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:

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

From software (Novix IQ) customers and their users

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

4. How We Use Your Information

We use information to provide and support the services you or your business have requested. Specifically:

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:

ProviderPurpose
CloudflareWebsite and application hosting, security, content delivery, and file storage. Privacy policy
SupabaseApplication database and authentication for Novix IQ software. Privacy policy
AnthropicArtificial intelligence features within certain applications, where enabled. Privacy policy
ResendTransactional email from the applications (for example, account and notification messages). Privacy policy
SignWellElectronic signature of documents and agreements. Privacy policy
FormspreeContact form processing on our website. Privacy policy
CalendlyConsultation scheduling. Privacy policy
Google AnalyticsAnonymized 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.

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:

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:

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