Last updated January 31, 2024
This privacy
notice for CTO Consulting Services Inc. (
- Visit our
website
at https://ctoconsulting.io , or any website of ours that links to this privacy notice
- Engage
with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this
privacy notice will help you understand your privacy rights and choices. If you do not agree
with our policies and practices, please do not use our Services.[email protected] .
SUMMARY OF KEY POINTS
This summary provides key points from our privacy
notice, but you can find out more details about any of these topics by clicking the link
following each key point or by using our table of
contents below to find the section you are looking
for.
What personal information do we process? When you
visit, use, or navigate our Services, we may process personal information depending on how you
interact with us and the Services, the choices you make, and the products and features you use.
Learn more about personal
information you disclose to us.
Do
we process any sensitive personal information?
Do
we receive any information from third parties?
How do we process your information? We process
your information to provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also process your information for
other purposes with your consent. We process your information only when we have a valid legal
reason to do so. Learn more about how we process your information.
In
what situations and with which
How do we keep your information safe? We have
What are your rights? Depending on where you are
located geographically, the applicable privacy law may mean you have certain rights regarding
your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way
to exercise your rights is by contacting us. We will consider and act upon any
request in accordance with applicable data protection laws.
Want to
learn more about what we do with any information we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT
INFORMATION DO WE
COLLECT?
Personal information you
disclose to us
In
Short: We collect
personal information that you provide to
us.
We collect
personal information that you voluntarily provide to us when you
Personal Information Provided by You. The
personal information that we collect depends on the context of your interactions with us and
the Services, the choices you make, and the products and features you use. The personal
information we collect may include the following:
-
names
-
phone numbers
-
email addresses
Sensitive Information.
Social Media Login Data. We may provide
you with the option to register with us using your existing social media account details,
like your Facebook, Twitter, or other social media account. If you choose to register in
this way, we will collect the information described in the section called
All
personal information that you provide to us must be true, complete, and accurate, and you
must notify us of any changes to such personal information.
2. HOW DO
WE PROCESS YOUR
INFORMATION?
In
Short: We process your information to
provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your
consent.
We
process your personal information for a variety of reasons, depending on how you
interact with our Services, including:
We
will
use
and
retain
the
collected
personal
information
as
needed
to
provide
the
Services
or
for:
Based
on
the
applicable
laws
of
your
country,
you
may
have
the
right
to
request
access
to
the
personal
information
we
collect
from
you,
change
that
information,
or
delete
it.
To
request
to
review,
update,
or
delete
your
personal
information,
please email us at [email protected]
.
- To respond to user inquiries/offer
support to users. We may process your information to
respond to your inquiries and solve any potential issues you might have with
the requested service.
3.
WHAT
LEGAL
BASES
DO
WE
RELY
ON
TO
PROCESS
YOUR
INFORMATION?
In
Short: We
only
process
your
personal
information
when
we
believe
it
is
necessary
and
we
have
a
valid
legal
reason
(i.e.
,
legal
basis)
to
do
so
under
applicable
law,
like
with
your
consent,
to
comply
with
laws,
to
provide
you
with
services
to
enter
into
or
fulfill
our
contractual
obligations,
to
protect
your
rights,
or
to
fulfill
our
legitimate
business
interests.
If
you
are
located
in
Canada,
this
section
applies
to
you.
We
may
process
your
information
if
you
have
given
us
specific
permission
(i.e.
,
express
consent)
to
use
your
personal
information
for
a
specific
purpose,
or
in
situations
where
your
permission
can
be
inferred
(i.e.
,
implied
consent).
You
can
withdraw
your
consent at
any
time.
In
some
exceptional
cases,
we
may
be
legally
permitted
under
applicable
law
to
process
your
information
without
your
consent,
including,
for
example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
-
For
investigations
and
fraud
detection
and
prevention
-
For
business
transactions
provided
certain
conditions
are
met
-
If
it
is
contained
in
a
witness
statement
and
the
collection
is
necessary
to
assess,
process,
or
settle
an
insurance
claim
-
For
identifying
injured,
ill,
or
deceased
persons
and
communicating
with
next
of
kin
-
If
we
have
reasonable
grounds
to
believe
an
individual
has
been,
is,
or
may
be
victim
of
financial
abuse
-
If
it
is
reasonable
to
expect
collection
and
use
with
consent
would
compromise
the
availability
or
the
accuracy
of
the
information
and
the
collection
is
reasonable
for
purposes
related
to
investigating
a
breach
of
an
agreement
or
a
contravention
of
the
laws
of
Canada
or
a
province
-
If
disclosure
is
required
to
comply
with
a
subpoena,
warrant,
court
order,
or
rules
of
the
court
relating
to
the
production
of
records
-
If
it
was
produced
by
an
individual
in
the
course
of
their
employment,
business,
or
profession
and
the
collection
is
consistent
with
the
purposes
for
which
the
information
was
produced
-
If
the
collection
is
solely
for
journalistic,
artistic,
or
literary
purposes
-
If
the
information
is
publicly
available
and
is
specified
by
the
regulations
In
Short: We
may
share
information
in
specific
situations
described
in
this
section
and/or
with
the
following
third
parties.
We
may
need
to
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.
In
Short: If
you
choose
to
register
or
log
in
to
our
Services
using
a
social
media
account,
we
may
have
access
to
certain
information
about
you.
Our
Services
offer
you
the
ability
to
register
and
log
in
using
your
third-party
social
media
account
details
(like
your
Facebook
or
Twitter
logins).
Where
you
choose
to
do
this,
we
will
receive
certain
profile
information
about
you
from
your
social
media
provider.
The
profile
information
we
receive
may
vary
depending
on
the
social
media
provider
concerned,
but
will
often
include
your
name,
email
address,
friends
list,
and
profile
picture,
as
well
as
other
information
you
choose
to
make
public
on
such
a
social
media
platform.
We
will
use
the
information
we
receive
only
for
the
purposes
that
are
described
in
this
privacy
notice
or
that
are
otherwise
made
clear
to
you
on
the
relevant
Services.
Please
note
that
we
do
not
control,
and
are
not
responsible
for,
other
uses
of
your
personal
information
by
your
third-party
social
media
provider.
We
recommend
that
you
review
their
privacy
notice
to
understand
how
they
collect,
use,
and
share
your
personal
information,
and
how
you
can
set
your
privacy
preferences
on
their
sites
and
apps.
6.
HOW
LONG
DO
WE
KEEP
YOUR
INFORMATION?
In
Short: We
keep
your
information
for
as
long
as
necessary
to
fulfill
the
purposes
outlined
in
this
privacy
notice
unless
otherwise
required
by
law.
We
will
only
keep
your
personal
information
for
as
long
as
it
is
necessary
for
the
purposes
set
out
in
this
privacy
notice,
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.
7.
HOW
DO
WE
KEEP
YOUR
INFORMATION
SAFE?
In
Short: We
aim
to
protect
your
personal
information
through
a
system
of
organizational
and
technical
security
measures.
We
have
implemented
appropriate
and
reasonable
technical
and
organizational
security
measures
designed
to
protect
the
security
of
any
personal
information
we
process.
However,
despite
our
safeguards
and
efforts
to
secure
your
information,
no
electronic
transmission
over
the
Internet
or
information
storage
technology
can
be
guaranteed
to
be
100%
secure,
so
we
cannot
promise
or
guarantee
that
hackers,
cybercriminals,
or
other
unauthorized
third
parties
will
not
be
able
to
defeat
our
security
and
improperly
collect,
access,
steal,
or
modify
your
information.
Although
we
will
do
our
best
to
protect
your
personal
information,
transmission
of
personal
information
to
and
from
our
Services
is
at
your
own
risk.
You
should
only
access
the
Services
within
a
secure
environment.
8.
DO
WE
COLLECT
INFORMATION
FROM
MINORS?
In
Short: We
do
not
knowingly
collect
data
from
or
market
to
children
under
18
years
of
age
.
We
do
not
knowingly
solicit
data
from
or
market
to
children
under
18
years
of
age.
By
using
the
Services,
you
represent
that
you
are
at
least
18
or
that
you
are
the
parent
or
guardian
of
such
a
minor
and
consent
to
such
minor
dependent’s
use
of
the
Services.
If
we
learn
that
personal
information
from
users
less
than
18
years
of
age
has
been
collected,
we
will
deactivate
the
account
and
take
reasonable
measures
to
promptly
delete
such
data
from
our
records.
If
you
become
aware
of
any
data
we
may
have
collected
from
children
under
age
18,
please
contact
us
at
[email protected]
.
9.
WHAT
ARE
YOUR
PRIVACY
RIGHTS?
In
Short:
In
some
regions,
such
as
Canada
,
you
have
rights
that
allow
you
greater
access
to
and
control
over
your
personal
information.
You
may
review,
change,
or
terminate
your
account
at
any
time.
In
some
regions
(like
Canada
),
you
have
certain
rights
under
applicable
data
protection
laws.
These
may
include
the
right
(i)
to
request
access
and
obtain
a
copy
of
your
personal
information,
(ii)
to
request
rectification
or
erasure;
(iii)
to
restrict
the
processing
of
your
personal
information;
(iv)
if
applicable,
to
data
portability;
and
(v)
not
to
be
subject
to
automated
decision-making.
In
certain
circumstances,
you
may
also
have
the
right
to
object
to
the
processing
of
your
personal
information.
You
can
make
such
a
request
by
contacting
us
by
using
the
contact
details
provided
in
the
section
"
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
"
below.
We
will
consider
and
act
upon
any
request
in
accordance
with
applicable
data
protection
laws.
Withdrawing
your
consent:
If
we
are
relying
on
your
consent
to
process
your
personal
information,
which
may
be
express
and/or
implied
consent
depending
on
the
applicable
law,
you
have
the
right
to
withdraw
your
consent
at
any
time.
You
can
withdraw
your
consent
at
any
time
by
contacting
us
by
using
the
contact
details
provided
in
the
section
"
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
"
below
.
However,
please
note
that
this
will
not
affect
the
lawfulness
of
the
processing
before
its
withdrawal
nor,
when
applicable
law
allows,
will
it
affect
the
processing
of
your
personal
information
conducted
in
reliance
on
lawful
processing
grounds
other
than
consent.
Opting
out
of
marketing
and
promotional
communications: You
can
unsubscribe
from
our
marketing
and
promotional
communications
at
any
time
by
clicking
on
the
unsubscribe
link
in
the
emails
that
we
send,
replying
"STOP"
or
"UNSUBSCRIBE"
to
the
SMS
messages
that
we
send,
or
by
contacting
us
using
the
details
provided
in
the
section
"
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
"
below.
You
will
then
be
removed
from
the
marketing
lists.
However,
we
may
still
communicate
with
you
—
for
example,
to
send
you
service-related
messages
that
are
necessary
for
the
administration
and
use
of
your
account,
to
respond
to
service
requests,
or
for
other
non-marketing
purposes.
If
you
have
questions
or
comments
about
your
privacy
rights,
you
may
email
us
at
[email protected]
.
10.
CONTROLS
FOR
DO-NOT-TRACK
FEATURES
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.
At
this
stage
no
uniform
technology
standard
for
recognizing
and
implementing
DNT
signals
has
been
finalized
.
As
such,
we
do
not
currently
respond
to
DNT
browser
signals
or
any
other
mechanism
that
automatically
communicates
your
choice
not
to
be
tracked
online.
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
notice.
11.
DO
UNITED
STATES
RESIDENTS
HAVE
SPECIFIC
PRIVACY
RIGHTS?
In
Short: If
you
are
a
resident
of
California
,
you
are
granted
specific
rights
regarding
access
to
your
personal
information.
What
categories
of
personal
information
do
we
collect?
We
have
collected
the
following
categories
of
personal
information
in
the
past
twelve
(12)
months:
| Category | Examples | Collected |
|
A.
Identifiers
|
Contact
details,
such
as
real
name,
alias,
postal
address,
telephone
or
mobile
contact
number,
unique
personal
identifier,
online
identifier,
Internet
Protocol
address,
email
address,
and
account
name
|
|
|
B.
Personal
information
as
defined
in
the
California
Customer
Records
statute
|
Name,
contact
information,
education,
employment,
employment
history,
and
financial
information
|
|
|
|
Gender
and
date
of
birth
|
|
|
|
Transaction
information,
purchase
history,
financial
details,
and
payment
information
|
|
|
|
Fingerprints
and
voiceprints
|
|
|
|
Browsing
history,
search
history,
online
|
|
|
|
Device
location
|
|
|
|
Images
and
audio,
video
or
call
recordings
created
in
connection
with
our
business
activities
|
|
|
|
Business
contact
details
in
order
to
provide
you
our
Services
at
a
business
level
or
job
title,
work
history,
and
professional
qualifications
if
you
apply
for
a
job
with
us
|
|
|
|
Student
records
and
directory
information
|
|
|
|
Inferences
drawn
from
any
of
the
collected
personal
information
listed
above
to
create
a
profile
or
summary
about,
for
example,
an
individual’s
preferences
and
characteristics
|
|
|
|
|
|
-
Category
B
-
As long as the user has an account with us
We
may
also
collect
other
personal
information
outside
of
these
categories
through
instances
where
you
interact
with
us
in
person,
online,
or
by
phone
or
mail
in
the
context
of:
-
Receiving
help
through
our
customer
support
channels;
-
Participation
in
customer
surveys
or
contests;
and
-
Facilitation
in
the
delivery
of
our
Services
and
to
respond
to
your
inquiries.
How
do
we
use
and
share
your
personal
information?
Learn
about
how
we
use
your
personal
information
in
the
section,
"
HOW
DO
WE
PROCESS
YOUR
INFORMATION?
"
Will
your
information
be
shared
with
anyone
else?
We
may
disclose
your
personal
information
with
our
service
providers
pursuant
to
a
written
contract
between
us
and
each
service
provider.
Learn
more
about
how
we
disclose
personal
information
to
in
the
section,
"
WHEN
AND
WITH
WHOM
DO
WE
SHARE
YOUR
PERSONAL
INFORMATION?
"
We
may
use
your
personal
information
for
our
own
business
purposes,
such
as
for
undertaking
internal
research
for
technological
development
and
demonstration.
This
is
not
considered
to
be
"selling"
of
your
personal
information.
We
have
not
disclosed,
sold,
or
shared
any
personal
information
to
third
parties
for
a
business
or
commercial
purpose
in
the
preceding
twelve
(12)
months.
We will
not
sell
or
share
personal
information
in
the
future
belonging
to
website
visitors,
users,
and
other
consumers.
California
Residents
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
using
the
contact
information
provided
below.
If
you
are
under
18
years
of
age,
reside
in
California,
and
have
a
registered
account
with
the
Services,
you
have
the
right
to
request
removal
of
unwanted
data
that
you
publicly
post
on
the
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
on
the
Services,
but
please
be
aware
that
the
data
may
not
be
completely
or
comprehensively
removed
from
all
our
systems
(e.g.
,
backups,
etc.).
CCPA
Privacy
Notice
This
section
applies
only
to
California
residents.
Under
the
California
Consumer
Privacy
Act
(CCPA),
you
have
the
rights
listed
below.
The
California
Code
of
Regulations
defines
a
"residents"
as:
(1)
every
individual
who
is
in
the
State
of
California
for
other
than
a
temporary
or
transitory
purpose
and
(2)
every
individual
who
is
domiciled
in
the
State
of
California
who
is
outside
the
State
of
California
for
a
temporary
or
transitory
purpose
All
other
individuals
are
defined
as
"non-residents."
If
this
definition
of
"resident"
applies
to
you,
we
must
adhere
to
certain
rights
and
obligations
regarding
your
personal
information.
Your
rights
with
respect
to
your
personal
data
Right
to
request
deletion
of
the
data
—
Request
to
delete
You
can
ask
for
the
deletion
of
your
personal
information.
If
you
ask
us
to
delete
your
personal
information,
we
will
respect
your
request
and
delete
your
personal
information,
subject
to
certain
exceptions
provided
by
law,
such
as
(but
not
limited
to)
the
exercise
by
another
consumer
of
his
or
her
right
to
free
speech,
our
compliance
requirements
resulting
from
a
legal
obligation,
or
any
processing
that
may
be
required
to
protect
against
illegal
activities.
Right
to
be
informed
—
Request
to
know
Depending
on
the
circumstances,
you
have
a
right
to
know:
-
whether
we
collect
and
use
your
personal
information;
-
the
categories
of
personal
information
that
we
collect;
-
the
purposes
for
which
the
collected
personal
information
is
used;
-
whether
we
sell
or
share
personal
information
to
third
parties;
-
the
categories
of
personal
information
that
we
sold,
shared,
or
disclosed
for
a
business
purpose;
-
the
categories
of
third
parties
to
whom
the
personal
information
was
sold,
shared,
or
disclosed
for
a
business
purpose;
-
the
business
or
commercial
purpose
for
collecting,
selling,
or
sharing
personal
information;
and
-
the
specific
pieces
of
personal
information
we
collected
about
you.
In
accordance
with
applicable
law,
we
are
not
obligated
to
provide
or
delete
consumer
information
that
is
de-identified
in
response
to
a
consumer
request
or
to
re-identify
individual
data
to
verify
a
consumer
request.
Right
to
Non-Discrimination
for
the
Exercise
of
a
Consumer’s
Privacy
Rights
We
will
not
discriminate
against
you
if
you
exercise
your
privacy
rights.
Right
to
Limit
Use
and
Disclosure
of
Sensitive
Personal
Information
We
do
not
process
consumer's
sensitive
personal
information.
Verification
process
Upon
receiving
your
request,
we
will
need
to
verify
your
identity
to
determine
you
are
the
same
person
about
whom
we
have
the
information
in
our
system.
These
verification
efforts
require
us
to
ask
you
to
provide
information
so
that
we
can
match
it
with
information
you
have
previously
provided
us.
For
instance,
depending
on
the
type
of
request
you
submit,
we
may
ask
you
to
provide
certain
information
so
that
we
can
match
the
information
you
provide
with
the
information
we
already
have
on
file,
or
we
may
contact
you
through
a
communication
method
(e.g.
,
phone
or
email)
that
you
have
previously
provided
to
us.
We
may
also
use
other
verification
methods
as
the
circumstances
dictate.
We
will
only
use
personal
information
provided
in
your
request
to
verify
your
identity
or
authority
to
make
the
request.
To
the
extent
possible,
we
will
avoid
requesting
additional
information
from
you
for
the
purposes
of
verification.
However,
if
we
cannot
verify
your
identity
from
the
information
already
maintained
by
us,
we
may
request
that
you
provide
additional
information
for
the
purposes
of
verifying
your
identity
and
for
security
or
fraud-prevention
purposes.
We
will
delete
such
additionally
provided
information
as
soon
as
we
finish
verifying
you.
Other
privacy
rights
-
You
may
object
to
the
processing
of
your
personal
information.
-
You
may
request
correction
of
your
personal
data
if
it
is
incorrect
or
no
longer
relevant,
or
ask
to
restrict
the
processing
of
the
information.
-
You
can
designate
an
-
You
may
request
to
opt
out
from
future
selling
or
sharing
of
your
personal
information
to
third
parties.
Upon
receiving
an
opt-out
request,
we
will
act
upon
the
request
as
soon
as
feasibly
possible,
but
no
later
than
fifteen
(15)
days
from
the
date
of
the
request
submission.
To
exercise
these
rights,
you
can
contact
us
by
email
at
[email protected]
,
or
by
referring
to
the
contact
details
at
the
bottom
of
this
document.
If
you
have
a
complaint
about
how
we
handle
your
data,
we
would
like
to
hear
from
you.
12.
DO
WE
MAKE
UPDATES
TO
THIS
NOTICE?
In
Short: Yes,
we
will
update
this
notice
as
necessary
to
stay
compliant
with
relevant
laws.
We
may
update
this
privacy
notice
from
time
to
time.
The
updated
version
will
be
indicated
by
an
updated
"Revised"
date
and
the
updated
version
will
be
effective
as
soon
as
it
is
accessible.
If
we
make
material
changes
to
this
privacy
notice,
we
may
notify
you
either
by
prominently
posting
a
notice
of
such
changes
or
by
directly
sending
you
a
notification.
We
encourage
you
to
review
this
privacy
notice
frequently
to
be
informed
of
how
we
are
protecting
your
information.
13.
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
If
you
have
questions
or
comments
about
this
notice,
you
may
email
us
at
[email protected]
14.
HOW
CAN
YOU
REVIEW,
UPDATE,
OR
DELETE
THE
DATA
WE
COLLECT
FROM
YOU?
