PRIVACY POLICY
Wohlfpack Collective, LLC d/b/a 56Networks
Effective Date: 1/1/2026
SECTION I: INTRODUCTION
56Networks ("Company," "we," "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal data in connection with the 56Networks website (Website) and our information technology managed services (Services). This Policy applies to personal data of Colorado residents processed by us, in compliance with the Colorado Privacy Act (CPA, Colo. Rev. Stat. § 6-1-1301 et seq.), and other applicable U.S. federal laws (e.g., FTC Act, CAN-SPAM, COPPA). It is governed by Colorado law. For non-Colorado users, it applies to U.S.-based interactions only. If you are a client, this Policy covers data we process as a service provider, but your primary data protections are governed by third-party providers (see Section III).
SECTION II: INFORMATION COLLECTION
We collect only the minimal personal data necessary to provide our Services, process payments, communicate, and ensure security, in line with CPA data minimization requirements. Categories of personal data we may collect include:
Contact Information, such as name, email address, and phone number for account creation and support.
Billing and payment information (e.g., transaction details), submitted through the Company's payment processor; we do not store full credit card numbers or sensitive financial data.
Basic technical metadata, such as IP address and device information, for security, diagnostics, and fraud prevention.
We do not collect sensitive data (as defined by CPA, e.g., racial or ethnic origins, religious beliefs, health information, sexual orientation, citizenship, or precise geolocation) unless explicitly provided by you for service needs (e.g., in support tickets). We do not store customer business content, mailbox content, productivity system data, or platform data on Company-owned infrastructure. Automatic collection may occur via cookies or logs for website functionality (see Section V for details).
SECTION III: INFORMATION USE
We process personal data for the following purposes:
To provide and manage Services (e.g., account setup, support).
To process payments and billing.
To communicate transactionally (e.g., confirmations, alerts).
For operational security, capacity monitoring, and website performance.
We retain personal data only as long as necessary for these purposes (e.g., billing data for 7 years per tax laws; contact info until account deletion) or as required by law. We do not sell personal data (as defined by CPA) or use it for targeted advertising or profiling.
SECTION IV: THIRD-PARTY PROVIDERS AND DATA SHARING
As an information technology managed service provider, we rely on trusted third-party providers for platform functions, such as Cloudflare, Google, Microsoft, and Hostinger. Customer data remains resident on those providers' systems at all times; we do not maintain persistent storage outside these platforms. We enter Data Processing Agreements (DPA) with providers to ensure they comply with CPA and other laws, including safeguards for data transfers. Data is stored in U.S. data centers and not transferred internationally without appropriate protections. We may share personal data with the following entities:
Service providers acting as processors (e.g., the above).
Affiliates for operational support.
Legal authorities if required (see Section IX).
For full details, review provider policies below. You consent to such sharing by using our Services.
SECTION V: COMMUNICATIONS AND ANALYTICS
a. COMMUNICATIONS
We send only transactional communications, including account setup confirmations, support responses, subscription billing notifications, and critical service alerts (e.g., security updates). We do not engage in automated bulk email marketing or profiling. You can opt out of non-essential communications (e.g., newsletters) by clicking unsubscribe links or emailing support@56networks.com. We comply with the CAN-SPAM Act.
b. ANALYTICS
We use minimal, privacy-forward analytics (e.g., Cloudflare for security and performance monitoring) solely for operational purposes. We do not use advertising tracking, behavioral retargeting, cross-site profiling, or third-party cookies for non-essential purposes. Our Website may use essential cookies for functionality; you can manage preferences via browser settings.
SECTION VI: PAYMENT PROCESSING
All payments are handled securely by Stripe, a PCI DSS-compliant processor. We do not store full credit card numbers or access unencrypted payment data. Any retained metadata (e.g., transaction IDs) is used only for billing reconciliation.
SECTION VII: CHILDREN’S PRIVACY
Our Website and Services are not intended for children under 13. We do not knowingly collect personal data from children under 13 and comply with the Children’s Online Privacy Protection Act (COPPA). If we learn of such collection, we will delete it promptly.
SECTION VIII: DATA SECURITY AND BREACH NOTIFICATION
We implement reasonable administrative, technical, and physical safeguards to protect the limited personal data we handle, including encryption in transit, access controls, regular security audits, and employee training. As an MSP, customers remain responsible for managing access permissions in third-party provider accounts. Despite these measures, no system is fully secure, and we cannot guarantee absolute protection. In the event of a data breach posing a risk to consumers, we will notify affected Colorado residents without unreasonable delay (and no later than 60 days, per CPA), as well as the Colorado Attorney General if required.
SECTION IX: DISCLOSURE OF PERSONAL DATA
We do not sell personal data or disclose it for monetary or other valuable consideration. Disclosures are limited to:
Complying with lawful requests (e.g., subpoenas, court orders).
Protecting the rights, property, or safety of the Company, customers, or others.
Enforcing our terms or as required by legal process.
We may also disclose aggregated, anonymized data for business purposes, which does not identify individuals.
SECTION X: COLORADO PRIVACY RIGHTS
As a Colorado resident, you have the following rights under the CPA:
Right to Know/Access: Request details on personal data we collect, use, or disclose (up to twice per 12 months).
Right to Correct: Request correction of inaccurate personal data.
Right to Delete: Request deletion of personal data (subject to legal exceptions, e.g., billing records).
Right to Opt-Out: Opt out of processing for targeted advertising, data sales (none occur), or profiling (none occur).
Right to Data Portability: Receive personal data in a portable format.
Right to Appeal: Appeal denials of rights requests.
To exercise these rights, submit a verifiable request to privacy@56networks.com, including your name, email, and description of the request. We will respond within 45 days (extendable to 90 days). We do not discriminate against rights exercisers (e.g., no denial of services). For appeals, reply to our response email within 60 days; we will notify you of the outcome within 60 days. Agents may submit on your behalf with authorization.
SECTION XI: CHANGES TO THIS POLICY
We may update this Privacy Policy to reflect changes in our practices or laws. Material changes will be posted on our Website with notice via email or in-app alert at least 30 days in advance. Continued use after changes constitutes acceptance. Check the Effective Date for the latest version.
SECTION XII: CONTACT US
For questions, rights requests, or concerns about this Privacy Policy, contact: support@56networks.com
Last Updated: 12/1/2025
This Privacy Policy may be subject to further revisions.
