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DATE UPDATED: 4/27/20

This Privacy Policy (at times, this “Policy”) discloses the privacy practices for www.castusglobal.com (the “Website”) and all services offered by us through the Website or otherwise, including without limitation, all mobile, tablet, and other smart devices applications and application program interfaces and associated services (collectively, the “Service” or our “Service”). Castus Consulting Limited Liability Company (“CASTUS,” “us,” or “we”) is committed to protecting your privacy online. Please read the information below to learn the following regarding your use of the Service. You acknowledge that this Privacy Policy is part of our Terms and Conditions of Use, and by accessing or using our Service, you agree to be bound by all of its terms and conditions. If you do not agree to these terms, please do not access or use the Service. For clarity, this Policy also hereby specifically incorporates CASTUS’s Terms and Conditions of Use by reference into this Policy in its entirety.  

CASTUS processes data on and through the Service as both a data processor and as a data controller.  This Privacy Policy is intended to help you understand:

• What personal information and data we collect and why we collect it;
• What we do with your personal information and data; and
• Your rights to access, update, and delete your personal information and data.  

We reserve the right to change this Privacy Policy at any time. Such changes, modifications, additions, or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to issuing an email to the email address listed by registered users and posting the revised Policy on this page. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Service and update the “Last Updated” date at the top of this Privacy Policy. We also may choose to provide you with notice of the modification by email before the date when such revised Privacy Policy becomes effective.

If you disagree with any revised version of this Privacy Policy, you may cease your use of the Service, or exercise any of your rights set forth herein with respect to your personal information. Otherwise, your continued access to or use of the Service will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by the modified Policy. You acknowledge and agree that it is your responsibility to maintain a valid email address as a registered user, to review the Website and the Service and this Policy periodically, and to be aware of any modifications.

1. Types of Information Collected

To better provide you with our numerous services, we collect two types of information about our users: (i) “Personally Identifiable Information;” and (ii) “Nonpersonally Identifiable Information” (at times collectively with the Personally Identifiable Information, your “Information”). Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our Service.

Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities through the Service, which includes filling out a survey, joining our email list, or sending us feedback, we ask you to provide certain information about yourself by filling out and submitting an online form(s). It is completely optional for you to engage in these activities. However, if you elect to engage in these activities, we ask that you provide us with Personally Identifiable Information, including your first and last name and email address. Depending upon the activity, some of the information we ask you to provide may be identified as mandatory while other information may be identified as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.

Non-personally Identifiable Information: This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on or throughout our Service in several ways. This information is compiled and analyzed on both a personal and an aggregated basis, including through the use of Google Analytics. This information may include the Website's Uniform Resource Locator (“URL”) from which your visit originated, which URL you access next, what browser you are using, and your Internet Protocol (“IP”) address. A URL is the global address of documents and other resources on the World Wide Web (the “Web” or the “Internet”). An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the Web, allowing Web servers to locate and identify your computer. Computers require IP addresses for users to communicate on or through the Internet.

2. Collection Methods and Use of Information

We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us. You provide certain Personally Identifiable Information to us when you: (a) send email messages; (b) submit forms; or (c) transmit other information by telephone or letter. We also may collect information from you at other points on or through our Service that state that such information is being collected, such as a survey.

In addition, we also may collect, or our third-party ad server and/or content server may collect, certain Non-personally Identifiable Information. This Non-personally Identifiable Information ultimately is stored in the form of store categories and in some cases, specific URLs. We use your IP address to diagnose problems with our servers, certain software, to administer our Service, and to gather demographic information. Our third-party ad servers also will provide us with summary, but not individual, reports that will tell us how many ads were presented and clicked upon at or through our Service.

We primarily will use your Personally Identifiable Information to respond to your correspondence. We also will use Personally Identifiable Information to improve our marketing and promotional efforts. We may use Personally Identifiable Information to deliver information to you and to contact you regarding administrative notices. You acknowledge that all such documents and agreements are incorporated herein by this reference in their entirety and apply to this Privacy Policy, further including without limitation, all rules of conduct, disclaimers of warranty, limitations of liability, indemnification, and dispute resolution provisions.

For clarity, we use, store, and process information and data, including Personally Identifiable Information, about you to provide, understand, improve, and develop the Service.  We use, store, and process information collected for the following purposes:

• To provide information or services you have requested.
• To provide customer service and/or respond to inquiries from you.
• To send you service or support messages.
• To fulfill any other purpose that you might request upon you consenting to our use of your personal information or data for such purpose if possible.
• To notify you about any changes to our Service or any products or services we offer or provide.

We process this personal information and data with your voluntary consent in disclosing it to us.

3. Release of Information

We do not sell, trade, or rent your Personally Identifiable Information to any third parties.

Occasionally, we may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order or subpoena or in pursuance of cooperating and complying with any law enforcement action or investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we have any information or reason to believe might possibly be unlawful and/or might possibly lead to unlawful activity of any kind.

In the event that our assets are sold or transferred to another party or that another transaction occurs in which your Personally Identifiable Information is one of the assets transferred, all information and data that has been collected and saved likely will be included in that transfer. We will post a notice on or through the Service in the event of such a transfer and all of your rights with regard to your Personally Identifiable Information will remain for you to exercise at all times as outlined in this Privacy Policy or otherwise through the Service.

We also may provide Nonpersonally Identifiable Information about our customers' and users’ sales, transaction, traffic patterns, and related Service information to third party advertisers, but these statistics will not include any Personally Identifiable Information.

4. Your Rights

You may exercise any of the rights described in this Section 4 by sending an email to hello@castusglobal.com. Please note that we may ask you to verify your identity before taking further action on your request.

         4.1 Managing Your Information: You may access your information through contacting CASTUS at hello@castusglobal.com.

         4.2 Rectification of Inaccurate or Incomplete Information: You have the right to ask us to correct inaccurate or incomplete personal information concerning you. We also believe you should have the ability to access the Personally Identifiable Information that you have provided to us. You also may access and correct your Personally Identifiable by contacting us by email at hello@castusglobal.com. Please include your name, address, and/or email address when you contact us.

        4.3 Data Access and Portability: In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or to request for us to transmit this information to another service provider (where technologically practicable and feasible).

       4.4 Data Retention and Erasure: If you no longer want us to use your information to provide access to the Service to you, you can request that we erase your personal information by following the instructions in the below Section 10 entitled  “Miscellaneous Privacy Issues and Contacting Us.” Please note that if you request the erasure of your personal information:

• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety and the functionality and improvement of the Service.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations, such as for tax, legal reporting, and auditing obligations.

       4.5 Withdrawing Consent and Restriction of Processing: Where you have provided your consent to the processing of your personal information by CASTUS, you may withdraw your consent at any time by sending an electronic communication to us specifying which consent you are withdrawing, as otherwise provided for under this Privacy Policy. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

       4.6 Lodging Complaints: You may have the right to lodge complaints about the data processing activities carried out by CASTUS to the appropriate data protection authorities. However, please understand that by communicating any such concerns to us in advance, you will help put CASTUS in the best position to resolve any such concerns in the most efficient and effective way, especially in light of CASTUS’s commitment to the safety, security, and privacy of your personal information and data.  

5. User Choices on Collection and Use of Information

From time to time, we may send you an email(s) regarding our products and services. If you do not want to receive such mailings, simply tell us at hello@castusglobal.com. As more fully outlined and explained below in Section 7 entitled “Cookies,” we do use cookies to track your computer’s browser while on our Website.  

6. Security of Information

With our Service, you can be assured that your Personally Identifiable Information is secure, consistent with current industry standards. The importance of security for all Personally Identifiable Information associated with our users is of utmost concern to us. Your Personally Identifiable Information is protected in several ways. Your Personally Identifiable Information resides on a secure server that only selected CASTUS personnel and contractors will be able to access via a separate password(s). We encrypt your Personally Identifiable Information and thereby prevent unauthorized parties from viewing such information when it is transmitted to us.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet that are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the Service cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

We are continuously implementing and updating our administrative, technical, and physical security measures to help protect your personal information against unauthorized access, loss, destruction, or alteration. We incorporate reasonable safeguards to protect the security, integrity, completeness, accuracy, and privacy of the personal information that we may collect, including firewalls, data encryption, and information access controls.

7. Cookies

A “cookie” is a small data text file, which a Web site stores on your computer's hard drive (if your Web browser permits it) that can later be retrieved to identify you to us. CASTUS does use “cookies” with your consent. We do not utilize “cookies” without your consent. Not consenting to the use of cookies will not stop you from having access to the Website or the Service.  

8. Privacy Policies of Third-Party Sites

Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information that we collect from you. Other sites accessible through our Service have their own privacy policies and related documentation and materials and control and handle their own data collection, data use, and data disclosure practices. Please consult each site's separate privacy policy and related documentation and materials in those regards. We are not responsible for the policies or practices of third parties. Additionally, other companies that place advertising on our Website and Service may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information and data. You should contact these advertisers directly if you have any questions about their use of the information and data that they collect and/or process.

9. California Privacy Rights

California law requires us to disclose information regarding the categories of personal information that we have collected about California residents, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the personal information was collected, and the categories of parties with whom we share personal information. The disclosures made in this Section 9 are in addition to those set forth elsewhere in this Privacy Policy, all of which also shall apply to California residents and their personal information.  

       9.1 Please refer to Sections 2 and 3 of this Privacy Policy for information regarding how we collect, use, and release your personal information.

       9.2 If you are a California resident, in addition to all of the rights outlined in the above Section 4 entitled “Your Rights” of this Privacy Policy, you also may exercise any of the following rights:

• You may request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to hello@castusglobal.com. You will be required to      verify your identity before we can verify your request. Please allow up to thirty (30) days for us to process any such request that you submit.      
• You may designate an authorized agent to make any request on your behalf. To do so, you might provide us with written authorization or a power of attorney that you have signed. In each case, you still will need to verify your identity directly with us.

• You have the right not to be discriminated against for exercising your rights. Please note, however, that we need certain types of information to provide the Service to you. If you ask us to delete it, you may no longer be able to access the Service.

10. Miscellaneous Privacy Issues and Contacting Us

You must be at least eighteen (18) years old to have our permission to use the Service. We do not knowingly collect, use, or disclose Personally Identifiable Information about visitors to the Service who are under eighteen (18) years of age.

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us by email at hello@castusglobal.com.  If you also would like us to contact us by other means, you may do so at the following:

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