Privacy Policy

Welcome, this is our privacy policy which applies to the website https://www.core-strategy.us, owned and operated by Core-CSI LLC (hereinafter referred to as “Core-CSI”, “Core-Strategy”, “we”, “our” and/or “us”) knows that you care how information about you is used and shared.

This Privacy Policy explains what information of yours will be collected by Core-CSI when you access the Core-Strategy Services (including through the websites of our partners), how the information will be used, and how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Policy.

This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources. For customers that have executed a services agreement or analogous document duly executed by the parties hereto, this Policy will supplement any personal data and privacy terms set forth in such ancillary documents.

For clarity,this Privacy Policy also applies to PI collected through the mobile and desktop version of our website, independently of the mobile operative system, mobile device or browser you use to access it.

1. DEFINITIONS

Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Service. The use of information collected through our website shall be limited to the purposes under this Privacy Policy and our Terms of Service to customers.

The following defined terms will be used in this Policy, whether they are used in the singular or plural form.

Privacy Policy shall be referred to as the“Policy”

A visitor, customer or end-user of our Service is referred to as “you”,“your(s)” or “yourself”.

The Core-CSI platform is referred to as “Service”

Personally Identifiable Information shall be referred to as “PI”

Our suite of rendered online SaaS services shall be the “Services”

PI or also“Personal Information”, as described in various privacy laws and information security standards, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.

In addition, the terms “collect”, “process”, “treat”, “use”, “share”, “disclose”, “divulge” and analogous words shall refer to your PI and other data collected from our visitors and end users.

2. USER AGREEMENT & REGISTRATION

As a user of our Service, you might be asked to agree to this Policy by clicking on the “I Agree” checkbox on the registration page, box, tab or other analogous means. Our Service may also include a pop-up box or banner. Through that action, you thereby acknowledge and agree to the terms of this Policy, which is and constitutes a legal, binding agreement between you and Core-CSI.

At Core-CSI, we view privacy as a key part of the value that we deliver to our end-users, and this Policy was developed to describe our core values regarding the data our customers entrust to us. Overall, this Policy is freely available for your review prior to registration, and if you do not agree to its terms, your remedy shall consist of not opening an account and exiting the web tab through which you visited our Service.

Accordingly, by registering with us and/or otherwise using our products and services, you consent to the collection, transfer, processing, storage, and disclosure of your PI as described in this Policy.

Commercial Message Communications

Occasionally, we will ask you for express permission and approval to receive electronic messages in electronic format which are then sent to an electronic address and that contains a message asking recipients to participate in commercial activities such as newsletters, purchase of products, services and invitations to participate in surveys.

We will send you service-related announcements on occasions when it is necessary to do so. For instance, if our Service is temporarily suspended for maintenance, or a new enhancement is released, which will affect the way you use our services, we might send you an email. Generally, you may not opt-out of these communications, which are neither commercial nor promotional in nature.

You have the right to object to the processing of your PI if grounds for said objection are to direct marketing. You also have the right to opt out of receiving promotional communications at any time by: (i) contacting us; (ii) when we may ask you to confirm or update your marketing preferences if you instruct us to provide further the features and functionality of our Services; (iii) if there are changes in the law, regulation, or the structure of our business.

3. INFORMATION WE COLLECT

Our Service: We may collect personally identifiable information about you through our Service when you register for an account, such as your full name, phone number and email address.

If you choose to purchase a product from us, we or our third-party payment processors will collect your payment information also.

We also collect data through our partners (customers) who use our Service (including by embedding our code on their websites) to analyze usage of their websites.

When you use our Service or if you visit such websites, your browser may send us certain information about you as described below.

We do not send any promotional emails; however, we may send you service-related emails related to your account. If you no longer wish to receive these emails, you may opt out of them by canceling your account.

Cookies and Tracking Technologies

Technologies such as: cookies, tags and scripts are used by Core-CSI and our partners (such as advertising, marketing, and analytics), affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole.

We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. Our partners may also use such technologies to deliver advertisements to you as described below. We use cookies to remember users’ settings, authentication and analytics. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

We may also use Embedded Scripts, which are programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Service and is deactivated or deleted thereafter.

When you access our platform via a mobile device, we may use your mobile device ID (i.e. the unique identifier assigned to a mobile device by the manufacturer) and/or Advertising ID (for Apple iOS) instead of cookies in order to recognize you and track displayed web pages, along with their performance. For the latest versions of Apple iOS, your device would request you one or more times for your express consent for advertising tracking.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. For mobile users, you have controls in your device’s mobile OS that enables you to choose whether to allow cookies, or share your advertising ID with companies like Core-CSI or our advertising service providers. For information on controlling your mobile choices

Log File Information

Log file information is automatically reported by your browser each time you access a web page on our Service. When you access the Service, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information. We do not link this automatically collected data to personally identifiable information.

Flash LSOs

We use Local Storage Objects (LSOs) such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 and Flash to collect and store information. To learn how to manage privacy and storage settings for Flash cookies click here.

Information Related to Data Collected for our Customers

Core-CSI LLC collects information under the direction of its customers, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our customers and would no longer like to be contacted by one of our customers that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.

Access and Retention of Data Controlled by our customers

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Core-CSI’s customer (the data controller). If requested to remove data we will respond within 30 days. We will retain personal data we process on behalf of our customers for as long as needed to provide our services. Core-CSI will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Aggregated Statistics

We may receive aggregated, non-individualized PI from advertisers or publishers, along with aggregate statistics, metrics, and other reports about the performance of their ads or content in your Service account. We may share aggregated anonymized or de-identified information with third parties for research, marketing, analytics, and other purposes.

Geographical Location Information

Includes information on the precise geo-location of your device. This option can be disabled on your web browser and your mobile device.

Camera & Microphone

Certain features of our Services may require access to your camera and microphone. This option can be disabled on your web browser and your mobile device.

4. HOW WE USE YOUR INFORMATION

We use the information that we collect to operate and maintain our Service, send you marketing communications, respond to your questions and concerns and to help our partners improve their online offerings. We will store PI for the purposes of managing collaboration with other users, improve your user experience and contact you about inquiries for our Services. Overall, we use the collected PI in order to:

• Provide our Services. To personalize your user experience and to allow us to deliver our Services to our customers, among other functionalities that include, but are not limited to, managing customer profiles, user registrations, responding to customer support requests, process transactions, and follow up with user support (e.g. live chat, email or phone inquiries).
• Account Configuration. To tailor the content and information that we may send through Core-CSI, process any user credentials, process any content which we may provide access to, suggest new content offerings, offer account customization, provide personalized help and user instructions, and to otherwise personalize your experiences while using our platform.
• User Communications. We may use your PI in order to enable user-to-user and user-to-business communications.
• User Evaluation. Evaluate your eligibility for financial or other marketing offers, products and services and assess whether we can provide certain features to you, such as your free credit reports and scores.
• Community management.  We may use de-identified PI on our social media pages and our community pages.
• Promotion of our Services. We may use de-identified PI in order to market our Services, products and platforms, including delivering promotional materials, recommendations and other non-transactional commercial communications via email, post, telephone, SMS or push notifications.
• Protection of our Services. We may use your PI as part of our efforts to keep our Service safe and secure (for example, for fraud monitoring, identity theft and fraud prevention).
• Aggregated Statistics. We may use your PI to combine and anonymize information about your interactions with Core-CSI to create aggregate, anonymized statistics for use in research and for marketing, promoting, improving and developing our Services.
• Enforce our Terms and Policies. We may use your PI to protect our Services against misuse or abuse of our Services and ensure compliance with our Terms of Use, including in relation to content our customers send or display through Core-CSI.
• Respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
• Research and Development. Core-CSI also will share de-identified data with select partners for research and product development.
• Sending Promotional Communications. We and our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Service, subscribing to marketing or otherwise contacting us, we will collect personal information from you.

5. HOW WE SHARE YOUR INFORMATION

Personally, Identifiable Information (PII)

Core-CSI will not rent or sell your personally identifiable information to others. We may store personal information in locations outside the direct control of Core-CSI (for instance, on servers or databases co-located with hosting providers). Any personally identifiable information you elect to make publicly available on the Service, such as posting comments on our blog page, will be available to other Users.

If you remove information that you have made public on the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. Our blog is managed by a third-party application that may require you to register to post a comment.

We do not have access or control of the information posted to the blog. You will need to contact or login into the third-party application if you want the personal information that was posted to the comments section removed. To learn how the third-party application uses your information, please review their privacy policy.

Non-Personally Identifiable Information

We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Core-Strategy services and those of our partners. If you choose to publish such results on our Service (for example, in our Results Gallery), you understand and agree that this information, along with any personally identifiable information you choose to make available in connection with such results, will be made publicly available.

By publishing your results on the Core-Strategy Service, you agree that you have obtained all necessary consents to make such information public and that doing so will not violate any laws. If you remove information that you have made public on the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. Non-personally identifiable information may be stored indefinitely.

Instances where we are required to share your information

Core-CSI will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to: (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Core-CSI, our Users or others.

What happens in the event of a change of control

We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, and other User information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Behavioral Targeting / Re-Targeting

We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this site and other sites to provide you advertising based upon your browsing activities and interests.

If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking below. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

The Core-CSI Privacy Policy does not apply to, and we cannot control the activities of, third-party ad servers and ad networks. Please contact or consult the respective privacy policies of such ad servers or ad networks for more information.

For Machine Learning and Automated Processing

From time to time we may process your PI using automated and manual (human) methods, which include artificial intelligence (AI) and a range of technologies commonly called machine learning.

Testimonials

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at legal@core-csi.com.

6. STORAGE AND PROCESSING

Your information collected through the Service may be stored and processed in the United States or any other country in which Core-CSI or its subsidiaries, affiliates or service providers maintain facilities. Core-CSI may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Core-CSI or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

7. HOW WE PROTECT YOUR INFORMATION

Core-CSI is concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any information you transmit to Core-CSI or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by breach of any of our industry standard physical, technical, or managerial safeguards. When you enter sensitive information (such as credit card number or log in credentials) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at legal@core-csi.com.

We use an outside help platform, and a credit card processing company to bill you if you purchase services. These companies do not retain, share, store or use personally identifiable information for any other purposes.

8. COMPROMISE OF PERSONAL INFORMATION

In the event that personal information is compromised as a result of a breach of security, Core-CSI will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.

9. YOUR CHOICES ABOUT YOUR INFORMATION

You can review, correct, update or delete inaccuracies to the information about you that Core-CSI keeps on file by logging into your account to update your password and billing information. Alternately, you can contact us directly at legal@core-csi.com. We will respond to your request to access within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

10. CHILDREN’S PRIVACY

Protecting the privacy of young children is especially important. For that reason, Core-CSI does not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address.

No one under age 13 is allowed to access or use the Service or to provide any personal information to Core-CSI. In compliance with the Children's Online Privacy Protection Act of 1998, 15 U.S.C. 6501–6505 ("COPPA"), if we learn or have reason to suspect that any user or that any client, project or customer data appertains people under the age of thirteen (13), we will freeze and/or delete any PI under that user’s account, without prior notice and without responsibility.

We reserve the right to request any and all applicable proof of identification and consent proof from our users, at any moment, without prior notice, and at our sole and final discretion. Upon the failure to provide such proof of age, we reserve the right to immediately freeze, block or cancel the account, with no liability.

If you believe that we might have any information from or about a child under 13, please contact us at legal@core-csi.com.

11. NOTIFICATION PROCEDURES

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business-related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on the Service, as determined by Core-CSI in its sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

12. LINKS TO OTHER WEB SITES

We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies.

Social Media Widgets

Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Service. Your interactions with these Features are governed by the privacy policy of the company providing it.

13. SECURITY OF COLLECTED INFORMATION

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all requirements and implement additional generally accepted industry standards.

You can be assured that personal information collected through the Service is secure and is maintained in a manner consistent with current industry standards. The importance of security for all personal information associated with our subscribers is of utmost concern to us.

Your personal information is protected in several ways, and we protect inputted information by undertaking the reasonable technical and administrative security measures (e.g. firewalls, data encryption, physical & administrative access controls to the data and servers) that limit the risk of loss, abuse, unauthorized access, disclosure, and alteration.

14. NOTICE TO CALIFORNIA RESIDENTS

Pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”), Core-CSI and its affiliates hereto provide the following Privacy Policy notice regarding the categories of PI that we have collected or disclosed within the preceding twelve (12) months about California residents who are not employees, independent contractors, owners, directors, officers, or job applicants of Core-CSI, or emergency contacts or benefits beneficiaries of the foregoing.

Henceforth, the CCPA provides Californians with the following rights:

• Requests for Information: you (or your authorized agent) can request a copy of your PI, including how we have collected, used, and shared your PI over the past 12 months (if any), including the categories of PI we collected and our purposes for doing so; the categories of sources for that information; the categories of third parties with whom we shared it for a business purpose and our purposes for doing so.
• Your Right to Notification: under the CCPA, we cannot collect new categories of PI or use them for materially different purposes without first notifying you.
• Nondiscrimination for exercising your CCPA Rights: the CCPA prohibits us from discriminating against you for exercising your rights under the law. Such discrimination may include denying services, charging different prices or rates for services, providing a different level or quality of services, or suggesting that you will receive a different level or quality of goods or services as a result of exercising your rights.
• Your Right to Delete PI: you can request that we delete your PI by contacting us. You also can request that we delete specific information, and we will honor such requests, unless a due exception applies, such as when the information is necessary to complete a transaction, verify a fraud, review a chargeback or contract for which it was collected or when it is being used to detect, prevent, or investigate security incidents, comply with laws, identify and repair bugs or ensure another consumer’s ability to exercise their free speech rights or other rights provided by law.
• Please take into consideration that we may deny your deletion request if retaining the PI is necessary for us, our affiliates or our service providers in order to:
• Complete the transaction for which we collected the PI information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug our products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation that has substantive grounds;
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Overall, we have, may or will collect the following categories of PI from our users, customers and individuals, as necessary to fulfill our legal obligations and operational business purposes:

• Personal information, as defined in the California Customer Records Law, such as contact information and financial information;
• Identifiers, such as online identifier, IP address and name;
• Financial information, such as transaction information and history and securities trading information and history;
• Internet or network activity information, such as browsing history and interactions with our and other websites and systems;
• Geo-localization data, such as device location and IP location;
• Audio, electronic, visual and similar information, such as video recordings and multimedia content created in connection with our business activities; and
• Inferences drawn from any of the PI listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

15. CHANGES TO OUR PRIVACY POLICY

If we change our privacy policies and procedures materially, we will post those changes on the Service to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner, we will let you know via email and/or a prominent notice on our Web site, prior to the change becoming effective and update the ‘effective date’ at the top of this page.

If we make any changes to this Policy that materially change how we treat your PI, we will endeavor to provide you with prompt notice of such changes, such as through a prominent notice on the Service, through a push notification or to your email address of record. Where required by law, we will obtain your consent or give you the opportunity to opt-out of such.

16. CONTACT

If you have any questions or comments about us, our Service, our Terms of Use and/or this Policy, please contact us. Note that communications made by email or the “Contact Us” page does not constitute legal notice to the Core-CSI legal entity.

Date of last effective update is [---------], 2024.