We are committed to protecting your privacy. This policy explains in plain language what information we collect, how we use it, and what your rights are, across both our advisory services and our software services. If you have questions, contact us at cbuentello@cbstrategicadvisors.com.
1. Who We Are
This Privacy Policy is issued by CB Investment Holdings, LLC, a Texas limited liability company, operating as CB Strategic Advisors (business advisory and financial consulting) and Novix IQ (software and data services). In this policy, "we," "us," and "our" refer to CB Investment Holdings, LLC and both of these business lines. Our principal place of business is Brownsville, Cameron County, Texas.
This single policy covers our public website, our advisory engagements, and the Novix IQ software applications we provide to business customers.
Contact:
CB Investment Holdings, LLC
dba CB Strategic Advisors and Novix IQ
Brownsville, Texas
cbuentello@cbstrategicadvisors.com
(956) 708-6776
2. Scope of This Policy
This policy applies to two distinct relationships, and the information we handle differs in each:
- Website visitors and advisory clients (CB Strategic Advisors): people who contact us, schedule consultations, or engage us for business advisory and financial services.
- Software customers and their users (Novix IQ): businesses that subscribe to our software applications, and the individual users those businesses authorize to use the applications.
For software customers, an important distinction applies. When a business uses a Novix IQ application, that business controls the data it enters and is the "controller" of that data. We act as the "processor," handling the data on the business's behalf and under its instructions. The terms governing that processing are set out in our Data Processing Addendum. This Privacy Policy governs the information we determine the purposes for, such as account administration, billing, and website analytics.
3. Information We Collect
From website visitors and advisory clients
- Contact form submissions: your name, company name, email address, and any message you write, transmitted through Formspree, our form processing service.
- Scheduling: when you schedule a consultation through Calendly, it collects your name, email address, and any responses to scheduling questions, subject to Calendly's Privacy Policy.
- Confidentiality agreement: if you accept our mutual confidentiality agreement online, we record your name, email, optional company, and the fact and time of your acceptance.
- Engagement records: information you share during advisory work, which is treated as confidential under our Mutual Non-Disclosure and Confidentiality Agreement.
From software (Novix IQ) customers and their users
- Account and billing data: business name, authorized user names and email addresses, role assignments, and subscription and payment records.
- Application content you submit: depending on the application and the modules a customer enables, this may include visitor and entry logs, photographs (including identification and security-seal images), GPS location stamps captured at the point of entry, customs and trade documentation, and compliance records such as those used for C-TPAT or other security programs.
- Usage and technical data: log-in events, feature usage counts, device and browser information, and error reports, used to operate, secure, and improve the applications.
The specific categories of application content depend entirely on which application a customer uses and which features the customer turns on. A customer's own configuration and its agreement with its users govern what is collected within its account.
Collected automatically on our website
- Server logs: standard logs may record your IP address, browser type, referring pages, and pages visited, used for security and technical troubleshooting.
- Cookies and analytics: our website uses minimal cookies. Google Analytics, where enabled, uses cookies to collect anonymized usage statistics. You can opt out at tools.google.com/dlpage/gaoptout.
4. How We Use Your Information
We use information to provide and support the services you or your business have requested. Specifically:
- To respond to inquiries and conduct scheduled consultations
- To deliver and administer advisory engagements
- To provide, secure, maintain, and improve the Novix IQ applications
- To administer accounts, authenticate users, and process billing
- To meet legal, regulatory, and security obligations
- To understand and improve the performance of our website (aggregated, anonymized data only)
We do not sell your personal information, and we do not use it for automated advertising, profiling, or any purpose unrelated to the services you requested. We do not use customer application content to train artificial intelligence models for other customers.
5. How We Share Your Information
We do not sell, rent, or trade your personal information. We share information only with service providers ("sub-processors") that help us operate, and only as needed to deliver our services. Our current providers are:
| Provider | Purpose |
|---|---|
| Cloudflare | Website and application hosting, security, content delivery, and file storage. Privacy policy |
| Supabase | Application database and authentication for Novix IQ software. Privacy policy |
| Anthropic | Artificial intelligence features within certain applications, where enabled. Privacy policy |
| Resend | Transactional email from the applications (for example, account and notification messages). Privacy policy |
| SignWell | Electronic signature of documents and agreements. Privacy policy |
| Formspree | Contact form processing on our website. Privacy policy |
| Calendly | Consultation scheduling. Privacy policy |
| Google Analytics | Anonymized website usage statistics, where enabled. Privacy policy |
We keep this list current. For Novix IQ software customers, the sub-processors that handle customer data, and the customer's right to advance notice of changes, are addressed in the Data Processing Addendum.
We may also disclose information when required by law, court order, subpoena, or government authority, consistent with our confidentiality obligations. If we are ever involved in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction, subject to this policy.
6. Confidentiality of Advisory Communications
Business information shared during consultations and advisory engagements is treated as confidential under our Mutual Non-Disclosure and Confidentiality Agreement. Please review that agreement for the complete terms governing confidentiality of advisory communications.
7. Data Retention
We retain information only as long as needed for the purpose it was collected and to meet legal obligations.
- Inquiries with no engagement: retained no longer than two years.
- Advisory engagement records: retained for the duration of the engagement and as required by applicable professional, tax, and legal obligations.
- Software (Novix IQ) customer data: retained for the term of the subscription and the period set in the customer's agreement and configured retention settings. On termination, customer data is deleted or returned as described in the Data Processing Addendum. Certain compliance records (for example, customs or security program records) may be subject to legally mandated retention periods set by the applicable regulator, not by us.
You may request deletion of your information at any time by contacting us. Where you are a user within a business customer's software account, please also direct deletion requests to that business, which controls the account.
8. Legal Bases for Processing
Where data protection laws such as the EU or UK General Data Protection Regulation (GDPR), or Mexico's Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP), apply to our processing, we process personal data only where we have a lawful basis to do so. Depending on the situation, those bases are:
- Consent: where you have given consent for a specific purpose;
- Contract: where processing is necessary to perform a contract with you or your organization, such as delivering an advisory engagement or the software you subscribed to;
- Legal obligation: where we must process data to comply with the law;
- Legitimate interests: where processing is necessary to operate, secure, support, and improve our services, and is not overridden by your rights and interests.
Where we rely on consent, you may withdraw it at any time. Where we rely on legitimate interests, you may object. Withdrawing consent or objecting does not affect processing already carried out, and may limit our ability to provide a service.
9. Your Rights
Depending on your location, you may have the right to:
- Request access to the personal information we hold about you
- Request correction of inaccurate or incomplete information
- Request deletion of your information, subject to legal retention obligations
- Object to, restrict, or limit our use of your information
- Request a portable copy of the information you provided, in a machine-readable form
- Withdraw consent where processing is based on consent
- Opt out of future communications from us
- Lodge a complaint with your local data protection or supervisory authority
To exercise any of these rights, contact us at cbuentello@cbstrategicadvisors.com or (956) 708-6776. We will respond within 30 days, or sooner where required by law, and will not discriminate against you for exercising a right. For data held inside a Novix IQ software account on behalf of a business customer, we will refer your request to that customer, who is the controller of that data.
Our website honors recognized browser opt-out preference signals, including Global Privacy Control (GPC), where applicable law requires us to. We do not track users across unaffiliated third-party websites for advertising.
10. Your US State Privacy Rights
If you are a resident of Texas, California, or another US state with a comprehensive consumer privacy law, you may have rights to access, correct, delete, and obtain a portable copy of your personal data, and to opt out of targeted advertising, the sale of personal data, or certain profiling. The Texas Data Privacy and Security Act (TDPSA) and the California Consumer Privacy Act (CCPA), among others, provide these rights to eligible residents.
We do not sell personal data, and we do not use it for cross-context behavioral or targeted advertising. To exercise your state-law rights, contact us using the details in the Contact section. You may appeal a decision we make about your request by replying to our response.
11. Security
We take reasonable precautions to protect your information. Our website and applications are served over HTTPS, access is restricted by role, and we use reputable infrastructure providers. However, no method of internet transmission or electronic storage is completely secure, and we cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will notify you and any affected business customer as required by applicable law.
12. International Data Transfers
Our services are operated from the United States, and information we handle is processed and stored in the United States. If you access our services from the European Union, the United Kingdom, Mexico, or elsewhere outside the United States, your information will be transferred to and processed in the United States, which may not provide the same level of data protection as the laws of your home jurisdiction.
Where required by applicable law, we use appropriate safeguards for cross-border transfers, such as the European Commission's Standard Contractual Clauses (with the UK Addendum where relevant) or other legally recognized transfer mechanisms. A copy of the relevant safeguard is available on request. For Novix IQ software customers, transfer terms are also addressed in the Data Processing Addendum.
13. Children's Privacy
Our services are directed exclusively to businesses and business professionals. We do not knowingly collect personal information from anyone under the age of 18. If we learn we have inadvertently done so, we will delete it promptly.
14. Governing Law
This Privacy Policy is governed by the laws of the State of Texas, without regard to conflicts of law principles. Any disputes arising from this policy are subject to the jurisdiction of the state and federal courts located in Cameron County, Texas.
15. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page. Continued use of our website or services following any change constitutes acceptance of the updated policy. For material changes affecting software customers, we will provide notice as set out in the applicable agreement.
16. Contact Us
If you have questions about this Privacy Policy or how we handle your information:
CB Investment Holdings, LLC
dba CB Strategic Advisors and Novix IQ
Brownsville, Texas
cbuentello@cbstrategicadvisors.com
(956) 708-6776
linkedin.com/in/carlosbuentello