Privacy Policy

Last modified: January 2, 2020

 
 

Introduction

Cusp Intelligence, LLC. (“Cusp Intelligence,” “Cusp Intel,” “Cusp,” “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy is incorporated into and is part of the Website's Terms of Service, and describes the types of information we may collect from you or that you may provide when you visit the website at www.cuspintel.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.

  • In email, text, and other electronic messages between you and this Website.

  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • us offline or through any other means, including on any other website operated by Company or any third party (including any of our affiliates and subsidiaries); or

  • any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy, below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY VISITING THE WEBSITE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

Children under the age of 13 

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at jay@cuspintel.com

Information we collect about you and how we collect it?

We collect several types of information from and about visitors to our Website, including information:

  • by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");

  • that is about you but individually does not identify you, such as your IP Address, devise, operating system, and browser; and/or

  • about your internet connection, the equipment you use to access our Website and usage details

We collect this information:

  • Directly from you when you provide it to us.

  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

  • From third parties, for example, our business partners or third-party service providers

Information you provide to us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. We may also ask you for information when you report a problem with our Website.

  • Records and copies of your correspondence (including email addresses), if you contact us.

  • Your responses to surveys that we might ask you to complete for research purposes.

  • Your search queries on the Website

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.

  • Store information about your preferences, allowing us to customize our Website according to your individual interests.

  • Speed up your searches.

  • Recognize you when you return to our Website

We may utilize cookies and other automatic data collection technologies, such as, web beacons (also known as "clear gifs" and "pixel tags") to recognize you, customize your experience, and provide advertisements. While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a "Do Not Track" signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for our services on third party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements. Cookies are small files placed on your computer, and they allow us to count the number of visitors to the Website and distinguish repeat visitors from new visitors. They also allow us to save user preferences and track User trends. We do not link cookies or web beacons to any personal information. Advertisers and ad servers may use cookies and/or web beacons to monitor information related to advertisements. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by Cusp Intelligence and does not cover the use of cookies by any advertisers. Most web browsers automatically accept cookies, but you do not have to accept them. To disable cookies, you should access the "help" tab on your browser or read the information that came with your browser software. However, your engagement with our Services will be enhanced if cookies are not disabled.

We use or may use services such as Google Analytics, Amazon Web Service, Microsoft Azure, Heroku, Segment, Auth0, Genderize, and Heap to help us understand you and how you find and interact with our Services. We never share any information we obtain from these providers with any third parties for advertising or any other purpose unless compelled to do so by valid legal process. You may be able to opt-out of Google's collection of data. Please visit Google's Ads Preferences Manager or the Google Analytics opt-out browser add-on for more information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • 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 Cusp Intelligence’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

  • To fulfill the purpose for which you provide it.

  • For any other purpose disclosed by us when you provide the information.

  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  • To enforce or apply our terms of use at cuspintel.com/terms and other agreements, including for billing and collection purposes.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cusp Intelligence, our customers, or others.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.

  • To provide you with information, products, or services that you request from us.

  • To fulfill any other purpose for which you provide it.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • To notify you about changes to our Website or any products or services we offer or provide though it.

  • In any other way we may describe when you provide the information.

  • For any other purpose with your consent.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

  • Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-out by contacting us at jay@cuspintel.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

  • We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to jay@cuspintel.com.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Correcting and Updating Your Information

If you are a resident of a country that provides you with the right to request a copy of the Personal Data Cusp Intelligence holds about you and/or to correct any inaccuracies within such data, and Cusp Intelligence is required by applicable laws to respond to such requests, then you may address such requests by emailing jay@cuspintel.com. Cusp will use reasonable efforts to supply, correct or delete information that we hold about you or to advise you if we are not required by applicable laws to comply with such requests.

Customers cannot opt out of receiving transactional emails related to their account with Cusp Intelligence or the Services.

Data Retention:

We will retain your Personal Data for as long as the information is needed for the purposes set forth above and for any additional period that may be required or permitted by law.

Privacy Shield

Cusp Intelligence complies with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Individual Customers in the European Union member countries and Switzerland. Cusp Intelligence has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

Cusp Intelligence's accountability for Personal Data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Cusp Intelligence remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the Personal Data on its behalf do so in a manner inconsistent with the Principles, unless Cusp proves that it is not responsible for the event giving rise to the damage. Cusp Intelligence is under the jurisdiction of the FTC.

Complaints and Dispute Resolution

In compliance with the Privacy Shield Principles, Cusp Intelligence commits to resolve complaints about our collection or use of your personal information. EU and/or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Cusp Intelligence at: jay@cuspintel.com. We suggest that you put in the subject line of any email or communication "Privacy Policy" or "Privacy Complaint." We will respond within 60 days.

Cusp Intelligence commits to cooperate with the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by the panel and/or Commissioner with regard to human resources data transferred from the EU and/or Switzerland in the context of the employment relationship.

Cusp Intelligence agrees to periodically review and verify its compliance with the Privacy Shield Principles, and to remedy any issues arising out of failure to comply with the Privacy Shield Principles. Cusp Intelligence acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department's list of Privacy Shield participants.

If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, you can also submit your complaint to Privacy Trust, an independent third party. Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

Mediation

You agree that, in the event any dispute or claim arising out of or relating to your use of the Site or the Services or this Privacy Policy that does not relate to your personal data (personal data), or that is not covered by the previous paragraph, you and Cusp Intelligence will attempt in good faith to negotiate a written resolution of the matter directly between the parties. Should you file any arbitration claims, or any administrative or legal actions without first having attempted to resolve the matter by mediation, then you agree that to the maximum extent permitted by applicable law, you will not be entitled to recover attorneys' fees, even if you would otherwise be entitled to them.

Verification

Cusp Intelligence self-assesses its compliance to the Privacy Shield Framework. Cusp Intelligence's Privacy Policy regarding personal data received from the EU and Switzerland is accurate, comprehensive and conforms to the Privacy Shield Principles.

Changes to this Privacy Shield Policy

This Privacy Shield Policy may be amended from time to time consistent with the requirements of the Privacy Shield. Appropriate notice regarding such amendments will be given.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you by email or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at jay@cuspintel.com