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Privacy Policy

Last Edited: February 7, 2025

Cornerstone Strategies, LLC’s Privacy Policy

Welcome to Cornerstone Strategies, LLC’s (“Cornerstone”) website, services and platform located at www.cornerstonestrategies.org. Cornerstone operates the cornerstonestrategies.org website and other websites and online platforms (the “Site”) and services, such as proctor training services and platforms, that may reference and incorporate this Privacy Policy (referred to collectively as the “Services”). In this document, “we”, “our”, “us” or “Company” refers to Cornerstone Strategies, LLC. “You”, “user”, or “visitor” means any user of the Site or Services.

We respect your privacy and want you to understand our privacy practices, including how we collect, use, share and protect personal information and how you can exercise your privacy rights. We use the term “personal information” in this Privacy Policy to mean any information that identifies you individually. Please read this Privacy Policy carefully to understand our practices regarding your personal information.

This Privacy Policy is incorporated into our Terms of Use and other agreements that incorporate this Privacy Policy, such as the PLACE Membership Terms (all collectively “Terms. When you agree to the Terms, you are acknowledging that you have read, understand and also agree to this Privacy Policy. You should not use the Site or any Services if you don’t agree with this Privacy Policy.
Below are details about our privacy policies and practices and information about how you can exercise your privacy rights and our Contact Us details.

What Information Is Collected?

As described below, we collect personal information that (a) you or your group administrator gives to us; (b) we collect automatically; and, in limited instances, (c) we infer.

Information You or Your Group Administrator Gives to Us:

In operating the Site or otherwise offering or providing the Services, we may collect the following information from you or your group administrator:

  • First and Last Name
  • Email address
  • Street address
  • Company information
  • User name and password
  • Other users personal information for group memberships – from the PLACE training platform, group administrators may enter information about users in their group.
  • Payment information (processed by a third party payment processor)
  • Inquiry and communications information, such as information provided in custom messages sent through web forms on our Site, as well as your preferred method of communication.

Automatically Collected Information: As you interact with our Services, we and/or our authorized service providers/processors may use automatic data collection technologies to collect certain personal data about your equipment, browsing actions, and patterns, including:

  • Information about the computer, smartphone, or other device you use, including your IP address, browser type, Internet service provider, device type/model/manufacturer, and date and time stamp.
  • Information about how you access and use our Services, including the content you click on or view, referring and/or exit page URLs, the amount of time you spend on our Site, and other browsing behavior and actions you take on the Site.
  • Information about your location, including your approximate geographic location that we or authorized third parties may derive from your IP address. We do not collect precise geolocation data.
  • Analytics information. For example, analytics data and tools like Google Analytics help us measure traffic and usage trends for the Site Features and to understand more about our users. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

The technologies we use for this automatic data collection may include:

  • Cookies. A cookie is a piece of information that a web server may place on your device when you visit a website that can be used to uniquely identify you and record information about the websites that you visit – and other technologies, such as pixels, web beacons, and gifs, that use embedded code in our Site/Services to record details about your use of those Sites, like whether you clicked on a link. A cookie will give us information about how you use the Site (e.g., the pages you view, the links you click, how frequently you access the Services, and other actions you take on the Services). You should refer to instructions in your browser and device to delete and disable cookies.
  • Web Beacons. Pages of our Site and our marketing emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related statistics.
  • Inferred Data: We may use the data that we have collected – directly from you, received from others, and automatically – to combine, compile, and infer new information about you. We and our service providers may infer the following categories of data: contact information, demographic information, financial information, interaction information, and preferences. Please note that some state privacy laws afford residents the right to opt out of profiling or automated decision-making that have legal or similarly significant impacts; we do not conduct these activities.

COOKIES AND DO NOT TRACK/OPT OUT SIGNALS

Our Site collects and processes a range of information about visitors to enable functionality and to deliver requested services. In addition to information we automatically collect for our purposes (see above Automatically Collected Personal Information), our Site/Services may include links to other websites operated by third parties (e.g., third-party payment processors), embedded media (e.g., YouTube videos), and embedded third-party social media applications that may collect information about you when you choose to interact with them. When you access this content, you are interacting directly with the third parties, whose data collection and other processing activities are governed by their privacy policies, and not by this Privacy Policy. When you view embedded media or interact with embedded third-party applications — hosted on other platforms, you will be interacting with such third party’s online environment.

What types of cookies do we use?

The specific types of cookies served through our Site/Services and the purposes they perform include:

  • Essential website cookies: These cookies are strictly necessary to operate our Site/Services and provide you with services and content available through our Site and Services.
  • Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our Site and Services but are non-essential to their use. However, without these cookies, certain functionality may become unavailable or you may not be able to access certain parts of the Site or Services.
  • Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Sites are being used. We use Google Analytics for this purpose.
  • Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Site and Services through third party social networking and other websites. When you visit these platforms, these providers may target ads and use your information for their own commercial purposes.

How can I reject cookies?

You may opt-out of the collection and use of information from social media providers by visiting their links below:

You can also reject cookies by selecting an option on your browser to reject cookies, however, some portions of the Site or Services may require certain personal information such as to create an account, register, or to access certain areas of the Services. In such cases, we ask that you register and provide us with basic information on our registration page or sign in if previously registered. Cookies enable our server to know that you are a registered user and will eliminate the need for you to log in each time you access our Site or Services. In addition, our registration system may require that you accept the cookies from the Site or Services in order to access that portion of the Site or Services.

Opt-Out Signals and Do Not Track: At this time, we do not accept opt-out signals or Do not track signals from your browser. 

We do not target ads to you or sell your personal information.

HOW DO WE USE PERSONAL INFORMATION?

We use the personal information we collect about you for the following purposes:

  • Register you for Services that we provide including access to the PLACE training platform
  • Process payments
  • Internal record keeping
  • Improve our products and services
  • Communicate with you: We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided. You can opt out of these emails at any time.
  • Request your response to surveys or participation in focus groups
  • Respond to your questions or information requests
  • Site and Services optimization and improvement
  • Security and Fraud Prevention
  • Provide the Services to you: We may use the information to provide products or services you have ordered to you.
  • Legal Requirements: we may use your personal information to meet legal requirements.
  • De-identification: We may use de-identified data for research purposes and to develop and to improve our Services. When we de-identify data permanently for privacy purposes, we will use it only in its de-identified form and will not attempt to re-identify the information.

We do not target ads to you or sell your personal information.

TO WHOM DO WE DISCLOSE PERSONAL INFORMATION?

We may disclose your personal information only to group administrators, certain service providers, and others including those listed below.

  • Group Administrator: Your group administrator may provide us with your name and email information, and will be able to view your activities such as account set-up, course progress, and quiz completion.
  • Service providers: We work with a variety of service providers/processors who help us process your personal information. These service providers may facilitate the operation of our Site and Services; support our marketing and communications; or provide tax, accounting, web hosting, analytics, security, and payment processing services. We have binding, written agreements with these service providers that require them to process personal information received from us in compliance with applicable laws.
  • Legal Requirements: We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (1) comply with the law or comply with legal process served on the Company or its parent company, subsidiaries or affiliates, (2) to enforce our Terms of Use and other agreements, protect the security and integrity of our Site and Services; or to protect and defend the rights or property of the Company or the users of the Site or Services, or (3) act under exigent circumstances to protect the safety of the public, users of the Site or Services, and employees.
  • Business Transition: In order to accommodate changes in our business, we may sell or buy portions of our company or other companies or assets, including the information collected through this Site or otherwise collected in connection with the Service. If the Company or substantially all of its assets are acquired, customer information will be one of the assets transferred to the acquirer.
  • With your consent: We may disclose personal information about you to certain other third parties or publicly with your consent or at your direction. For example, with an individual’s consent or at their direction, we may register you for an event we host or participate in.

YOUR PRIVACY CHOICES & PRIVACY RIGHTS

Depending on where you reside, and subject to certain legal limitations, you may have some or all of the following rights in relation to the personal information we have collected or processed about you. Please note that some states in the U.S. and the European Union have privacy laws that afford residents the right to opt-out of profiling or automated decision-making that have legal or similarly significant impacts; we do not conduct these types of activities.

We will make reasonable attempts to comply with your privacy rights requests but may refuse requests where there is risk to the privacy of others, that are impractical, that are unreasonably repetitive, that require a disproportionate technical effort, or where prohibited by law.

  • Access. You may have the right to confirm whether we process your personal information and access that data.
  • Correction. If any personal information we have collected about you is inaccurate or out of date, you may have the right to have that information corrected or updated.
  • Deletion. You may have the right to request deletion of your personal information in certain situations.
  • Portability. Subject to the rights of others, you may have the right to request a copy of your personal information (if available) and transfer it in a commonly used electronic form (if feasible).
  • Opt-out. You may have the right to opt out of certain processing activities, including, for example, the use of your personal information for direct marketing.
  • Withdraw consent. If you have provided consent for the processing of your personal information, you may have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.

Submitting a Privacy Rights Request:

  • Contact Us: You may submit a privacy rights request to us or authorize another party to do so on your behalf by contacting us at privacy@cornerstonestrategies.org.
  • Identity Verification: When we receive a privacy rights request, we will need to confirm your identity. We may contact you for additional information to verify your identity.
  • Appeals: If we deny your request, you may appeal our decision within a reasonable period after we have notified you by contacting us at privacy@cornerstonestrategies.org. We will review and provide a written explanation for our response in compliance with applicable legal requirements.

SECURITY; RETENTION PERIOD FOR PERSONAL INFORMATION

We maintain industry standard safeguards to ensure the security, integrity and privacy of the personal information that you provide to us and our Site and Services. Importantly, no security system or website is impenetrable and we cannot guarantee the security of our systems, Site and Services. If personal information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with any applicable laws and regulations.

Except as otherwise mentioned in this privacy notice, we keep your personal information for a reasonable period of time, including:

  • to provide you with the services and products you have requested;
  • to comply with other law, including for the period demanded by our tax authorities;
  • to support a claim or defense in court.

LINKS TO OTHER WEBSITES AND SERVICES

The Site and Services may contain links to other websites and services. If you choose to visit other websites, including those of our third-party service providers, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

We use an online third party payment processor to process any payments for Services.  At the point of payment online, you are transferred to a secure page on the website of the third party payment processor. That page may be branded to look like a page on our website, but it is not controlled by us. We do not receive any payment card details from this service provider.

MINOR’S PERSONAL INFORMATION

The Site and Services are designed for a general audience and are not directed to anyone under the age of 18. We do not knowingly collect or solicit personal information from individuals under the age of 18 through the Services. If we become aware that we have collected personal information from someone under the age of 18, we will promptly delete the information from our records unless required otherwise by law. If you believe that an individual under the age of 18 may have provided us with personal information, please contact us at privacy@cornerstonestrategies.org.

USE AND TRANSFER OF YOUR INFORMATION

The Site and Services are operated in the United States and service providers with whom we might share your personal information as explained above are also located in the United States. If you are located in the EEA or elsewhere outside of the United States, please be aware that any information you provide will be transferred to and used by us and our service providers in the United States. By using the Site, participating in any of our Services and/or providing your information, you understand and agree to your personal information being transferred, processed, and stored within the United States.

CHANGES TO OUR PRIVACY POLICY

From time to time, we may make changes to our Privacy Policy. We will notify you of any material changes to our Privacy Policy as required by law. We will also post an updated copy on our Site. Please check our Site periodically for updates. Your continued use of our Site or Services, means that you consent to the collection, use, and disclosure of your personal information as set out in the updated Privacy Policy.

HOW TO CONTACT US

If you have any questions regarding our Privacy Policy, please contact us at:

Cornerstone Strategies LLC
P.O. Box 104
Chariton, IA 50049, USA.
(888) 771-4654
privacy@cornerstonestrategies.org