Privacy Policy

This Privacy Policy describes how your personal information is collected, used, and shared when you visit www.CumbreAltaAdvisors.com (the “Site”).

 

PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

 

We collect Device Information using the following technologies:

•  “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

• “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

 

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Information that we collect generally to fulfill any requests placed through the Site. Additionally, we use this Information to: communicate with you; screen our clients for potential risk or fraud; and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

 

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we may use Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

 

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

 

BEHAVIORAL ADVERTISING
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

 

You can opt out of targeted advertising by:
      FACEBOOK – https://www.facebook.com/settings/?tab=ads
      GOOGLE – https://www.google.com/settings/ads/anonymous
      BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

 

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

 

DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

 

YOUR RIGHTS
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

 

DATA RETENTION
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

 

CALIFORNIA PRIVACY RIGHTS: Your rights under the CCPA ​

For purposes of this section, the term Personal Information means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including without limitation any information that is subject to applicable data protection laws, as defined under the California Consumer Privacy Act, California Civil Code section 1798.100 et seq., as amended (CCPA).

 

No sale of Personal Information: We do not sell Personal Information. 

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Access to specific information and data portability rights: You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your Personal Information over the past 12 months. This right of access includes information about:

• The categories of Personal Information we collected about you

• The categories of sources for the Personal Information we collected about you

• Our business or commercial purpose for collecting that Personal Information

• The categories of third parties with whom we share that Personal Information

• The categories of Personal Information that each recipient received

• The specific pieces of Personal Information we collected about you

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Deletion request rights: You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your Personal Information that it has collected from you and retained, subject to certain exceptions.

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Exercising access, data portability, and deletion rights: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us via the information provided below, or calling us toll-free at +1 844 505 4848.

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The verifiable consumer request must:

Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected Personal Information. This may include requesting that you provide us with at least two or more pieces of Personal Information to match against Personal Information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.

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Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

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We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

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Authorized Agent: Only you, or a person you have designated in writing as your authorized agent, or who is registered with the California Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465 (Authorized Agent) may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

If you wish to have an Authorized Agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information.

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Non-discrimination: You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.

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YOUR RIGHTS UNDER THE CALIFORNIA “SHINE THE LIGHT” LAW

Websites operated by Cumbre Alta Advisors currently do not respond to “do not track” signals or similar mechanisms.

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If you are a California resident, California Civil Code section 1798.83 permits you to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain personal information for direct marketing purposes. We do not share personal information about you with any third parties for their own marketing purposes. We are only required to respond to such a request once during any calendar year. To make such a request, you should send a letter to the address listed below. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.

 

CHANGES
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

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CONTACT US
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at info@CumbreAltaAdvisors.com or by mail using the details provided below:

15332 Antioch Street, Suite 120, Pacific Palisades, CA, 90272, United States