A CTO, LLC (“A CTO”; or “we”) is committed to protecting your privacy through compliance with this Privacy Policy (the “Policy”). This Policy explains the types of information we may collect or process related to you (“personal information”) when you visit the A CTO.com website (the “Site”) and our practices for collecting, using, maintaining, protecting, and disclosing your personal information.

This Policy does not apply to other online or offline A CTO websites, products or services. Related services and offerings with links from this Site, including partner sites, have their own privacy statements which can be viewed by clicking on the corresponding links within each respective website.

If you do not agree with the practices described in this Policy, please choose not to use the Site. By visiting the Site, you are accepting and consenting to the collection of personal information and use practices described in this Policy.

How do we use your personal information?
How do we share your personal information with third parties?
How do you access and maintain accuracy of your personal information?
How do we protect your information?

What information do we collect?

We ask for and you may provide personal information when submitting webforms on the Site or as you interact with features on the Site. The personal information we collect may include your name, title, company or organization name, work e-mail, work phone, work or home address, information about your job function, information about your company, or any other information that you choose to submit. Your decision to provide any personal information to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal information. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this Policy, and you may not be able to use certain tools and systems which require the use of personal information.

With regard to each of your visits to the Site we will automatically collect certain information about your visit, such as: the name of the Internet service provider and the Internet Protocol (IP) address through which you access the Internet; the date and time you access the Site; the pages that you access while at the Site and the Internet address of the website from which you linked directly to our site.

How do we use your personal information?

We use personal information collected from you in the following ways:

• To personalize your experience
• Marketing A CTO services or products to you
• Sending periodic communication related to A CTO products or services that may include updates
• Operating and managing A CTO business operations
• Monitoring your use of the Site
• Undertaking data analytics
• Maintaining and improving the security and functionality of the Site
• Compliance with any court order, law, or legal process, including to respond to any government or regulatory request

How do we share your personal information with third parties?

We occasionally hire trusted third party service providers to help us improve, protect and promote our Site, services and products. Third party service providers are required to maintain the confidentiality of information accessed or received as part of the service engagement and prohibited from using personal information for any other purpose. Further, we only provide those third-party service providers with the information necessary to deliver services to A CTO and to users of the Site.

All personal information you submit and is collected through your use of this Site is stored at third party data centers. Personal information collected on the Site may be stored and processed in the United States or any other country in which A CTO or its affiliates, subsidiaries or agents maintain facilities. By using the Site or submitting information to us through the Site, where applicable law permits, you consent to the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different.

We do not disclose or sell your personal information to third parties for a business or commercial purpose.

Except as otherwise described in this Policy, personal information you provide on the Site will not be shared outside of A CTO and its controlled subsidiaries and affiliates without your consent. As described below in the next section, you can access your personal information and make choices about how you wish to be contacted.

How do you access and maintain accuracy of your personal information?

We need your help in keeping your personal information accurate and up to date. You can access and review your personal information by contacting A CTO.com as described at the bottom of this Policy.

If you need additional assistance or help with accessing, correcting, suppressing, or deleting your personal information, contact us directly. We make good faith efforts to honor reasonable requests to access, delete, update, suppress, or correct your data. We will respond to your request within 30 days. If we are unable to honor your request, we will provide you with an explanation.

How do we protect your information?

A CTO is committed to protecting the security of your personal information entrusted to us and treat your personal information securely in accordance with this Policy. We use a variety of physical, administrative, and technological safeguards designed to protect your personal information from unauthorized access, use, or disclosure. We also contractually require that third party service providers protect such information from unauthorized access, use, or disclosure. Additionally, when we transmit any sensitive personal information (such as a credit card number) over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

How long do we keep your information?

We will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and to enforce compliance with our agreements.

Protection of Children’s Personal Information

We do not knowingly collect personal information from children under the age of 13. If you are under the age of 13, please do not submit personal information to the Site. We encourage parents and guardians to monitor their children’s Internet usage to help enforce this Policy. If you believe that we may have collected personal information from someone under the applicable age of consent in your country without proper consent, please let us know using the methods described in the Contact Us section and we will use commercially reasonable efforts to delete that information.

Do we use Cookies?

The Site uses cookies to distinguish you from other users of the Site. For detailed information on the cookies that we use and the purposes for which we use the cookies, please see our Cookies Policy.

Your Rights

You are entitled (in circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:

• Request access to the personal information we process about you: this right entitles you to know whether A CTO holds your personal information and, if so, obtain personal information on and a copy of such personal information.
• Request a rectification of your personal information: this right entitles you to have your personal information corrected if it is inaccurate or incomplete.
• Object to the processing of your personal information: this right entitles you to request that A CTO no longer processes your personal information.
• Request the erasure of your personal information: this right entitles you to request the erasure of your personal information, including where such personal information would no longer be necessary to achieve the purposes.
• Request the restriction of the processing of your personal information: this right entitles you to request that A CTO only processes your personal information in limited circumstances including with your consent.
• Request portability of your personal information: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal information that you have provided to A CTO, or request A CTO to transmit such personal information to another data controller.

If, despite our commitment and efforts to protect your personal information, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to A CTO first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against us with a competent court (either in the country you live, the country where you work, or the country you deem that data privacy law has been infringed).

Contact us to exercise any of your rights.

Updates to this Policy

We may occasionally update this Policy. When we do, we will post the revised version here, revise the “updated” date at the top of this Policy page, and may also send you a notification directly. You agree to visit this page periodically to review this Policy to stay informed about how we are helping to protect the personal information we collect.

Contact Information

A CTO welcomes your comments or questions regarding this Policy. If you believe that A CTO has not adhered to this Policy, please contact us electronically (support@a-cto.com) or via postal mail at the address provided below, and we will use commercially reasonable efforts to promptly determine and remedy the problem.

A CTO, LLC
16292 Arlington Ln
Huntington Beach, CA
92649