Privacy Policy

This Privacy Policy describes how CW Intelligent Systems ("CWIS," "we," "us," or "our"), a division of G.C.E. Inc., collects, uses, discloses, and protects your personal information when you visit our website at cwis.systems, use our services, or otherwise interact with us. By using our website or engaging our services, you agree to the practices described in this policy.

CWIS is based in Milwaukee, Wisconsin, and provides custom, locally deployed AI solutions for businesses and individuals. Our core commitment is to data privacy — the AI systems we build run entirely on our clients' own hardware, and client data never leaves their premises.

1. Information We Collect

1.1 Information You Provide Directly

We collect information that you voluntarily provide to us, including:

• Contact Form Submissions: When you submit a message through our website contact form (powered by FormSubmit.co), we receive your name, email address, and the content of your message.
• Scheduling Information: When you book a consultation through our Calendly scheduling widget, Calendly collects your name, email address, and any information you provide in the booking form. We receive this information through our Calendly account.
• Phone Communications: When you call us at (414) 301-2069 (a Google Voice number), we may retain your phone number, voicemail recordings, and notes about our conversation. Google Voice processes the call and may retain its own records subject to Google's privacy policies.
• Email Communications: When you email us at [email protected], we retain the content of your email, your email address, and any attachments you send.
• Consultation and Project Information: During consultations and throughout the course of a project, you may provide us with business information, technical requirements, preferences, and other details necessary to deliver our services.

1.2 Information Collected Automatically

When you visit our website, certain information may be collected automatically:

• Cloudflare Analytics: Our website is hosted on Cloudflare Pages. Cloudflare may collect basic web analytics data, including page views, visitor counts, and general geographic information. Cloudflare Web Analytics is privacy-focused and does not use client-side tracking or cookies for analytics purposes.
• Server Logs: Cloudflare may collect standard server log data such as your IP address, browser type, referring URL, pages visited, and timestamps. This data is used for security, performance optimization, and abuse prevention.
• Google Fonts: Our website loads fonts from Google's CDN (fonts.googleapis.com and fonts.gstatic.com). When these fonts load, Google may receive your IP address and browser information. Google's use of this data is subject to Google's Privacy Policy.

1.3 Information We Do Not Collect

Our website does not currently use any first-party analytics, tracking pixels, advertising cookies, or social media tracking tools. We do not engage in behavioral advertising or sell your personal information to third parties.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Responding to Inquiries: To reply to your contact form submissions, emails, and phone calls.
• Scheduling and Consultations: To manage appointment bookings and prepare for consultations.
• Service Delivery: To plan, design, build, install, configure, and support the custom AI systems we create for you. This includes understanding your requirements, selecting appropriate hardware and software, and providing training.
• Project Communication: To communicate with you about project progress, timelines, deliverables, and support matters.
• Billing and Administration: To process payments, maintain records, and manage our business relationship with you.
• Improving Our Services: To understand how our website is used and to improve the quality of our services and website experience.
• Legal Compliance: To comply with applicable laws, regulations, and legal obligations.

3. Third-Party Services

Our website and business operations rely on certain third-party services. Each of these services has its own privacy policy governing how it handles data:

4. Cookies and Tracking Technologies

Our website itself does not set any first-party cookies, tracking pixels, or similar technologies. We do not use any first-party analytics tools, advertising networks, or retargeting services.

However, third-party services embedded on or used by our website may set their own cookies or use similar technologies:

• Cloudflare may set cookies for security purposes, such as bot detection and DDoS protection (e.g., the __cf_bm cookie).
• Calendly may set cookies when the scheduling widget is loaded or used on our contact page.
• Google Fonts CDN requests may include cookies if you are already signed into a Google account in your browser, though Google states that Font API requests do not set or log cookies.

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies. Please note that blocking certain cookies may affect the functionality of third-party features on our website, such as the scheduling widget.

6. Data Security

We take reasonable measures to protect your information from unauthorized access, use, alteration, or destruction. Our security practices include:

• Encryption in Transit: Our website uses SSL/TLS encryption (provided by Cloudflare) to protect data transmitted between your browser and our website.
• Secure Communications: We encourage the use of encrypted communication channels for sensitive project information.
• Local System Security: AI systems we install are configured with appropriate security measures including network segmentation, access controls, and encryption at rest where applicable.
• Limited Access: Only authorized CWIS personnel who need access to your information to perform their duties are granted such access.
• No Cloud Storage of Client Data: Because our AI solutions run locally, your business data is not stored on cloud servers or third-party platforms.

While we strive to protect your information, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to implementing and maintaining appropriate safeguards.

7. Data Retention

We retain your information for the following periods:

• Contact Form Submissions and Emails: Retained for as long as necessary to respond to your inquiry and for our reasonable business records, generally up to three (3) years after last communication, unless a longer retention period is required by law or for ongoing business purposes.
• Calendly Booking Data: Retained in our Calendly account for as long as necessary for scheduling and record-keeping purposes. Calendly may retain its own records subject to its privacy policy.
• Phone Records: Call logs and voicemails through Google Voice are retained for as long as necessary for business purposes. Google may retain its own records subject to its privacy policy.
• Client Project Records: Business records related to completed projects (such as contracts, invoices, project specifications, and correspondence) are retained for a minimum of seven (7) years for tax and legal compliance purposes, or longer if required by law.
• Client Business Data: As described in Section 5, we do not retain your business data on our systems. All client data remains on the client's own hardware.

You may request deletion of your personal information at any time, subject to our legal obligations to retain certain records. See Section 8 for details on exercising your rights.

8. Your Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. We respect and will accommodate these rights to the extent required by applicable law:

• Right of Access: You may request a copy of the personal information we hold about you.
• Right to Correction: You may request that we correct any inaccurate or incomplete personal information we hold about you.
• Right to Deletion: You may request that we delete your personal information, subject to certain legal exceptions (such as our obligation to retain tax and financial records).
• Right to Restrict Processing: You may request that we limit how we use your personal information.
• Right to Data Portability: Where technically feasible, you may request a copy of your personal information in a structured, commonly used, machine-readable format.
• Right to Opt Out: You have the right to opt out of any marketing communications. We do not currently send marketing emails, but if we do in the future, every communication will include an unsubscribe option.

To exercise any of these rights, please contact us using the information provided in Section 13. We will respond to your request within thirty (30) days. We may ask you to verify your identity before processing your request.

We will not discriminate against you for exercising any of your privacy rights.

9. Children's Privacy

Our website and services are not directed to children under the age of thirteen (13). We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately using the information provided in Section 13.

If we become aware that we have collected personal information from a child under the age of 13 without verification of parental consent, we will take steps to delete that information from our records as promptly as possible, in compliance with the Children's Online Privacy Protection Act (COPPA).

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with specific rights regarding your personal information:

• 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 it was collected, the business purpose for collection, and the categories of third parties with whom it is shared.
• Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions.
• Right to Correct: You have the right to request correction of inaccurate personal information.
• Right to Opt Out of Sale or Sharing: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising purposes.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.

Categories of Personal Information Collected: In the preceding twelve (12) months, we may have collected the following categories of personal information: identifiers (name, email address, phone number, IP address); Internet or other electronic network activity information (browser type, pages visited); and professional or employment-related information (business name, job title, provided during consultations).

Sale of Personal Information: CWIS does not sell and has not sold personal information in the preceding twelve (12) months.

To submit a verifiable consumer request under the CCPA/CPRA, please contact us using the information in Section 13. You may also designate an authorized agent to submit a request on your behalf.

11. Wisconsin State Law Compliance

As a business based in Milwaukee, Wisconsin, CWIS complies with applicable Wisconsin state laws governing data privacy and security, including:

• Wisconsin Data Breach Notification Law (Wis. Stat. § 134.98): In the event of a data breach involving your personal information, we will notify affected individuals and, where required, the appropriate regulatory authorities in a timely manner consistent with Wisconsin law. Notification will include a description of the breach, the types of information involved, and steps you can take to protect yourself.
• Wisconsin Consumer Act: We adhere to fair business practices in all our consumer dealings in compliance with Wisconsin consumer protection statutes.
• Record Retention: We maintain business and financial records in accordance with Wisconsin state requirements and applicable federal regulations.

If you are a Wisconsin resident and have questions about your rights under state law, or if you wish to file a complaint, you may also contact the Wisconsin Department of Agriculture, Trade and Consumer Protection (DATCP) at datcp.wi.gov.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will:

• Update the "Last Updated" date at the top of this page.
• Post the revised policy on our website at cwis.systems/privacy.
• For material changes, we may notify you by email if you have provided your email address to us, or by posting a prominent notice on our website.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our website or services after any changes to this policy constitutes your acceptance of the updated terms.

13. Contact Information

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