Privacy Policy
Cypher Global Strategies LLC (“Cypher Strategies”), publisher of the information service accessed at or through www.cypherstrat.com or its related or subsidiary Web sites or mobile applications, or provided to you by email or other electronic means (collectively, the “Service”), is committed to maintaining the privacy of information that you provide to us when using the Service. This Privacy Policy describes how we treat information we receive or obtain about you when you visit www.luminaegroup.com or its related or subsidiary Web sites or mobile applications, purchase a course, or sign up to receive emails from us that are part of the Service, otherwise use the Service, or otherwise interact with Cypher Strategies. As you read this Privacy Policy, keep in mind that Cypher Strategies maintains equivalent privacy practices with respect to data that is collected off-line.
Cypher Strategies complies with the Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from EU member countries to companies in the United States, including human resources (HR) data. Cypher Strategies has certified that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, recourse, enforcement and liability.
We may make content or services from other Web sites, including our affiliated or co-branded Web sites, available to you from links located on the Service. These other Web sites are not subject to this Privacy Policy. We recommend that you review the privacy policy at each such Web site to determine how that site protects your privacy. Cypher Strategies has no control over these Web sites and is not responsible or liable for the policies and practices followed by these other Web sites. The personal data you choose to provide to or that is collected by these other Web sites is not covered by this Privacy Policy.
Information We Collect About You
General: When you subscribe to or otherwise use the Service, sign up to receive emails from us, and at other times, we may ask you to provide us with certain categories of personal information. Personal information is information that could reasonably be used to identify you personally, such as your name, date of birth, age, gender, occupation, industry, interests, e-mail address(es), physical address, telephone number(s), profession, facts about your computers and other devices through which you access the Service, any information we receive from the applicable third parties when you register or otherwise interact with the Service by means of LinkedIn or other social media, and similar information (collectively, to the extent we collect it from time to time, "Personal Information"). We may collect this information through various forms and in various places, including account registration forms, contact us forms, or when you otherwise interact with us.
Children Under the Age of Thirteen: We do not knowingly collect Personal Information from children under the age of thirteen. By providing any Personal Information to us, you represent and warrant to us that you are at least thirteen years of age. If you are under the age of thirteen, we require that you do not provide any Personal Information to us. If you are the parent or guardian of a child under the age of thirteen, please contact us at inquiries@cypherstrat.com so that we may delete that information from our systems.
Credit card information: The credit card information you provide when you make a purchase from the Service is stored and used by our third party credit card processors in order for them to process your payment.
Surveys: We may conduct occasional online surveys. We collect information about your participation in and responses to these surveys (“Survey Information”). For example, when you're within our Web sites, you may see a pop-up window offering you the optional opportunity of participating in a survey. These surveys are entirely voluntary and you may decline to participate.
Usage Information: We automatically collect IP addresses, Web site usage information and other technical information regarding your interaction with the Service from you when you visit our Web sites (“Usage Information”). This information helps us evaluate how our visitors and subscribers use and navigate our Web sites on an aggregate basis, including the number and frequency of visitors and subscribers to each Web page, the length of their visits, the web browser version they use, and any publications or other information that they download.
Social Media Features: Our Service may include social media features, such as the Facebook Like button, and widgets such as a "Share This" button, or interactive mini-programs that run on our Service. These features may collect your IP address, which page you are visiting on our Service, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Service. Your interactions with these features and widgets are governed by the privacy policy of the company providing them.
Community Forums: Our Service may include community or user forums, or similar features (each a “Forum”) that are designed to be visible to other users and participants, including your screen name or other identifying information, as well as comments or other information that you may post on a Forum. By using any Forum, you agree to abide by the terms and conditions we have posted for such Forum, and you consent to the disclosure of your screen name (if a screen name is permitted or used in the applicable Forum, or if not, your actual name), identifying information and comments or other information that you may post on the Forum. We are not responsible for any Personal Information that you may choose to post in any Forum.
Conferences and Other Events: We may invite you to, or you may otherwise participate in, video or telephonic conferences, webinars, or other live or recorded events that we offer. We may share any information you provide when signing up for any such event with other sponsors of the event.
Testimonials: We display personal testimonials of satisfied subscribers on our Web sites from time to time. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us at inquiries@cypherstrat.com.
Contests, Drawings and Sweepstakes: We collect Personal Information from you when you participate in contests, drawings, sweepstakes and other special offers. If this information is also being collected by or shared with a third party other than Cypher Strategies, we will notify you at the same time. If you do not want to provide any Personal Information, you should not participate in the contest, drawing, sweepstakes and other special offer.
Technical Information: We also collect certain technical information, as described below under the heading “Additional Technical Information We May Collect.”
How We Use the Information Collected
Our primary goal in collecting your Personal information, Survey Information and Usage Information is to provide you with an enhanced experience when using the Service. We may use information about you, including Personal Information, Survey Information and Usage Information, in the following ways:
We may use information about you for the purposes for which you specifically provided the information including, for example: to enable us to process, validate, and verify subscriptions; to send you e-mail notifications about our new or existing products and services, special offers, or to otherwise contact you; to send you e-mail notifications, through companies who work on behalf of Cypher Strategies, about certain approved third-party products and services (unless we tell you differently, these companies do not have any right to use the Personal Information we provide to them beyond what is necessary to assist us); to enhance existing features or develop new features, products and services; to provide advertisers and other third parties with aggregate information about our user base and usage patterns; to allow us to personalize the content and advertising that you and others see based on personal characteristics or preferences; to enable you to participate in contests, drawings, sweepstakes or other special offers.
We may combine the information that we collect from you with information that you provide to us in connection with our other products, services and Web sites, including marketing those products, services and sites to you.
Cypher Strategies uses web analytics services (which may include, but are not limited to, Google Analytics) to analyze how users use our Web sites. These services may use javascript, cookies, or other tools that include cookies that we place on your computer or mobile device. We and our service providers use these tools to collect information about your usage of our Web sites, such as your IP address, the name of your internet service provider, your operating system and other computer or mobile device information and statistics, the URL for the Web pages you visit and how long you spent on those pages, how you arrived at our pages, and the date and time you visited. The information generated about Web site usage may be transmitted to Google or other service providers and used for a variety of purposes, including, without limitation, to improve our Web sites, prevent fraud, evaluate users’ use of our Web sites, complete statistical reports on Web site and user activity, provide other related services, and enable, improve and support our marketing programs. This information may be stored on servers located in the United States or elsewhere. For more information about Google Analytics or the Google Analytics opt-out browser add-on, go to https://tools.google.com/dlpage/gaoptout.
You are responsible for maintaining the accuracy of the information you submit to us, such as your user preferences and contact information provided as part of subscription registration. If your Personal Information changes, or if you no longer desire our Service, you may correct, delete inaccuracies, or amend information by making the change in your profile on-line, or by contacting us by email at inquiries@cypherstrat.com. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.
We will retain your Personal Information, Survey Information and Usage Information for as long as your account with the Service is active and as needed to provide you the Service. Even after your account is terminated, we will retain your Personal Information, Survey Information and Usage Information as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account (such as addressing chargebacks from your credit card companies), investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reasons as we deem appropriate.
At times Cypher Strategies may use third party network advertisers to deliver ads to you on our behalf. We may also use third-party service providers to contact you on our behalf, or facilitate some aspects of the Service or fulfill your purchase requests. These network advertisers and service providers may be supplied with or have access to your Personal Information solely for the purpose of providing these services to us or on our behalf, to the extent permitted by applicable law.
We may disclose and use Personal Information, Survey Information, and Usage Information at our discretion without notice, unless such disclosure is prohibited by law or the PCI Security Standards (to the extent applicable). We may disclose and use Personal Information in special circumstances where it is necessary to enforce our contracts or our Terms of Use (for example, when necessary to protect our intellectual property rights).
We may also disclose or use your Personal Information when we believe that the law requires us to do so. For example, we may be obligated to release your Personal Information pursuant to judicial or other government subpoenas, warrants, or other orders. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your Personal Information including disclosure to third parties such as government or law enforcement officials or private parties, as we reasonably determine is necessary and appropriate: to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process; to protect the safety, rights, property or security of Cypher Strategies, the Service, or any third party; to detect, prevent or otherwise address fraud, security or technical issues; and to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Further, we may use IP addresses or other unique identifiers for computers, tablets, smartphones or other devices used to access the Service, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion.
We contract with other companies to provide services on our behalf, including credit card and billing processing, ad serving, email distribution, list processing and analytics or promotions management. We provide these companies only with the information they need to perform their services. These service providers are restricted from using your Personal Information in any way other than to provide services for us, except for certain anonymized, aggregated statistical data.
We may share your information, including your Personal Information, Survey Information and Usage Information, with our parent company, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information to a subsequent owner, co-owner or operator of the Service, or in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including during the course of any due diligence process.
Any and all of the foregoing disclosures may be carried out without notice to you.
Information for Persons Located Outside the United States
If you are located anywhere outside of the United States, please be aware that information we collect, including, Personal Information, will be transferred to, processed and stored in the United States and possibly other countries. The data protection laws in the United States or those other countries may differ from those of the country in which you are located (and may be less protective of your Personal Information than the country in which you are located). Your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States or those other countries according to laws of the United States or those other countries. By using the Service or providing us with any information, you consent to this transfer, processing and storage of your information in the United States or those other countries.
Cypher Strategies' Commitments Under Privacy Shield
Cypher Strategies is committed to achieving and maintaining customer trust. Integral to this mission is providing a robust security and privacy program that carefully considers data protection matters.
Cypher Strategies is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Cypher Strategies also commits to cooperate with European Union (EU) data protection authorities (DPAs) with regard to customer data and human resources data transferred from the EU.
Cypher Strategies is required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. To the extent permitted by applicable law, Cypher Strategies commits to inform its subscribers in the event of an information request regarding their Personal Information.
In the context of an onward transfer, Cypher Strategies has responsibility for the processing of Personal Information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Cypher Strategies remains liable under the Privacy Shield Principles if its agent processes such personal information in a manner inconsistent with the Principles.
Cypher Strategies complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit www.privacyshield.gov.
Dispute Resolution
In compliance with the Privacy Shield Principles, Cypher Strategies commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy, including EU individuals, should first contact Cypher Strategies by email at inquiries@cypherstrat.com.
Cypher Strategies has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources and non-human resources data transferred from the EU.
Additional Technical Information We May Collect
Device Information: We may collect non-personal information about the computer, mobile device or other device you use to access the Service, such as IP address, geolocation information, unique device identifiers, browser type, browser language and other transactional information.
Analytics, Log Files and Reading History: We may gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses (the region or general location where your computer or device is accessing the Internet), browser type, operating system and other usage information about the use of the Service, including a history of the pages you view.
Cookies: We may employ cookies or other technology to help visitors and subscribers move faster through our site and for the other purposes described above. When you sign on to our Web sites or take advantage of several key features, we may pass cookies to your computer. A cookie is a string of information that is sent by a Web site and stored on your hard drive or temporarily in your computer's memory (read our Cookie Disclosure Statement below for more information on our use of cookies).
Security: The Personal Information we collect about you is stored in limited access servers. We will maintain commercially reasonable safeguards to protect the security of these servers and your Personal Information. However, no security technology or system is impenetrable. We cannot guarantee the security of our systems or databases, nor can we guarantee that your information will not be intercepted while being transmitted to us over the Internet or wireless communication.
Other Information: We (directly, or through third parties that support our distribution of emails and related matters) use a variety of technical means, which may include, but are not limited to, pixels, cookies or transparent GIF files, to help manage online advertising. These files may be provided by one or more of our advertising management partners. These files enable Cypher Strategies and those partners to recognize a unique cookie or other script associated with or on your Web browser, which in turn enables us to learn which advertisements bring users to our Web sites. The information that we collect and share through such means is anonymous and not personally identifiable. It does not contain your name, address, telephone number or email address.
Policy Modifications
We may change this Privacy Policy from time to time. We will post any changes here and revise the “last updated” date accordingly, so be sure to check back periodically. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of Personal Information you have provided to us, we will attempt to obtain your consent before implementing the change. Except as stated in the preceding sentence, any changes will be effective when we post them here, and your use of the Service after we post any changes means you consent to those changes.
Choice/Opt-Out
Cypher Strategies provides its users the opportunity to opt-out of receiving communications from Cypher Strategies and its partners. To remove your information from our database, to not receive future communications, or to no longer receive our Service, please send an e-mail request to: inquiries@cypherstrat.com.
Correcting/Updating Your Information
You can change or modify information you previously provided to us by sending an email to inquiries@cypherstrat.com.
Comments and Questions
If you have any comments or questions about this Privacy Policy, Cypher Strategies’ practices, the Service, or your dealings with us, you can email us at: inquiries@cypherstrat.com
Cookie-Disclosure Statement
We employ cookies at Cypher Strategies to, among other things, allow you to move quickly through the Service. Below you'll find information describing Cypher Strategies' most common uses of cookies, which are an inherent part of our production, communication, and distribution processes and have enabled us to better serve our users.
What's a cookie? A cookie is a small file that is sent to your computer by a site's server. A cookie can be a record of your visit to our Web sites, including information such as your user name, registration information, time of last visit, pages viewed, etc. Cookies created by the servers of one site can be retrieved only by that site’s servers.
Cypher Strategies uses cookies for a variety of purposes, including, without limitation, to allow you to move quickly through the Service, and to evaluate users’ use of our Web sites, complete statistical reports on Web site and user activity, provide other related services, and enable, improve and support our marketing programs. Cypher Strategies accomplishes this in many ways, using several different cookies. When you first enter one of our Web sites or otherwise access the Service, for example, Cypher Strategies may use a test cookie to confirm your browser's ability to retain cookies. Other cookies that you might receive are from Cypher Strategies or our third-party service providers or third-party network advertisers. These network advertisers may use their own cookies in order to serve ads on our Web sites, to reduce the likelihood that you see the same ads over and over again.
Some of the advantages of cookies include:
Faster, more convenient access. We can deliver customized information and store your settings (such as preferences and account information) more efficiently.
Better information. Cypher Strategies wants to provide features and services in which you are interested. Through the use of cookies, Cypher Strategies can determine which features are most popular with subscribers on an aggregate basis and thus better serve your needs by developing new features and services in response to Cypher Strategies's analysis of usage of the Service.
More efficient ad processing. Cookies enable us to streamline our ad presentations. Will the cookies Cypher Strategies sends to your devices go away? Some cookies are long term. Some cookies expire after a short period of time. Cookies are small files (just a few hundred bytes) and should not pose any significant disk-space concerns. You are, of course, free to clear cookies from your devices at any time.
Can you set your browsers to not accept cookies or to alert you each time you receive one? Most browsers can be set to alert users each time a cookie is passed to the applicable device.
Last Updated: October 12, 2024