Privacy Policy

Last Updated: July 30, 2025 

This Privacy Policy (“Policy”) describes the privacy practices of Consertus, Inc., a Delaware corporation with its principal place of business at 1111 Brickell Avenue, Suite 1000, Miami, Florida 33131, and/or its subsidiaries or affiliates (collectively, “Consertus,” “we,” “us,” or “our”), which operates the www.consertus.com website (“Website”), and may operate other websites, mobile applications, and digital agents and services (together with the Website, collectively, the “Services”). 

This Policy informs users (“user(s)“, “you” or “your“) about our collection, use, disclosure, and protection of information we collect from you and applies to information we collect or process whenever you interact with us, including when you visit our Website, use our mobile applications, create an account with us through our Services, apply for a job opportunity, provide services on our behalf, or enter into contracts to receive our services (collectively “user information” or “personal data”). This Policy also covers rights and choices related to your personal data, but does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Services.  

UPDATES 

We may modify this Policy at any time, and any modifications will be posted on this Website. Your continued use of the Services following any such modifications constitutes your agreement that such use is legally sufficient consideration and your acceptance of the revised Policy then in effect. You agree that you will review this Policy periodically and that you shall be bound by this Policy and any modifications to it.  

PERSONAL DATA WE COLLECT 

We collect personal data about you in different ways. For example, we collect personal data: 

  • Directly from you. This includes when you sign up to receive our emails or request that we contact you.  
  • Automatically. This includes user information collected through cookies, server logs, and other tools on our Website or other Services.  
  • From other sources. These sources can include our affiliates, vendors, social media, publicly available sources, and other companies.  

The following are a few examples of our collection and use of personal data:  

Context  Examples of Personal data  Primary Purpose and Legal Basis  
Client Information   We collect the name and contact information of our clients and their employees or other personnel with whom we may interact.   We have a legitimate interest in contacting our clients and communicating with them about business activities such as projects, services, and billing. 
Demographics  We collect personal data, such as your age, geographic location, occupation, education level, and years of experience.   We have a legitimate interest in understanding our users and potential customers, partners, and vendors  better.  
Email Interactions  If you receive email from us, we may use tools to capture when you open our message or click on links or banners in it.  We have a legitimate interest in understanding how you engage with our messages. 
Feedback/Support  If you provide feedback or contact us for support, we collect your name and email, as well as other content that you send.  We have a legitimate interest in receiving and acting upon feedback. 
Job Applicants  If you apply for a job, we collect information needed to process your application. This may include, among other personal data, your social security number. Providing this information is required for employment.  In some contexts, we are required by law to collect personal data about our job applicants. We also have a legitimate interest in using personal data to evaluate your application or consider you for other positions. If you become an employee, you will be subject to different privacy policies that relate to  how we collect, use, and share additional personal data about our employees. 
Mailing List  When you sign up for our mailing lists, we collect your contact information.   We have a legitimate interest in sharing information about our services.  Where required by law we will ask for your consent before communicating with you. 
Partner Promotion  We collect personal data that you provide as part of co-branded promotions with other companies.  We have a legitimate interest in fulfilling our promotions. Note that many co-branded promotions involve the collection of personal data by us, and the other company identified in the promotion.  Where personal data is jointly collected, your information may be submitted, or sent, to both companies.  This Policy applies to our use of your personal data.  You should review the privacy policy of the other company identified to understand their use of your personal data. 
Surveys  We collect personal data you share through surveys. If a third-party offers a survey, the third party’s privacy policy also applies to the collection, use, and disclosure of your personal data.  We have a legitimate interest in understanding your opinions. 
Use of Our Website    We use technology (e.g., a cookie or a pixel) to learn how you engage with our Website and other Services. This may include the links you click or the information you type into our online forms. We may also track your IP address, the Website that referred you to us, and personal data about your device.   We have a legitimate interest in making our Website and other Services operate. We also use it to understand how you interact with our Website and other Services, gather analytics, improve our Website and other Services, and learn your preferences. We may also use this personal data to help detect and prevent fraud.  Where required by law, we base the use of technologies upon consent. 

 
Website Targeted Advertising Technology  We may let third parties place tracking technology on our Website and other Services (e.g., a cookie or a pixel). The third party might also collect personal data over time and across other websites. Among other things, they may use this personal data to serve ads tailored to your interests, which may include ads about our services.    Where required by law, we base the use of third-party tracking technologies upon consent. You can also find more information about your options with regard to this technology in the Your Choices section below. 

 

How We Use Personal Data 

We also use personal data to:  

  • Identify you when you visit our Website or the Services;  
  • Improve or create services; 
  • Conduct analytics; 
  • Connect with you (e.g., addressing your requests, inquiries, issues, or feedback);  
  • Respond to your application for employment;  
  • Market our Services; 
  • Market the services of our business partners; 
  • Find and prevent malicious, deceptive, fraudulent, or illegal activity; 
  • Find and prevent security incidents;  
  • Enforce our policies and agreements; 
  • Debug, find, and fix errors that impair our Website and other Services; 
  • Comply with legal or regulatory obligations;  
  • Establish or exercise our rights; 
  • Defend against legal claims; 
  • Manage our relationships; 
  • Offer additional services and augmented experiences; and 
  • For other reasons with your consent. 

The sections above describe our main purposes in collecting your personal data, but often we have multiple purposes. For instance, we may collect your information to perform our contract with you. We also have a legitimate interest in maintaining that personal data so that we can easily address questions about your projects or the services you have elected to purchase from us. As a result, our collection and processing of your personal data is based in different contexts on your consent, our need to perform a contract, our legal obligations, and/or our legitimate interest in conducting our business. If you access or use additional services, integrations, or features made available through our Website or other Services – by way of example, our augmented services designed to generate analyses and business insights through the use of proprietary methodologies interacting with third-party artificial intelligence tools (“Augmented Services”) – your personal data may be processed as necessary to enable and deliver those services. These services, and any personal data you submit, upload or transmit through those services, may be subject to additional terms and conditions, including third party terms and conditions, policies, and procedures over which we have no responsibility or control. Where applicable, we will provide you terms and conditions governing such services and, if required by law, we will provide you a clear notice and obtain your consent before enabling any such service.  

To the extent we store and use deidentified personal data, we will not try to reidentify the information, except to test our deidentification methods. 

How We Share Personal Data 

In addition to the specific situations discussed elsewhere in this Policy we may share personal data in the following situations:  

  • Affiliates and Acquisitions. We may share personal data with our affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If a company acquires or enters negotiations to acquire, our company, business, or assets, we may share personal data with that company.  
  • Other Disclosures without Your Consent. We may share personal data to cooperate with law enforcement, participate in a legal process, or for legal compliance. We may share your personal data to establish or exercise our rights, to defend against legal claims, to investigate, prevent, or act on possible illegal activities, threats to safety of person or property, or a violation of our policies.  
  • Public. Our Website or Services may allow for comments or reviews in a public forum. If you post on these pages, what you share may be publicly available.  
  • Service Providers. We may share your personal data with service providers. Service providers may help us to run our Website or Services, conduct surveys, provide technical support, process payments, fulfill orders, and more. 
  • Professional Services. We may share personal data with our professional service providers, such as auditors or lawyers. 
  • Other Disclosures with Your Consent. We may share your personal data with third parties when you consent or direct us to.  

Some jurisdictions require us to disclose whether the following categories of personal data are collected, shared with third parties for a “business purpose,” or “sold,” or transferred for “valuable consideration.”  The table below indicates the categories of personal data we collect and transfer in a variety of contexts.  We do not “sell” your personal data for money.  We also do not collect, “sell’ or “share” any sensitive personal data as those terms are defined by applicable laws. 

Category of Personal Data  Category of Recipients 
Disclosures for a
Business Purpose 		 Sharing for Targeted Advertising  Sales   
Identifiers – this may include things like name, alias, postal address, unique personal identifier, online identifier, email address, or account name. 
  • Affiliates or subsidiaries. 
  • Business partners. 
  • Data analytics providers. 
  • Internet service providers. 
  • Other Service Providers. 
  • Professional services organizations, which may include auditors and law firms. 
  • Social networks. 
  • Others, as required by law 
  • Advertising networks. 

 

 N/A 
Government Issued Identification – this may include things like social security number, driver’s license number, or state issued identification number. 
  • Affiliates or subsidiaries. 
  • Other Service Providers. 
  • Professional services organizations, which may include auditors and law firms. 
  • Others, as required by law 
 N/A  N/A 
Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc. 
  • Affiliates or subsidiaries. 
  • Other Service Providers. 
  • Professional services organizations, which may include auditors and law firms. 
  • Others, as required by law 
 N/A  N/A 
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 
  • Affiliates or subsidiaries. 
  • Other Service Providers. 
  • Professional services organizations, which may include auditors and law firms. 
  • Others, as required by law 
  • Advertising networks. 

 

 N/A 
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, app, or ad. 
  • Affiliates or subsidiaries. 
  • Business partners. 
  • Data analytics providers. 
  • Internet service providers. 
  • Other Service Providers. 
  • Professional services organizations, which may include auditors and law firms. 
  • Social networks. 
  • Others, as required by law 
  • Advertising networks. 

 

 N/A 
Geolocation data – this could include precise or non-precise geolocation information. 
  • Affiliates or subsidiaries. 
  • Other Service Providers. 
  • Professional services organizations, which may include auditors and law firms. 
  • Others, as required by law 
 N/A  N/A 
Audio, electronic, visual, thermal, olfactory, or similar information 
  • Affiliates or subsidiaries. 
  • Business partners. 
  • Data analytics providers. 
  • Data brokers. 
  • Internet service providers. 
  • Operating systems and platforms. 
  • Other Service Providers. 
  • Payment processors and financial institutions. 
  • Professional services organizations, which may include auditors and law firms. 
  • Social networks. 
  • Others, as required by law 
 N/A  N/A 
Professional or employment-related information – this includes, for example, information submitted by job applicants. 
  • Affiliates or subsidiaries. 
  • Other Service Providers. 
  • Professional services organizations, which may include auditors and law firms. 
  • Others, as required by law 
 N/A  N/A 
Non-public education information (as defined in the Family Educational Rights and Privacy Act) 
  • Affiliates or subsidiaries. 
  • Other Service Providers. 
  • Professional services organizations, which may include auditors and law firms. 
  • Others, as required by law 
 N/A  N/A 
Inferences drawn from any of the information listed above  
  • Affiliates or subsidiaries. 
  • Other Service Providers. 
  • Professional services organizations, which may include auditors and law firms. 
  • Others, as required by law 
 N/A  N/A 
Additional categories of personal data described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics, or description, insurance policy number. 
  • Affiliates or subsidiaries. 
  • Other Service Providers. 
  • Professional services organizations, this may include auditors and law firms. 
  • Others, as required by law 
 N/A  N/A 

 

Your Choices 

Some jurisdictions give you a right to make the following choices: 

  • Access. You may request access to your personal data or confirmation that we have personal data about you. In certain limited cases, you may ask to receive access to your data in a portable, machine-readable form.  
  • List of Third-Party Recipients. You may request a list of specific third parties to which we have disclosed personal information. Some areas also allow you to obtain a list of the categories of third parties to which we have disclosed personal information. You can find that information in the table above under the “How We Share Personal Data” section. 
  • Change. You can ask us to correct inaccurate or incomplete personal data by contacting us at the email address below. We may keep historical personal data in our backup files as permitted by law. 
  • Deletion. You may ask us to delete your personal data and/or otherwise make the data inaccessible. If required by law, we will grant such a request, but note that in many cases, we must keep your personal data to comply with legal obligations, resolve disputes, enforce agreements, or for other business purposes.  
  • Opt-out of Website Targeted Advertising. You may opt-out of online targeted advertising (e.g., cookies) by clicking the cookie settings link here. Note that if you change browsers or devices, or if you clear your browser’s cache, you may need to click the link again to apply your preference. We recognize Global Privacy Control (GPC) signals broadcast from web browsers as a valid opt-out request where required by applicable law. Please note that the GPC will apply only to your current browser. We do not recognize the “Do Not Track Signal.” If there is a conflict between the GPC signal and a manual choice that you have made on our Website regarding targeted advertising, we will honor your manual choice.  
  • International Obligations. Where required by law or in jurisdictions such as the United Arab Emirates and the Kingdom of Saudi Arabia, we will not process sensitive personal data (such as religious affiliation, health information, or biometrics) without your explicit consent. 
  • Objection to or Restriction of Certain Processing. In certain circumstances, you may object to the processing of your personal data, or ask that we restrict processing of your personal data. To do so, follow the instructions below under Submitting Requests.  
  • Promotional Emails. You may provide us with your email address to allow us to send newsletters, surveys, offers, or other promotional content, as well as targeted offers from third parties. You can stop receiving such emails by following the unsubscribe instructions at the bottom of those emails. If you choose not to receive such emails, we may still send you service-related communications.  
  • Promotional Text Messages. If you get a text message from us that has promotional content, you can opt-out of future text messages by replying “STOP.” 
  • Revocation Of Consent. Where we process your personal data based upon consent, you may revoke consent. Note, if you revoke consent for processing personal data, we may no longer be able to provide you some types of services. 
  • Jurisdiction-Specific Choices: Depending on your location, you may have additional rights under the laws of your jurisdiction. You may contact us at privacyinquiries@consertus.com to exercise those rights or to obtain more information.  

Not all the rights above are absolute, and they do not apply in all circumstances. We may limit or deny a request because the law permits or requires us to. We will not discriminate against individuals who exercise a privacy right. 

Submitting Requests 

You may exercise the above rights by contacting us via the contact information below. If you disagree with our denial of a request, you may appeal our decision by contacting us with the subject line “Appeal.”  

We will require you to prove your identity when making most types of requests. We may verify your identity by phone or email. Depending on your request, we will ask for information such as your name, and we may also ask you to send us a signed declaration confirming your identity. 

In some circumstances, you may designate an authorized agent to exercise rights on your behalf. To do so, you must provide that authorized agent written and signed permission to submit the request on your behalf and verify your own identity directly with us. Note that we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. 

How We Protect and Retain Personal Data 

No method of internet transmission or electronic storage is fully secure. While we use reasonable efforts to protect personal data, we cannot guarantee its security. If we are required to inform you about a security incident, we will do so electronically, in writing, or by phone, as the law permits. 

Our Website and Services may permit you to create an account. You are responsible for selecting a unique and complex password and keeping it confidential.  You are responsible for any access to or use of your account by someone who has obtained your password, whether or not you approved of such access or use. Notify us of unauthorized use of your password or account immediately. 

We keep your personal data for only as long as necessary to fulfil the purposes in this Policy unless a longer retention period is required or permitted by law. This includes the purposes of satisfying legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data. We also weigh the potential risk of harm from unauthorized use or disclosure of the personal data, the purposes for which we obtained the personal data and whether we can meet those purposes through other means, as well as applicable legal requirements. 

Where we provide services in connection with federally funded projects, we may be subject to additional safeguarding obligations under applicable federal regulations. If you have any questions regarding these obligations, you may contact us at privacyinquiries@consertus.com.  

Transmission Of Personal Data To Other Countries 

By submitting your personal data to us you acknowledge that we may transfer, store, and process your personal data in a country other than your country of residence including, but not limited to, the United States. For more information on our attempts to apply the privacy principles applicable in one area to data when it goes to another, contact us using the contact information below. You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the European Economia Area (“EEA”) or UK, which include the categories of information transferred by contacting us using the contact information below. If you are located outside of the United States, the EEA, and the UK, we may transfer your personal data outside your jurisdiction to countries that may not have the same level of data protection. In such cases, we will use commercially reasonable efforts to implement safeguards to protect your personal data, such as contractual clauses or regulatory approvals where required. 

Third-Party Applications/Websites 

We may provide links to websites and other third-party content or services that we do not own or operate. We have no control over the privacy practices of websites or services we do not own. For details about such third parties’ privacy practices, see their privacy notices. 

Changes To This Policy 

We may change this Policy and privacy practices.  Updates to this Policy will be published on our Website.  If changes are material, the Policy that was in place when you submitted personal data to us will generally govern that data unless you consent to the new Policy. Our Policy shows the date of last update above.  

Contact Information 

If you have questions, comments, or complaints on our privacy practices, or if you need to access this Policy in a different form due to a disability, please contact us at privacyinquiries@consertus.com. We will try to address your requests and provide you with additional privacy-related information. If you are not satisfied with our response and are in a country outside of the United States, you may have a right to lodge a complaint with the relevant data protection authority in your country.  

 

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