Privacy

Last updated on: July 31 st , 2024

The Web Site (the “Web Site”) located at https://cci-fund.org/ is published and maintained by Corundum Convergence Institute, a Delaware 501(c)3 Nonprofit (“CCI,” “we,” “us,” “our,” or other similar pronouns).

This Privacy Policy applies to our practices regarding the collection, use and disclosure of personal information that we collect online, including via our website or by email, marketing communications, and other methods. This Privacy Policy does not apply (i) to information that you may provide to us, or that we may obtain, other than through the Web Site or such capability, software or service, such as by phone, through postal mail and through other live and print media or (ii) to information that is not Personal Information.

You should read this entire Privacy Policy before submitting information to us or using our Website. Whenever you submit information via our Website or otherwise to us, whether online or offline, you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy.

Your privacy is important to us. In order to make your visits to the Web Site and use of any capability, software or service that may be made available through the Web Site as worthwhile as possible, we may ask you for Personal Information and we may collect certain information from your computer when you visit us. The aim of this notice regarding our Privacy Policy is to:

• Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;


• Explain the way we use the personal data that you share with us in order to give you a great experience when you are using any of our capabilities, software or services that may be made available through the Web Site; and


• Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.

We hope this helps you to understand our privacy commitments to you.

“Personal Information” is information that can be used to identify, locate, or contact an individual, including, for example, the individual’s name, postal address, e-mail address, telephone, wireless and/or fax number, demographic information, employment or education-related information, and/or other information that may identify the individual or allow online or offline contact with him/her. It also includes other information to the extent that it is associated with Personal Information.

Personal Information is collected as part of the application and registration process on the Website. Personal Information includes, but is not limited to, family name, given name, address, email, and phone number. Additionally, as you use our Website some information can be “passively” collected using various technologies (including mobile devices), such as cookies, web beacons and navigational and location data collection (clickstream, log files, server logs).

We also collect Personal Information from persons access or use any capability, software or service that may be made available through the Web Site, through such users’ activities, submission of information or materials or completion of online forms on the Web Site and/or registration for use of or access or use of any such capability, software or service, including, for example, when users submit information or materials on or through the Web Site or such other capability, software or service, send us an e-mail, or in any other way submit Personal Information to us via the Web Site.

We may use your Personal Information:

• to operate, maintain or improve the Web Site, any capability, software or service that may be made available through the Web Site or our business;


• to respond to your requests or inquiries;


• to support auditing, legal or compliance functions;


• to contact you, including to request your feedback on any of our capabilities, software or services;


• to keep our capabilities, software and services safe and secure (for example, for fraud monitoring and prevention);


• to manage your account; and/or


• to maintain our internal record keeping.

We may also link this information with other information that you provide to us or that we obtain from other sources and Web Site Usage Information (as defined below). We may analyze user behavior as a measure of interest in, and use of, the Web Site and/or any capability, software or service that may be made available through the Web Site and e- mails, both on an individual basis and in the aggregate.

We may process or share your data that we hold based on the following basis:

• Consent: We may process your data if you have given us specific consent to use your Personal Information for a specific purpose.


• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.


• Performance of a Contract: Where we have entered into a contract with you, we may process your Personal Information to fulfill the terms of our contract.


• Legal Compelled Disclosure: We may disclose Personal Information to government authorities, and to other third parties when compelled to do so by government authorities or regulators, at our discretion, or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas, regulator requests or to enforce our legal rights or agreements with you or others. We also may disclose Personal Information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Web Site, or anyone else that could be harmed by such activities.


• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. More specifically, we may need to process your data or share your personal information in the following situations:


• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.


• Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.


• Business Partners: We may share your information with our business partners to offer you certain products, services or promotions.


• We have not disclosed any Personal Information to third parties for a business or commercial purpose in the preceding 12 months.

We may use third-party partners to help operate the Web Site and/or any capability, software or service that may be made available through the Web Site, and, as discussed above, may share your information with our affiliates and related entities, service providers and other third parties that provide products or services for or through the Web Site and/or any capability, software or service that may be made available through the Web Site or for our business (such as Web site or database hosting companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfillment companies, and other similar service providers that use such information on our behalf).

As you use our Website and galleries some information can be “passively” collected using various technologies (including mobile devices), such as cookies, web beacons and navigational and location data collection (clickstream, log files, server logs). Your Internet browser automatically transmits some of this information, such as the URL of the website you just visited and the Internet Protocol (IP) address and browser version currently being used by your computer. Most mobile devices allow you to control or disable the use of location services by any application on your mobile device in the device’s settings menu. Such technologies help us to keep track of your interactions with our Website, the pages you view, the links you click, and other actions you take, within our advertising, email or newsletter content, to provide you with a more customized experience.

Cookies allow us to recognize you when you return so you will not be required to register again for use of the same and track your use of the Web Site and/or any such capability, software or service. They also help us to detect certain kinds of fraud. A “cookie” is a small text file that is placed onto an Internet user’s web browser or device and is used to remember and/or obtain information about the user. Some cookies are temporary, whereas others may be configured to last longer.

Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us or our service providers. These tools allow us to measure response to our communications and improve the Web Site and/or any such capability, software or service.

We collect many different types of Web Site Usage Information. For example, we may collect information from the devices you use to access the Web Site and/or any capability, software or service that may be made available through the Web Site, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the Internet Protocol (“IP”) addresses of the devices you use to interact with the Web Site and/or any such capability, software or service. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. In many cases, the information we collect using cookies and other tools is used in non- identifiable ways, without any reference to Personal Information. For example, we use information we collect about users of the Web Site and/or any such capability, software or service to optimize same and understand its usage patterns. In other cases, we may associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Policy governs how we use that information. If you do not wish to have cookies placed on your computer, you should set your browser to refuse cookies before using our Website, with the drawback that certain features may not function properly without the aid of cookies. To find more information about cookies and for instructions on how to disable them please visit www.allaboutcookies.org or visit the help section of your browser. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use.

We may disclose aggregate statistics regarding user behavior as a measure of interest in, and use of, the Web Site and e-mails to third parties in the form of aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user.

While we will endeavor to protect the security and integrity of sensitive Personal Information provided to the Web Site and/or any capability, software or service that may be made available through the Web Site, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information will be absolutely safe from intrusion by others, such as hackers, during transmission through the Internet or while stored on our system or otherwise in our care.

If you contact us by e-mail or a “contact us” or similar feature on the Web Site and/or any capability, software or service that may be made available through the Web Site, you should be aware that your transmission might not be secure. A third party could view information you send by these methods in transit. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification.

By providing Personal Information to us through the Web Site and/or when you register for use of or use any capability, software or service that may be made available through the Web Site, you understand that it may be used by us and our affiliates for the purposes described herein, and you further understand and consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories, which may have different privacy laws from your country of residence and which may afford varying levels of protection for your Personal Information, and such laws may not be as comprehensive as those that exist in your country or residency. Regardless of the laws in place in these countries, we will treat the privacy of your information in accordance with this Privacy Policy. By providing your Personal Information to the Web Site, you consent to our transmission to, and processing of your information in, any jurisdiction, in accordance with this Privacy Policy.

This Privacy Policy only addresses the use and disclosure of Personal Information we collect from you. Other websites that may be accessible through the Web Site have their own privacy policies and data collection, use and disclosure practices. If you link to any such website, we urge you to review its privacy policy. We are not responsible for the policies or practices of third parties.

We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to Do Not Track signals. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal 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.

If you are under 18 years of age, reside in California, and have a registered account with us, you have the right to request removal of unwanted data that you publicly post on our services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed by us, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

We are in compliance with the requirements of the Children’s Online Privacy Protection Act (“COPPA”) and other applicable privacy laws. Our Website recognizes the importance of protecting the privacy of children under the age of 13. As such, we do not knowingly collect personal information from children under 13 without verified parental consent. If we become aware that we have inadvertently received personal information from a visitor under the age of 13 without verified parental consent, we will take appropriate steps to delete the information from our records.

If you are a parent or guardian and believe that your child under the age of 13 has provided us with personal information, please contact us using the information below to request the deletion of that information.

We reserve the right to change or update this Privacy Policy, or any other of our policies or practices, at any time, and will notify users of the Web Site by posting such changed or updated Privacy Policy on this page. Any changes or updates will be effective immediately upon posting to the Web Site. Under certain circumstances, we may also elect to notify you of any changes or updates to our Privacy Policy by additional means, such as posting a notice on the front page of the Web Site to sending you an email. Be sure to check the Policy whenever you submit personal information to us.

If you have any questions or comments regarding our privacy practices, you may contact us at info@cci-fund.org