Privacy Policy

Cornerstone Systems, Inc.

INTRODUCTION

Thank you for visiting Cornerstone Systems, Inc. (“Cornerstone”, “us”, “we”, or “our”). Because your privacy is important to us, we provide this Privacy Policy (“Privacy Policy”) explaining our online practices and your choices regarding our use of information about you collected through our online and mobile websites, services, and applications (collectively the “Website” or “Websites”).

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND YOUR CHOICES.  IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE WEBSITE.  

THE WEBSITE IS INTENDED FOR USERS LOCATED IN THE UNITED STATES, AND IT IS NOT INTENDED FOR USERS LOCATED IN OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA.

By accessing our Website, you consent and agree to the collection, use, and storage of your information by us in the manner described in the Privacy Policy. We reserve the right to change and update the Privacy Policy and such updated versions will be posted on the Website. In addition to this Privacy Policy, your use of our Website is governed by our Terms of Use.

  • INFORMATION WE COLLECT 

Registration, Social Media, and Other Information. In the course of our certain business activities and providing our services, Cornerstone may need to process personal information.  Without your personal information, we may not be able to provide you with the requested services.  As a rule, the information that you provide directly or indirectly to Cornerstone when using our services and visiting our Websites may include contact information such as name, address, telephone number, and e-mail address and information about your interest in and use of our products and services. If you connect to our Website or sign up for promotions using your social media credentials (e.g., Facebook), you authorize us to collect information, such as your name, username, e-mail address, or other profile information in connection with your social media account.

If you post information or content, such as by posting photos, commenting on a blog, or participating in online forums or communities at our Websites, or when you interact with our Websites through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. Therefore, we cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. For more information about how you can customize your privacy settings and how third-party social media sites handle your personally identifiable information, please refer to their privacy help guides, privacy policies and terms of use.

In addition to personally identifiable information, we may collect other types of information which may or may not contain personally identifiable information, such as information related to shipments and services.  This type of information may include shipment tracking number, shipment routing information, location data, status of a shipment, delivery location, packaging type, number of pieces, weight, picture of the parcel, and customs information.  

Technical and Usage Information. We also collect certain information when you use our Websites such as the type of browser you are using (e.g., Chrome, Safari, Firefox), the type of operating system you are using (e.g., Windows, Mac OS, iOS, and Android), the domain name of your Internet service provider or mobile carrier, IP address, and certain usage information.

Information from Mobile Devices. If you access our Websites on your mobile device, we also may collect information that is automatically assigned to your devices used to access our Website including your unique device identifier and mobile device IP address (e.g., MAC address), as well as information about your device’s operating system, mobile carrier, and mobile Internet browsers, geolocation information, and other information described in this Privacy Policy.

  • HOW WE USE YOUR INFORMATION

We may, to the extent permitted by applicable law, use the information described above as follows:

Registration and Account Information. We use information you provide to fulfill your requests for our events and offerings (e.g., send you the information about events, subscribe to our newsletters, participate in one of our contests or promotions), respond to your questions, improve Website content, and to offer you other products, programs, or events that we believe may be of interest to you.

We also may use your information to contact you regarding your use of our offerings or events, changes to this Privacy Policy, Terms of Use, or other policies or terms that affect you and use of our Websites or our offerings. In addition, we may use such information to improve the content and navigation of our Websites, or for other internal purposes.

Use of Mobile Device Data. When you access our Websites on a mobile device, we may use the information collected for any of the purposes set forth in this Privacy Policy. For example, we use information collected on mobile devices to enable you to do things like (i) watch video clips, (ii) get event news and updates, (iii) locate and access personalized information or functionality based on your location (e.g., find events near you, tag photographs, or check in to a certain venue), and (iv) follow blogs. We may also use this information to offer you products, programs and events we believe may be of interest to you and otherwise tailor your experience.

Why we use your information.  We rely on a number of legal bases to use your information, including:

To fulfill a contract, or take steps linked to a contract. This includes:

  • Account creation and processing any tickets, services or merchandise that you have requested;
  • Verifying your identity;
  • Processing payments; 
  • Sending you necessary communications (for example, related to shipment tracking, routing information, etc.); and
  • Providing customer service or support.

As required to conduct our business and pursue our legitimate interests, in particular:

  • Provide you with our products and services;
  • Analyzing your use and measuring effectiveness of our websites to better understand how they are being used so we can improve them and engage and retain users;
  • Sending you information about products, services, special offers, and similar information, and sharing your information with third parties for their own marketing purposes;
  • Analyzing your use of our websites, your content, and your interaction with our communications, to tailor and customize the website and marketing communications;
  • Diagnosing problems with our Websites;
  • Detecting, preventing, or otherwise addressing fraud, security or technical issues, as well as protecting against harm to the rights, property or safety of Cornerstone, our users, or the public;
  • Conducting surveys and market research about our customers, their interests, the effectiveness of our marketing campaigns, and customer satisfaction (unless we need consent to undertake such surveys, in which case we will only do this with your permission);
  • If we merge with or are acquired by another company, sell a website or business unit, or if all or a substantial portion of our assets are acquired by another company, your information will likely be disclosed to our advisers and any other prospective purchaser’s advisers and will be one of the assets that is transferred to the new owner; and
  • In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with government agency requests, legal process or litigation).

Where required, when you give Cornerstone your consent or otherwise consistent with your choices:

  • Sending you information about Websites, tickets, events, special offers and similar information, and sharing your information with third parties for their own marketing purposes;
  • Placing cookies and using similar technologies, such as Google Analytics on our websites and in email communications; and
  • For targeted online and offline marketing including through tools like Facebook Custom Audience.
  • HOW WE MAY SHARE YOUR INFORMATION

We may disclose or share the information described above as permitted by applicable law in the following contexts:

Our Affiliates. We may disclose your information to our corporate subsidiaries or entities affiliated with Cornerstone. Any information provided to Cornerstone’s subsidiaries or entities affiliated with Cornerstone will be treated by those subsidiaries and affiliated entities in accordance with the terms of this Privacy Policy.

Agents, Contractors, and Service Providers. We may use the services of agents, contractors, and other service providers that need access to information to assist us in providing our offerings, services, and products.

Brand Partners. We may, from time to time, share your information with unrelated third parties (e.g., other marketers/brand partners) to enable them to provide users with opportunities to learn of products or events in which they may be interested. Please see the “Your Choices” section below for more information on how you can express your preferences regarding our sharing of information.

With your Consent.  We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy.  We will only disclose your information in this context with your consent.  

Legal, Law Enforcement, Fraud Prevention, Safety and Security Purposes. We may disclose your information in response to legal process (e.g., a court order or a subpoena) or comply with legal requirements. We also may disclose such information in response to a law enforcement agency’s request or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, to detect, prevent or otherwise address fraud, security or technical issues, situations involving potential threats to the property or safety of any person, violations of our terms of use, or as otherwise required or permitted by law.

Professional Advisors.  We may share your information with our professional advisors, including attorneys and accountants that need access to your information to provide operational or other support services on our behalf.  

Change of Control. We may transfer information about you in the event of a business transaction, such as if we or one of our business units or our relevant assets are acquired by, sold to, or merged with another company.

De-Identified or Aggregated Data. We may disclose anonymous, de-identified, or aggregated user statistics to third parties for a variety of purposes. For example, we may disclose how many individuals visited certain areas of our Websites, how many men or women sign up to a particular product, or other demographic data about users of our offerings.

  • YOUR CHOICES 

Marketing Communications. As noted above, consistent with your choices and permission we may use the information we collect from you to offer you products, opportunities, and events that may be of interest to you. If you would like to opt out of future promotional materials from us, you may indicate this preference by following the unsubscribe instructions at the end of e-mail communications or by contacting us at info@cornerstone-systems.com Please note that even if you opt out of promotional messages from us, we will continue to send you important account-related information.

We may, from time to time and consistent with your choices or permission where required, share your information with companies whose practices are not covered by this Privacy Policy (e.g., brand partners/other marketers) that want to market products or services to you.  If you would like to request that we not share your information for such purposes, please send us an e-mail at info@cornerstone-systems.com

Mobile. If you no longer wish to have any information collected by the Website, you may uninstall the application by using the standard uninstall processes available on your mobile device or via the mobile application marketplace or network.

  • CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS 

If you are a California resident, please view our California Privacy Policy available at here.  As set forth therein, California residents have specific privacy rights regarding their information and how it is used.  Information regarding those rights, including how to exercise such rights, are included in the California Privacy Policy.  

  1. DATA COLLECTION TECHNOLOGIES – COOKIES AND SIMILAR TECHNOLOGIES

Cookies. To enhance your experience with our Websites, our Web pages may use “cookies.” Cookies are small data files (e.g., text files) created by a web server that can be stored on your device (if you allow).  Some cookies are deleted as soon as your close your particular browsing session (a “session” cookie).  Other cookies remain on your device until they expire or are deleted by you (a “persistent” or “permanent” cookie). Cookies help store user preferences and activity and allow web sites to recognize a unique browsers or devices. Cookies can be set by the website you’re visiting (“first-party cookies”) or by parties other than that website (“third-party cookies”).

We and our third-party service providers may place a number of cookies on your device to understand Website usage and to improve the content and offerings on our Websites. These cookies include: 

  • Essential Cookies.  We use essential cookies to authenticate users, prevent fraudulent use of the Website, and to allow the Website and its features to function properly.  
  • Functional Cookies.  We use functional cookies to provide enhanced functionality and personalization and to remember your preferences.
  • Analytics Cookies. Our analytics providers use cookies as part of their tools.  Analytics cookies allow us and our analytics providers to help measure how users interact with our Website content.  These cookies “remember” what visitors have done on previous pages and how they’ve interacted with the Website.  
  • Advertising Cookies.  Our third-party service providers use advertising cookies on our Website to tailor marketing to you and your interests and provide you with a more personalized service in the future.  These cookies remember that you visited our Website and we may share this information with third-parties, such as advertisers, to help deliver advertisements that are more relevant to you and your interests.  Although these cookies can track your device’s visits to our Website and other sites, they typically cannot personally identify you.  

You can control how websites use cookies by configuring your browsers’ privacy settings (please refer to your browser’s help function to learn more about cookie controls). This includes the potential to disable cookies and limit the collection and use of information through them.  Note that if you disable cookies entirely, our Websites may not function properly.

Other Similar Technologies. In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, tracking pixels, and single-pixel gifs), and navigational data collection (log files, server logs, etc.), that we may use to collect data as users navigate through and interact with a website:

Web Beacons:  Web beacons (or Web bugs) are small strings of code that enable delivery of a graphic image on a Web page for the purpose of transferring data, such as the IP (Internet Protocol) address of the computer that downloaded the page on which the Web beacon appears, the URL (Uniform Resource Locator) of the page on which the Web beacon appears, the time the page containing the Web beacon was viewed, the types of browser that fetched the Web beacon and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, Web beacons and similar technologies let us know whether you received and opened our email.

Tracking-Pixels:  A tracking pixel is a small piece of code we may use to collect and share with online advertiser’s information on your usage of our website, such as the pages that you have visited, or the way you have interacted with them. Through the tracking pixels, your browser automatically establishes a connection with the server of an online advertiser. In this way, the online advertiser receives information that you access our website. This can allow us to ensure that we are serving ads that match your interests, when you are visiting any of the websites of the online advertiser, or a website that includes ads served by the online advertiser. If you are authenticated to an online advertiser using tracking pixels, e.g. by being registered and logged in to a social network, the online advertiser can assign the visit to our website to your account. We have no influence on the extent to which the data collected through the tracking pixels is used by the online advertisers and therefore direct you to their privacy notices.  Please note that, unlike cookies, you cannot control the deletion of tracking pixels yourself (e.g. by deleting them from your browser cache) because tracking pixels, unlike cookies, are stored on the servers of online advertisers and not in your browser.

Social Widgets: These are buttons or icons provided by third-party social media platforms that allow you to interact with social media services when you view a webpage or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.

UTM Codes: These are strings that can appear in a URL (the “Uniform Resource Locator,” which is typically the http or https address entered to go to a webpage) when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

Particular third-party cookies or tracking technologies used on our Website include, but are not limited to:

Google Analytics: We use Google Analytics to collect and process data about the number of people using the Website and to better understand how they find and use the Website. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions on the Website.  These third-party cookies remember what visitors have done on previous pages and how they have interacted with the Website.  Google Analytics may also receive information about you from applications you have downloaded that partner with Google.  We do not combine the information collected through the use of Google Analytics with personally identifiable information.  Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en).

Google Marketing: We use Google’s marketing technologies to track user activity on the Website and to provide personalized advertisements. Your browser is assigned a pseudonymous ID to track the ads that have been served to your browser and to identify those on which you’ve clicked. The cookies enable Google and its partners to select and display ads based on your browsing behavior. For more information on how Google uses this information, you can visit https://policies.google.com/technologies/ads,https://support.google.com/displayvideo/answer/7621162, and https://support.google.com/google-ads/answer/7548399?hl=en. To block certain ads served by Google, please visit https://support.google.com/ads/answer/2662922. Google’s Privacy Policy is available at: https://www.google.com/policies/privacy.

Facebook Pixel.  We use Facebook Pixel to customize and display advertisements only to Facebook users who have shown an interest in our Website or who have specific characteristics (e.g., certain demographics or interests in certain topics or products determined by websites visited) that we submit to Facebook.  The use of Facebook Pixel helps ensure that our advertisements are in line with the potential interests of users and do not have a nuisance effect.  Facebook Pixel also allows us to track the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether uses have been redirected to our Website after clicking on a Facebook advertisement.   The Facebook Pixel is directly integrated into our Website by Facebook and can store a cookie on your device.  The information collected about you is anonymous for us.  However, the information collected via the Facebook Pixel, on the Website as well as other websites on which Facebook Pixel is installed, is also stored and processed by Facebook.  Facebook may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook’s Data Usage Policy. 

LinkedIn Pixel. We use LinkedIn Marketing Solutions Pixel (also known as the LinkedIn InsightTag) which is a snippet of JavaScript code implemented on our Website to track page views and conversions and to provide insight into post-click and view-through conversions of our ad campaigns on LinkedIn. LinkedIn collects information relating to your visit to our Website, including referring address, IP address, device, and browser characteristics. LinkedIn does not share this information with us and only provides us with aggregated reports and alerts about the Website visitors and ad performance. However, LinkedIn may use this information to serve you ads elsewhere. For more information on how LinkedIn uses this information, see their privacy notice. LinkedIn members can control the use of their information for advertising purposes through their LinkedIn account settings.

Other Third-Party Technologies

Some content or applications, including advertisements, on the Website are served by third parties. These third parties may use cookies to collect information about you when you browse the Internet or use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different online services. They may use this information to provide you with interest-based advertising or other targeted content. 

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible party directly or consult their privacy policies.

Choices About Cookies

Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may choose to not allow certain cookies via your browser settings to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Website.

Please be aware that, if you decline the use of cookies, you may not have access to the full benefits of the Website. In addition, adjusting the cookie settings on the Website may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings on the Website. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies

Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265

To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.

Do Not Track. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

Third-Party Information.  From time to time, we may offer content (e.g., promotions) that is sponsored by or co-branded with an identified third party (e.g., brand partners).  In these instances, the third party may obtain information that you voluntarily submit to participate in a Website activity. We have no control over the third party’s use of this information.

Our Website also may contain links to other sites whose information practices may be different than ours. You should consult the other sites’ privacy notices as we have no control over information that is submitted to, or collected by, these third parties.

  • DATA SECURITY 

We have reasonable security measures in place to protect against the loss, misuse or alteration of information that we have collected from you at our Websites.  From time to time, we review our security procedures to consider appropriate new technologies and methods.  

Despite these measures, no security system is perfect, and no data transmission is 100% secure.  As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from our Website.  We cannot guarantee that your data will remain secure in all circumstances. The safety and security of your information also depends upon you.  Where you use a password for access to restricted parts of our Website or our services, you are responsible for keeping your password confidential.  Do not share your password with anyone.  

  • DATA RETENTION

We will retain your information only for as long as is necessary for the purposes set out in this Privacy Policy, for as long as your account is active, or as needed to provide our Websites and services to you. If you no longer want Cornerstone to use your information to provide our services to you, you may close your account. We will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this Privacy Policy.

We may delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations.  When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.  

To the extent permitted by law, we may retain and use anonymous, de-identified, or aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.  

  • UPDATES 

From time to time, we may update this Privacy Policy to reflect any changes to how we treat your information or in response to changes in law. In the event we make changes to this Privacy Policy, such changes will be re-posted on this page.  We may notify you of material changes to our Privacy Policy by placing a notice on our Website or contacting you with the email address we have in our records. Please check back to this Privacy Policy statement at our Websites to learn what information we collect, how we use it, and to whom we share it.  All changes are effective on the date listed at the top of this page and will apply to all information we have collected about you.  Your continued use of the Website after the “Last Updated” date indicates your acceptance of the changes and your continued consent to our processing of your personal information according to the terms of the then-current Privacy Policy.  

  • THIRD-PARTY WEBSITES AND SERVICES

This Privacy Policy only applies to the Website and does not address or apply to, and we are not responsible for, the privacy, information or other practices of any third parties, including, without limitation any other third-party application or website to which our Website may contain a link. These third parties may at times gather information from or about you and have their own privacy policies. We do not control and are not responsible for the privacy practices of these third parties.  If you click on an embedded third-party link, you will be redirected away from the Website to the external third-party website.  You can check the URL to confirm that you have left the Website.  

We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content or media provided by any third parties or their websites; (2) control third parties’ independent collection or use of your information; or (3) endorse any third-party information, products, services, or websites that may be reached through embedded links on the Website . Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use.  If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.  

  • CHILDREN’S ONLINE PRIVACY PROTECTION ACT

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet.  Our Website and services are not directed to children under the age of 18, nor is information knowingly collected from children under the age of 18. No one under the age of 138 may access, browse, or use the Website or provide any information to or on the Website.  If you are under 18, please do not use or provide any information on the Website (including, for example, your name, telephone number, email address, or username).  If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 18, please contact us via the “Contact Us” details provided at the end of this Privacy Policy.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

This Website is being monitored by one or more third-party monitoring software(s) and may capture information about your visit that will help us improve the quality of our service. You may opt-out from the data that https://doublesmart.digital is collecting on your visit through a universal consumer options page located at https://doublesmart.digital/Unsub/unsub.html

__________________________________________________________________________________________

Cornerstone Systems, Inc.

Privacy Notice to California Employees and Applicants

Last Updated: March 6, 2023

This Privacy Notice to California Employees and Applicants (“Privacy Notice”) is provided by Cornerstone Systems, Inc. (“Cornerstone”, “we”, “us”, or “our”) pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 (“CPRA”), and its implementing regulations (collectively the “California Privacy Laws”) and applies solely to all of Cornerstone’s employees, job applicants, contractors, temporary workers, officers, or similar individuals who reside in the State of California (collectively, “employees”, “you”, or “your”). Any terms defined in the CPRA shall have the same meaning when used in this Privacy Notice. 

Notice at Collection

Cornerstone collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular employee (“personal information”). 

We may collect the following categories of personal information from employees listed in the table below: 

 

Category Description
Identifiers

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

 

Sold or Shared? We do not sell or share this category of personal information.  

Retention Period. We will retain and use this category of personal information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to administer all aspects of our employment practices, and other purposes to the extent provided in this Privacy Notice. We take reasonable steps to delete this category of personal information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under CPRA.

We are required to maintain records of consumer requests submitted under the CPRA, which may include this category of personal information and how we responded to such requests, for at least twenty-four (24) months. Such information related to consumer requests is retained only for recordkeeping purposes.

Personal information described in Cal. Civ. Code § 1798.80(e)

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, or medical information

 

Sold or Shared? We do not sell or share this category of personal information.  

Retention Period. We will retain and use this category of personal information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to administer all aspects of our employment practices, and other purposes to the extent provided in this Privacy Notice. We take reasonable steps to delete this category of personal information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under CPRA.

We are required to maintain records of consumer requests submitted under the CPRA, which may include this category of personal information and how we responded to such requests, for at least twenty-four (24) months. Such information related to consumer requests is retained only for recordkeeping purposes.

Protected classification characteristics under California or federal law

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, pregnancy or childbirth and related medical conditions), sexual orientation, veteran, or military status.

 

Sold or Shared? We do not sell or share this category of personal information.  

Retention Period. We will retain and use this category of personal information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to administer all aspects of our employment practices, and other purposes to the extent provided in this Privacy Notice. We take reasonable steps to delete this category of personal information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under CPRA.

We are required to maintain records of consumer requests submitted under the CPRA, which may include this category of personal information and how we responded to such requests, for at least twenty-four (24) months. Such information related to consumer requests is retained only for recordkeeping purposes.

Internet or other similar network activity

Examples: Browsing history, search history, information on an employee’s interaction with a website, application, or advertisement.

 

Sold or Shared? We do not sell or share this category of personal information.  

Retention Period. We will retain and use this category of personal information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to administer all aspects of our employment practices, and other purposes to the extent provided in this Privacy Notice. We take reasonable steps to delete this category of personal information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under CPRA.

We are required to maintain records of consumer requests submitted under the CPRA, which may include this category of personal information and how we responded to such requests, for at least twenty-four (24) months. Such information related to consumer requests is retained only for recordkeeping purposes.

Geolocation data

Examples: Physical location or movements.

 

Sold or Shared? We do not sell or share this category of personal information.  

Retention Period. We will retain and use this category of personal information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to administer all aspects of our employment practices, and other purposes to the extent provided in this Privacy Notice. We take reasonable steps to delete this category of personal information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under CPRA.

We are required to maintain records of consumer requests submitted under the CPRA, which may include this category of personal information and how we responded to such requests, for at least twenty-four (24) months. Such information related to consumer requests is retained only for recordkeeping purposes.

Sensory data

Examples: Audio, electronic, visual, or similar information.

 

Sold or Shared? We do not sell or share this category of personal information.  

Retention Period. We will retain and use this category of personal information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to administer all aspects of our employment practices, and other purposes to the extent provided in this Privacy Notice. We take reasonable steps to delete this category of personal information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under CPRA.

We are required to maintain records of consumer requests submitted under the CPRA, which may include this category of personal information and how we responded to such requests, for at least twenty-four (24) months. Such information related to consumer requests is retained only for recordkeeping purposes.

Professional or employment-related information

Examples: Current or past job history or performance evaluations.

 

Sold or Shared? We do not sell or share this category of personal information.  

Retention Period. We will retain and use this category of personal information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to administer all aspects of our employment practices, and other purposes to the extent provided in this Privacy Notice. We take reasonable steps to delete this category of personal information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under CPRA.

We are required to maintain records of consumer requests submitted under the CPRA, which may include this category of personal information and how we responded to such requests, for at least twenty-four (24) months. Such information related to consumer requests is retained only for recordkeeping purposes.

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student identification codes, or student financial information. 

 

Sold or Shared? We do not sell or share this category of personal information.  

Retention Period. We will retain and use this category of personal information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to administer all aspects of our employment practices, and other purposes to the extent provided in this Privacy Notice. We take reasonable steps to delete this category of personal information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under CPRA.

We are required to maintain records of consumer requests submitted under the CPRA, which may include this category of personal information and how we responded to such requests, for at least twenty-four (24) months. Such information related to consumer requests is retained only for recordkeeping purposes.

Sensitive Personal Information

Examples: Social Security number, driver’s license number, state identification number, passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation information, racial or ethnic origin, religious, or philosophical believes, or union membership, contents of mail, email, and text messages unless the business is the intended recipient of the communication, genetic data, biometric data for the purposes of uniquely identifying a consumer, health information, sex life or sexual orientation information.

 

Sold or Shared? We do not sell or share this category of personal information.  

Retention Period. We will retain and use this category of personal information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to administer all aspects of our employment practices, and other purposes to the extent provided in this Privacy Notice. We take reasonable steps to delete this category of personal information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under CPRA.

We are required to maintain records of consumer requests submitted under the CPRA, which may include this category of personal information and how we responded to such requests, for at least twenty-four (24) months. Such information related to consumer requests is retained only for recordkeeping purposes.

**We only collect Sensitive Personal Information for legitimate business purposes appropriate for the use and disclosure of Sensitive Personal Information as defined in the California Privacy Laws, and do not otherwise use it to infer characteristics about you.

Exclusions from Personal Information: Personal information does not include: 

  • Publicly available information or lawfully obtained, truthful information that is a matter of public concern. 
  • Consumer information that is de-identified or aggregated.
  • Information excluded from the scope of the CPRA including, but not limited to:
    • Personal information collected, processed, sold, or disclosed subject to the Gramm-Leach-Bliley Act (GLBA) or the California Financial Privacy Act.
    • An activity involving the collection, maintenance, disclosure, sale, communication, or use of any personal information bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living by a consumer reporting agency, a furnisher of information who provides information for use in a consumer report, and by a user of a consumer report provided that the agency, furnisher, or user is subject to regulation under the Fair Credit Reporting Act (FCRA).  
    • Medical information governed by the Confidentiality of Medical Information Act or protected health information as governed by the U.S. Department of Health and Human Services pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
    • Personal information collected, processed, sold, or disclosed pursuant to the Driver’s Privacy Protection Act of 1994.

Business or Commercial Purposes: We may use the categories of personal information identified above for one or more of the following purposes: 

  • To consider your employment application or fulfill or meet the purpose for which you provided the information. 
  • To conduct background checks as part of the application process.
  • To contact you and inform you about benefits or information relating to your employment or potential employment.
  • To administer all aspects of our employment practices, including recruiting, hiring, discipline, termination, promotions, transfers, compensation, benefits, training, leaves of absence, and other terms and conditions of employment.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests or transactions and prevent transactional fraud.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
  • To provide you with support and to respond to your inquiries, including to investigate and address your complaints and monitor and improve our responses.
  • To help to ensure safety, security, and integrity of our systems, software or smart-device applications or website, services, databases, and other technology assets and business.
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
  • To debug to identify and repair errors that impair existing intended functionality.
  • To maintain emergency contact and beneficiary details.
  • To compile internal directories, such as employee directors (excluding a job applicant’s personal information).
  • To conduct research, analysis, and business development, including to develop and improve our business processes, website, and services.
  • To fulfill other legitimate purposes reasonably required to day-to-day operations, such as accounting, financial reporting, and business planning.
  • As described to you when collecting your personal information or as otherwise set forth in the CRPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cornerstone’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Cornerstone about our consumers is among the assets transferred.

Other Processing Activities: As permitted by applicable law, we may use the personal information we collect in order to: 

  • Comply with federal, state, or local laws or comply with a court order or subpoena to provide information.
  • Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities.
  • Cooperate with law enforcement agencies concerning conduct or activity that we, a service provider, or third party reasonably and in good faith believes may violate federal, state, or local law.
  • Cooperate with a government agency request for emergency access to a consumer’s personal information if a natural person is at risk or danger of death or serious physical injury.
  • Exercise or defend legal claims.
  • Collect, use, retain, sell, share, or disclose consumers’ personal information that is de-identified or aggregate consumer information.

Cornerstone will not collect additional categories of personal information or use personal information collected for additional purposes that are incompatible with the disclosed purpose for which the personal information was collected without providing you notice as may be required under the CPRA.

 

Data Practices During Last 12 Months

Personal Information Collected: As described in this Privacy Notice, we have collected the categories of personal information listed below during the preceding 12 months:

  • Identifiers.
  • Personal information described in Cal. Civ. Code § 1798.80(e).
  • Protected classification characteristics under California or federal law.
  • Internet or other similar network activity.
  • Geolocation data.
  • Sensory data.
  • Professional or employment-related information.
  • Non-public education information (per the Family Education Rights and Privacy Act).
  • Sensitive Personal Information.

Categories of Sources: Cornerstone obtains the categories of personal information identified in this Privacy Notice from the following categories of sources:

  • Directly from you. For example, from forms you complete related to the job in which you are applying or hired for or participating in Cornerstone’s health or retirement benefit programs.
  • Indirectly from you. For example, if you apply for a job with Cornerstone through a staffing company or through cookies.
  • Service Providers.  For example, credit bureaus, background check providers, or other third parties that provide services to us in connection with our business operations.

Business and Commercial Purpose for Collecting: We have collected the categories of personal information identified for the purposes listed in the “Business or Commercial Purposes” section above.

Categories of Personal Information Disclosed for a Business Purpose: We have disclosed the following categories of personal information to third parties for a business purpose during the preceding 12 months: 

  • Identifiers.
  • Personal information described in Cal. Civ. Code § 1798.80(e).
  • Protected classification characteristics under California or federal law.
  • Internet or other similar network activity.
  • Geolocation data.
  • Sensory data.
  • Professional or employment-related information.
  • Non-public education information (per the Family Education Rights and Privacy Act).
  • Sensitive Personal Information.

These categories of personal information have been disclosed for a business purpose to the following categories of third parties: 

  • Service providers or contractors (for services such as data analytics, data storage, HR recruitment-related promotional or advertising activities, payroll processing, website and platform administration, technical support, security monitoring, and operating systems and platforms, plan administrators, insurers, and other professional advisers that need access to your information to provide support on our behalf). 
  • Third parties with your consent
  • Consumer reporting agencies for employment background checks.
  • Government entities.

Prior to disclosing any personal information to a service provider or contractor for a business purpose, we enter into a written contract which describes, among other things: (1) the specific purpose which the personal information can be used by the service provider or contractor to perform the services specified in the contract; (2) requires the service provider or contractor to keep any personal information confidential; (3) prohibits the service provider or contractor receiving the personal information from retaining, disclosing, or using the personal information for any purpose other than performing and providing services under the contract; (4) provides us the right to take reasonable and appropriate steps to ensure that the service provider or contractor uses personal information in accordance with contractual terms.

Categories of Personal Information Sold or Shared to Third Parties: We have not sold or shared any categories of personal information to third parties in the preceding 12 months. 

California Privacy Rights and Choices 

Consumer Rights

The California Privacy Laws provide California residents with specific rights regarding their personal information.  This section describes your rights and explains how to exercise those rights.  You may submit requests to us as described below and we honor those rights unless an exception applies. 

Right to Know: You have the right to request that Cornerstone disclose personal information that it has collected, sold, or shared about you.  This includes a request for any or all of the following: 

  • The categories of personal information we have collected about you.
  • The categories of sources from which the personal information is collected.
  • The categories of personal information that we have sold or disclosed for a business purpose about you.
  • The categories of third parties to whom the personal information was sold or disclosed for a business purpose.
  • The specific pieces of personal information we collected about you.
  • The business or commercial purpose for collecting, selling, or sharing personal information.

Right to Delete: You have the right to request that Cornerstone delete any personal information that we have collected, sold, or shared about you. 

Right to Limit: In certain circumstances, you have the right to limit the use and disclosure of sensitive personal information.  Our use of your sensitive personal information is solely for business purposes and not for those purposes for which you may exercise a right to limit the use or disclosure under the CPRA.  Therefore, we include this disclosure of information for informational purposes only.  

Right to Opt-Out of Sale/Sharing: You have the right to direct a business that sells or shares personal information about you to third parties to stop doing so.  Cornerstone does not sell or share any personal information as defined by the CPRA.  Therefore, we include this disclosure of information for informational purposes only. 

Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you. Our goal is to keep your personal information accurate, current, and complete.  

How to Submit Requests to Know, Requests to Delete, and Requests to Correct

You may submit a request a Request to Know, Request to Delete, or Request to Correct by either: 

  • Calling us at 901-842-0660; or
  • Sending an email to info@cornerstone-systems.com

Verification Procedures

We are required by the CPRA to verify the identity of individuals who submit a Request to Know, Request to Delete, or Request to Correct. We will take steps to verify your identity before granting you access to such personal information or acting on your request to exercise your rights as outlined below.  

A verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected information.  Whenever feasible, we will verify your identity by matching the identifying information provided by you in the request to the personal information we may already maintain about you.  As part of this process, we ask that you provide the following information when submitting your request: name, telephone number, email address, and your home address at the time of submitting your job application to Cornerstone or your last home address while employed with Cornerstone.

You may designate an authorized agent to make a Request to Know, Request to Delete, or Request to Correct on your behalf.  If you use an authorized agent to submit a request, we require the authorized agent to provide proof that the consumer gave the authorized agent signed, written permission to submit the request.  We may also require you to verify your identity directly with us and you to directly confirm with us that you provided the authorized agent permission to submit the request.  We will inform you if we cannot verify your identity.

  • If we cannot verify the identity of the person making a Request to Know specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor.  However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.  If we still cannot verify the request, and the request is denied in whole or in part, we will provide a copy of, or direct you to, our privacy policy.  
  • If we cannot verify the identity of the person making a Request to Delete or Request to Correct, we may deny the request and inform the person making the request that their identity cannot be verified.

Response Timing: Upon receiving a Request to Know, Request to Delete, or Request to Correct, we will confirm receipt of the request within 10 business days and provide information about how we will process your request. The information provided will include our verification process and when you should expect a response from us (unless we have already granted or denied the request).  In general, we will respond to a request within 45 calendar days from the day the request is received but, if necessary, we may take an additional 45 calendar days to respond to the request.  If this extension is needed, we will notify you of the extension and explain the reasons that responding to your request will take more than 45 calendar days.

Response Process: We will deliver our written response and any requested personal information that may be responsive to you by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable.  

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Limitations: We are committed to responding to requests in accordance with applicable law.  However, your rights are subject to certain limitations including, but not limited to, the following:

  • We are only required to respond to Requests to Know twice in a 12-month period.
  • A response to a Request to Know may be limited to the 12-month period preceding receipt of the request if it would be impossible, involve disproportionate effort, or the request is for data for a specific time period.  
  • We are prohibited from disclosing certain specific pieces of personal information in response to a Request to Know including, but not limited to, Social Security numbers, driver’s license numbers, and financial account numbers.

We are not required to delete your personal information if it is reasonably necessary for us, our service providers, or our contractors to maintain the personal information in order to: 

  • Complete the transaction for which the personal information was collected, provide a loan or service that you requested, take actions reasonably anticipated by the you within the context of our ongoing business relationship with you, or otherwise perform a contract with you.
  • Help ensure the security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Ca. Penal Code § 1546 et. seq.).  
  • Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent. 
  • To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information.
  • Comply with a legal obligation.

Non-Discrimination

We will not discriminate against you for exercising any of your CPRA rights including, but not limited to, by:

  • Denying you goods or services.
  • Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Providing you a different level or quality of goods or services.
  • Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Accessibility

We are committed to ensuring this Privacy Notice is accessible to individuals with disabilities. If you wish to access this Privacy Notice in an alternative format, please contact us using the information provided below.

Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which Cornerstone collects and uses your information described below and in the Privacy Policy, or your choices and rights regarding such use, please do not hesitate to contact us at:

Phone: 901-842-0660 

Website: www.cornerstone-systems.com/careers

Postal Address

Cornerstone Systems, Inc.

Attn: Blythe Mobley

3250 Players Club Parkway

Memphis, TN 38125