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PRIVACY POLICY

Keystone Global Holdings, LLC, Keystone Global Strategies, LLC and KSG Advisors, LLC (collectively, “Keystone Global.” “we” or "us") are committed to protecting your privacy (the words “you” and “your” refer to the user visiting the Site and your institution or organization). We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at ksglobalholdings.com (the “Site“) and the data, text, reports, templates, agreements and other materials that are made available or enabled via the Site.

 

1. Questions; Contacting Keystone; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address, email or phone number:

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Keystone Global Holdings, LLC
Attn: Legal
390 N. Broadway, 3rd Floor
Jericho, NY 11753
516-882-4095
info@keystoneglobaladvisors.com

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2. What Information Does the Site Collect? 

 

a. Information You Provide to Us
Personal Information. We may ask you to provide us with your personally identifiable information such as your first and last name, telephone number and e-mail address (“Personal Information”). We may collect this Personal Information through various forms and in various places on the Site, including the contact us page, when you sign up for our newsfeed, or when you otherwise contact or interact with the Site. 


b. Information Collected or Stored As You Access and Use the Site 
In addition to any Personal Information or other information that you choose to submit to us via the Site, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with the Site. To the extent we associate Usage Information with your Personal Information that we collect directly from you on the Site, we will treat it as Personal Information. 


This Usage Information may include:

  • your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;

  • your Device functionality (including browser, operating system, hardware, mobile network information);

  • the URL that referred you to the Site;

  • the areas within the Site that you visit and your activities there, including remembering you and your preferences, if any;

  • your Device location;

  • your Device characteristics; and

  • certain other Device data, including the time of day, among other information.

 

Tracking Technologies

We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

  • Cookies. Like many online services, we use cookies to collect information. “Cookies” are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website or mobile application. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes those cookies. You can find out more information about cookies at http://www.allaboutcookies.org/. Cookies are widely used in order to make sites work, or to work more efficiently, as well as to provide information to the owners of the platform. We use cookies to enhance the online experience of our visitors and to better understand how our site is used.
     

  • Pixel Tags. We may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
     

Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:

  • Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access the Site, including cookies required to prevent fraudulent activity and improve security.

  • Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site.

  • Functionality Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Site, including identifying you when you visit the Site or keeping track of your specified preferences, including in terms of the presentation of content on the Site.

  • Targeting Related. We may use Tracking Technologies to deliver content relevant to your interests on the Site and third-party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you. 

 

Tracking Technologies Choices and Consent.
We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable cookies as set forth above. Please note that we are not required to obtain your consent to the information collection Tracking Technologies identified above that are strictly necessary.
We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.


3. Use of Your Personal Data
General Use. In general, Personal Data you submit to us is used to respond to requests that you make. We use your Personal Data in the following ways:

  • to provide improved administration of the Site;

  • to improve the quality of experience when you interact with the Site;

  • to send you follow-up communications when you contact us via e-mail, submit feedback, or post an event; and

  • to send you administrative e-mail notifications, such as updates regarding the Site, security, or support and maintenance advisories
     

4. How and When Do We Share Information with Third Parties?

We may share non-Personal Information, such as aggregated user statistics, with third parties. We may share your Device Identifiers with third parties along with data related to you and your activities. We do not share your Personal Information with third parties for those third parties’ direct marketing purposes unless we have given you the choice to consent or withhold consent to such sharing at the time you provide your Personal Information, in which case we will honor your choice. If we de-identify data about you, it is not treated as Personal Information by us, and we may share it with others freely. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy.

We may also disclose your information as follows:

a. When You Request Information From or Provide Information to Third Parties. You may be presented with an option on the Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. 
 

b. Third Parties Providing Websites on Our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Site, such as hosting the Site, designing and/or operating the Site’s features, tracking the Site’s activities and analytics, and enabling us to send you offers or perform other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device, and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third-party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third parties’ opt-out options.
 

c. Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described in Section 8 below), Keystone may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Keystone; (c) to protect or defend the rights or property of Keystone or users of the Site; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use. 


d. Affiliates and Business Transfer. We may share your Personal Information with our subsidiaries or affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process. 


e. Third Party Websites. The Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

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5. Changing your Personal Information & Communication Preferences. 
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information.  The Site may allow you to review, correct or update Personal Information you have provided, and you may provide updates and changes by contacting us at info@ksglobalholdings.com.  If you request updates or changes to provided Personal Information, we will make good faith efforts to make the requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).  Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Site, information that you remove may persist internally for our administrative purposes.  You may cancel or modify our marketing communications or newsfeed you receive from us by following the instructions contained within our newsfeed or  e-mails.  This will not affect subsequent subscriptions and, if you opt-out, may be limited to certain types of e-mails or communications subject to the opt-out.  Please note that we reserve the right to send you certain communications relating to your use of our Site, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.  If you have any questions about the Privacy Policy or practices described in it, you should contact us using the information set forth in Section 1 (above).


6. What About Transfer of Information to the United States?
If you are from a non-U.S. country, please be aware that the Personal Information you submit, ‎including information provided through our Site, is being sent to a location in the United States.  ‎The data protection laws in the United States may differ from those of the country in which you are ‎located, and your Personal Information may be subject to access requests from governments, ‎courts, or law enforcement in the United States according to laws of the United States. By providing ‎such Personal Information, you are consenting to (and represent that you have authority to consent ‎to), the transfer of such information to the United States for the uses and purposes described in this ‎Privacy Policy.‎

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7. What Should Parents Know About Children?
Our Site is intended for general audiences, and we do not knowingly seek or collect Personal Information from children under the age of majority in your jurisdiction. In accordance with the Child Online Privacy Protection Act, in the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any Personal Information from or about a child, please contact us by e-mail using the subject heading “COPPA Inquiry” at info@ksglobalholdings.com or by using the contact information set forth in Section 1.

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8. What About Security?
We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. No data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information, however, is guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk. 

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9. What About Changes to the Privacy Policy?
We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of the Site indicates your consent to the Privacy Policy posted at the time of use. We will not, however, use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

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Last Updated June 2023.

Resources: Files
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