PRIVACY POLICY

ORC International, Inc. (the “Company”, “we”, or “us”), along with its parent, subsidiaries and affiliates, offers the Cassandra website (the “Website”) and marketing reports, online webinars and online presentations via mobile and web, including Cassandra Daily® (the “Service”) that are accessible to you and other authorized users of the Service (collectively, “Users”).

Your privacy is important to us. That is why we want you to be informed about how we protect the privacy of visitors to our Website. Please take a moment to read the following policy, which describes our practices for the collection and use of personally identifiable information on this Website. Sites that are linked to our Website, or from which you linked to arrive at this Website, may have different policies; please review the privacy policy notices on those sites for details.

If you have any questions about this policy please contact us as follows:

Phone: (212) 645-4500
Email: info@cassandra.co
Address: 261 Madison Ave, 4th Floor, New York, New York 10016

This Privacy Policy is supplemental to our Terms of Service.

What Information Do We Gather About You?

We may collect information that you voluntarily give us, as well as location-based information and user content as described herein. We do not collect personally identifiable information about you on this Website except as expressly noted in this policy.

Personally Identifiable Information. In order to take advantage of certain features of our Service, we may ask you to provide your e-mail address, name, phone number or other information about yourself. We collect such registration information in order that you are able to use the Service, be added to the list to receive e-mail updates, and are able to conduct transactions elsewhere on the Website. You are not required to provide us with this information, but if you choose not to, you may not be able to use some or all of the Website.

Non-Personally Identifiable Information. Some non-personally identifiable information may automatically be collected as you browse our Website. Our web server automatically collects information known as “clickstream data,” such as the domain name of the service providing you with Internet access, the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Website, pages viewed, information searched for, access times and other relevant statistics. We also use cookies on our Website. Cookies are pieces of information that a web Website transfers to the hard drive of a visitor’s computer for record-keeping purposes.

We use clickstream data and cookies only in the aggregate to measure the use of our Website and to administer and improve our Website. When we collect personal information, we may extract some of the information and combine it with other information, such as clickstream data. This combined information is used and analyzed only at an aggregate level to help us understand trends and patterns.

Information Collected By Third Parties. Some of the services and advertisements included via our Service are delivered or served by third-party companies. These companies may place or recognize cookies, web beacons, or other technology to track certain non-personal information about users. We do not have access to, nor control over, third party use of cookies or other tracking technologies or how they may be used.

What Do We Do With The Information We Gather About You?

Service Participation. We use the information we collect from you to allow you to participate in the Website activities for which the information is collected. For example, when you give us your e-mail address in order to receive the free daily Cassandra Daily® newsletter, that address is added to the e-mail list for the newsletter. On each e-mail you receive, you are given the opportunity to unsubscribe; once you unsubscribe, you will no longer receive such e-mails.

Statistical Analysis. We may perform statistical, demographic and marketing analysis of Users and their patterns. We use this information for analysis purposes.

User Activity Data. We may use information you voluntarily provide in conjunction with your registration information for analysis and marketing purposes and to generate aggregated, anonymous reports.

With Whom Do We Share The Information That We Gather?

Within the Company. We may use information that we collect or that you provide internally, through Cassandra Daily®, to Engine Group and its affiliated companies, divisions and subsidiaries, including ORC International, Inc. and Engine USA (the “Group Companies”). By using an internet site operated or maintained by a Group Company or providing personal information to us directly, you are consenting to the collection, use and disclosure of your personal information as described in this policy. If you do not so consent, do not use the sites or their related forms.

Third Parties. Non-personally identifiable information regarding trends, personal habits, download history and preferences which is provided by individuals is aggregated and made available on the Website and to clients without attribution to any individual and only for the purpose for which it was originally collected, or to which individuals subsequently consent (e.g., research and information regarding trends, lifestyle and culture). Additionally, we may disclose to our affiliates the information you voluntarily provide to us, including your registration information.

Service Providers. Personal information collected on the Website may be shared with those with whom we contract to operate this Website. These contractors have agreed with us to use personal information of Website visitors only for the purposes of operating this Website. To the extent required or permitted by law, we may also collect, use and disclose personal information in connection with security-related or law enforcement investigations or in the course of cooperating with authorities or complying with legal requirements. We may also use your information as permitted by law to protect our rights or property, our Website, or its users. Information collected on the Website may also be used in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of a Group Company or any of their business units, or in similar circumstances.

As Permitted by Law. We may disclose information we collect, including personally identifiable information, to third parties as required or permitted by law. For example, we may disclose information:

§ to regulators;

§ to law enforcement authorities pursuant to an official request;

§ to vendors who provide us with services; and

§ to companies that may acquire part or all of Company or an affiliated company.

What Is Our Email Policy?

CAN-SPAM Act of 2003. We will not send you marketing messages if you have opted out of them. We will not share, sell, rent, swap or authorize any third party to use your email address for commercial purposes without your permission.

Service-Related Email. If you choose to sign up for a Cassandra Daily® newsletter, you may elect to sign up for third party mailings or announcements. Whether you choose to receive these mailings or announcements is your choice. If you choose to receive them from a specific source, you will receive commercial messages from independent third parties over whom we have no control and who each have their own privacy policies which you should review. You may typically remove your email address from these third party lists by following the instructions on emails that you receive. You may unsubscribe from the Cassandra Daily® newsletter at any time by email (info@cassandra.co) or by calling (212) 645-4500.

How Do I Change Or Update My Personal Information? You may update your registration information by contacting us directly by email (info@cassandra.co) or by calling (212) 645-4500.

Is My Information Protected?

We try to keep the information we collect from you as current as possible, and we take steps to maintain the security of your personal information and to prevent unauthorized access to it by those who do not have a legitimate need for it. To that end, we periodically review our security measures. We will never post your e-mail address or other identifying information you have provided on our Website without your consent. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure.

Miscellaneous

Safe Harbor Data Privacy Notice. In the U.S., we comply with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework published by the U.S. Department of Commerce (the “Safe Harbor Principles”) with respect to personally identifiable information it receives from the European Union and Switzerland. The Company has certified that it adheres to the Safe Harbor Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. This notice outlines the Company’s general policy and practices in compliance with the Safe Harbor Principles, including the type of information to which this notice applies, how we use information, and your choices regarding our use of, and your ability to correct, your personally identifiable information. For purposes of this notice, “personally identifiable information” includes information (a) transferred from the European Union and Switzerland to the United States; (b) recorded in any form by us; and (c) pertaining to a specific individual who is identified in, or is identifiable from, the data. This notice applies to all personally identifiable information we handle, including on-line (except as noted below), off-line, and manually processed data. If there is any conflict between this Privacy Policy and the Safe Harbor Principles, the Safe Harbor Principles will apply. If you would like to learn more about the U.S.-EU and U.S.-Swiss Safe Harbor Frameworks, please visit http://export.gov/safeharbor.

We obtain personal information only as permitted by the Safe Harbor Principles or with the consent of the individual affected. We may ask for your consent to collect, use, and/or disclose personal information in certain ways, and you may be required to give your consent in order to use our services. To the extent permitted under the Safe Harbor Principles, we reserve the right to process personal information in the course of providing services through the Service without the knowledge of individuals involved. If you wish to opt out of our collection or our disclosure of personally identifiable information to third parties, you may contact us at info@cassandra.co with a request to do so. The request should include your name, email address, login information, and any specifics that may help us to prevent the collection of personally identifiable information you do not wish to have collected or disclosed. Please note that if you opt out of our data collection practices, the Service may be less functional for you.

The Company will obtain assurances from its affiliates that they will safeguard personal information consistently with this Privacy Policy. If we learn that an affiliate is using or disclosing personal information in a manner contrary to this Privacy Policy, we will take steps to prevent or stop the use or disclosure. Transfers of information permitted under this notice, either to third parties or amongst the Company and its affiliates, may include the transfer of data from one jurisdiction to another, such as transfers to and from the United States of America, the UK and Australia.

The Company will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, and it will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Policy. We cannot guarantee, in every circumstance, the security of the personal information you provide through the Services. All incoming encrypted information is routed through our firewall, which serves as a gatekeeper for our system. Only data containing the correct authorization is permitted past the firewall. Attempts to pass the firewall are constantly monitored for suspicious activity.

We will provide you reasonable access to personal information that you provide through the Website and the reasonable ability to review and correct it, as applicable, to the extent providing such access and means to review and correct:

(a) are not outweighed, in our sole discretion, by the burden of providing of it; or

(b) are otherwise impracticable for any reason.

By using our Website you consent to our collection and use of your personal information as described in this policy. We reserve the right to modify this privacy statement and related business practices at any time by posting updated text on this Website, and your continued use constitutes acceptance of those changes. Thank you for visiting our Website, and for taking the time to read this policy.

Any controversy or claim arising out of or relating to this Privacy Policy, or the breach thereof, shall be settled by arbitration administered by the American Arbitration Association’s Safe Harbor Program in accordance with its Commercial or other Arbitration Rules, and judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof.

The operator of this Website is ORC International, Inc.

Updated February 1, 2016.