Privacy Policy

1. Who We Are

Arrowhead Advisory Group LLC ("Arrowhead," "we," "our," or "us") is a payments infrastructure and advisory holding company. This Privacy Policy applies to information collected through the websites and digital properties operated by Arrowhead Advisory Group LLC and its portfolio companies, including arrowheadadvisorygroup.com, 0030.io, penumbrahq.com, aquiferhq.com, echelon.institute, and merchantkings.com (collectively, the "Sites").

By using any of our Sites, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Information We Collect

Information You Provide Directly

We collect information you voluntarily provide when you:

• Submit a contact form, inquiry, or application on any of our Sites
• Request a demo, early access, or more information about our products or services
• Apply to join the Echelon program or request a franchise territory through Merchant Kings
• Communicate with us by email or other channels

This information may include your name, email address, phone number, company name, business type, and any other information you choose to provide.

Information Collected Automatically

When you visit our Sites, we may automatically collect certain technical information, including:

• IP address and approximate geographic location
• Browser type and version, operating system, and device type
• Pages visited, time on page, and navigation path
• Referring URL and exit URL
• Date and time of visit

This information is collected through server logs, cookies, and third-party analytics tools such as Google Analytics. See Section 5 for more information about cookies.

Information from Third Parties

We may receive information about you from third-party services if you interact with us through those services, or from publicly available sources in connection with business development or partnership activities.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To respond to your inquiries, applications, and requests
• To communicate with you about our products, services, and programs
• To evaluate applications for the Echelon program, Merchant Kings franchise territories, or other partnership arrangements
• To operate, maintain, and improve our Sites and services
• To analyze how visitors use our Sites and to improve the user experience
• To send you marketing or informational communications, where you have consented or where permitted by law
• To comply with legal obligations and enforce our terms and agreements
• To protect the security and integrity of our Sites and operations

We do not use your information for automated decision-making that produces legal or similarly significant effects without human review.

4. How We Share Your Information

We do not sell your personal information to third parties. We may share your information in the following circumstances:

Service Providers

We work with third-party service providers who assist us in operating our Sites and communicating with you. These providers are contractually obligated to use your information only as directed by us and to maintain appropriate security measures. Categories of service providers include email delivery services, analytics providers, web hosting providers, and CRM platforms.

Portfolio Companies

Arrowhead Advisory Group operates multiple portfolio companies, including 0030 Payments, Penumbra, AquiferHQ, Echelon, and Merchant Kings. If you submit an inquiry that is most appropriately handled by one of our portfolio companies, we may share your information with that entity. All portfolio companies operate under consistent data handling standards.

Legal Requirements

We may disclose your information when required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, prevent fraud, or ensure the safety of our users or the public.

Business Transfers

In connection with a merger, acquisition, financing, or sale of all or substantially all of our assets, your information may be transferred to the acquiring or successor entity. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

5. Cookies and Tracking Technologies

Our Sites use cookies and similar tracking technologies to enhance your experience and collect usage data. Cookies are small text files stored on your device when you visit a website.

Types of Cookies We Use

• Essential cookies: Required for the Sites to function properly. These cannot be disabled.
• Analytics cookies: Help us understand how visitors interact with our Sites. We use Google Analytics (GA4) for this purpose. Analytics data is aggregated and anonymized where possible.
• Preference cookies: Remember your settings, such as your color theme preference.

Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies. Note that disabling certain cookies may affect the functionality of our Sites. You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria we use to determine retention periods include the nature of the information, the purpose for which it was collected, and any applicable legal requirements.

When we no longer need your personal information, we will securely delete or anonymize it.

7. Your Rights and Choices

Depending on your location and applicable law, you may have the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete personal information
• Request deletion of your personal information, subject to certain exceptions
• Object to or restrict certain types of processing
• Opt out of marketing communications at any time by using the unsubscribe link in any email we send or by contacting us directly
• Withdraw consent where processing is based on consent

To exercise any of these rights, please contact us at the address provided in Section 12. We will respond to verifiable requests within the timeframes required by applicable law.

8. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Right to Know

You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collected it, our business purpose for collecting it, and the categories of third parties with whom we share it.

Right to Delete

You have the right to request that we delete personal information we have collected from you, subject to certain exceptions permitted by law.

Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you.

Right to Opt Out of Sale or Sharing

We do not sell personal information as that term is defined under the CCPA/CPRA. We do not share personal information with third parties for cross-context behavioral advertising purposes.

If this changes, you will have the right to opt out. To exercise this right at any time, click the link below or contact us at the address in Section 12.

Do Not Sell or Share My Personal Information

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights.

Submitting a Request

To submit a verifiable consumer request, email us at privacy@arrowheadadvisorygroup.com with the subject line "California Privacy Request." We will respond within 45 days. We may need to verify your identity before processing your request.

9. Children's Privacy

Our Sites are not directed to individuals under the age of 18, and we do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a minor, we will take steps to delete that information promptly. If you believe we have collected information from a minor, please contact us at privacy@arrowheadadvisorygroup.com.

10. Security

We implement reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, use, alteration, and disclosure. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

If you have reason to believe that your personal information has been compromised, please contact us immediately at privacy@arrowheadadvisorygroup.com.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, provide additional notice. Your continued use of our Sites after any changes become effective constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: