Privacy Policy

Last updated March 4, 2025

1. Who we are

Computer Generated Solutions, Inc. (hereinafter “CGS”, “we, “us” or similar) is a company, with its principal office at 200 Vesey Street, New York, NY 10281-1017, United States of America. We collect and process several categories of personal data from you as a user of the www.cgsinc.com, the website for our Cicero product, and any other related websites (hereinafter the “Websites”). We are a controller with regard to the data we process.

We take your privacy extremely seriously and this Privacy Policy describes our practices regarding our collection and use of your personal data – such as what data we collect, why we collect it, and what we do with it, and sets forth your privacy rights.

Please read this Privacy Policy carefully to understand how we handle your personal information.

2. How we collect your personal data

Personal Data may be collected or accessed in a number of ways, including:

directly from you (from your form input data on the Websites);
automatically you navigate on the Websites (cookies, tracking pixels, analytics, etc.); or
through a third party, such as Google or Marketo.

2.1 Data provided by you directly

Personal data that is voluntarily provided by visitors may be collected through the Websites. Our Websites use forms by which you may contact us, apply as a candidate for employment, subscribe to our newsletter or access documentation provided on our Websites (e.g. whitepapers or product information), and logins that allow you to access our products. To utilize these features, you may need to complete fields such as name, email address, phone number, position held at your company. Also, you may voluntarily submit personal data to us by providing additional information (not requested by us) in such forms or via your comments on our blog sections of the Websites.

Such personal data you provide us is processed by us based on our legitimate interest and/or to fulfill our contractual obligation to you and will be used to respond to your inquiry and/or to keep a record of your complaint, accommodate a request, and facilitate your access to our products and services. This data is stored as required by law or regulation.

We do not use your data to send you marketing communications unless you expressly opt in for such communication. Even in such cases, we make sure that you have an easy-to-use option to unsubscribe (withdraw your consent) at any time, either in the communication itself or by contacting us as indicated in Section 8 below.

2.2 Use of the Websites

The Websites collect certain information automatically and store it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the Internet, browser type, operating system and other usage information about the use of the website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our Websites, analyze trends, track visitor movements and gather broad demographic information that assists us in identifying visitor preferences. Our Websites also use cookies and web beacons, about which you can read below.

On each subsequent visit to the Websites, the browser searches for cookies. If the browser finds cookies, it sends the information stored by the cookie to the Websites. The Websites download cookies onto your computer, tablet or mobile phone which are strictly necessary for the functioning of the Websites, such as cookies which ensure that you can retrieve information on the Websites quickly, and cookies which are strictly necessary to provide a service which has explicitly been requested by you, such as a cookie which remembers your cookie settings. To download cookies which are not strictly necessary, such as cookies for gathering statistical information, CGS needs your prior consent.

If you have adjusted your cookie settings so that websites are not permitted to place cookies on your computer, the Websites may not be able to download the cookie which remembers whether or not you consented to the placing of cookies. If so, you will be asked to indicate your cookie preferences each time you visit the Websites. If you do not wish to be asked about your cookie preferences each time you visit the Websites, you need to adjust your browser’s cookie settings.

2.3 Categories of Information Collected

We collect the following categories of personal information for the purposes described below:

Identifiers (including name, contact, and other identification information)
- We use this information to manage your account, to communicate with you, and to connect you with potentially relevant products and services.
Commercial information (including records of products purchased)
- We use this information to manage your account.
Internet or other electronic network activity information (IP address, cookies, pixels, and analytics data)
- We use this information to connect you with potentially relevant products and services as well as to optimize the performance of our website and analyze how visitors arrive at the website, and what type of content is most popular.

3. How we share information

We will disclose your personal data only for the purposes and to those third parties, as described below. We will take appropriate steps to ensure that your personal data are processed, secured, and transferred according to applicable law.

3.1 Disclosure to CGS group companies

Your personal information may be shared with any company that is a member of our group, where we consider that it is in our legitimate interests to do so for internal administrative purposes (e.g. storage of data, CRM), or for auditing and monitoring of our internal processes.

We may also share your personal information with our group companies where they provide products and services to us, such as information technology systems.

Access to your personal information is limited to our group’s employees who need to know the personal information, and usually include employees in the marketing, information technology, human resources, and security departments.

3.2 Disclosure to third parties

We may share the strictly necessary parts of your personal data, on a need-to-know basis with the following categories of third parties:

(a) companies that provide products and services to us (processors), such as:

media agencies, such as those organizing promotional campaigns and those administering the Websites;
website services for analytics, advertising;
infrastructure agencies (other parties that handle the email newsletter, SMS marketing or other kinds of marketing, client support or sales activities in our name); or
information technology systems suppliers and support, including email archiving, telecommunication suppliers, back-up and disaster recovery and cyber security services.

(b) companies involved in the operation of our Websites, where they are not providing a service for us.

(c) other parties such as public authorities and institutions, accountants, auditors, lawyers and other outside professional advisors, where their activity requires such knowledge or where we are required by law to make such a disclosure.

We may also disclose your personal information to third parties:

(a) if you request or authorize us to do so;

(b) if individuals have demonstrated legal authority to act on your behalf;

if we sell any business or assets related to the Website you are subscribing to, we may disclose your personal information to the prospective buyer of such business or assets, in order to ensure that the activity continues as a going concern; or
if CGS or substantially all of its assets are acquired by a third party, in which case personal information held by CGS will automatically be one of the transferred assets;

(d) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;

(e) to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or

(f) to protect the rights, property or safety of CGS, our employees, customers, suppliers or other persons.

3.3 Restrictions on use of personal information by recipients

Any third parties with whom we choose to share your personal information pursuant to the above are limited (by law and by contract) in their ability to use your personal information for the specific purposes identified by us. We will always ensure that any third parties with whom we choose to share your personal information are subject to privacy and security obligations consistent with this Privacy Policy and applicable laws. However, for the avoidance of doubt, this cannot be applicable where the disclosure is not our decision.

Except as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, if applicable, obtaining your consent.

4. Provisions applicable for persons in the European Union or United Kingdom

4.1 Processing of information outside of the EU and UK

Because we are a company in the USA, information that you provide to us flows directly to the United States and we process your personal data outside of the European Union or the United Kingdom. That personal information will be processed by staff operating outside the European Union or United Kingdom working for us, other members of our group, or third-party data processors for the purposes mentioned above.

Where your personal data is transferred to other entities as mentioned above, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy.

Further details on the steps we take to protect your personal information in these cases is available from us on request by contacting us at any time (please see Section 8 below).

4.2 Your rights

Individuals in the European Union or United Kingdom may have specific legal rights relating to the personal data we collect from you. We will respect your individual rights and will deal with your concerns adequately.

(a) Right to withdraw consent: Where you have given consent for the processing of your personal data, you may withdraw your consent at any time.

(b) Right to rectification: You may obtain from us rectification of personal data concerning you. We make reasonable efforts to keep personal data in our possession or control which are used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us. In appropriate cases, we provide self-service Internet portals where users have the possibility to review and rectify their personal data.

(c) Right to restriction: You may obtain from us restriction of processing of your personal data, if:

you contest the accuracy of your personal data, for the period we need to verify the accuracy;
the processing is unlawful, and you request the restriction of processing rather than erasure of your personal data;
we do no longer need your personal data, but you require them for the establishment, exercise or defense of legal claims; or
you object to the processing while we verify whether our legitimate grounds override yours.

(d) Right to access: You may ask us for information regarding personal data that we hold about you, including information as to which categories of personal data we have in our possession or control, what they are being used for, where we collected them, if not from you directly, and to whom they have been disclosed, if applicable.

We will provide you with a copy of your personal data upon request. If you request further copies of your personal data, then we can charge you with a reasonable fee that we base on the administrative costs.

(e)Right to portability: You have the right to receive your personal data that you have provided to us, and, where technically feasible, request that we transmit your personal data (that you have provided to us) to another organization.

You have these two rights if:

we process your personal data by automated means;
we base the processing of your personal data on your consent, or our processing of your personal data are necessary for the execution or performance of a contract to which you are a party;
your personal data was provided to us by you; and
the transmission of your personal data does not adversely affect the rights and the freedoms of other persons.

You have the right to receive your personal data in a structured, commonly used and machine-readable format.

Your right to receive your personal data must not adversely affect the rights and the freedoms of other persons. This may be the case if a transmission of your personal data to another organization also involves the transmission of the personal data of other (non-consenting) individuals.

Your right to have your personal data transmitted from us to another organization is a right you have if such transmission is technically feasible.

(f) Right to erasure: You have the right to request that we delete the personal data we process about you. We must comply with this request if we process your personal data, unless the data is necessary:

for exercising the right of freedom of expression and information;
for compliance with a legal obligation that binds us;
for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
for the establishment, exercise or defense of legal claims.

(g)Right to object: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing or for the establishment, exercise or defense of legal claims. If you object to the processing, please specify whether you also wish the erasure of your personal data, otherwise we will only restrict it.

You may always object to the processing of your personal data for direct marketing that was based on our legitimate interest, regardless of any reason. If the marketing was based on your consent, you can withdraw consent.

(h)Right to lodge a complaint: You can lodge a complaint to the data protection authority in your state or to the data protection authority in Romania:

Name: Autoritatea Nationala de Supraveghere a Prelucrarii Datelor cu Caracter Personal
Address: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, cod postal 010336, Bucuresti, Romania
Telephone: +40.318.059.211, +40.318.059.212
Fax: +40.318.059.602
Email: [email protected]

Please note:

Time period: We will try to fulfill your request within 30 days, which may be extended due to specific reasons relating to the specific legal right or the complexity of your request. In all cases, if this period is extended, we will inform you about the term of extension and the reasons that led to it.

Restriction of access: In certain situations, we may not be able to give you access to all or some of your personal data due to statutory provisions. If we deny your request for access, we will advise you of the reason for the refusal.

No identification: In some cases, we may not be able to look up your personal data due to the identifiers you provide in your request. In such cases, where we cannot identify you as a data subject, we are not able to comply with your request to execute your legal rights as described in this section, unless you provide additional information enabling your identification. We will inform you and give you the opportunity to provide such additional details.

Exercise your legal rights: In order to exercise your legal rights, please contact us in writing (including electronically) at the contact details provided in Section 8 below.

5. Certain State Privacy Rights

Residents of certain U.S. states have unique rights available to them under state data privacy laws. Depending on your residency, you may have the following rights:

Right to Access

You may have the right to request that we disclose the categories of personal information collected, the categories of sources from which personal information is collected, the business or commercial purpose for collection, the categories of third parties with which we share personal information, and the specific pieces of personal information that we have about you. You also may have the right to request that we provide your personal information to you in a readily useable format.

Right to Request Deletion

You may have the right to request that we delete personal information that we collected from you. Note, however, that certain requests to delete personal information may be denied if we are required to retain the information as a matter of law, the information is necessary for detecting security incidents, exercising free speech, protecting or defending against legal claims, or for internal uses reasonably aligned with consumer expectations. Records reflecting purchase histories cannot be deleted.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for exercise of these privacy rights. We do not offer financial incentives related to the provision of data.

Authorized Agent

You may have the right to designate an authorized agent to make these requests on your behalf.

To exercise any of these rights, please contact us at [TOLL FREE NUMBER] or [EMAIL ADDRESS]. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.6. Security

CGS is committed to protecting personal information from loss, misuse, disclosure, alteration, unavailability, unauthorized access and destruction and takes all reasonable precautions to safeguard the confidentiality of personal information, including through use of appropriate organizational and technical measures. Organizational measures include physical access controls to our premises, staff training and locking physical files in filing cabinets. Technical measures include use of encryption, passwords for access to our systems and use of anti-virus software.

In the course of provision of your personal data to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information between you and us over the internet is not completely secure. As such, we cannot guarantee the security of your personal information transmitted to us over the internet and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it.

6. Security

7. Changes to our Privacy Notice

We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this privacy notice at any time. For this reason, we encourage you to refer to this privacy notice on an ongoing basis. This privacy notice is current as of the date which appears at the top of the document. We will treat your personal data in a manner consistent with the privacy notice under which they were collected, unless we have your consent to treat them differently.

8. Contact information

Please direct your questions regarding the subject matter of data protection and any requests in the exercise of your legal rights to the following contact details:

New York City - Headquarters
200 Vesey Street, Brookfield Place
27th floor
New York, NY 10281
Phone: (315) 849-5491
E-mail: [email protected]

We will investigate and attempt to resolve any request or complaint regarding the use or disclosure of your personal information.

If you are not satisfied with our reply and you are from the European Union, you may also make a complaint to the data protection authority, as indicated in section 4.2(h) above.