Effective Date: March 1, 2024

Last Updated: March 1, 2024

At Cerebrum Strategic Advisors, we are committed to providing you with the best possible online experience using our products and services while maintaining your privacy. To that end, Cerebrum Strategic Advisors has adopted the following cerebrumadvisors.com Privacy Policy (the “Policy”) to demonstrate our firm commitment to protecting user privacy and sensitive user information. Please note that other Cerebrum Strategic Advisors websites or mobile apps, such as CerebrumFinancialEducation.com, may have separate privacy policies, which are available at the corresponding login page where personally information may be requested.

Purpose

The purpose of this Policy is to provide you, as Cerebrumadvisors.com visitor, with a complete description of what information we collect, how we use that information, and how you can access or correct your information. This Policy applies to all information collected or submitted on this website, kellybenefits.com, and any subdomains (the “Site”). This Policy is available on the homepage of the Site and at any login page on the Site where personally identifiable information may be requested. Use of the Site is also subject to the Cerebrumadvisors.com Terms of Use.

Commitment to Security and Privacy

Your privacy, and the privacy of the information provided, is important to us. We use reasonable care to protect your data from loss, misuse, unauthorized access, disclosure, alteration and untimely destruction. We grant access to personal information about you only to our employees, agents, affiliates and service providers so they can provide you with the necessary online services and support.

Information Collection and Use

What information is collected?

We limit the collection of personal information to the information that we need to administer and improve the Site, to provide our services to our customers, and to fulfill any legal and regulatory requirements. The type of information gathered by Cerebrum Strategic Advisors is entirely dependent upon your use of the Site.

There are three main types of information gathered by Cerebrum Strategic Advisors on the Site: (1) Visitor Profile Data, (2) Registration Information, and (3) Personal Data.

Visitor Profile Data.

When you visit the Site, Visitor Profile Data, such as your computer’s unique Internet protocol (IP) address, domain name, and the address of the website you came from upon visiting the Site, may be automatically collected to help us provide better services and a more effective Site. Visitor Profile Data is gathered on an aggregate, anonymous basis, meaning no personally identifiable information is associated with it and thus does not contain information that individually identifies a visitor.

Registration Information.

Although registration may not be required to use general portions of the Site, in order to visit certain areas of the Site, or to use certain services, you may be asked to provide Registration Information, such as your name, company name and email. If you decline to provide this requested information, our ability to serve you may be limited.

Personal Data.

Personal information means personally identifiable information about an individual collected online. The Site only collects the personal information that you provide voluntarily.

How is aggregated, non-personal information used?

Cerebrum Strategic Advisors may use general, non-personal, statistical information from a Visitor’s Profile to determine information regarding the use and security of the Site and general information about our customers and their viewing preferences. Cerebrum Strategic Advisors may use this information in marketing to registered users, improving, or customizing the content of the Site for a visitor, or directing certain type of information to a particular visitor. Cerebrum Strategic Advisors may share aggregate profile information (without personal data) with third parties.

How is Personal Information Used?

We use the information provided by you on the Site to perform service requests and send you information related to Cerebrum Strategic Advisors services. Cerebrum Strategic Advisors does not use or share the provided to us in ways unrelated to the ones described in this Policy without also providing you with an opportunity to opt-out or otherwise prohibit such unrelated uses. Cerebrum Strategic Advisors does not sell or rent your personally identifiable information.

Mode and Place of Processing User Information

The processing of user information is carried out using computer and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated in this Policy. In some cases, user information may be accessible to certain types of persons involved with the operation of the Site (administration, sales, marketing, legal, and/or system administrators) or appointed external parties (such as third-party technical service providers, and/or hosting providers), if necessary.

User information provided via the Site is processed at Cerebrum Strategic Advisors’ operating offices and in any other places where the parties involved with the processing are located.

Security

Secure Transmissions

Please be assured that the Site is equipped with security measures to protect the information you provide us. Cerebrum Strategic Advisors processes user information in a proper method and takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of personal identifiable information.

Personal identifiable information collected by Cerebrum Strategic Advisors from our users, information generated by cookies, Google Analytics, LinkedIn, Facebook by Meta and any third-party personally identifiable information provided by our users are stored in electronic logs behind a firewall and can be accessed only by approved Cerebrum Strategic Advisors personnel through password-protected administration sites. All Cerebrum Strategic Advisors personnel that have access to personal identifiable information are made aware of current security practices through regular cybersecurity and data privacy training.

Protection of Personal Identifiable Information

The personal identifiable information that you provide to us via the Site will not be shared or transferred to unrelated third parties without your prior consent, unless it is required by law or judicial order, or directly related to the services requested. If you supply personal identifiable information through an associated or affiliated website, the associate or affiliate may also have access to such information as allowed by law.

Protection of Email Addresses

Cerebrum Strategic Advisors does not share email addresses provided via the Site with unrelated third parties.

Cookies

Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page.

We may collect information about your computer, including your IP address, operating system and browser type, for system administration and in order to create reports. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

Third Party Personally Identifiable Information

Cerebrum Strategic Advisors may request that brokers or small businesses submit census data regarding the prospective covered employees in order to use rate quoting functions. Census data may consist of the prospective beneficiary’s name, gender, birth date, zip code of residence and workplace, marital status, and number of children. In addition, Cerebrum Strategic Advisors may request that brokers provide certain information about the medical condition of prospective beneficiaries that will be used in generating the requested rate quotations.

This information may be used for the purpose of generating rate quotations at the request of the broker or small business. This information is not shared with any unrelated third-party, except when requests are sent by the user for rate quotes. Upon request, Cerebrum Strategic Advisors may retain a completed rate quotation incorporating the census data described above for further access by the requesting party.

You are responsible for any personal information shared through use of the Site that belongs to a third-party. By sharing such personal information through use of the Site, you confirm that you have the third party’s consent to provide such personal information to Cerebrum Strategic Advisors.

Compliance

Information from Children

The Site is a general audience website that is not targeted to children under the age of 13 and complies with the Children’s Online Privacy Protection Act of 1998, 15 U.S.C. 6501-6505 (“COPPA”). The Site does not knowingly collect personally identifiable information from children under the age of 13. In order to comply with COPPA, we ask that you not provide personally identifiable information to us if you are under the age of 13. We urge parents and guardians to supervise their children’s website browsing.

Company Information

When you as a company representative request information about services on the Site, we ask that you give us your company name, address, and phone number. We use this information to contact you and provide you with the materials that you have requested.

Questions About Your Personal Data

Cerebrum Strategic Advisors is committed to transparency. We want individuals to understand how we collect and use personal data so they may interact with Cerebrum Strategic Advisors and our clients with confidence. The materials provided on this webpage may help you find the information you need about privacy at Cerebrum Strategic Advisors. If you have any questions related to the content of this webpage, please contact our Privacy Officer by completing the contact form on this page. As an employee of a Cerebrum Strategic Advisors client, please reach out to your employer for more information regarding the collection and processing of your personal data.

Right to Contact User

We may use your personal information to communicate with you if you have provided us the means to do so. For example, if you have given us your email address, we may send you promotional email offers regarding new services or products that become available or email you about your use of our services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. You may opt-out of receiving any, or all, of these communications from us as follows: Opt-Out Right to Contact User.

Opt-Out Procedures

Users have the option to opt-out of receiving communications from Cerebrum Strategic Advisors. In order to opt-out of future communications or to modify current contact settings, please complete the form as follows: User Opt-Out Procedures.

Accessing and Correcting Your Information

Keeping your information accurate and up to date is very important. You can review or correct your account information by contacting a customer service representative at Cerebrum Strategic Advisors. If you are a registered user, you can make changes to your account information after you log in to the Site. Please note that some information changes must be done through your employer.

Site Privacy Contact Information

For questions about your privacy while using this Site, please use our “Contact Us” page. Please do NOT include any private health information in your email to us (this would include your Social Security number, financial information or health conditions).

Other Sites

At times, we may provide you with links to other websites operated by third parties. This Policy extends to this Site only and the information collected by this Site. We encourage our users to be aware when they leave our Site, and to read the privacy statements of third-party websites to determine its website practices. Please be aware that Cerebrum Strategic Advisors is not responsible for the privacy practices of other websites.

Personal Data Retention and Retention Schedule

Any personal data, that you provide, will be transmitted, retained, and stored by a third-party provider, SiteGround.com, for the period necessary to fulfill the purposes described in this Policy unless a longer retention period is permitted by law.

Your Privacy Rights

Protecting the privacy of our clients and users of our Site is important. Our Privacy Policies describe how we use and protect the personal information provided to us. We may change or update our Privacy Policies from time to time. When we do, we will post the revised Policies on this page and website with a new “Last Updated” date.

California Consumer Privacy Act (CCPA)

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), Cerebrum Strategic Advisors and any affiliate(s), are providing the following privacy statement as required under California law, which provides specific disclosures to residents of California about how we treat personal information that may be collected through our website where this Policy is posted.

Nevada Privacy Rights

Cerebrum Strategic Advisors may collect personal information from you in the course of providing requested services. Unless otherwise stated, Cerebrum Strategic Advisors does not sell any personally identifiable information, as defined under Nevada law (S.B. 220). If you would like to make a further inquiry regarding your information, as defined under Nevada law, please contact our Privacy Officer on this page.

Changes to Policies

Our policies can change. If we do change them, we will note the date of the last change. We recommend that you check this page periodically to see if information has changed since your last visit. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we would notify users by way of email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

Cerebrum Strategic Advisors can be contacted regarding the Site by mail at:

Cerebrum Strategic Advisors

Attn: Privacy Officer

16 Campus Blvd., Suite 175A

Newtown Square, Pennsylvania 19073

Additionally, you may reach us via telephone at 215.376.5601, or completing the form on this page. Please do NOT include any sensitive information in your message to us (this would include your Social Security number, financial information or health conditions).