PRIVACY POLICY

Talent Fuel

Effective date: August 31, 2026

1. Who we are, and what this policy covers

Talent Fuel is a registered trade name of Cochran Cochran & Yale [LLC / LLP / Inc. — confirm exact legal suffix] ("CCY," "we," or "us"), an executive search firm based in Rochester, New York. Talent Fuel is powered by CCY — it is our newsletter, not a separate company.

We want to be straightforward about what that means. Because Talent Fuel and CCY are the same legal entity, the information you give us as a subscriber is held by CCY. There is no corporate wall between the two, and we are not going to imply there is one.

What there is, instead, is a policy we hold ourselves to. We keep Talent Fuel subscriber information separate from our recruiting records, and Section 3 sets out exactly what that means in practice. If you would rather we did not, Section 8 tells you how to say so.

This policy covers the Talent Fuel newsletter and www.talentfueliq.com. If you are also a candidate, client, or applicant of CCY, that relationship is described in our main privacy policy at [LINK TO CCY PRIVACY POLICY]. Where the two overlap, the one covering how you gave us the information applies.

Questions about any of this? Email info@talentfueliq.com and a person will answer.

2. What we collect

When you subscribe: your email address, and [your first name and company, if you give them]. We also record when you subscribed and which page or link brought you here.

When you pay: payments are processed by PayPal. We never see or store your full card number. From PayPal we receive confirmation of payment, the name on the PayPal account, the email address associated with it, and a transaction ID. Note that the email address on your PayPal account may differ from the one you subscribe with.

When we send you an issue: our email tools record whether you opened it and which links you clicked. This is linked to your email address, not anonymous. We use it to see which topics land and to stop emailing people who have plainly lost interest.

When you visit www.talentfueliq.com: we use Google Analytics for aggregate traffic measurement, and HubSpot, which sets cookies that recognise your browser across visits and records the pages you view.

Worth stating plainly: HubSpot assigns your browser an identifier before we know who you are. If you later subscribe or submit a form, HubSpot links that identifier to you, including pages you viewed before you subscribed. From then on, your reading history on this site is associated with your email address in our contact records.

When you email us: whatever you write, plus your email address.

3. What we do not do

We do not sell, rent, or trade your personal information. Not to sponsors, not to data brokers, not to anyone.

Subscribing does not put you into our recruiting database. Reading Talent Fuel will not cause a recruiter to contact you about a role. If you want that, tell us — it is your choice, not an automatic consequence of subscribing.

We do not tell clients or sponsors who reads Talent Fuel. Not your name, not your employer, not whether you opened an issue.

We do not use your information for cross-context behavioural advertising, and we run no retargeting or advertising pixels on this site.

4. Why we collect it

To send you Talent Fuel. To run and bill your subscription, if you pay. To understand which pieces are read so we can write more of what works. To answer you when you write to us. That is the whole list, and we will tell you before we use your information for anything else.

5. Who else touches your information

Provider: Mailchimp (Intuit)

What it does: Stores our list, sends the newsletter, records opens and clicks

What it receives: Email address, name, engagement history

Provider: HubSpot

What it does: Contact records and website visitor tracking

What it receives: Email address, pages viewed, form submissions, engagement history

Provider: PayPal

What it does: Processes payments

What it receives: Payment and account details you provide to PayPal directly

Provider: Google Analytics

What it does: Aggregate website traffic measurement

What it receives: IP address, browser and device data, pages viewed

Provider: WIX
What it does: Hosts www.talentfueliq.com

What it receives: Server log data, including IP address

Mailchimp, HubSpot, Google, and our host process this information on our behalf and, under our agreements with them, may use it only to provide services to us.

PayPal is different. PayPal is an independent company that handles your payment under its own privacy policy at [https://www.paypal.com/us/legal/privacy-full], and it uses transaction information for its own purposes, including fraud prevention and legal compliance. We do not control that, and you should read PayPal’s policy if it matters to you.

We may also disclose information if the law requires it, or to protect our rights, safety, or property. If Talent Fuel is ever sold or transferred, subscriber information may move with it, and we will tell you before that happens.

6. Cookies and tracking

www.talentfueliq.com sets the following:

Cookie or tool: HubSpot (hubspotutk, __hstc, __hssc, __hsfp)

Purpose: Recognises your browser across visits; links browsing to your contact record once you identify yourself

Roughly how long: Up to 13 months

Cookie or tool: Google Analytics (_ga, _ga_*)

Purpose: Aggregate traffic measurement

Roughly how long: Up to 14 months

Cookie or tool: [Consent banner cookie]

Purpose: Remembers your tracking choice

Roughly how long: [12 months]

You can decline non-essential tracking using the banner on your first visit, and change your mind at any time at [LINK TO PREFERENCES]. You can also block or delete cookies in your browser, or use Google’s opt-out add-on at [https://tools.google.com/dlpage/gaoptout]. The site works normally either way.

7. Do Not Track

Some browsers send a "Do Not Track" signal. There is no industry consensus on how a site should respond, and we do not currently respond to these signals. Use the controls in Section 6 instead — those work.

[We honour Global Privacy Control (GPC) signals where our tools support them.]

8. Your choices and rights

Unsubscribe using the link at the bottom of any issue. It takes effect immediately.

Turn off tracking using the cookie banner or the preferences link in Section 6.

Ask us not to track your opens and clicks. Email info@talentfueliq.com and we will exclude you.

See, correct, or delete what we hold about you — email info@talentfueliq.com and we will respond within [30] days. No form, no explanation needed.

Ask us to keep your Talent Fuel subscription separate from any other relationship you have with CCY. We will confirm in writing.

Depending on where you live, state law may give you further rights. Ask, and we will honour them whether or not we are technically required to.

9. How long we keep things

We keep your subscriber record while you are subscribed and for [12] months afterwards. If you ask us to delete it, we will do so within [30] days, keeping only a minimal suppression entry — your email address alone — so we do not add you back by mistake. Engagement history is kept for [12] months. Payment records are kept for [seven] years because tax law requires it. Analytics data expires on the schedule in Section 6.

10. Security

We limit access to the people who need it, use established providers, and require multi-factor authentication on the accounts holding your data. No system is perfectly secure and we will not pretend otherwise, but we will tell you promptly if something goes wrong in a way that affects you.

11. Children

Talent Fuel is written for working professionals and is not intended for children. We do not knowingly collect information from anyone under [16]. If you believe a child has subscribed, email info@talentfueliq.com and we will delete the record.

12. Where we operate

We are based in the United States and run Talent Fuel for US subscribers. If you are elsewhere, your information is processed here, where privacy laws may differ from your own.

13. Changes to this policy

If we change how we handle your information, we will update this page and the date at the top. If the change is material, we will email subscribers before it takes effect. We will not apply a materially different practice to information we already hold without telling you first.

14. Contact

Cochran Cochran & Yale [suffix] d/b/a Talent Fuel — [STREET ADDRESS], Rochester, NY [ZIP] — info@talentfueliq.com

Appendix A — Before You Publish

INTERNAL ONLY — delete before publishing.

A1. File the Certificate of Assumed Name before you take any money

This is the most urgent item in any of these documents, and it is cheap to fix.

New York General Business Law § 130 requires an entity doing business under a name other than its real name to file a Certificate of Assumed Name. For an LLC, corporation, or limited partnership, that is filed with the Department of State in Albany, not the county clerk — the $25 filing fee applies to LLCs, with additional per-county fees for corporations.

The penalty is the part that matters. Under § 130(9), a business that has not filed is prohibited from maintaining any action or proceeding in any New York court on any contract, account, or transaction made under the assumed name, until the certificate is filed. Every subscriber agreement you enter into as "Talent Fuel" is exactly such a contract. Courts have read the bar broadly, extending it to equitable claims as well, and there are circumstances in which the defect cannot be cured after the fact.

Confirm whether CCY has already filed for "Talent Fuel." If it has, get a copy for the file. If not, file it before the first paid subscriber, not after.

Use "Cochran Cochran & Yale [suffix] d/b/a Talent Fuel" as the contracting party in the Terms, the Subscriber Agreement, and the payment descriptor. Contracting as "Talent Fuel" alone is what creates the § 130 problem.

Run a trademark clearance search on "Talent Fuel" before you invest in the brand. The domain being talentfueliq.com rather than talentfuel.com suggests someone else may already be using the shorter form. This is a cheap search now and an expensive rebrand later.

A2. Privacy thresholds are measured at CCY, not at Talent Fuel — correction

Earlier drafts concluded the CCPA does not reach you. That reasoning was wrong, because it measured the newsletter rather than the entity.

Since Talent Fuel is a DBA, the relevant business for every privacy statute is Cochran Cochran & Yale as a whole. The CCPA applies to a business with annual gross revenue over $26,625,000 for 2026 — and California has confirmed that this means total revenue from all sources, not revenue earned in California. It also applies to a business that buys, sells, or shares the personal information of 100,000 or more California residents annually.

Someone at CCY already knows the revenue figure. Get it, and answer this before launch. If CCY is over the threshold and does business in California at all, the CCPA applies to the entire entity, which is a substantially larger compliance program than this document — consumer rights requests, opt-out mechanisms, service provider agreements, and privacy policy content requirements that this draft does not attempt to satisfy.

Check the 100,000 figure against the candidate database, not the subscriber list. A search firm’s accumulated candidate records are the exposure here, not the newsletter.

The NY SHIELD Act applies to CCY regardless of size. Any business holding private information of New York residents must maintain reasonable administrative, technical, and physical safeguards and must notify on breach. A search firm holding candidate records is squarely covered. If CCY does not already have a written information security program, that is a gap well outside this newsletter but worth naming.

A3. Fill these in — the remaining placeholders

Exact legal entity name and suffix. "Cochran Cochran & Yale" needs its LLC / LLP / Inc. and any comma placement matched to the formation documents. This name appears in all four documents.

Street address in Rochester. CAN-SPAM requires a valid physical postal address in every commercial email. A P.O. box registered to CCY works; a home address is not required. Section 14 and every issue footer need it.

Link to CCY’s existing privacy policy for Section 1. If CCY does not have one covering candidate and client data, that is a much larger gap than anything in this document, and it should be raised with whoever handles CCY’s compliance.

Website host for the Section 5 table.

Consent preferences link for Section 6, once the banner is configured.

A4. The candidate-data boundary — the real issue here

This is the item most likely to cause an actual problem, and it exists because CCY is a search firm rather than a media company.

Your newsletter subscribers will overlap heavily with people already in your systems as candidates, client contacts, and prospects. If Talent Fuel subscription data flows into the same HubSpot records used for recruiting, the separation promised in Sections 1 and 3 is not real — and those are the two sections a subscriber is most likely to rely on.

Decide whether Talent Fuel lives in the same HubSpot portal as the recruiting operation. A separate portal is cleanest. If it shares a portal, subscription status must be a property that does not trigger recruiting workflows, sequences, or lead scoring.

Confirm no recruiting workflow can be triggered by newsletter engagement. Section 3 promises that reading Talent Fuel will not cause a recruiter to contact you. A lead-score threshold that fires an outreach sequence would break that promise silently, and nobody would notice until a subscriber complained.

Decide what happens when a subscriber becomes a candidate, and vice versa. Both directions need an answer, and the answer needs to match what Sections 1 and 8 say.

Do not import CCY’s existing contact lists into Talent Fuel. Someone who gave you their address as a candidate did not consent to a newsletter, and adding them is both a CAN-SPAM problem and a trust problem with people whose goodwill is your actual business.

Check that this policy does not contradict CCY’s existing privacy policy. Two published policies from the same entity saying different things is worse than one imperfect policy.

A5. PayPal specifics

Section 5 gives PayPal its own paragraph on purpose. Unlike Mailchimp or HubSpot, PayPal is not acting purely on your instructions — it uses transaction data for its own fraud and compliance purposes. Describing it as a processor that "may use data only to provide services to us" would have been inaccurate.

PayPal gives you the payer’s name and PayPal email address, which is more than Stripe hands over and may differ from the subscription email. Section 2 discloses this. Decide whether you actually want to store it.

Recurring billing works differently. PayPal subscriptions run on a billing agreement the subscriber can cancel from inside their own PayPal account. That is convenient, but it does not satisfy your obligation to provide cancellation through your own site under New York and California auto-renewal law. You still need your own online cancellation path.

A6. Still outstanding from the earlier drafts

HubSpot tracking script on www.talentfueliq.com. The v2 recommendation stands, with one refinement: keep HubSpot as CCY’s CRM if it is already embedded in the business — the issue is specifically the visitor-tracking script on the newsletter site, which is what draws the California tracking claims. You can run the CRM without running the script on this domain.

If the script stays, the consent banner must actually block it. Verify on the live site what fires before and after someone declines.

Mailchimp: decide on open and click tracking, turn off predictive demographics, accept the DPA, set retention to match Section 9.

Enable MFA on Mailchimp, HubSpot, PayPal, and the domain registrar. Section 10 says you have.

A7. Changes needed in the other three documents

These details do not stay contained in the privacy policy.

Replace Stripe with PayPal throughout the Terms and the Subscriber Agreement, including the failed-payment and card-updater language, which is Stripe-specific and does not describe how PayPal works.

Venue is Monroe County, New York — fill that into the governing-law sections.

Retune the no-advice disclaimer. The drafts offer [financial, investment, legal, tax, medical] as options. For Talent Fuel the exposure is different: hiring, compensation, employment-law, and career guidance. A search firm publishing on employment topics should disclaim employment-law and HR advice specifically, and should be careful that content does not read as guidance on hiring decisions that carry discrimination risk for the reader.

Consider whether CCY’s professional liability insurer should know about the newsletter. Publishing commentary is a different activity from placing candidates, and it may or may not sit inside the existing policy.