CTFSI Privacy Policy

Last Updated: May 2024

Cambridge Technology Financial Services, Inc (“CTFSI”, “us”, “our”, or “we”) is committed to transparency. This Privacy Notice is intended to provide users of our website (“Users’”) with an understanding of how we collect, use, share and protect users’ personal information, as well as how users can manage the personal information we collect. This Privacy Notice applies to Users’ interactions with us through their use of our website (www.ctfsi.com) (our “Website”).

Please note that the Website is primarily for informational purposes. For more information about how to become an enterprise customer, please contact us at info@ctfsi.com. This Privacy Notice does not apply to other CTFSI services or webpages associated with other CTFSI paid solutions. The collection and use of information for such services is governed by contractual services agreements we have with specific customers.

By using our Website, users acknowledge the terms of this Privacy Notice. If users do not agree to the terms of this Privacy Notice, they should not use our Website. If users do not understand, or if users have questions about this Privacy Notice, we ask that they contact us before using, or continuing to use, our Website. We reserve the right to change our Privacy Notice from time to time by posting the changes here. If we choose to change this Privacy Notice, we will revise the Last Updated date at the top of this Privacy Notice when we post the updated version. We may also provide users with notice by prominently posting on our Website and/or other communications channels, if we make any significant changes to this Privacy Notice. We may also highlight those changes at the top of this Privacy Notice and provide a prominent link to it for a reasonable length of time following the change. Users’ use of our Website after we have informed users in one of these ways that we made changes to our Privacy Notice will mean that users have accepted those changes.

Types of information CTFSI Collects

We may collect two basic types of information from users when users either provide it to us or when users use or interact with our Website: personal information, and non-personal information.

Personal information includes all information that relates to users that either identifies or may be used to identify users personally (collectively, “personal information”). We may collect the following types of personal information from users depending upon the device users are using and how users interact with us or use or interact with our Website, such as users’ device Information, IP address, browser type and version, browser plug-in types and versions, operating system and platform, device type and device identifiers.

Non-personal information includes information that does not personally identify users or information that has been anonymized (collectively, “non-personal information”). When we combine non-personal information with personal information, we treat the combined information as personal information.

How CTFSI Collects Personal Information

See separate Cookies Policy Statement here.

How We Use Personal Information

We may use personal information to do any or all of the following:

Enable us to provide users with our Website
Facilitate users’ interactions and transactions with us
Respond to users’ requests, communications, suggestions, comments, inquiries, and requests (including users’ feedback about our Website)
Maintain and improve our business
Develop new products and features
Better understand the preferences of our customers
Provide personalized content, including ads
Respond to legally binding requests from law enforcement, regulatory authorities, or other third parties
Defend, protect or enforce our rights or applicable terms of service or to fulfill our legal or contractual obligations
To prevent fraud or the recurrence of fraud assist in the event of an emergency
Comply with applicable law
Any other purpose with users’ consent

We may also combine users’ personal information collected through various sources, including information collected through our Website, and develop a customer profile that will be used for the purposes above. Except as otherwise permitted or required by applicable law, we only retain personal information for as long as we need to use the information for the purposes listed above, including, for legal, regulatory, backup, archival, accounting, and/or audit purposes.

We may use personal information to create non-personal information. We may use non-personal information for any legitimate business purpose. HOW CTFSI SHARES PERSONAL INFORMATION We may share personal information with our third party service providers, suppliers, vendors, professional advisors and business partners, which may include IT service providers, financial institutions and payment providers, customer relationship management vendors, other cloud-based solutions providers, lawyers, accountants, auditors and other professional advisors. We contract with such vendors and advisers to ensure that they only process users’ personal information under our instructions and ensure the security and confidentiality of users’ personal information. We share personal information with these third parties to help us: with the uses described in the How We Use Information section above;

in the operation, management, improvement, research and analysis of our Website and/or business; with our marketing and promotional projects, such as sending users’ information about products users may like and other promotions (provided users’ have not unsubscribed from receiving such marketing and promotional information from us); and comply with users’ directions or any consent users have provided us. We may share personal information with law enforcement and regulatory authorities or other third parties as required or permitted by law for the purpose of: responding to a subpoena, court order, or other legal processes; defending, protecting, or enforcing our rights; assisting in the event of an emergency; and complying with applicable law. In accordance with applicable law, we may also transfer or assign personal information to third parties as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a legal claim, we may disclose personal information about users’ that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings. We share non-personal information with third parties as reasonably necessary to meet our business needs.

HOW CTFSI PROTECTS PERSONAL INFORMATION

We are dedicated to ensuring the security of users’ personal information. We use physical, electronic, and administrative security measures appropriate to the risks and sensitivity of the personal information we collect. We aim to provide secure transmission of users’ personal information from users’ devices to our servers. We have processes to store personal information, if collected, in secure operating environments. Our security procedures mean that we may occasionally request proof of identity before we disclose users’ personal information to users. We try our best to safeguard personal information once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If users suspect an unauthorized use or security breach of users’ personal information, please contact us immediately.

USERS’ DATA TRANSFERS We are a global business. As such, information we collect may be transferred to, stored, and processed in any country or territory where one or more of our business partners or service providers are based or have facilities which may be different to a users’ home country. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to users’ personal information through the laws of that country. While other countries or territories may not have the same standards of data protection as those in a users’ home country, we will continue to protect personal information that we transfer in line with this Privacy Notice by requiring that our business partners or service providers adhere to this Privacy Notice and the applicable privacy regulations in a users’ home country.

CHILD PRIVACY

CTFSI’s Website is not for children or those under the age of 13. We do not knowingly collect personal information from children or other persons who are under 13 years of age. Individuals who are children or those under the age of 13 should not attempt to provide us with any personal information. If users think we have received personal information from children or those under the age of 13, please contact us immediately.

California Privacy Rights

We do not share personal information with third parties for their own direct marketing purposes without users’ consent. California residents under 18 years of age, in certain circumstances, may request and obtain removal of personal information or content that users have posted on our Website. Please be mindful that this would not ensure complete removal of the content posted by users on our Website. To make any request pursuant to California privacy law, please contact us.

USERS’ OPTIONS

CTFSI offers users certain choices in connection with our Website.

Email Communications / Direct Marketing: Users may have the opportunity to receive certain communications from us related to our business. Users can opt-out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting users’ email preferences. Please note that certain emails may be necessary for the operation of our business. Users will continue to receive these necessary emails, if lawful and appropriate, even if users unsubscribe from our optional marketing communications.
Cookies / Beacons: If users wish to minimize information collected by cookies or beacons, users can adjust the settings of their device or browser. Users can also set their device or browser to automatically reject any cookies. Users may also be able to install plug-ins and add-ins that serve similar functions. However, please be aware that our Website may not work properly if users reject cookies. In addition, the offers we provide when users visit us may not be as relevant to users or tailored to users’ interests. For more information about how our Website use cookies, please visit our Cookie policy page.
Do Not Track: Some devices and browsers support a “Do-Not-Track” (or DNT) feature, a privacy preference that users can set in certain browsers, which is intended to be a signal to websites that users do not wish to be tracked across different websites or online services users visit. Please note that we cannot control how third-party websites or online services users visit through our Website respond to DNT signals. Check the privacy policies of those third parties for information on their privacy practices. Our Website does not currently change the way they operate upon detection of a DNT or similar signal.

THIRD-PARTY WEBSITES AND APPS

Our Website may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Notice do not apply to information gathered through these third-party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

CONTACT CTFSI

Questions on this Privacy Notice and our management of personal information are welcome. For users protection, we may need to verify a users’ identity before assisting with users’ request, such as verifying that the information used to contact us matches the information that we have on file.