Last updated: April 6,
2022
This Privacy Policy (the “Policy”) governs the https://clientportal.cornerstone-ip.com/
website and the content, features and tools available on this website (the
website and all of the foregoing collectively, the "Service") operated by Cornerstone Investment Partners, LLC (“Cornerstone”, "us", "we", or "our",
as the context requires).
This Policy describes:
·
The
types of information we may collect or that you may provide when you download, register
with, access, or use the Service.
·
Our
practices for collecting, using, maintaining, protecting, and disclosing that
information.
This Policy applies only to information we
collect on or through the Service. This Policy does not apply to information
that we collect offline, or that you provide to or is collected by any third
party, which may have their own privacy policies that we encourage you to read
before providing your information on or through them (see “Third-Party
Information Collection” below).
Please read this Policy carefully to understand
our policies and practices regarding your information and how we will treat it.
In using the Service, you agree to be bound by this Policy. If you do not
accept the terms of this Policy you may not access or
use the Service and you should discontinue your use of it.
This Policy may change from time to time (see “Changes to Our Privacy Policy” below). Your continued use of
the Service after we revise this Policy means you accept those changes, so
please check this Policy periodically for updates.
How We Collect
Information
We collect information from and about users of the
Service:
·
Directly
from you when you provide it to us.
·
Automatically
when you use the Service.
Information
You Provide Directly to Us
When you download, register with, access, or
use any aspect of the Service, we may ask you to provide the following types of
information:
·
Information
by which you may be personally identified, including but not limited to, your
name, postal address, email address, and telephone number (“personal information”).
·
Payment
information, including but not limited to, credit card information.
This information may be provided by you in the
following ways:
·
Filling in forms on the
Service.
This includes information that you may provide when downloading, registering
with, accessing, or using any aspect of the Service, when requesting further
services, and when reporting problems with the Service.
·
Contacting us. This includes
information you may provide when you correspond with us, including, but not
limited to, email addresses and phone numbers.
·
Participating in
surveys.
This includes information you may provide when you respond to surveys that we
might ask you to complete for research purposes.
·
Carrying out
transactions.
Details of transactions you carry out through the Service and of the
fulfillment of your orders. You may be required to provide financial information
before placing an order through the Service.
·
Searching within the
Service. This
includes information you may provide when you perform search queries on the
Service.
If you provide information for publication or
display (“Posted”) on public areas
of the Service or websites you access through the Service (collectively “User Contributions”), then your User
Contributions are Posted and transmitted to others at your own risk.
Additionally, we cannot control the actions of third parties with whom you may choose
to share your User Contributions. Therefore, we cannot and do not guarantee
that your User Contributions will not be viewed by unauthorized persons.
Automatic
Information Collection and Tracking
When you download, register with, access, or
use any aspect of the Service, the Service may use technology to automatically
collect:
·
Usage Details. When you access and
use the Service, we may automatically collect certain details of your access to
and use of the Service, including traffic data, location data, logs, and other
communication data and the resources that you access and use on or through the
Service.
·
Device Information. We may collect
information about your mobile device and internet connection, including the
device’s unique device identifier, IP address, operating system, browser type,
mobile network information, and the device’s telephone number.
·
Stored Information and
Files.
The Service may also access metadata and other information associated with
other files stored on your device. This may include, for example, photographs,
audio and video clips, personal contacts, and address book information.
If you do not want us to collect any of the
above information, then you may decide not to use the Service or not to download
the mobile application, or delete the mobile application
from your device. For more information, see “Your Choices
About Our Collection, Use, and Cornerstone sure of Your Information” below.
Information
Collection and Tracking Technologies
The technologies we use for automatic
information collection may include:
·
Cookies (or mobile
cookies).
A cookie is a small file placed on your smartphone. It may be possible to
refuse to accept mobile cookies by activating the appropriate setting on your
smartphone. However, if you select this setting you
may be unable to access certain parts of our App.
·
Web Beacons. The Service and our
emails may contain small electronic files known as web beacons (also referred
to as clear gifs, pixel tags, and single-pixel gifs) that permit Cornerstone, for
example, to count users who have visited those pages or opened an email and for
other related app statistics (for example, recording the popularity of certain
app content and verifying system and server integrity).
Third-Party
Information Collection
Generally. When you use the Service or its content,
certain third parties may use automatic information collection technologies to
collect information about you or your device. These third parties may include:
·
Advertisers,
ad networks, and ad servers.
·
Analytics
companies. Please see additional information below under “Our Use of Google
Analytics”.
·
Your
mobile device manufacturer.
·
Your
mobile service provider.
These third parties may use tracking
technologies to collect information about you when you use the Service. The
information they collect may be associated with your personal information or
they may collect information, including personal information, about your online
activities over time and across different websites, apps, and other online
services websites. They may use this information to provide you with
interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking
technologies or how they may be used. If you have any questions about an
advertisement or other targeted content, you should contact the responsible
provider directly.
Payments Processing. We may provide paid products and/or
services within the Service. In that case, we use third-party services for
payments processing (e.g., payment processors).
Cornerstone itself will not store or collect your payment card details.
That information is provided directly by you to our third-party payment
processors whose use of your personal information for such purposes is governed
by their privacy policy. Payment
processors are required by an industry self-governing body to adhere to the
standards set by PCI-DSS as managed by the PCI Security Standards Council,
which is a joint effort of brands like Visa, MasterCard, American Express and
Discover. PCI-DSS requirements help ensure the secure handling of payment
information.
Other Sites. Our Service may contain links to other sites
and applications/apps that are not operated by us. If you click a third party link, you will be directed to that third party’s
site or app. We strongly advise you to review the applicable privacy policy of
every site or app you visit. We have no
control over and assume no responsibility for the content, privacy policies or
practices of any third party sites, apps or services
that are linked from our Service.
Our
Use of Google Analytics
We use a tool called “Google Analytics” to
collect information about use of this site. Google Analytics collects
information such as how often users visit or use the Service, what pages users
visit when they do so, and what other sites user used prior to coming to the
Service. For more information regarding how Google uses such information,
please visit the following website: https://www.google.com/policies/privacy/partners/.
We use the information we get from Google
Analytics to improve the Service. Google’s ability to use and share information
collected by Google Analytics about your visits to the Service is subject to
and restricted by the Google Analytics Terms of Use (https://marketingplatform.google.com/about/analytics/terms/us/) and the Google
Privacy Policy (https://policies.google.com/privacy). You can prevent
Google Analytics from recognizing you on return visits to the Service by
disabling cookies on your browser. For more information on disabling cookies on
your browser, see “Your Choices About Our Collection, Use,
and Cornerstone sure of Your Information” below.
We use information that we collect about you or
that you provide to us, including any personal information, to:
·
Provide
you with the Service and its contents, and any other information, products, or
services that you request from us.
·
Fulfill
any other purpose for which you provide it.
·
Carry
out our obligations and enforce our rights arising from any contracts entered
into between you and us, including for billing and collection.
·
Notify
you when updates for the Service are available, and of changes to any products
or services we offer or provide though it.
The usage information we collect helps us to
improve the Service and to deliver a better and more personalized experience by
enabling us to:
·
Estimate
our audience size and usage patterns.
·
Store
information about your preferences, allowing us to customize the Service
according to your individual interests.
·
Speed
up your searches.
·
Recognize
you when you use the Service.
We may also use your information to contact you
about goods and services that may be of interest to you, including our own good
and services or the goods and services of third parties. For more information,
see “Your Choices About Our Collection, Use, and Cornerstone
sure of Your Information” below.
We may use the information we collect to
display advertisements. Even though we do not disclose your personal
information for these purposes, if you click on or otherwise interact with an
advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of
Your Information
We may disclose aggregated information about
our users, and information that does not identify any individual without
restriction.
In addition, we may disclose personal
information that we collect or you provide:
·
To
our subsidiaries and affiliates.
·
To
contractors, service providers, and other third parties we use to support our
business.
·
To
a buyer or other successor in the event of a merger, divestiture,
restructuring, reorganization, dissolution, or other sale or transfer of some
or all of Cornerstone ’s assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which personal information
held by Cornerstone about the Service’s users is among the assets transferred.
·
For
any other purpose disclosed by us when you provide the information.
·
With
your consent.
·
To
comply with any court order, law, or legal process, including to respond to any
government or regulatory request.
·
To
enforce our rights arising from any contracts entered into between you and us and
for billing and collection.
·
If
we believe disclosure is necessary or appropriate to protect the rights,
property, or safety of Cornerstone, our customers, or others.
Your Choices
About Our Collection, Use, and Disclosure of Your Information
This section describes mechanisms that we
provide for you to control certain uses and disclosures of your information.
·
Tracking Technologies. You can set your
browser to refuse all or some browser cookies, or to alert you when cookies are
being sent. However, if you disable or refuse cookies or block the use of other
tracking technologies, some parts of the Service may then be inaccessible or
not function properly.
·
Promotion by Cornerstone. You can opt-out of
receiving promotional materials by logging into the Service and adjusting your
user preferences in your account profile or by selecting “unsubscribe” in emails
we send to you.
California residents may have additional
personal information rights and choices. Please see “Your
California Privacy Rights” below for more information.
Accessing and
Correcting Your Personal Information
You can review and change your personal
information by logging into the Service and visiting your account profile page.
You may also send us an email at marketing@cornerstone-ip.com
to request access to, correct, or delete any personal information that you have
provided to us. We may not accommodate a request to change information if we
believe the change would violate any law or legal requirement or cause the
information to be incorrect.
If you delete your User Contributions from the
Service, copies of your User Contributions may remain viewable in cached and
archived pages, or might have been copied or stored by other Service users.
California residents may have additional
personal information rights and choices. Please see “Your California Privacy
Rights” below for more information.
Children’s Privacy and Age
Limitations for the Service
The Service
is intended for use by persons aged 18 or older, and by your use of this Service
you affirm that you are at least 18 years of age. We do not knowingly collect personal
information from children under the age of 18. If we discover or are made aware
that we have received personal information from an individual who indicates
that he or she is, or whom we otherwise have reason to believe is, under the
age of 18, we will delete such information from our systems. If you are a parent or legal guardian of a
child under the age of 18 and believe that your child has disclosed personal information
to us we welcome you contacting us as provided below so that we can address such
matter.
From time
to time there may be instances when we collect information through the Service
about children under the age of 18 but we will only do this when such
information is provided to us by that child’s parent or legal guardian. In all cases where we’ve collected
information about a child under the age of 18, the parent or legal guardian may
contact us as provided below to review and request deletion of such child's
personal information as well as to prohibit the further use of such information
by us.
California Minors
California residents
under 18 years of age may have additional rights regarding the collection and
sale of their personal information. Please see “Your
California Privacy Rights” below for more information.
We may update this
Policy from time to time. If we make material changes to how we treat our
users’ personal information, we will post the most recent privacy policy on
this page.
The date that this
Policy was last revised is identified at the top of the page. You are
responsible for periodically visiting this Policy to check for any changes.
To ask questions or
comment about this Policy and our privacy practices, contact us via email at marketing@cornerstone-ip.com,
or via regular mail at Cornerstone Investment Partners, LLC, 3438 Peachtree Rd. NE Suite 900 Atlanta, GA 30326.
Your
California Privacy Rights
The following additional privacy notices for
California residents (the “California
Notice”) supplement the information contained in the other portions of this
Policy and apply solely to individuals who reside in the State of California (“California consumer” or “you”). Cornerstone adopts this
California Notice to comply with the California Consumer Privacy Act, as
amended by the California Privacy Rights Act, and their related regulations (collectively
the “California Privacy Law” or the
“CPL”) and other applicable
California laws.
Overview of Consumer Rights Under the CPL
Under the CPL, California consumers have certain
rights regarding their personal information, including:
·
The right to know the categories of personal information that Cornerstone
has collected and the categories of sources from which we obtained such
information.
·
The right to know Cornerstone ’s business purposes for sharing personal
information.
·
The right to know the categories of third parties with whom Cornerstone shared
personal information.
·
The right to know if we sold or disclosed your personal information for
a business purpose, comprising two separate lists disclosing:
·
any sales, which list identifies the personal information categories
that each category of recipient purchased (note that at present we do not sell
personal information that we collect); and
·
any disclosures for a business purpose, which list identifies the personal
information categories that each category of recipient obtained.
·
The right to access the specific pieces of personal information that Cornerstone
has collected
·
The right to correct personal information that Cornerstone has
collected.
·
The right to delete your personal information.
·
The right to not be discriminated against if you exercise your rights
under the CPL.
The provisions below of this California Notice
provide further details about these and other rights and certain details about
the exercise of such rights.
Information We Collect
We collect information that identifies, relates to,
describes, references, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular California
consumer, household or device (collectively, "personal information").
Personal information does not include:
·
Publicly available information from government records.
·
De-identified or aggregated California consumer information.
·
Information excluded from the CPL’s scope, including:
·
Health or medical information covered by the Health Insurance
Portability and Accountability Act of 1996 (HIPAA) and the California
Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
·
Personal information covered by certain other laws, including the Fair
Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California
Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection
Act of 1994.
We have collected the following categories of personal
information from consumers within the last twelve (12) months:
|
Category |
Examples |
|
Identifiers |
An individual’s name, alias, postal address,
unique personal identifier, online identifier, Internet Protocol address,
email address, account name, Social Security number, driver’s license number,
passport number or other similar identifiers |
|
Personal
information categories described in Cal. Civ. Code § 1798.80(e) |
A name, signature, Social Security number, physical
characteristics or description, address, telephone number, passport number,
driver's license or state identification card number, insurance policy
number, education, employment, employment history, bank account number,
credit card number, debit card number, or any other financial information, medical
information, or health insurance information (Note: Certain of the above
information may be considered to be sensitive personal information under the
CPL and, to the extent such data is considered to be sensitive personal
information you have the right to limit the use and disclosure of such data.) |
|
Commercial
information |
Records of personal property, products or
services purchased, obtained, or considered, or other purchasing or consuming
histories or tendencies |
|
Internet
or other similar network activity |
Browsing history, search history, information on
a California consumer's interaction with our website, application, or
advertisement and any social media sites from which user information is
linked, connected or obtained |
|
Geolocation data |
Physical location or
movements (Note: Certain precise geolocation data may be considered to be
sensitive personal information under the CPL and, to the extent such data is
considered to be sensitive personal information you have the right to limit
the use and disclosure of such data.) |
|
Professional or employment information |
Business contact
details in order to provide you our services at a business level or job
title, work history, and professional qualifications if you apply for a job |
|
Inferences
drawn from other personal information |
Examples
include a person's preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities and aptitudes |
Sources of Personal Information
In addition to sources of personal information
addressed elsewhere in this Policy, we obtain the categories of personal
information listed above from the following categories of sources:
·
Directly From You. For example, from forms
you complete or products and services you purchase or from communications with
you such as when you contact Cornerstone (whether in person, by mail, by phone,
online, via electronic communication or by other means) including our customer
support service.
·
Indirectly From You. For example, from
observing your actions on our Service or from products or services that you
have purchased from Cornerstone, if you have enabled such functionality, such
as telemetry services.
·
From Others.
o
From third party service providers. For example, if you choose to make
an electronic payment directly to Cornerstone, or through a linked website or mobile
application, or through an affiliate of ours, Cornerstone may receive personal
information about you from third parties such as payment services providers,
for the purposes of that payment.
o
From affiliates. We may collect personal information about you from our
affiliates or others acting on their behalf.
·
From Public Sources. For example, we may
collect information from public records.
Uses of Personal Information
In addition to uses of personal information
addressed elsewhere in this Policy, we may use or disclose the personal
information we collect for one or more of the following business purposes:
·
To fulfill the reason that you provided the information. For example, if
you share your name and contact information to request a price quote, request
to be contacted by an affiliate, or ask a question about our products or
services, we will use that personal information to respond to your inquiry. If
you provide your personal information to purchase a product or service, we may
use that information to process your payment and facilitate delivery. We may
also save your information to facilitate new product or service orders or to
process returns.
·
To perform services such as customer service, order fulfillment, payment
processing, financing and advertising, marketing or analytic services.
·
To advance our commercial or economic interests, such as by helping you
to buy, rent, lease, join, subscribe to, provide, or exchange products,
information, or services, or enabling or effecting, directly or indirectly, a
commercial transaction.
·
To verify or maintain quality or safety standards or improve or upgrade
a product or service provided or controlled by or for us.
·
To provide, support, personalize and develop our Service, products and
services such as to perform warranty related services or other post-sale
activities such as product or service monitoring or repairs.
·
To create, maintain, customize and secure your account with us.
·
To process your requests, purchases, transactions and payments and
prevent transactional fraud.
·
To provide you with support and to respond to your inquiries, including
to investigate and address your concerns and monitor and improve our responses.
·
To personalize your Service experience and to deliver content and
product and service offerings relevant to your interests, including targeted
offers and ads through our Service, third-party sites and via mail, email or
text message (with your consent, where required by law).
·
To help maintain the safety, security and integrity of our Service,
products and services, databases and other assets and business.
·
For testing, research and analysis purposes, including to develop and
improve our Service, products and services.
·
To respond to law enforcement requests and as required by applicable
law, court order or governmental regulations.
·
As described to you when collecting your personal information or as
otherwise set forth in the CPL or applicable law.
·
To send you information relevant to your past purchases and interests,
subject to compliance with applicable laws regarding direct marketing.
·
To otherwise use as reasonably necessary and proportionate to achieve
our operational or notified purpose for collecting personal information and as
compatible with the context in which we collected the information.
·
To perform services on behalf of a CPL-covered business or its service
provider, such as customer service, order fulfillment, payment processing,
financing and advertising, marketing, or analytic services.
·
To review and audit our business interactions with you.
·
To detect or prevent security incidents or other illegal activity.
·
To evaluate or conduct a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of some or all of our
assets, whether as a going concern or as part of a bankruptcy, liquidation, or
similar proceeding, in which personal information held by us about our Service
users, including California consumers, is among the assets transferred.
We will not collect additional categories of
personal information or use the personal information we collected for
materially different, unrelated or incompatible purposes without providing you
notice.
Sharing Personal Information
We may disclose your personal information to a third
party for a business purpose. When we disclose personal information for a
business purpose, we enter a contract that describes the purpose and requires
the recipient to both keep that personal information confidential and not use
it for any purpose except performing the contract.
In the preceding twelve (12) months, Cornerstone
has disclosed the following categories of personal information for a business
purpose:
n
Identifiers
n
Personal information categories described in Cal. Civ. Code § 1798.80(e)
n
Commercial information
n
Internet or other similar network activity
n
Inferences drawn from other personal information
The categories of third parties to which we may
disclose personal information collected by us include the following:
·
Service providers
·
Affiliates
·
Recipients of data from cookies
Sales of Personal Information
Cornerstone does not sell personal information to
third parties.
Exercising Your CPL Rights and Choices
The sections below describe how you may exercise
your rights under the CPL.
Access to
Specific Information and Data Portability Rights. You have the right to
request that we disclose certain information to you about our collection and
use of your personal information. Once we receive and confirm your verifiable
consumer request (see “Exercising Access, Data Portability and Deletion Rights”
below), we will disclose to you:
·
The categories of personal information we collected about you.
·
The categories of sources for the personal information we collected
about you.
·
Our business or commercial purpose for collecting that personal
information.
·
The categories of third parties with whom we share that personal
information.
·
The specific pieces of personal information we collected about you (also
called a data portability request).
·
If we disclosed your personal information for a business purpose, a list
disclosing the personal information categories that each category of recipient
obtained.
As allowed by the CPL, we do not provide these
access and data portability rights for business-to-business personal
information.
Deletion and
Correction Request Rights.
You have the right to request that we delete any of
your personal information that we collected from you and retained, subject to
certain exceptions. Once we receive and confirm your verifiable consumer
request (see “Exercising Access, Data Portability, Deletion and Correction Rights”
below), we will delete (and direct our service providers to delete) your
personal information from our (and service provider) records, unless an
exception applies.
We may deny your deletion request if retaining the
information is necessary for us or our service provider(s) to:
·
Complete the transaction for which we collected the personal
information, provide a good or service that you requested, take actions
reasonably anticipated within the context of our ongoing business relationship
with you, fulfill the terms of a written warranty or product recall conducted
in accordance with federal law, 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 products or services to identify and repair errors that impair
existing intended functionality.
·
Exercise free speech, ensure the right of another California 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 et seq.).
·
Engage in public or peer-reviewed scientific, historical, or statistical
research in the public interest that adheres to all other applicable ethics and
privacy laws, when the information's deletion may likely render impossible or
seriously impair the research's achievement, if you previously provided
informed consent.
·
Enable solely internal uses that are reasonably aligned with California
consumer expectations based on your relationship with us, such as future field
campaigns or product safety issues.
·
Comply with a legal obligation.
·
Make other internal and lawful uses of that information that are
compatible with the context in which you provided it.
As allowed by the CPL, we do not provide these
deletion rights for business-to-business personal information.
In addition, if you provide us with a verifiable
consumer request to correct inaccurate personal information that we maintain
about you, we will use commercially reasonable efforts to correct such
information in accordance with your instructions.
Exercising
Access, Data Portability, Deletion and Correction Rights.
To exercise the access, data portability, deletion and
correction rights described above, you should submit a verifiable consumer
request to us by one of the following methods:
·
Emailing us at marketing@cornerstone-ip.com
·
By postal mail at Cornerstone Investment Partners, LLC, 3438 Peachtree
Rd. NE Suite 900 Atlanta, GA 30326.
·
Accessing your online account that you maintain with us.
Only you, or someone legally authorized to act on
your behalf, may make a verifiable consumer request related to your personal
information. You may also make a verifiable consumer request on behalf of a
minor child for whom you are a parent or legal guardian.
You may only make a verifiable consumer request for
access or data portability twice within a twelve (12) month period. The verifiable
consumer request must provide sufficient information that allows us to
reasonably verify that you are the person about whom we collected personal
information or an authorized representative, which may include:
·
Your name
·
Your address
·
Additional information depending upon the type of request and the
sensitivity of the information involved with such request
·
Describe your request with sufficient detail to enable us to properly
understand, evaluate and respond to such request.
We cannot respond to your request or provide you
with personal information if we cannot verify your identity or your authority
to make the request and confirm that the personal information involved with the
request relates to you.
Making a verifiable consumer request does not
require you to create an account with us. However, we will consider requests
made through a password-protected online account that you maintain with us to
be sufficiently verified when the request relates to personal information
associated with that online account, provided such online account functionality
is then made available by us on the Service.
We will only use personal information provided in a
verifiable consumer request to verify the requestor's identity or authority to
make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer
request within forty-five (45) days of its receipt. If we require more time, we
will inform you of the reason and extension period in writing.
If you have an online account with us, we may
deliver our written response to that online account, provided that such online
account functionality is then made available by us on the Service. If you do
not have an online account with us, or such functionality is not available for
your online account we will deliver our written response by mail or
electronically, at your option.
If we’re unable to comply with your request, the response
we provide will also explain the reasons we cannot comply with the request. For
data portability requests, we will select a format to provide your personal
information that is readily usable and should allow you to transmit the
information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to
your verifiable consumer request unless it is excessive, repetitive or
manifestly unfounded. If we determine that the request warrants a fee, we will
tell you why we made that decision and provide you with a cost estimate before completing
your request.
Non-Discrimination
We will not discriminate against you for exercising
any of your CPL rights. Unless permitted by the CPL or other applicable law, we
will not as a result of you exercising any of your rights under the CPL:
·
Deny you goods or services;
·
Charge you different prices or rates for goods or services, including
through granting discounts or other benefits, or imposing penalties;
·
Provide you a different level or quality of goods or services; or
·
Suggest that you may receive a different price or rate for goods or
services or a different level or quality of goods or services.
However, we may offer you certain financial
incentives permitted by the CPL that can result in different prices, rates, or
quality levels. Any CPL-permitted financial incentive we offer will reasonably
relate to your personal information's value and contain written terms that
describe the program's material aspects. Participation in a financial incentive
program requires your prior opt in consent, which you may revoke at any time.
Retention of Personal Information
Our policy is to retain personal information only
for as long as is necessary to fulfill the reason for which the personal
information was collected and as necessary to process such personal information.
In addition to the above, we will retain your personal information for the
purposes of satisfying any professional, legal, accounting or reporting
requirements to which we are subject. To determine the appropriate retention
period for personal information, we consider the scope, nature and sensitivity
of the personal information, the potential risk of harm from unauthorized use
or disclosure of the personal information, the purposes for which we collected
and processed your personal information and whether we can reasonably achieve
those purposes through other means, as well as any applicable legal and
professional requirements.
Other California Privacy-Related Disclosures
Sharing
Personal Information for Direct Marketing Purposes. Before sharing personal
information of California consumers with third parties for direct marketing
purposes we will obtain opt-in consent from the applicable California consumers
or provide such California consumers with a cost-free method to opt out.
California
Do-Not-Track Disclosure. At this time, the Service is not set up to honor web browser
do-not-track settings. Do-not-track is a
privacy preference that users can set in their web browsers. When a user
activates the do-not-track settings in browsers that offer this setting, the
browser sends a message to websites or applications requesting them not to
track the user. For more information about do-not-track matters, please visit
www.allaboutdnt.org.
Information
on Marketing Disclosures. California Civil Code Section 1798.83 permits our users who are
California residents to request and obtain from us once a year, free of charge,
information about the personal information (if any) we disclosed to third
parties for direct marketing purposes in the preceding calendar year. If
applicable, this information would include a list of the categories of personal
information that was shared and the names and addresses of all third parties
with which we shared information in the immediately preceding calendar year. If
you are a California resident and would like to make such a request, please
submit your request in writing to us at: marketing@cornerstone-ip.com or Cornerstone
Investment Partners, LLC, 3438 Peachtree Rd. NE Suite 900 Atlanta, GA 30326.
Content
Removal Requests for Service Users Under 18 Years Old. If you are a Service user
under 18 years of age and reside in California, you may request and obtain
removal of, content or information that you have posted on the Service. You may
send us any such requests by one of the following methods: (i) by email
(writing “Privacy Policy/Removal Request” in the subject line) at marketing@cornerstone-ip.com;
or (ii) by writing to us at Cornerstone Investment Partners, LLC, 3438 Peachtree Rd. NE Suite 900 Atlanta, GA 30326. We will
review the request and respond promptly.
You should be aware that a request to remove content or information
posted by you on the Service does not ensure or require complete or
comprehensive removal of such content or information from our databases.
Complaints
If you have any complaint about use of the Service,
you may contact us by email at marketing@cornerstone-ip.com, or by postal mail
at Cornerstone Investment Partners, LLC, 3438 Peachtree Rd. NE Suite 900
Atlanta, GA 30326. In accordance with California Civil Code Section 1789.3,
California residents may also file complaints with the Complaint Assistance
Unit, Division of Consumer Services, California Department of Consumer Affairs
by postal mail at 1625 North Market Road, Suite N112, Sacramento, CA 95834 or
by telephone at 800-952-5210.
Changes to Our California Notice
We reserve the right to amend this California
Notice at our discretion and at any time. When we make changes to this
California Notice, we will post the updated California Notice on the Service
and update the California Notice’s effective date. Your continued use of our Service
following the posting of changes constitutes your acceptance of such changes.
Your
EU Privacy Rights
Persons who are residents of the member countries
of the European Union (“EU”) or
other data subjects covered by the EU’s General Data Protection Regulation,
(EU) 2016/679 (the “GDPR”), have
certain additional privacy rights under applicable law. The following
provisions of this Privacy Policy provide an overview of these additional
rights.
Legal Bases for Processing Personal Information of
European Union Citizens
When processing your personal information, Cornerstone
may rely on one or more of the following legal bases (or other available legal
grounds), depending on the circumstances:
·
Legitimate Interests. We may process your
personal information where Cornerstone has a legitimate interest in such
processing for managing, operating or promoting our business, and that
legitimate interest is not overridden by your interests, fundamental rights or
freedoms.
·
Consent. We may process your
personal information where Cornerstone has obtained your consent to the
processing.
·
Contractual Necessity. We may process your
personal information where such processing is necessary in connection with any
contract that Cornerstone has with you.
·
Legal Requirements. We may process your
personal information where such processing is required by applicable law.
Disclosures to Third Parties
Your personal information will not be disclosed to
third parties except for where it is necessary for fulfillment of Cornerstone ’s
obligations to you or where Cornerstone is obliged or permitted to do so by law
(including, without limitation, through the terms of any agreement Cornerstone may
have with you), or where Cornerstone makes disclosures that are otherwise
consistent with the uses described in this Policy.
Cornerstone may also disclose any information
(including personal information) relating to you to law enforcement authorities
or any regulatory or government authority in response to any request including
requests in connection with the investigation of any suspected illegal
activities.
Cornerstone reserves the right to transfer any
personal information Cornerstone has about you in the event Cornerstone sells
or transfers all or a portion of our business or assets, or merges with another
organization. Should such a sale, transfer or merger occur, Cornerstone will
use reasonable efforts seeking to require that the transferee uses personal
information you have provided to Cornerstone in a manner that is consistent
with this Policy.
We will not sell, resell or lease your personal
information to any third parties but Cornerstone may, if required for the
purpose(s) for which your personal information was collected and processed,
share it with Cornerstone partners and/or service providers to enable them to
provide their services to Cornerstone or to you, as applicable. The foregoing
are in addition to the other uses described elsewhere in this Policy.
Security of Personal Information of European
Citizens
Cornerstone has policies and technical and
organizational measures in place which are intended to safeguard and protect
your personal information against unauthorized access, accidental loss,
improper use and disclosure. However, you should be aware that information
transmitted over the internet is not completely secure because of the nature of
the internet and that systems and measures used to secure information are not
flawless. For these reasons, although Cornerstone will use reasonable efforts
to protect your personal information, Cornerstone does not warrant the security
of personal information transmitted to Cornerstone or stored by Cornerstone,
and personal information that is transmitted to Cornerstone by you electronically
is done at your own risk.
Retention of Personal Information of European
Citizens
Our policy is to retain your personal information
only for as long as is necessary to fulfill the purposes for which Cornerstone collected
such personal information, including for the purposes of satisfying any
professional, legal, accounting or reporting requirements to which Cornerstone is
subject. To determine the appropriate retention period for personal
information, Cornerstone considers the scope, nature and sensitivity of the
personal information, the potential risk of harm from unauthorized use or
disclosure of the personal information, the purposes for which Cornerstone collected
and processed your personal information and whether Cornerstone can achieve those
purposes through other means, and any applicable legal and professional
requirements.
Your Rights as a European Citizen
You have a number of rights concerning your
personal information that Cornerstone holds and uses, including the following:
·
Right of Access. You have the right to be
informed about what personal information Cornerstone holds about you and to a
copy of this personal information.
·
Right to Rectification. You have the right to have
any inaccurate personal information which Cornerstone holds about you updated
or corrected.
·
Right to Erasure. In certain circumstances
you may request that Cornerstone delete the personal information that Cornerstone
holds about you.
·
Right to Complain. You have the right to
lodge a complaint regarding the processing of your personal information to an
applicable governmental or supervisory authority in your country.
·
Right to Withdraw Consent. Where processing of
personal information is based on your consent, you have the right to withdraw
such consent at any time.
·
Right to Object. Where Cornerstone relies
on our legitimate interests to process your personal information, you have the
right to object to such use and Cornerstone is required to discontinue such
processing unless Cornerstone can demonstrate an overriding legitimate interest
in such processing.
·
Right to Restriction. You have the right to
request that Cornerstone stop using your personal information in certain
circumstances including if you believe that the personal information Cornerstone
holds about you is inaccurate or that Cornerstone ’s use of your personal
information is unlawful. If you validly exercise this right, Cornerstone will
store your personal information and will not carry out any other processing
until the issue is resolved.
You may exercise any of the above requests in
writing to Cornerstone via email at marketing@cornerstone-ip.com, or via
regular mail at Cornerstone Investment Partners, LLC, 3438 Peachtree Rd. NE Suite
900 Atlanta, GA 30326. You are also free at any time to request that Cornerstone
stop using your personal information for marketing purposes by writing to Cornerstone
via email at marketing@cornerstone-ip.com, or via regular mail at Cornerstone
Investment Partners, LLC, 3438 Peachtree Rd. NE Suite 900 Atlanta, GA 30326.