Last modified December 13, 2021.
On behalf of Cornerstone Commercial investments LLC, thank you for visiting our website (“CCI, “we” or “us”).
• What do we do?
• What type of information we collect
• How we collect your information
• Google Analytics
• Simpler Database
• How we use the information we collect
• With whom we share the information, and for what purpose
• For how long we retain the information we collect
• How do we safeguard your information
• Opt-out options
• How to contact us
What do we do?
CCI offers you real estate related services, including investment opportunities for qualified persons.
The type of information we collect
We collect two types of information from our users.
The first type of information is un-identified and non-identifiable information pertaining to a user(s), which may be made available or gathered via your use of the Services (“Non-personal Information”). We are not aware of the identity of the user from which the Non-personal Information was collected.
• Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name from which you linked to the Services; etc.).
• Analytics information: We collect information about your use of the Services, such as applications’ usage, log files, user activity (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, installs, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Such information may include:
• Account Information: When you sign-up and register to the Services, you will be asked to provide us certain details about yourself.
• Voluntary information: We collect information which you provide us voluntarily. For example, when you respond to communications from us, performing a purchase into an investment opportunity, communicate with us via email or the website or share additional information about yourself or about others through your use of the Services.
• Device Information: We may also collect Personal Information from your device. Such information includes geolocation data, IP address and other information which relates to your activity through the Services.
How we collect information
There are four main methods we may use to collect information about you:
• We collect information through your use of the Services. In other words, when you are using our Services, we are aware of it and may gather the information relating to such usage).
• We collect information which you provide us voluntarily. For example, we collect Personal Information which you provide when you register an account, interact with our customer support or otherwise access our website.
We may use third party services for performance tracking and measurement such as Google Analytics, Flurry Analytics, Fabric or other third party services that may use some of the Non-Personal Information for analyzing and statistic purposes.
The Contact Information we collect from you when you use our Services (e.g. name, phone number, email address, etc.) is stored in our central database (the “CCI Database”). The CCI Database may also contain data from publicly available sources and from our trusted business partners. Our algorithms process the data contained in the CCI Database in order to identify the most up-to-date information for each contact.
We may also disclose to our affiliates and business partners (or permit their access to) Contact Information obtained in CCI Database for the purposes of ensuring that their current contact information is up to date. We will not disclose Contact Information to business partners for the purpose of enriching their data with new Contacts, but merely provide them Contact Information which will help them to check if their existing contact information is up to data and provide them with our current Contact Information. CCI strives, but is not obligated, to keep any information it collects, whether directly from you or from other public sources, complete and accurate.
If you prefer that we will not disclose your Contact Information with our affiliates and business partners, you may opt-out by following the instructions below (under “Opt-out options”). In this case, we shall not continue to disclose your Contact Information.
How may we use the information we collect?
• To enrich CCI Database with current and up to date Contact Information;
• To manage your account and provide you with customer support;
• To serve you advertisements when you use our Services;
• To identify and authenticate your access to the Services;
• To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services;
• To communicate with you and to keep you informed of our latest updates, upgrades and investment products;
• To perform a research or to conduct analytics in order to improve and customize our Services to your needs and interests;
• To support and troubleshoot our Services and to respond to your queries; and
• To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
With whom we share the information we collect
• Affiliates and business partners. We may disclose to our affiliates and business partners (or permit their access to) Contact Information obtained in CCI Database (as explained above, under “CCI Database”) for the purposes of ensuring that their existing contact information is current and up to date.
• Recipients. We may also share Personal Information with the following recipients: (i) our subsidiaries; (ii) subcontractors and other third party service providers (e.g. payment processors, advertisers, etc.); (iii) auditors or advisers of our business processes.
• We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
Third party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via our Services (e.g. by clicking on a link to any other website or location) or via other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them.
For how long we retain the information we collect?
We value your privacy and control over your Personal Information, and therefore you may, at any time, request to change and update it by emailing us at firstname.lastname@example.org.
At any time, you may stop using our Services and request for a full removal of your data, by emailing us at email@example.com.
Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
How do we safeguard and transfer your information?
We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse our Services or acted in an inappropriate manner, please contact us directly at firstname.lastname@example.org.
Advertising ID and Advertising Identifier
The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we will collect and use it for advertising and user analytic purposes. We may also use Apples’ Advertising Identifier (IDFA), which is a non-permanent device identifier provided by Apple, and any information obtained through the use of the Advertising Identifier, for the purpose of advertising.
By downloading or using our Services you explicitly agree that we may associate your Advertising ID and your Advertising Identifier with your applicable persistent device identifier. This will facilitate our ability to improve your personalized experience. Further, we may use other persistent identifiers for non-advertising purposes. If your device does not have Advertising ID or Advertising Identifier respectively, we will use other identifiers.
At any time, you may choose to opt-out from presenting contact information to other users, by sending such opt-out request to email@example.com, with sufficient information about the contact you refer to and the data usage from which you wish to opt-out.
At any time, you may decide to opt-out from enabling us to disclose or allow access to you Contact Information stored on CCI Database with our business partners, by sending such request firstname.lastname@example.org.
At any time, you may stop using our Services and request for a full removal of your data (via an e-mail to email@example.com). This email should include the subject line “Request to delete my data” and an explicit request from you that you want to close your account and delete all of your data. However, CCI may retain such information as necessary for its business record keeping, accounting and safety.