • Right to opt out of targeted advertising, data sales, or profiling with significant legal or similar effects
  • Right to non-discrimination for exercising your privacy rights
  • California additional rights: Right to limit use of sensitive personal information; ‘Shine the Light’ disclosure rights under Cal. Civil Code 1798.83; opt-out of automated decision-making technology disclosure (effective January 1, 2027)

How to Exercise Your Rights

To exercise any of the rights above, you may:

  • Email us at info@akoperations.com with ‘Privacy Rights Request’ in the subject line
  • Submit a data subject access request using the contact form at akoperations.com/contact
  • For visitor identification opt-out specifically, visit https://getswan.com/opt-out

We will verify your identity and respond within 45 days (California standard), or the timeframe required by your applicable state law. You may designate an authorized agent to submit requests on your behalf.

Appeals

If we decline to act on your request, you may appeal within 30 days by emailing info@akoperations.com with ‘Appeal’ in the subject line. We will respond within 45 days with a written explanation. If your appeal is denied, you may file a complaint with your state’s Attorney General

California ‘Shine The Light’ Law

California Civil Code Section 1798.83 permits California residents to request, once per year and at no charge, information about categories of personal information disclosed to third parties for direct marketing purposes. Submit this request in writing to info@akoperations.com.

11. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements. The updated version will indicate a revised date at the top. If we make material changes (e.g., new data sharing practices or new third-party processors), we will notify you by email if we have your contact information, or by posting a prominent notice on our website at least 30 days before the changes take effect. We encourage you to review this policy periodically.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, please contact us:

AK Operations, LLC

PO Box 115

Cottleville, MO 63304

United States

info@akoperations.com

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on applicable laws of your state of residence, you may have the right to request access to the personal information we collect, request corrections, or request deletion. To submit such a request, email us at info@akoperations.com or use the contact form at akoperations.com/contact. We will respond within the timeframe required by your applicable state law, generally within 45 days.

14. HOW DO WE HANDLE INTERNATIONAL DATA TRANSFERS?

If you are located outside the United States, your personal information may be transferred to and processed in the United States, where our primary operations are based. Additionally, Swan and its sub-processors may process visitor data in other countries. We ensure that such transfers comply with applicable data protection laws. For questions about our international transfer practices, contact us at info@akoperations.com.

15. WEBSITE VISITOR IDENTIFICATION TECHNOLOGY (SWAN)

This section provides the specific disclosures required by applicable privacy laws regarding our use of website visitor identification technology.

What It Is

We use Swan (Shalosh Labs LTD, Tel Aviv, Israel), a B2B visitor identification platform, to identify companies and business contacts who visit akoperations.com. Swan uses cookies, IP address matching, and third-party B2B data sources to associate anonymous website visits with business contact information. This is a standard B2B sales intelligence practice.

What Data Is Collected and How

When you visit our website, Swan’s tracking pixel collects:

  • Your IP address
  • Cookie identifiers placed on your device by Swan
  • Your session behavior (pages visited, time on site)

Swan and its data partners (including Retention.com (RB2B), registered as a data broker in California, Texas, Vermont, and Oregon) may then match this information against business contact databases to return:

  • For US-based visitors: Your name, business email address, employer, phone number, and LinkedIn profile (where available)
  • For non-US visitors: Company-level information only — company name, size, industry, and related firmographic data. Individual-level identification does not occur for non-US visitors.

Why We Do This

We use this technology to identify business professionals who visit our website, assess whether our services may be relevant to their organization, and initiate relevant business outreach. Our lawful basis for this processing is legitimate interest — specifically, our business interest in reaching companies and professionals who have demonstrated interest in our services by visiting our website. We have assessed that this interest is proportionate and not overridden by the privacy interests of business visitors in a B2B context.

How to Opt Out

You have several options to opt out of visitor identification:

  • Swan global opt-out: Visit https://getswan.com/opt-out to be removed from Swan’s identification and processing.
  • B2B contact data provider database opt-out: Visit https://app.retention.com/optout to be removed from Retention.com (RB2B)’s identity database.
  • Cookie consent: Use our cookie consent tool (accessible at any time via the ‘Consent Preferences’ link in our footer) to block visitor identification cookies before they fire.
  • Global Privacy Control: If you use a browser or extension that sends a GPC signal, we will honor it as an opt-out of data sharing. See Section 9.
  • Direct request: Email info@akoperations.com and we will ensure your data is excluded from our visitor identification processes.

Swan’s Privacy Practices

Swan processes visitor data as a data processor on our behalf. Their privacy policy is available at https://www.getswan.com/legal/privacy-policy. Swan is the data processor; AK Operations is the data controller for this activity.