Privacy Policy

This Privacy Policy describes how Emergent Systems, LLC, doing business as The Chalfant Group (“Chalfant,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information when you visit this website (the “Site”), communicate with us, or use any online tools, applications, chat features, or services we make available through the Site (collectively, the “Services”). It also describes the privacy rights available to you and how to exercise them.

This Privacy Policy applies to information we collect through the Services. Client consulting engagements are governed by the applicable engagement agreement, statement of work, and, where applicable, our Data Processing Addendum, which control over this Privacy Policy with respect to client data processed in the course of an engagement.

By using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Services.

1. Notice at Collection (California Residents)

For California residents, this section, together with Sections 2 through 5 and Section 9 of this Privacy Policy, serves as our Notice at Collection under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). At or before the point of collection, we collect the categories of personal information described in Section 2 for the purposes described in Section 3, and we retain that information as described in Section 6. Depending on your cookie preferences, certain information collected through advertising and analytics technologies may be “shared” for cross-context behavioral advertising as described in Section 4. You may opt out at any time via the “Do Not Sell or Share My Personal Information” link on the Site, through our cookie preference center, or by broadcasting a Global Privacy Control signal, each as described in Section 9. We do not knowingly sell or share the personal information of consumers under 16 years of age.

2. Personal Information We Collect

2.1 Information You Provide Directly

• Contact and identity information — such as your name, email address, phone number, company name, and job title, when you submit a contact or inquiry form, request a consultation, subscribe to communications, or register for an account (if account features are offered).
• Communications and inquiry content — the contents of messages, forms, emails, chat sessions, scheduling requests, and any documents or materials you choose to submit to us.
• Account and transaction information — if we offer self-service or subscription features, credentials, preferences, billing contact details, and records of purchases. Payment card details are collected and processed by our payment processors, not stored by us.

2.2 Information Collected Automatically

When you use the Services, we and our service providers automatically collect certain information using cookies, pixels, software development kits, and similar technologies (“Tracking Technologies”), subject to your consent preferences where required:

• Device and browser information — IP address, browser type and version, operating system, device identifiers, language settings, and screen characteristics.
• Usage and interaction information — pages viewed, links clicked, referring and exit pages, date and time stamps, time spent on pages, scrolling and navigation activity, and general engagement with Site features. With your consent, our analytics tools may capture how visitors interact with pages and forms in order to diagnose issues and improve usability; these tools are configured to suppress the capture of sensitive input fields.
• Approximate location — general geographic location inferred from your IP address (e.g., city and region). We do not collect precise geolocation.
• Inference data — inferences drawn from the information above, such as interest in particular services, used for analytics and, with your consent, for marketing.

2.3 Interactive and AI-Assisted Features

If the Services include chat, virtual assistant, or other interactive or AI-assisted features, the inputs you submit and the responses generated are collected and retained by us as part of our records, in accordance with Section 6. Where an automated feature is not staffed by a human, it will be identified as automated. Do not submit confidential, sensitive, or personal information about yourself or others through these features unless expressly requested.

AI-assisted features are currently powered by the Anthropic API, provided by Anthropic, PBC, acting as our service provider under Anthropic’s commercial terms of service. Under those terms: (a) Anthropic is prohibited from using inputs and outputs submitted through our commercial API integration to train its models; and (b) Anthropic’s stated policy is to automatically delete commercial API inputs and outputs from its systems within a short period (generally up to 30 days), except where longer retention is required for trust-and-safety purposes (such as content flagged for potential policy violations) or to comply with law. Anthropic’s practices are described in its commercial terms and data retention documentation, available at https://www.anthropic.com/legal/commercial-terms and https://privacy.anthropic.com. Note that these provider retention periods apply to Anthropic’s systems and are separate from our own retention of feature inputs and outputs described above. If we change AI providers, we will engage providers under terms that are materially no less protective and will update this Privacy Policy.

2.4 Information from Other Sources

We may receive information from business partners, publicly available professional sources (such as company websites or professional networking platforms), event organizers, referral partners, and analytics or advertising providers, and may combine it with information collected through the Services.

2.5 Sensitive Personal Information

We do not seek to collect sensitive personal information (as defined under the CCPA) through the Services, and we ask that you do not submit it. Any account log-in credentials we collect are used solely to provide and secure the Services and are not used to infer characteristics about you.

3. How We Use Personal Information

We use personal information for the following business and commercial purposes:

• Providing the Services — operating the Site, responding to inquiries, scheduling and delivering consultations, administering accounts, processing transactions, and providing requested features and content.
• Improvement and analytics — understanding how the Services are used, diagnosing technical issues, testing features, improving usability, and developing new services and offerings, including evaluating and improving the performance of AI-assisted features we deploy.
• Marketing and communications — sending newsletters, insights, service announcements, and promotional communications (with opt-out available in every message), and, with your consent, measuring and delivering interest-based advertising.
• Security, integrity, and fraud prevention — detecting, investigating, and preventing security incidents, fraud, abuse, and violations of our Terms of Use, and protecting the rights, property, and safety of Chalfant, our clients, and others.
• Legal compliance — complying with applicable law, responding to lawful requests, enforcing agreements, and establishing, exercising, or defending legal claims.
• Business operations — record-keeping, auditing, accounting, and, in connection with any merger, acquisition, financing, or sale of assets, evaluating and completing that transaction.

We do not use personal information collected through the Services to train generalized artificial intelligence models, and we do not permit our AI providers to do so. All backend AI processing is performed through commercial API agreements — currently with Anthropic, PBC, as described in Section 2.3 — under terms that prohibit the provider from using your inputs and outputs to train its models and that restrict the provider’s use of that data to providing services to us, along with limited security, safety, and legal-compliance purposes.

4. How We Disclose Personal Information

• Service providers and contractors — hosting, analytics, communications, scheduling, payment processing, customer relationship management, security, and AI technology providers that process information on our behalf under contractual restrictions.
• Advertising and analytics partners — with your consent, third-party advertising and analytics partners may collect information via Tracking Technologies for cross-context behavioral advertising and campaign measurement. Under the CCPA this may constitute “sharing.” You may opt out as described in Section 9.
• Professional advisors — lawyers, accountants, auditors, and insurers as necessary for the professional services they provide to us.
• Legal and safety disclosures — courts, regulators, law enforcement, or other parties where we believe disclosure is required by law or appropriate to protect rights, safety, or the integrity of the Services.
• Business transfers — a successor or acquirer (and its advisors) in connection with a merger, acquisition, reorganization, financing, or sale of all or part of our business or assets.
• With your direction or consent — any other disclosure you request or authorize.

We do not sell personal information for money. Except for the consent-based advertising and analytics activity described above, we do not share personal information for cross-context behavioral advertising.

5. Cookies and Tracking Technologies

We use the following categories of Tracking Technologies. Except for strictly necessary technologies, these load only in accordance with your choices in our cookie consent banner and preference center, which is available on every page of the Site.

• Strictly necessary — required for core Site functions, security, load balancing, and recording your consent choices. These cannot be disabled.
• Functional — remember preferences such as language, region, and form state.
• Analytics and performance — measure traffic, usage patterns, and page interactions to help us understand and improve the Services.
• Advertising — deliver and measure marketing campaigns, cap ad frequency, and enable interest-based advertising across websites and services.

You can change your preferences at any time via the “Cookie Preferences” link on the Site. You can also control cookies through your browser settings, though blocking some categories may affect Site functionality.

Global Privacy Control and Do Not Track

We recognize the Global Privacy Control (“GPC”) browser signal as a valid request to opt out of the sale or sharing of personal information for the browser or device transmitting the signal. Because no uniform industry standard has been adopted for legacy “Do Not Track” signals, we do not respond to them; we honor GPC signals as described above.

6. Retention of Personal Information

We retain personal information only as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law. In determining retention periods, we consider the nature and sensitivity of the information, the purposes for which it was collected, our legal and contractual obligations, applicable limitations periods, and legitimate business needs. By way of example: inquiry and communication records are generally retained for the duration of our relationship and a reasonable period thereafter; analytics data is retained in identifiable form only as long as needed for measurement and is aggregated or deleted thereafter; and consent records are retained as required to demonstrate compliance. When retention is no longer necessary, we delete, de-identify, or aggregate the information.

7. Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and destruction, consistent with the New York SHIELD Act and other applicable law. These safeguards are appropriate to our size, the nature of our activities, and the sensitivity of the information we handle. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a data breach affecting private information, we will provide notifications as required by applicable law.

8. Children’s Privacy

The Services are intended for business and professional audiences and are not directed to children. We do not knowingly collect personal information from anyone under 18, and we do not knowingly sell or share the personal information of consumers under 16. If you believe a minor has provided personal information to us, contact us using the details in Section 13 and we will delete it as required by law.

9. Your Privacy Rights and Choices

9.1 Rights for California Residents

Subject to applicable law and verification, California residents may exercise the following rights without discrimination for doing so:

• Right to know/access — request the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of recipients.
• Right to delete — request deletion of personal information, subject to legal exceptions.
• Right to correct — request correction of inaccurate personal information.
• Right to opt out of sale/sharing — direct us not to sell or share personal information, including for cross-context behavioral advertising.
• Right to limit use of sensitive personal information — we do not use sensitive personal information for purposes requiring a right to limit, but you may contact us with any concerns.
• Right to non-discrimination — we will not deny services, charge different prices, or provide a different level of quality because you exercised your rights.

9.2 How to Exercise Your Rights

You may submit a request by: (a) using the “Privacy Request” or “Do Not Sell or Share My Personal Information” links on the Site; or (b) writing to Emergent Systems, LLC, Attn: Privacy, PO Box 251, Delmar, NY 12054. For opt-out of sale/sharing, you may also use the cookie preference center or a GPC signal; no account or verification is required to opt out.

For access, deletion, and correction requests, we will verify your identity by matching information you provide against information we maintain, and may request additional information where necessary. You may designate an authorized agent to act on your behalf; we may require proof of the agent’s authority and direct confirmation of your identity. We will respond within 45 days, with one 45-day extension where reasonably necessary, in which case we will notify you. If we decline a request in whole or in part, we will explain why, and you may appeal by replying to our response with the subject line “Privacy Appeal.”

9.3 Rights for Other Residents

Residents of other states with comprehensive privacy laws may have similar rights of access, correction, deletion, portability, and opt-out of targeted advertising, sale, or certain profiling. We extend the request process described above to all users regardless of residence and will honor requests as required by the law applicable to you. New York residents may also contact us with any privacy question or complaint, and may direct concerns to the New York Attorney General’s Bureau of Internet and Technology.

9.4 Marketing Choices

You may opt out of marketing emails at any time by using the unsubscribe link in any message or contacting us. We will continue to send transactional and service communications as needed.

10. Automated Decision-Making

We do not use personal information collected through the Services to make decisions that produce legal or similarly significant effects concerning you (such as decisions about employment, credit, housing, or insurance) without human involvement. If that changes, we will update this Privacy Policy and provide any notices and rights required by applicable law, including California regulations governing automated decision-making technology.

11. Third-Party Sites and Services

The Services may link to third-party websites, platforms, and services (including scheduling tools, social media, and payment processors) that operate under their own privacy policies. We are not responsible for the privacy practices of third parties, and this Privacy Policy does not apply to information you provide to them.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top indicates when it was most recently revised. If we make material changes, we will provide prominent notice on the Site and, where required by law, obtain consent. Changes are effective when posted unless otherwise stated.

13. Contact Us

Emergent Systems, LLC
d/b/a The Chalfant Group
Attn: Privacy
PO Box 251
Delmar, NY 12054