Terms And Conditions; Privacy Policy

Last Updated: 2 January, 2024

1. Services and License

1.1 Services. On the terms and subject to the conditions set forth in these General Terms and Conditions (this “Agreement”), Cestrian Capital Research, Inc. (“Cestrian”) shall provide to the user (“User”) the services as indicated on the online checkout page relating to this Agreement (the “Services”), as well as all data, information, notes, reports, materials, and other content made available to User by Cestrian through the Services (collectively, “Content”). All Services and Content will be provided to User through Cestrian’s website, located at https://cestriancapitalresearch.com/, and/or at Cestrian’s Slack Workspace, located at https://cestriansymposium.slack.com/. Cestrian and User may each be referred to herein as a “Party” or, collectively, the “Parties”.

1.2 Grant of License. Subject to the terms and conditions of this Agreement, Cestrian hereby grants to User, during the term of this Agreement, a limited, non-exclusive, non-transferable, non-sublicensable license to access and use the Services and Content solely for User’s internal investment management, reference, or information purposes.

1.3 Use Restrictions. Except for the limited rights expressly granted in this Agreement, User has no rights in or to the Services or Content. Without limiting the generality of the foregoing, except in each case as otherwise permitted by this Agreement, User shall not (and shall not permit any third party to): (i) sell, rent, lease, sublicense, transfer, assign, time-share, distribute, or otherwise make the Services or Content available to any third party; (ii) decompile, disassemble, reverse engineer, or otherwise attempt to separate the components of the Services or Content, or any part thereof (including, without limitation, viewing or otherwise obtaining source code); (iii) copy, modify, adapt, translate, or create derivative works of the Services or Content; (iv) alter, remove, or obscure any disclaimers, copyright notices, proprietary markings, trademarks or trade names from the Services or Content; (v) use the Services or Content, or any part thereof, in any manner to compete with or facilitate any third party in competing with any Cestrian product or service; (vi) use the Services or Content in violation of applicable law; (vii) damage the Services or interfere with the security or proper working of the Services, including, without limitation, any upload or transmission of any information, files, code, or other materials that contain viruses or are able to disrupt or damage the Services or Content, or take any action that imposes an unreasonable or disproportionately large load on the Services’ infrastructure; or (viii) attempt to defeat, modify, or work around any security features protecting the Services or any Content.

1.4 Accounts. In order to access and use the Services and Content, User may be required to set up and maintain an active user account (“Account”). To set up an Account, User may be required to provide certain information, such as User’s first and last name, email address, and billing information. User may also need to create a username and password for the Account and acknowledge and agree to this Agreement. User must provide complete and accurate information when setting up an Account, and User shall at all times keep current and promptly update its Account information (including payment information) as necessary. User shall be solely responsible for maintaining the confidentiality of its password and Account. User agrees to: (i) use a strong password and keep its password confidential and not share it with anyone else; (ii) not transfer any part of its Account to anyone else; and (iii) immediately notify Cestrian of any unauthorized use of its username, password, or Account. You acknowledge and agree that Cestrian is authorized to act on instructions received through use of User’s username, password, and/or Account, and that Cestrian may, but is not obligated to, deny access or block any use of User’s username, password, and/or Account, without prior notice, if Cestrian believes User’s username, password, and/or Account are being used by someone other than User, or for any other reason. User is solely responsible for all activity that occurs under its Account unless User reports misuse.

2. Term and Termination

2.1 Term. If User has selected a monthly subscription as indicated on the online checkout page relating to this Agreement, the term of this Agreement shall commence on the date of purchase and automatically renew on a month-to-month basis unless either Party gives the other Party at least thirty (30) days’ prior written notice of non-renewal. If User has selected an annual subscription as indicated on the online checkout page relating to this Agreement, the term of this Agreement shall commence on the date of purchase and continue for an initial term of one (1) year thereafter. Following expiration of such initial term, this Agreement shall automatically renew for successive one (1) year periods unless either Party gives the other Party at least thirty (30) days’ prior written notice of non-renewal.

2.2 Termination. Either Party may terminate this Agreement at any time if the other Party: (i) materially breaches any provision of this Agreement and fails to cure such breach within thirty (30) days following written notice thereof from the non-breaching Party; or (ii) commences or becomes subject to any proceeding seeking liquidation, reorganization, or other relief with respect to itself or its debts under any bankruptcy, insolvency, or other similar law, or makes a general assignment for the benefit of creditors.

2.3 Effect of Termination. Upon termination of this Agreement for any reason, User shall immediately cease all use of the Services and Content, and shall promptly destroy all Content in its possession or control, including all copies thereof. Unless this Agreement is terminated by User due to Cestrian’s breach, User shall not be entitled to any refund of any License Fees paid to Cestrian hereunder.

3. License Fees

3.1 License Fees. In exchange for the Services and Content provided and rights granted hereunder, User agrees to pay Cestrian the amount set forth on the online checkout page relating to this Agreement (“License Fees”) in accordance with the billing frequency indicated therein. Cestrian shall be entitled to increase the License Fees upon notice to User.

3.2 Payment. All payments are due in advance of service delivery for the period in question.

3.3 Taxes and Duties. All taxes, duties, fees, and other governmental charges of any kind (including sale and use taxes, but excluding taxes based on the gross revenues or net income of Cestrian) that are imposed by or under the authority of any government or any political subdivision thereof on User payment obligations under this Agreement, shall be borne and paid solely by User.

4. Title and Ownership

4.1 Acknowledgement of Ownership. User acknowledges and agrees that: (i) as between Cestrian and User, the Services, Content, and every part thereof, including, without limitation, any modifications, enhancements, and updates thereto, and any originals and copies thereof, in whole or in part, and all intellectual property rights therein, are owned or licensed by Cestrian; and (ii) the Services and Content are protected by United States and international copyright law, intellectual property law and international treaty provisions. All rights not expressly granted to User under this Agreement are reserved by Cestrian.

5. Representations and Warranties

5.1 Mutual Warranties. Each Party represents and warrants that: (i) it has the full right, power, and authority to enter into and perform its obligations under this Agreement; and (ii) the execution and delivery of this Agreement will constitute a legal, valid, and binding obligation of such Party, enforceable against it in accordance with its terms.

5.2 Cestrian Warranties. Cestrian represents and warrants that it will provide the Services and Content in a professional and workmanlike manner and in accordance with generally accepted industry standards.

5.3 GENERAL DISCLAIMER. EXCEPT AS EXPRESSLY SET FORTH IN THIS AGREEMENT, NO OTHER REPRESENTATIONS OR WARRANTIES ARE BEING GIVEN BY CESTRIAN AS TO THE SERVICES, CONTENT, OR ANY PART THEREOF, ALL OF WHICH IS BEING PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. EXCEPT AS EXPRESSLY SET FORTH IN THIS SECTION 5, CESTRIAN DISCLAIMS ALL OTHER WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, ANY IMPLIED WARRANTIES OF TITLE, NON-INFRINGEMENT, MERCHANTABILITY, AND FITNESS FOR A PARTICULAR PURPOSE. IN PARTICULAR, CESTRIAN DOES NOT REPRESENT OR WARRANT THAT THE SERVICES OR CONTENT IS OR WILL BE ACCURATE, CURRENT, SECURE, COMPLETE, RELIABLE, FREE OF ERRORS OR DEFECTS, CONSTANTLY AVAILABLE, OR APPROPRIATE FOR ANY PARTICULAR USE TO WHICH USER OR OTHERS MAY PUT IT.

5.4 NO INVESTMENT RECOMMENDATIONS OR PROFESSIONAL ADVICE. USER ACKNOWLEDGES AND AGREES THAT THE SERVICES AND CONTENT ARE NOT INTENDED TO PROVIDE TAX, LEGAL, INSURANCE, OR INVESTMENT ADVICE, AND NOTHING IN THE SERVICES OR CONTENT SHOULD BE CONSTRUED AS AN OFFER TO SELL, A SOLICITATION OF AN OFFER TO BUY, OR A RECOMMENDATION FOR ANY SECURITY BY CESTRIAN. USER IS SOLELY RESPONSIBLE FOR DETERMINING WHETHER ANY INVESTMENT, SECURITY OR STRATEGY, OR ANY OTHER PRODUCT OR SERVICE, IS APPROPRIATE OR SUITABLE FOR USER BASED ON USER’S INVESTMENT OBJECTIVES AND PERSONAL AND FINANCIAL SITUATION. USER SHOULD CONSULT AN ATTORNEY OR TAX PROFESSIONAL REGARDING ITS SPECIFIC LEGAL OR TAX SITUATION.

6. Indemnification and Limitation of Liability

6.1 Indemnification. User shall indemnify, defend, and hold harmless Cestrian, its affiliates, and its and their respective officers, directors, shareholders, employees, contractors, suppliers, agents, successors, and assigns from and against any and all claims, demands, suits or other proceedings, and all resulting losses, damages, liabilities, costs and expenses (including reasonable attorneys' fees), arising out of or relating to User’s access to or use of the Services or Content, including, but not limited to, any investment action (or inaction) taken by or on behalf of User based on User’s use of or reliance on the Services, Content, or any part thereof.

6.2 Limitation of Liability. IN NO EVENT SHALL CESTRIAN BE LIABLE FOR ANY: (I) INDIRECT, CONSEQUENTIAL, EXEMPLARY, INCIDENTAL, OR PUNITIVE DAMAGES, INCLUDING, BUT NOT LIMITED TO, LOST PROFITS OR LOST REVENUE, EVEN IF CESTRIAN HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES; OR (II) DIRECT DAMAGES ARISING OUT OF THIS AGREEMENT, WHETHER SOUNDING IN CONTRACT, TORT (INCLUDING NEGLIGENCE) OR ANY OTHER LEGAL THEORY, EXCEEDING THE TOTAL LICENSE FEES PAID BY USER DURING THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE FIRST EVENT GIVING RISE TO THE LIABILITY. IN A JURISDICTION THAT DOES NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CERTAIN DAMAGES, THE LIABILITY OF CESTRIAN SHALL BE LIMITED IN ACCORDANCE WITH THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

7. Confidentiality

7.1 Confidential Information. User shall maintain as strictly confidential all non-public information of Cestrian, including, but not limited to, the Services, Content, and the terms of this Agreement (“Confidential Information”), using measures at least as rigorous as those used to protect User’s own confidential information, but in no event less than a reasonable degree of care. User shall use Confidential Information solely as necessary to perform its obligations and exercise its license rights hereunder, and shall not disclose Confidential Information to any third party. Upon any expiration or termination of this Agreement, User shall, at Cestrian’s option, return or securely destroy all Confidential Information in User’s possession or control, including all copies thereof.

7.2 Exceptions. The confidentiality obligations in this Section 7 will not apply to information that: (i) is in or enters the public domain without breach of this Agreement by User; (ii) User was in possession of prior to first receiving it from Cestrian; (iii) was developed by User independently without reference to Cestrian’s confidential information; or (iv) User receives from a third party without restriction on disclosure and without breach of a nondisclosure obligation. In addition, User may disclose Confidential Information to the extent required by law or by order of a court or governmental agency; provided, however, that User shall give Cestrian prompt written notice, and shall reasonably cooperate with Cestrian to obtain an appropriate protective order or other appropriate remedy.

7.3 Injunctive Relief. User acknowledges and agrees that any breach of this Section 7 may cause immediate and irreparable injury to Cestrian, and in the event of such breach, Cestrian shall be entitled to seek injunctive relief in addition to any and all other remedies available at law or in equity.

8. Miscellaneous

8.1 Governing Law. This Agreement shall be governed by and construed in accordance with the laws of the United States of America and the State of California without regard to the conflicts of law rules of that jurisdiction. Each Party consents to the exclusive jurisdiction of the state and federal courts located in Los Angeles, California in connection with all disputes arising hereunder and waives any objection to the propriety or convenience of venue in such courts. EACH PARTY HEREBY WAIVES ITS RIGHT TO A JURY TRIAL IN CONNECTION WITH ANY DISPUTE OR LEGAL PROCEEDING ARISING OUT OF THIS AGREEMENT.

8.2 Notices. All notices to Cestrian in relation to this Agreement must be sent by email to minerva@cestriancapital.com. All notices to User in relation to this Agreement will be sent either by email to the email address on file for User and/or by message within the Slack Workspace. Notices shall be deemed given forty-eight (48) hours after transmission, unless the email bounces back or the Slack Workspace specifically reports that the message was undelivered.

8.3 Assignment. User may not transfer or assign any of its rights or obligations hereunder without the prior written consent of Cestrian. Any purported assignment, transfer, or delegation in the absence of such consent shall be null and void. This Agreement shall be binding upon the successors and permitted assigns of the Parties hereto.

8.4 Independent Parties. The Parties shall at all times be independent contractors with respect to this Agreement. Neither Cestrian nor User is, or will be considered, the agent, employee, legal representative, partner or joint venturer of the other for any purpose.

8.5 Force Majeure. Cestrian shall be excused from performance of its obligations under this Agreement, in whole or in part, if the failure or inability to perform is caused by acts of God, governmental authorities, riots, strikes, acts of war, epidemics, fire, flood, communication line or equipment failures, power failures, the infrastructure of the Internet, or any other cause beyond Cestrian’s reasonable control.

8.6 No Waiver of Enforcement Rights. No failure or delay on the part of either party in exercising any right hereunder shall operate as a waiver of or impair any such right. No provision of this Agreement may be waived except by a written instrument signed by the Parties waiving compliance.

8.7 Severability. If any provision in this Agreement is determined to be invalid or unenforceable, the remaining provisions of this Agreement shall not be affected thereby and shall be binding upon the Parties hereto, and shall be enforceable, as though the invalid or unenforceable provision were not contained herein.

8.8 Survival. Sections 1.3, 2.3, 4.1, 5.3, 5.4, and 6 through 8, and any other terms that by their nature should survive termination of this Agreement, will survive termination of this Agreement.

8.9 Entire Agreement. This Agreement constitutes the entire agreement between the Parties with respect to the subject matter hereof, and supersedes any and all prior and contemporaneous agreements, understandings, promises, and representations. This Agreement may not be amended or modified in any matter except by a written instrument signed by both Parties.

8.10 Changes. Cestrian may change or modify this Agreement at any time, and all such changes and modifications will become effective immediately upon notice, which, for the avoidance of doubt, Cestrian may give by any means, including, but not limited to, by sending a message to the User’s email address that Cestrian has on file for User (if any) or posting a revised version of this Agreement or other notice on or within the Services. User agrees to view this Agreement often to stay informed of changes and modifications that may affect User. User’s use of the Services and Content constitutes User’s continuing agreement to be bound by this Agreement, as it may be changed or modified from time to time.

Privacy Policy

Last Updated: 2 January 2024

Cestrian Capital Research, Inc. (“Cestrian”, “we”, “us”, or “our”) understands your concerns with regard to how information about you is used and shared, and we appreciate your trust that we will use and share information about you carefully and sensibly. This Privacy Policy (this “Policy”) applies to information about you collected in connection with your use of our investment research, third-party content, and related services (collectively, “Services”), as well as your access to and use of our websites and online hosted portals that support the Services (including, without limitation, the website located at https://cestriancapitalresearch.com/ and Cestrian’s Slack Workspace, located at https://cestriansymposium.slack.com/) (collectively, the “Site”). This Policy describes what information we collect about you in relation to your use of the Site and Services, how we collect it, how we use it, with whom we may share it, and what choices you have regarding it.

Please read this Policy carefully. By clicking “accept” or otherwise accessing and using the Site and Services, you agree that you have read and understand this Policy and that you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Policy.

When do we collect your information?

We collect information relating to you and your use of the Site and Services in order to provide services and features that are responsive to your needs. We collect information in the following ways:

Directly from you. We collect information from you when you register an account with us, place an order for any Services, submit content or information to the Site, fill out a registration or other form, complete a survey, request information, send us an inquiry or other communication, or otherwise interact with us or the Site or Services.
From other third-party sources. We may receive information about you from our third-party service providers who help us to provide services to you, including the Site and Services.
Automatically as you navigate the Site. Information collected automatically as you use and navigate the Site may include usage details, email address, IP address, and information collected through cookies and other tracking technologies.

What information do we collect?

Information you provide to us. We collect the information you provide directly to us when you register an account, fill out a form, place an order, or otherwise access and use the Site and Services, including, but not limited to, your:

· First and last name

· E-mail address

· Billing information (collected by our third-party payment processor)

· Account information (including password and account settings)

· Contact preferences

· Messaging content and information

· Any other information regarding your utilization of the Site and Services

Information sent to us by web browsers. We and our third-party service providers collect information that is sent to us automatically by your web browser or device. This information typically includes your IP address, the identity of your Internet service provider, the name and version of your operating system, the name and version of your browser, the date and time of your visit (and the number of your visits), the pages you visit, the length of your visit, average time spent, and the websites you visit before coming to and after leaving the Site. The information we receive may depend on your browser or device settings.

The information we receive from your web browser and/or device is not, in and of itself, personally identifiable. Generally, we use this information in the aggregate to help us improve the Site and make it more compatible with the technology used by our visitors. However, we may combine it with other information in an attempt to identify you or we may combine it with information that does identify you. We may also review our server logs for security purposes – for example, to detect intrusions into our network – and we might share our server logs, which contain visitors’ IP addresses, with the appropriate investigative authorities who could use that information to trace and identify you.

Information collected by cookies and other technologies. We use “cookies” and other tracking technologies to collect information and support certain features of the Site. A cookie is an element of data that can be sent to your browser, which may then store it on your system. Cookies are used on the Site to allow access to certain secured functions and better serve you when returning to the Site. Cookies do not contain any personal information about you and are not written into your hard drive. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or not.

How do we use your information?

We use your information in order to provide the Site and Services to you and any additional services you request, as well as to respond to inquiries and other communications from you.

Generally, we use the information we collect from you to:

Provide you with the Site, Services, and any other information or services you request. For example, we may use your information to provide certain features and functions of the Site and Services, to process your orders, and to otherwise respond to and process your other requests.
Support the Site, Services, and our business. For example, we may use your information to respond to inquiries and troubleshoot any issues with the Site or Services.
Manage our business needs, such as improving the Site and Services and developing new services and offerings. For example, we monitor and record website user behavior to conduct research and analysis about the way you and other users use the Site and to improve its content and ease of use.
Market, promote, and provide other information regarding our services and offerings (including the Site and Services). For example, we may use your information to tailor our offerings to your preferences and interests and to send you information about our products, services, and system changes that we think may be of interest to you.
Manage risk and protect the Site. We use data to better protect the Site, Services, and you by enhancing Site security and helping to detect and prevent fraud and abuse of the Site and Services.
Comply with our other contractual, legal, and regulatory obligations. We will use your information as necessary to enforce the terms of the Site and Services, to address emergency situations, and to comply with our contractual obligations and applicable legal requirements.
Carry out other purposes for which you provide your consent. For example, we will use your information for other purposes which are disclosed to you at the time your information is collected or for purposes which can be inferred from or are obvious given the circumstances of collection.

Please see below for information about the choices you have about the ways we use your information.

Do we disclose your information to third parties?

Third-Party Service Providers

We may disclose your information for a business purpose to our third-party service providers, such as payment processors, website hosts, and analytics providers, that help us to support the Site and provide our Services to you. Further, our online service providers may implement technologies that allow for the collection of personally identifiable information over time and across websites. We may also disclose aggregated, de-identified information, and analyses and reports derived from such information, to our service providers.

We may use analytics providers, such as Google Analytics, to measure and report how users interact with the Site, and to analyze the traffic to the Site and for the other purposes as set forth in this Policy. For more information about Google Analytics and how it collects and processes data, please see “How Google Uses Data When You Use Our Partners’ Sites or Apps.” For more information about how Google uses and shares information collected by Google Analytics through your visits to Site, please see Google’s Terms of Service and Privacy Policy. If you do not want your Site visit data reported by the Google Analytics JavaScript, you can install the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript to prohibit sending visit information to Google Analytics, but does not prevent information from being sent to the Site itself or in other ways to other website analytics services. Click here if you would like to learn more about the Google Analytics opt-out browser add-on, and click here to install the opt-out browser add-on.

Legal Requirements and Business Transfers

We may disclose your information: (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other government official request; (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (iii) in connection with an investigation of a complaint, security threat, or suspected or actual illegal activity; (iv) in connection with an internal audit; or (v) in the event that Cestrian is subject to mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, your information (including personal information) may be shared, sold, or transferred, and it may be used subsequently by a third party.

What choices do you have about your information?

We offer certain choices about how we communicate with you and what information we obtain about you and share with others.

Account. If you have registered an account on the Site, you can update, modify, or delete certain of your account information and preferences after you log into your account using the features and functionalities available there. You may also contact us at the email address below for assistance in updating, modifying, or deleting any of your information.

Email preferences. You may opt out from receiving future promotional or informational emails from us by following the instructions for unsubscribing in the emails we send to you or by contacting us at the email address below. However, you cannot opt out of transactional emails related to your account registration or other transactions with us.

Do Not Track. While we take reasonable steps to protect the privacy of our Site visitors, we cannot promise that the current limitations of our online applications programming will address every browser setting or honor every personal browser preference. In particular, we have not implemented the necessary program changes to honor “Do Not Track” or “DNT” browser signals. As our online applications programming is refined, we will take reasonable steps to honor such requests in the future. Please return to this Policy for further updates on this topic.

Cookies. Most web browsers automatically accept cookies, but you can change your browser’s settings to disable all or certain cookies if you wish. Please be aware that if you change the preferences on your device to prevent or limit your device’s acceptance of cookies, this may prevent you from taking advantage of some of the features on the Site.

Location of the Site

The Site is hosted and operated in the United States. However, we and our service providers may store information about individuals in the United States, or we may transfer it to, and store it within, other countries.

Visitors from jurisdictions outside the United States visit us at their own choice and risk.

If you are not a resident of the United States, you acknowledge and agree that we may collect and use your personal information outside your home jurisdiction, and that we may store your personal information in the United States or elsewhere. Please note that the level of legal protection provided in the United States from which you may access the Site may not be as stringent as that under privacy standards or the privacy laws of other countries, possibly including your home jurisdiction.

How long do we retain your information?

We will keep your information (including your information in each category of personal information described in the “State Privacy Rights” section below, if applicable) only for the period necessary to fulfil the purposes described in this Policy, unless a longer retention period is permitted or required by law.

Links to other sites

We may provide links to external sites, such as government organizations, distributors, affiliates, and other third parties, as a convenience to you. The inclusion of any link does not imply Cestrian endorsement of the external site company, its website, or its products or services. When you leave the Site to visit one of these linked sites, the only information transferred to the third party is the fact that you came from the Site. This practice allows the third party to monitor its own website traffic, but does not provide them with any information about you. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for other sites’ content or privacy practices.

You should consult the privacy policies at those third-party sites to determine what information they collect and how your information may be used.

How do we protect your information?

We have implemented reasonable physical, technical, and organizational security standards designed to protect your information from unauthorized access, use, disclosure, or destruction. We strive to protect your personal information through the use of security technologies and procedures, such as encryption and by limiting access only to authorized individuals. However, no system or procedures are entirely secure or failsafe, and we cannot and do not guarantee the security of your information.

State Privacy Rights

Pursuant to certain state laws, including, as applicable, the California Consumer Privacy Act (“CCPA”), Cestrian makes the following disclosures regarding the personal information we collect:

Category of Personal Information	Category of Source from which Data is Collected	Purpose of Collection	Category of Third Parties to whom Data is Disclosed
Identifiers, such as name, e-mail address, mailing address, and account login information	Directly from users	To provide the Site and Services; to support our electronic and digital programs	Service Providers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)), such as credit card number and billing address (collected by our third-party payment processor)	Directly from users	To process and fulfill your orders	Service Providers
Commercial information, such as order information, history, and tendencies	Directly from users	To provide the Site and Services; to process your orders, requests, and other inquiries; to support our electronic and digital programs	Service Providers
Inferences, such as interests, preferences, and activities	Directly from users	To personalize the Services according to your personal preferences; for developing new goods and services; for enhancing, improving, or modifying our Services; for identifying usage trends and determining the effectiveness of our service promotions; for operating and expanding our business activities	Service Providers
Internet or network activity information, such as IP address, device type, and browser type	Cookies and other tracking technologies	For data analysis, audits, security and fraud monitoring and prevention; for developing new goods and services; for enhancing, improving or modifying our Services; for identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities	Service Providers

Other than for a business purpose as described in this Policy, we have not sold or shared consumers’ personal information in the twelve (12) months preceding the effective date of this Policy.

Under certain state laws, including, but not limited to, the CCPA, you may have the right to request:

the categories of personal information we have collected about you;
the categories of sources from which your personal information is collected;
the business or commercial purpose of collecting or selling your personal information;
the categories of third parties with whom we share your personal information;
the specific pieces of personal information we have collected about you;
when and if applicable, the categories of personal information that we have sold about you and the categories of third parties to whom the personal information was sold, if applicable;
access to your personal information;
deletion of your personal information;
correction of inaccurate personal information we maintain about you;
an opt out of having your personal information sold to third parties or shared with third parties for purposes of cross-context behavioral advertising (if applicable); and/or
limitation on use of any sensitive personal information we maintain about you to that which is necessary to provide a good or service requested by you (if applicable).

To submit a request, or designate an authorized agent to make a permitted request under an applicable state law on your behalf, please contact us at minerva@cestriancapital.com, or complete the web form located at https://www.cestriancapitalresearch.com/contact/ . To verify your identity when you submit a request, we will match the identifying information you provide us to the personal information we have about you. If you have an account with us, we will also verify your identity through our existing authentication practices for your account. Requests will typically be honored within forty-five (45) days or less, but may take up to ninety (90) days based on the results of verification. Note that certain state laws may limit the number of requests you may make within a 12-month period.

Notwithstanding any of the above, we will not be required to comply with your request to delete your personal information if it is necessary for us to maintain your personal information in order to:

complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
debug to identify and repair errors that impair existing intended functionality;
exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;
to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
comply with a legal obligation; or
otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

We will not discriminate against you in the event you exercise any of the aforementioned rights under state laws, including, but not limited to, by:

denying goods or services to you;
charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
providing a different level or quality of goods or services to you; or
suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Do we collect information from children?

The Site and Services are not intended for children under 16 years of age. No one under age 16 may provide any information on or to the Site or Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Site or Services or on or through any of their features, including your name or email address. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at minerva@cestriancapital.com.

Comments; Contacting us

Comments, suggestions, or other such unsolicited ideas and concepts sent to us via the Site will not be treated as confidential and will become the property of Cestrian. We will not have obligation of any kind with respect to such comments, suggestions, ideas, or concepts and will be free to use and distribute any such submissions without limitation, including, but not limited to, developing and marketing the concepts without obligation to the party making the submission.

If you have any questions or concerns about this Policy, please contact us at minerva@cestriancapital.com.

Changes to this Policy

We reserve the right, at our discretion, to, modify, add, or remove portions of this Policy at any time. If we update or change this Policy, the changes will be posted on this page. If the changes are significant, we may provide a more prominent notice, and at our discretion may email you directly with notification of the same if we have an email address on file for you. Your continued use of the Site and Services following the effective date of any change signifies your assent to the updated Policy. You are solely responsible for periodically visiting the Site and this Policy to check for any changes.