Effective Date: April 1, 2025
Last Updated: April 1, 2025

Cornerstone Strategy LLC (“we,” “our,” or “us”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website, https://cornerstone-strategy.com/ (the “Site”) or use our services.

1. Information We Collect

We collect and process the following types of information:

A. Personal Information You Provide Directly

• Name, email address, phone number, and other contact details.
• Information provided through forms, inquiries, and subscription requests.
• Billing and payment information for service transactions.
• Any additional information you provide through customer surveys, event registrations, or service feedback.

B. Automatically Collected Information

• Device Information: IP address, browser type, operating system, and unique device identifiers.
• Usage Data: Pages visited, time spent on the Site, referral URLs, and clickstream data.
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies. (See Section 8 for details.)

C. Sensitive Personal Information

We may collect and process sensitive personal information when required by applicable laws or when you explicitly consent to provide such information. Examples include:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Health-related information
• Biometric data (where applicable)

2. How We Use Your Information

We use the information collected for the following purposes:

• Service Delivery: To provide, maintain, and improve our services.
• Customer Communication: To respond to your inquiries and provide support.
• Analytics and Improvement: To analyze usage trends and enhance the Site’s performance.
• Marketing and Communication: To send newsletters, promotions, and updates, with the option to opt-out.
• Compliance and Legal Obligations: To comply with applicable laws, prevent fraud, and protect our legal interests.

3. Legal Basis for Processing
(For EEA/UK Residents)

If you are located in the European Economic Area (EEA) or the UK, we process your data under the following legal bases:

• Contractual Necessity: To fulfill contractual obligations related to your use of our services.
• Consent: Where you have given consent to specific processing activities.
• Legal Obligation: To comply with applicable legal requirements.
• Legitimate Interests: To improve our services and protect against security threats.

4. Sharing Your Information

We do not sell or rent your personal information. However, we may share your information with:

• Service Providers: Third-party vendors that assist in operating the Site, providing analytics, and supporting customer communications.
• Legal Authorities: When required to comply with applicable laws or in response to valid legal requests.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity.

5. Your Privacy Rights

We recognize and respect your rights under applicable data privacy laws, including:

A. New Jersey Residents (NJDPA Compliance)

Under the New Jersey Data Privacy Act (NJDPA), effective January 15, 2025, New Jersey residents have the following rights:

• Right to Know: Request information about the categories and specific pieces of personal information we have collected about you.
• Right to Correct: Request corrections to inaccurate or incomplete personal information.
• Right to Delete: Request deletion of personal information, subject to legal exceptions.
• Right to Data Portability: Receive a copy of your personal data in a portable format.
• Right to Opt-Out of Targeted Advertising and Profiling: Opt-out of targeted advertising, automated decision-making, and profiling.

B. California Residents (CCPA/CPRA Compliance)

California residents have the following rights under the California Consumer Privacy Act (CCPA/CPRA):

• Right to Know: Access the categories of personal information collected, used, and shared.
• Right to Delete: Request the deletion of your personal information.
• Right to Correct: Correct any inaccurate or incomplete personal information.
• Right to Opt-Out: Opt-out of the sale or sharing of personal information.

C. Virginia, Colorado, Connecticut, and Utah Residents

Residents of Virginia, Colorado, Connecticut, and Utah have similar rights to access, correct, delete, and opt-out of targeted advertising and profiling.

D. EEA/UK Residents (GDPR Compliance)

If you reside in the EEA or UK, you have the following rights under the General Data Protection Regulation (GDPR):

• Right to Access: Obtain a copy of your data.
• Right to Rectification: Request correction of inaccurate data.
• Right to Erasure: Request deletion of data (“right to be forgotten”).
• Right to Restrict Processing: Restrict the processing of your data.
• Right to Data Portability: Transfer your data to another provider.
• Right to Object: Object to data processing, including profiling.

E. How to Exercise Your Rights

To exercise any of these rights, please contact us using the information provided below:

• Email: [email protected]

We will acknowledge your request within 10 business days and respond within 45 days as required by applicable laws.

6. Automated Decision-Making and Profiling

We may use automated decision-making technologies to improve our services and personalize content. However, you have the right to:

• Request an explanation of the decision-making process.
• Opt-out of automated processing that affects your legal or similar rights.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Enhance your browsing experience.
• Analyze Site performance and trends.
• Enable personalized advertisements and content.

Managing Cookies:
You can manage your cookie preferences through your browser settings. Disabling cookies may affect the functionality of the Site.

8. Third-Party Links and Services

Our Site may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review their privacy policies.

9. Data Retention and Security

We retain your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by applicable law.

Security Measures:
We implement appropriate technical and organizational measures to safeguard your information against unauthorized access, disclosure, or alteration.

10. International Data Transfers

If you access our Site from outside the United States, you acknowledge that your information may be transferred to, stored, and processed in the United States or other countries where our servers are located. We ensure that such transfers comply with applicable laws, including through Standard Contractual Clauses (SCCs).

11. Children’s Privacy

Our Site is not intended for children under the age of 13. We do not knowingly collect personal information from children. If we discover that we have collected information from a child under 13, we will delete it promptly.

12. Data Breach Notification

In the event of a data breach that affects your personal information:

• We will notify affected individuals and relevant authorities within 72 hours of discovery, as required by applicable laws.
• We will provide details of the breach, potential risks, and steps taken to mitigate the impact.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes by updating the Effective Date and providing additional notice as required by applicable law.

14. Contact Us

If you have any questions about this Privacy Policy or your rights, please contact us:

Cornerstone Strategy LLC
Email: [email protected]