Privacy Policy
Last updated: April 2026
Introduction
Raymond Payne ("I," "we," "us," or "our") respects your privacy and is committed to protecting it. This Privacy Policy explains how I collect, use, store, and protect your personal information when you visit raymondpayne.com (the "Website"), use our services, or interact with us through other channels.
Data Controller
Raymond Payne (sole proprietor, trading as "Raymond Payne")
Email: raymond@raymondpayne.com
Location: Toronto, Canada & São Paulo, Brazil
Data Protection Officer / Privacy Contact: raymond@raymondpayne.com
Information We Collect
Information You Provide to Us
When you interact with us, you may provide:
- Full name and email address
- Company name, title, and industry
- Phone number and business address
- Service interests and business challenges
- Message content and any documents you attach
- Calendar availability and meeting preferences (via Calendly)
Information Collected Automatically
When you visit the Website, we automatically collect:
Technical Information
- Browser type and version
- Operating system
- IP address (anonymized via Google Analytics)
- Device type and screen resolution
- Internet connection speed and type
Behavioral Information
- Pages visited and time spent on each page
- Referring URL and search terms
- Links clicked and actions taken
- Scroll depth and engagement metrics
- Error messages or crashes
Tracking Information
Information is collected through cookies, web beacons, and tracking pixels placed by analytics and advertising platforms (detailed below).
Legal Basis for Processing Your Information
Under applicable privacy laws (GDPR, LGPD, PIPEDA, etc.), we process your information based on the following legal grounds:
Consent
For analytics, marketing cookies, and newsletter subscriptions, we rely on your explicit consent. You can withdraw consent at any time via the cookie banner or by emailing us.
Performance of a Contract
We process information needed to provide advisory services, book appointments via Calendly, or send invoices.
Legitimate Interests
We process information to improve our Website, prevent fraud, ensure security, and understand how our services are used. Our legitimate interests do not override your privacy rights.
Legal Obligation
We may process information to comply with applicable laws, court orders, or regulatory requests.
How We Use Your Information
We use the information we collect for the following purposes:
- Respond to Inquiries: If you contact us via the website form or email, we'll respond within 24 hours.
- Manage Appointments: Schedule and conduct discovery calls, consultations, and meetings through Calendly.
- Deliver Services: Provide AI strategy assessments, vCAIO services, workshops, and advisory services; maintain engagement with clients.
- Send Communications: Send newsletters, insights, and updates (only if you've opted in). You can unsubscribe at any time.
- Improve the Website: Analyze usage patterns to understand what content resonates and improve user experience.
- Marketing and Audience Building: Retarget website visitors with relevant content through Meta and LinkedIn (with consent).
- Security and Fraud Prevention: Detect and prevent fraud, abuse, and unauthorized access.
- Legal Compliance: Comply with legal obligations and respond to lawful requests from authorities.
Cookies and Tracking Technologies
The Website uses cookies and similar technologies to improve your experience and measure performance. Below is a detailed breakdown of each tracking tool:
Google Analytics 4 (GA4)
- Purpose: Measure page views, user behavior, traffic sources, and engagement metrics
- Data Collected: Anonymized IP address, browser type, pages visited, session duration, events
- Retention: 14 months (user-initiated data deleted after 14 months of inactivity)
- Tracking ID: G-3TTNJV17TQ
- Consent: Required in EU/UK/Canada; implied consent in other regions
- Google's Policy: Google Privacy Policy
Google Tag Manager (GTM)
- Purpose: Manage and deploy analytics and marketing tags
- Data Collected: Depends on configured tags (GA4, Meta, LinkedIn)
- Container ID: GTM-K927FXT9
- Google's Policy: Google Privacy Policy
Meta Pixel (Facebook Conversion Tracking)
- Purpose: Track website conversions and build custom audiences for retargeting ads
- Data Collected: Pixel ID, page visits, button clicks, form completions, IP address, browser info
- Retention: Up to 180 days (user can opt out)
- Pixel ID: 1484243999887806
- Consent: Required for marketing purposes under GDPR/CCPA/LGPD
- Meta's Policy: Meta Privacy Policy
LinkedIn Insight Tag
- Purpose: Track conversions and build audiences for LinkedIn advertising
- Data Collected: Page views, clicks, form submissions, partner ID, IP address
- Retention: 30 days (unless matched to LinkedIn member)
- Partner ID: 9912353
- Consent: Required for marketing purposes under GDPR/CCPA/LGPD
- LinkedIn's Policy: LinkedIn Privacy Policy
Managing Cookies
You can manage your cookie preferences using the cookie banner at the bottom of the site. You can also:
Data Sharing and Third-Party Processors
We do not sell your personal information. We only share data with trusted third-party processors who help us deliver services. All third parties are contractually bound to protect your data.
Google (Analytics, Tag Manager, Fonts)
- Anonymized IP, browser info, page views, events
- Analytics and performance measurement
- Data transferred to US servers (see Data Transfers section)
- Data Processing Agreement: Google Data Processing Terms
Meta (Facebook Pixel)
- Page events, conversions, audience data
- Advertising and retargeting
- Data transferred to US servers (see Data Transfers section)
- Data Processing Agreement: Meta Data Processing Terms
LinkedIn (Insight Tag)
- Page views, conversions, partner ID
- Advertising and audience building
- Data transferred to US/Ireland servers
- Data Processing Agreement: LinkedIn DPA
Calendly (Appointment Scheduling)
- Name, email, timezone, meeting availability
- Schedule and manage appointments
- Privacy Policy: Calendly Privacy Policy
Email Service Provider (Newsletter)
- Email address, name, engagement metrics
- Send newsletters and updates
- We only send emails to those who have explicitly opted in
Legal Compliance
We may disclose your information if required by law, court order, or government request. We will notify you of such requests unless legally prohibited.
International Data Transfers
As a Canada-based business with clients worldwide, your data may be transferred across borders:
Data Flow
- Canada → US (Google, Meta, LinkedIn)
- Canada/Brazil ↔ US (Calendly, email)
- EU visitors → US (with Standard Contractual Clauses)
Legal Mechanisms
- Standard Contractual Clauses (SCCs): Used for EU → US transfers (Google, Meta, LinkedIn, Calendly)
- Canada-US: Covered under USMCA and adequacy agreements for personal data
- Brazil-US: LGPD-compliant transfers via Binding Corporate Rules (for personal clients)
Schrems II Impact
Following the Schrems II ruling, we have implemented supplementary safeguards including encryption, access controls, and audit mechanisms with our US-based processors (Google, Meta, LinkedIn) to ensure adequate protection under GDPR.
How Long We Keep Your Information
- Contact Form Data: 2 years (unless you become a client or unsubscribe)
- Client Information: For the duration of our engagement + 7 years (legal/tax compliance)
- Newsletter Subscribers: Until you unsubscribe
- Analytics Data: 14 months (Google Analytics default); automatically deleted thereafter
- Marketing Cookies: 180 days (Meta); 30-90 days (LinkedIn)
- Backup/Archive: May be retained for up to 1 year for disaster recovery
You can request deletion of your data at any time. We will honor requests within 30 days, subject to legal obligations.
Your Privacy Rights
Depending on where you are located, you have specific rights under applicable privacy laws. You can exercise these rights by emailing raymond@raymondpayne.com.
Universal Rights (All Users)
- Right to Access: Request a copy of all personal information we hold about you
- Right to Correction: Update or correct inaccurate or incomplete information
- Right to Deletion: Request deletion of your data (subject to legal retention obligations)
- Right to Opt-Out: Unsubscribe from emails, newsletters, and marketing communications at any time
EU, UK, and EEA Residents (GDPR / UK GDPR)
- Right to Data Portability: Receive your data in a portable, machine-readable format (e.g., CSV, JSON)
- Right to Restrict Processing: Limit how we use your data while a complaint or correction request is pending
- Right to Object: Object to processing based on legitimate interests or direct marketing
- Right to Withdraw Consent: Withdraw consent for marketing, analytics, or cookies at any time (without affecting past processing)
- Right to Complain: Lodge a complaint with your local data protection authority
California Residents (CCPA / CPRA)
- Right to Know: Request what personal information is collected and how it's used
- Right to Delete: Request deletion of personal information (with limited exceptions)
- Right to Opt-Out of Sale or Sharing: We do not sell your data. If you have concerns, contact us
- Right to Non-Discrimination: We do not discriminate for exercising your rights
Brazil Residents (LGPD)
- Right to Confirmation: Confirm whether we process your personal data
- Right to Access: Access detailed information about how your data is used
- Right to Correction: Correct incomplete, inaccurate, or outdated data
- Right to Anonymization: Request anonymization of your data
- Right to Portability: Receive data in portable format; transfer to another provider
- Right to Deletion: Request deletion of data (except where legally required to retain)
- Right to Information About Sharing: Know which third parties your data is shared with
- Right to Withdraw Consent: Withdraw consent at any time
Canada Residents (PIPEDA / CASL / Bill C-27)
- Right to Access: Request access to your personal information
- Right to Correction: Request correction of inaccurate information
- Right to Complain: Lodge a complaint with Canada's Privacy Commissioner
- Right to Opt-Out of Marketing Emails: Unsubscribe from emails per CASL requirements (includes unsubscribe link in all emails)
Australia Residents (Privacy Act / Australian Privacy Principles)
- Right to Access: Request access to personal information we hold
- Right to Correction: Request correction of inaccurate or incomplete information
- Right to Complain: Lodge a complaint with Australia's Office of the Australian Information Commissioner (OAIC)
New Zealand Residents (Privacy Act 2020)
- Right to Access: Request access to personal information we hold
- Right to Correction: Request correction of inaccurate or incomplete information
- Right to Complain: Lodge a complaint with New Zealand's Privacy Commissioner
Children's Privacy
The Website is not directed at children under 16 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 16, we will delete it promptly. If you believe we have collected information from a child, please contact us immediately at raymond@raymondpayne.com.
Do Not Track / Global Privacy Control Signals
Some browsers include a "Do Not Track" (DNT) feature. While we respect DNT signals, we cannot guarantee all third-party vendors (Google, Meta, LinkedIn) honor them. We support Global Privacy Control (GPC) signals: if you send a GPC signal, we will honor your preference to limit the sale and sharing of your data (where applicable by law).
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in law, our practices, or other factors. We will notify you by updating the "Last updated" date at the top of this page. Significant changes will be announced via email or a prominent notice on the Website. Your continued use of the Website after changes means you accept the updated policy.
Contact Information
If you have questions about this Privacy Policy, wish to exercise your rights, or have concerns about how your data is handled, please contact:
Raymond Payne
Email: raymond@raymondpayne.com
Office: Toronto, Canada & São Paulo, Brazil
Response Time: Within 14 days (or as required by law)
Lodging Complaints
If you believe we have violated your privacy rights, you have the right to lodge a complaint with your local data protection authority:
I take privacy seriously and am committed to protecting your data. This privacy policy reflects best practices under GDPR, CCPA, LGPD, PIPEDA, and other applicable regulations.