Privacy Policy

Last updated: 9 September 2026

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Couloir Capital Partners HV, LLC

2650 E Valley View Ave, Salt Lake City - 84117-5450, United States (US)

Email: serve@couloirhv.hair  |  Phone: +19145948642

Table of Contents

  1. Introduction and Scope
  2. Who We Are
  3. Information We Collect
  4. How We Collect Information
  5. How We Use Information
  6. Legal Bases for Processing
  7. When We Share Information
  8. Service Providers and Subprocessors
  9. Data Security Measures
  10. Data Retention Periods
  11. Cookies and Automatic Data
  12. Privacy for Children
  13. Your Rights
  14. California Residents
  15. Other United States Residents
  16. International Transfers
  17. Marketing and Communications
  18. Third Party Links
  19. Changes to This Policy
  20. How to Contact Us

1. Introduction and Scope

This Privacy Policy explains how Couloir Capital Partners HV, LLC, the company that operates the developer practice known as CouloirHV, handles personal information when you visit the website hosted at the couloirhv.hair address, use the services offered there, or otherwise engage with the company by email, telephone or post at the registered address given below.

The policy describes what kinds of personal data may be collected, the reasons for collecting that data, the lawful ways in which the data is used, the parties with whom the data is shared, and the choices and rights that you hold as a visitor, an enquirer or a client. Please read this document carefully before you provide any personal information. Where the text refers to the practice name CouloirHV, it means the design and delivery team that serves the clients of Couloir Capital Partners HV, LLC. Where it refers to the Company, it means Couloir Capital Partners HV, LLC itself.

This policy applies to information gathered on this website, by mail, by electronic mail to serve@couloirhv.hair, by telephone on +19145948642, and in the course of any delivered engagement that the Company carries out for a client. It does not apply to websites run by third parties that you may reach through links placed on this site; each of those sites is governed by its own privacy notice.

2. Who We Are

Couloir Capital Partners HV, LLC is a limited liability company registered in the United States, based at 2650 E Valley View Ave, Salt Lake City - 84117-5450, United States (US). The Company designs computer integrated systems for US operators, including enterprise systems integration, custom software architecture, cloud infrastructure design, legacy system modernisation, data pipeline engineering and IT service management platforms. The company trades and is known to its clients as the CouloirHV practice.

For the purposes of data protection law, the Company acts as the controller of the personal information that it collects from you through this website and through the correspondence channels listed above. The person responsible for data protection within the Company may be reached by writing to the street address above or by sending electronic mail to serve@couloirhv.hair with the phrase Privacy Enquiry written at the head of the message so that the matter is routed to the right desk.

3. Information We Collect

The Company collects only the categories of personal information described in this section, and it does so no more widely than the purpose of the visit or the engagement requires. The categories are set out below, each with an account of why the information is held.

Contact and identity information

When you write to the Company through the station ledger form on the contact page, or by electronic mail or post, the Company may collect your name, your electronic mail address, your telephone number, the subject of your note and the body of the message that you send. This is held so that the Company can answer you on the channel by which you chose to write.

Professional information

If an enquiry matures into an engagement, the Company may collect the name of your employer, your job title, the department in which you work and your business contact details. This information is used to agree the scope of the work, to issue the engagement documents and to keep the delivery in step with the expectations of the commissioning team.

Technical data

The servers that deliver this website record limited technical data associated with each visit, including the internet protocol address of the device making the request, the type of browser in use, the general geographic region indicated by the address and the pages of the site that were requested. This data is described in fuller detail in the section of this policy headed Cookies and Automatic Data.

Correspondence records

The Company keeps a record of the correspondence that it exchanges with a client or an enquirer, including the dates of messages, the substance of the exchanges and the outcome that was reached. These records exist so that the Company can demonstrate what was agreed and so that a later enquiry can be answered with the earlier context in hand.

4. How We Collect Information

The Company gathers personal information through four principal routes, each of which is explained here so that you know where your data comes from and when it may be collected without you actively entering it.

  • Directly from you. You volunteer your contact details when you complete the station ledger form on the contact page, when you send electronic mail to serve@couloirhv.hair, when you telephone the office on +19145948642, or when you post or hand over a written note at the street address.
  • Through the operation of the network. As described in the section on automatic data, the hosting servers log the technical markers of each request in the ordinary course of keeping the service running and protected.
  • From your commissioning team. When the Company is brought into an engagement, a member of your own team may provide the contact details of colleagues who should be party to the delivery, such as the owner of an application estate or the holder of a network account.
  • From publicly available registers. Where the Company needs to verify a business contact, it may consult public company registers or the official website of the organisation concerned, but it does not gather personal data from the open market for the sake of building a mailing list.

5. How We Use Information

Every item of personal information that the Company holds is put to a defined use. The principal uses are described in this section. The Company does not sell personal information to any third party, and it does not use the data it collects for purposes that are incompatible with those described in this policy.

  • To answer an enquiry. When you write through the station ledger, by electronic mail or by telephone, the Company uses your contact details to compose and deliver a reply on the same channel.
  • To agree and carry out an engagement. Information about you and your organisation is used to prepare proposals, statements of work and contracts, and to deliver the services in line with the agreed scope.
  • To keep the site safe and standing. Technical data is used to detect abusive traffic, to stop automated attacks and to diagnose faults so that the site remains a safe place for every visitor.
  • To meet a legal obligation. Where a law, a regulation, a court order or an authority of the United States requires the Company to keep or to hand over certain records, the Company complies within the limits that the law sets.
  • To protect a legitimate interest. The Company may use contact data to guard against fraud, to exercise its rights under a contract, or to defend a claim that is brought against it, always in a manner that weighs the interests of the person concerned.
  • To send service notices. Where the Company already works with you, it may write with operational matters such as planned maintenance, security advisories attached to delivered systems, or the scheduling of a delivery call.

The station ledger on the contact page does not hold a copy of your note on this website. The message is passed to your own electronic mail program and travels to serve@couloirhv.hair by ordinary mail, which means the Company sees your note only when it arrives in the shared inbox of the practice.

6. Legal Bases for Processing

Where a data protection law of a United States state or of another jurisdiction requires the Company to point to a lawful basis before it processes personal information, the Company relies on one or more of the grounds set out below, chosen according to the circumstances of each piece of processing.

  • Consent. Where the Company asks for and receives your clear permission to do a particular thing with your data, such as adding you to a brief operational mailing list, it processes on that consent, and you may withdraw the consent at any time by writing to serve@couloirhv.hair.
  • Performance of a contract. Where the Company is carrying out an engagement agreement with you or your employer, it processes the personal information needed to perform that agreement, including invoicing, delivery, support and aftercare.
  • Compliance with a legal obligation. Where a law of the United States, a state of the United States, or another authority requires the keeping or the disclosure of information, the Company processes on that ground.
  • Legitimate interest. Where a purpose is genuinely beneficial, does not override your fundamental rights, and could not sensibly be met another way, the Company may rely on its legitimate interest. Typical examples are the protection of the website from attack, the prevention of fraud, and the maintenance of accurate records so that the Company may answer later enquiries with its own earlier context in hand.

7. When We Share Information

The Company treats the personal information in its care as belonging to its own operation and does not trade in it. There are, however, a small number of circumstances in which information must pass to another party, and each is set out below so that you can see exactly where your data can travel.

  • Within the practice team. The designers, engineers and administrators of CouloirHV share the data that a piece of work requires, and every member of the team is bound to treat the data in accordance with this policy.
  • To engaged subcontractors. Where the Company brings in a specialist contractor to help deliver an engagement, it shares only the information that the contractor needs, under a binding agreement that restricts further use and protects the data.
  • To legal and accounting advisers. Where necessary to obtain a legal, tax or accounting opinion, records that touch on personal data may be shown to professional advisers, who owe the Company a duty of confidence.
  • To a lawful authority. Where a court, a regulator or a law enforcement body of competent jurisdiction demands records under lawful process, the Company complies to the extent that the law compels and provides only the records that the demand covers.
  • In a business transition. If the Company sells an asset, merges or is otherwise absorbed, the personal records attached to the sold activity pass to the successor under the protection of the same duty to respect this policy.

8. Service Providers and Subprocessors

A small number of trusted service providers hold or touch the Company systems and therefore the personal data that passes through them. Each provider is engaged under a contract that limits the use of the data to the task for which the provider is hired and that requires a standard of protection not lower than the one described in this policy.

  • Hosting and infrastructure providers, who run the servers that serve this website and hold the correspondence that arrives at the shared inbox of the practice.
  • Electronic mail and office productivity services, which carry the messages that the practice sends and receives and which store the records of the practice calendar and files.
  • Secure remote working tools, which may carry video calls or shared screens in the course of a delivery that runs with a client located outside Salt Lake City.
  • Telephony services, which carry the voice line on +19145948642 and may, in the ordinary course of the provider, keep records of the routing of a call.

The current list of named subprocessors is available on request. Write to serve@couloirhv.hair and the practice will furnish the names of the providers engaged at that moment together with the regions in which they store data.

9. Data Security Measures

The protection of personal information is treated as part of the engineering discipline of the practice rather than as an afterthought. The Company applies a combination of organisational, technical and physical controls, scaled to the sensitivity of the data and to the harm that a breach could cause.

  • Encryption in transit. Traffic to this website and traffic between the practice systems travels over channels protected by current cryptography, so that data is not legible if it is intercepted in passage.
  • Encryption at rest. Where a system allows, stored records are protected at the disk or database layer so that data cannot be read from stolen media without the keys.
  • Least privilege access. Each member of the practice and each automated service is granted only the access that its role needs, and nothing more, so that a single compromised account does not lay open the whole store.
  • Managed identities and keys. The Company keeps shared secrets in a managed vault rather than in configuration files or mail, and rotates them on a regular schedule.
  • Backups and recovery. Records are copied to a separate protected location so that an accident or an attack can be recovered without the loss of the whole estate.
  • Trained staff. Everyone who handles data is made aware of the standards of this policy and of the duty to report an anomaly promptly.

No method of storage or of transmission is entirely free of risk, and no promise can be absolute. If the Company learns of a breach that touches personal information in a way that a law requires be reported, it will report within the period that the law sets and will take steps to reduce the harm.

10. Data Retention Periods

The Company keeps personal information only for as long as the purpose that first justified its collection still stands, and it deletes or anonymises the data once that purpose falls away. The period that applies to each class of record is described here so that you have a clear sense of how long the Company can hold your data after it is received.

  • Enquiries that do not become engagements. Correspondence about an enquiry that never matures into a contract is generally kept for 24 months from the last exchange, so that a returning enquirer enjoys the continuity of the earlier conversation, and then retired.
  • Engagement records. The records of a delivered project, including contact details, invoices and delivery notes, are kept for the period required for legal and fiscal reasons, which is usually no less than six full tax years after the close of the financial year in which the work was invoiced.
  • Technical logs. Server logs carry internet protocol addresses and request markers for a limited window, typically 30 days, after which they are overwritten, so that attack traffic can be traced while it is still relevant and then forgotten.
  • Operational mailing entries. If you have consented to receive brief operational notices, your entry is kept until you withdraw the consent or until the address proves inactive, after which it is removed.

11. Cookies and Automatic Data

This website is a plain and quiet crossing. It does not set marketing cookies, does not run advertising trackers, and does not hand data to analytics networks to build a profile of your browsing. The site does, however, generate records in the ordinary operation of a web server, and a small number of purely functional mechanisms may set a short-lived marker on your device.

  • Server logs. Each request to the site records the internet protocol address of the caller, the type of device and browser, the page requested and the instant of the request. These logs protect the service from abuse and are held only briefly as described in the retention section.
  • Essential functional storage. The site stores no account on your device and does not require you to sign in. Nothing on the contact page writes a lasting marker that follows you elsewhere.
  • No third party content. The site draws in no remote advertisements and no embedded feeds, so your visit is not reported onward as a side effect of loading a foreign frame.

Because the site sets no advertising or analytical markers, there is no need for a separate cookie consent banner, and none is used. You do not surrender a browsing history to the practice by reading its pages.

12. Privacy for Children

The services of Couloir Capital Partners HV, LLC are offered to business operators and are not directed at children. The Company does not knowingly collect personal information from children under the age of thirteen, and no part of this website seeks data from a young visitor.

If a parent or guardian believes that a child under thirteen has provided personal information to the Company by mistake, the parent should write at once to serve@couloirhv.hair with the phrase Child Data Enquiry in the subject line. On receipt and verification of the request, the Company will delete the information as soon as is practicable and confirm the deletion in a return note. Where a state law sets a different age for consent, the higher of that age and thirteen is the working threshold for this site.

13. Your Rights

You hold certain rights over the personal information that the Company keeps about you. Not every right is absolute, and some are subject to conditions set by law, but the Company honours the spirit of each request and answers promptly. The principal rights are set out below.

  • The right of access. You may ask for a copy of the personal information that the Company holds about you and for an account of how it is used.
  • The right to rectification. You may ask the Company to correct information that is inaccurate or to complete information that is incomplete.
  • The right to erasure. In some circumstances you may ask the Company to delete your personal information, for example where the data is no longer needed for the purpose for which it was collected.
  • The right to restrict processing. In some circumstances you may ask the Company to hold your data without further using it, for example while a disputed accuracy is being checked.
  • The right to data portability. Where the law so provides, you may ask for the personal information that you gave the Company to be handed to you in a structured, machine-readable form.
  • The right to object. Where the Company processes on a legitimate interest, you may object on grounds relating to your particular situation, and the Company will weigh your ground before continuing.
  • The right to withdraw consent. Where processing rests on consent, you may withdraw that consent at any moment without affecting the lawfulness of what was done before the withdrawal.
  • The right to complain. You may complain to the supervisory authority of your own state or region if you believe that the handling of your data departs from the law.

To exercise any of these rights, write to serve@couloirhv.hair or post a letter to the street address at the head of this policy. The Company will verify your identity before acting on a request, and will respond within the window that the governing law allows, normally no later than thirty days. Providing a request does not cost you a fee unless a law allows a reasonable charge for a repeated or manifestly unfounded demand.

14. California Residents

If you live in California, the California Consumer Privacy Act and its later amendments grant you certain rights over the personal information that a business holds about you. The Company sets out here how it answers to that law for residents of that state.

  • Categories collected. The Company may hold identifiers such as your name, electronic mail address, telephone number and internet protocol address, and limited professional information connected to an engagement, each as described earlier in this policy.
  • Right to know. You may ask the Company to tell you the categories and specific pieces of personal information that it keeps about you, the purposes for which they are used and the categories of recipient with whom they are shared.
  • Right to delete. You may ask the Company to delete the personal information that it holds about you, subject to the exceptions that the law allows, such as the completion of a transaction or the meeting of a legal obligation.
  • Right to correct. You may ask the Company to correct inaccurate personal information about you, and the Company will act with the care that the accuracy of the data warrants.
  • Right to opt out of sale or sharing. The Company does not sell personal information and does not share it for cross-context behavioural advertising, so there is nothing to opt out of at present. If that position ever changes, this policy will be amended and a clear opt out will be given.
  • No discrimination. The Company will not deny you a service, charge you a different price, or treat you differently because you choose to exercise a right under the California law. Any difference in service will rest on a genuine difference in the value of the work, never on the exercise of a right.

To make a request as a California resident, you may write to serve@couloirhv.hair or use the postal address above. The Company will confirm the identity of the person making the request and will respond within forty five days, or within the longer window that the law permits when the claim is complex, in which case the extension will be explained in writing.

15. Other United States Residents

A growing number of states, including Colorado, Connecticut, Utah and Virginia, have enacted consumer privacy laws that share a common design. The Company recognises these laws for the residents they protect and extends the spirit of the rights set out in the earlier section of this policy to those who ask under a state statute of the United States.

A resident of a covered state may ask to know, to access, to delete, to correct and to port personal information, and may direct the Company not to sell or to use the data for targeted advertising. As the Company does not sell personal information, does not profile for advertising and does not build a behavioural picture of its visitors, the principal practical effect of a request from a covered state is the right of access and deletion, both of which the Company will honour in the same way it honours the rights described above. A request must carry enough detail to let the Company verify the identity and to locate the records; the Company will not keep or use the identifying data you supply for the request beyond the task of satisfying it.

16. International Transfers

Couloir Capital Partners HV, LLC is based in the United States and delivers the majority of its work to operators within the United States. Where, in the course of an engagement, information crosses the border of the territory in which you stand, the Company ensures that the transfer is protected by a fitting legal mechanism rather than left to chance.

For a transfer from a jurisdiction whose law shepherds the exit of personal data, the Company relies on the recognised safeguards, on an adequacy decision where one covers the receiving country or on the contractual terms that the law endorses, so that your data keeps its protection as it passes the gate. Where a transfer takes place only because a law of the United States compels the handing over of records to an authority, the Company will satisfy itself that the demand is lawful before it complies, and will keep a record of what the law required.

17. Marketing and Communications

The Company does not send unsolicited marketing to strangers and does not build a purchased list of names upon which to draw. The only messages of an operational or occasional character go to a person who already has a working relationship with the practice or who has asked to receive such notices.

  • Operational notices go to clients, normally about a delivered system, planned maintenance or a security advisory, and are part of carrying out the engagement rather than a separate marketing activity.
  • A brief newsletter may be offered to those who ask for it. It arrives infrequently, carries no third party advertising and includes a plain way to cease receiving it at the foot of every edition.
  • Every operational mail that leaves the practice carries the real name of the sender and the working address of the Company, so that no message is anonymous and no reader is left to wonder who wrote.

18. Third Party Links

This website carries no advertisements and no embedded foreign content, but its pages may from time to time place a link to a document or to a service that is run by a different owner, such as a standards body, a regulator or a client portal. When you leave this site through such a link, you pass beyond the reach of this policy.

The Company cannot accept a duty of care for the practices of a third party site, and it encourages you to read the privacy notice of any site that you visit after leaving the crossing. A link from this site is a convenience and a pointer; it is not an endorsement of the whole data handling of the target, and it does not mean that the Company shares your data with that owner simply because the two addresses appear in the same file.

19. Changes to This Policy

The practice grows, the law moves and the tools of the crossing change, so this policy must be allowed to change with them. The Company reviews the document from time to time and updates the date at the top of the page whenever a revision is published.

Where a change is material, such as a new category of data collected, a new reason for sharing it or a new right for the visitor, the Company will draw the change to the attention of those who hold a working relationship with it and will summarise what has altered at the head of the document. A continuing relationship with the practice after a revised policy is published will be taken as acceptance of the current text. The version that applies to an enquiry is the one that stands at the moment the enquiry is made, unless a later version expressly says otherwise.

20. How to Contact Us

Questions about this policy, about the data that the Company holds about you, or about any of the rights described above should be directed to the desk that answers on privacy. The Company pledges to respond to a genuine enquiry with care and without delay.

Couloir Capital Partners HV, LLC

2650 E Valley View Ave, Salt Lake City - 84117-5450, United States (US)

Email: serve@couloirhv.hair

Telephone: +19145948642

Please use the phrase Privacy Enquiry in the subject line of any electronic mail about this document so that it reaches the right desk on the first pass. If you are not satisfied with the answer that the practice gives, you are free to complain to the office of the state attorney general for your own state or to the appropriate federal authority.

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Couloir Capital Partners HV, LLC  |  2650 E Valley View Ave, Salt Lake City - 84117-5450, United States (US)

serve@couloirhv.hair  |  +19145948642

© 2026 Couloir Capital Partners HV, LLC. The CouloirHV practice. All rights reserved.