Mr. Christopher Wolf Crutcher (referred to herein as “I,” “me,” “Christopher Wolf Cruther,” or “Mr. Crutcher,” describes, in this privacy policy (the “Privacy Policy”), how he collects, uses, and handles your personal information when you use his personal website (the “Website”), inclusive of any software, products, and services (altogether, the “Services”).
I collect and use the following information to provide, improve, and protect my Services:
Account information: I collect, and associate with your account, the information you provide to me when you do things such as sign up and/or contract with me for any of my Services, including, but not limited to: personally delivered Consulting Services, upgrades to service plans, and authentication set-up (such as your name, e-mail address, phone number, payment info, and physical address). Some of my Services let you access your accounts and your information via other service providers (for example, an internet service provider).
Your Items: My Services (whether extant or delivered in future) are or will be designed to make it simple for you to pay for said Services (collectively: “Your Items”), utilizing cryptocurrencies (including GMU’s) or various fiat currencies, as well as accessing Empire Group’s “Virtual Safes™” (via lease). To make that possible, I will store, process, and transmit Your Items, as well as all information related to them, into and throughout Empire Group’s private blockchain-protected servers. This related information includes things such as the size of the file, the time it was uploaded, the type and nature of the item (and its designated value), and usage activity, as well as applicable information that identifies Your Items on the blockchain and/or within your Virtual Safe™, as applicable, as well as information related to or arising from providing service to your account (once generated).
When you use the Services, you hereby consent to my limited rights to use your data to enable me to offer the Services. Your permissions include the hosting of your data, backing it up as necessary, and sharing it when you ask me to do so. The Services may also require the systems to which I have access, via contract, to access, store, and scan your data. You hereby give me permission to do those things, and this permission extends to my affiliates, and to the trusted third parties with whom I work
Usage information: I collect information related to how you use the Services, including actions you may take in your account (including, but not limited to: viewing transactions; and moving items). I use this information to: provide and improve my Services; develop new services and features; undertake legitimate business activities related to the Services; monitor my network; and protect all of my end-users.
In addition to account registration information, I may ask you for information at other times, for example, when you ask questions or report a problem with my Services. In the event you contact me, I may keep a record of that session or correspondence. I may also occasionally ask my customers to complete surveys for research purposes. Collecting information contained in transmissions made through the Services is necessary to provide the highest level of service. My detailed business records are also used for accounting purposes, account billing, and providing my customers with information pertaining to the Services.
Device information: I also collect information from and about the devices you use to access the Services. This includes items such as IP addresses, the type of browser and device you use, the web page you visited before coming to my Personal Website, and the identifiers associated with your devices. Said devices (depending on their settings) may also transmit location information to the Services.
Cookies and Other Technologies: I use technologies like cookies and pixel tags to provide, improve, protect, and promote my Services. For example, cookies help me with tasks such as remembering your username for your next visit, understanding how you are interacting with my Services, and improving them based on that information. You can set your internet browser to not accept cookies, but this may limit your ability to use the Services.
Note: The end-user’s account information is unique to each customer, and password protected, so that (other than any of my personal staff or consultants who have an administrative need to know) only you will have access to this information.
Marketing: I will, from time to time, send you information about upgrades or new services, when permissible. End-users who receive these marketing materials can opt out at any time. If you do not want to receive marketing materials from me, simply click the “unsubscribe” link as given in any e-mail, or update your preferences in your personal account.
Bases for Processing your Data: I collect and use the personal data described above in order to provide you with the Services in a reliable and secure manner. I also collect and use your personal data for my legitimate business needs. To the extent that I would process your personal data for other purposes, I would ask for your consent in advance, or require that my partners or affiliates (if applicable) obtain such consent.
With Whom: I may share information, as discussed below, but I will never sell it to advertisers or other third parties without your prior written permission (given electronically).
Others working for and with Me: I use certain trusted third parties (for example, providers of data centers, network and IT service companies, attorneys, and accountants (collectively: the “Trusted Affiliates”)) to help me provide, improve, protect, and promote my Services. These Trusted Affiliates will access your information only to perform tasks on my behalf, in compliance with this Privacy Policy, and I will remain responsible for their handling of your information, as per my explicit written instructions to them.
Other Applications or Agents: You may also give third-party providers or agents (such as accountants or lawyers) access to your information and account. If you do so, however, such third-party knowledge, access, or use of your information will be governed by their privacy policies and terms, and their agreements with you. Such third-party access which you may grant to others is outside of my control, and remains your sole responsibility and liability.
Law & Order and the Public Interest: I may disclose your information to third parties if I determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of my Services or my end-users; (d) protect my rights, property, safety, or interests; or (e) perform a task carried out in the public interest.
By accessing and using the Services, you agree that such information may be disclosed, as described above, in the event that I have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action to enforce any of my rights. These rights may include, but are not limited to: actions against customers, or a third party, for non-payment; violation of the License for Terms of Use; and causing injury to or interference with my rights or property (or those of other end-users or anyone else that could be harmed by such activities). I may disclose or access account information when I believe, in good faith, that the law requires me to produce such information, and for administrative reasons or other purposes that I deem necessary to maintain, service, and improve my Services (or to protect my proprietary rights or property).
In addition, I may, from time to time, make collective user information available to selected third parties for the purpose of improving the Services as offered to my Customers. However, this information will be provided only in the aggregate, and never with usernames, passwords, or accounting information included. I will not disclose any personally identifiable information, concerning any customer, at any time.
Stewardship of your personal and/or corporate data is critical to me, and represents a responsibility that I embrace. I believe that your data should receive the same legal protections, regardless of whether it is stored as part of my Services, or on your home computer’s hard drive. I will abide by the following “Government Request Principles” when receiving, scrutinizing, and responding to any government requests (including national security requests) for your data: to be transparent; to fight blanket requests; to protect all end-users; and to provide my trusted Services.
Security: I have a team dedicated to keeping your information secure, and testing for vulnerabilities. I also continue our work on developing features to keep your information safe, such as one- or two-factor biometric authentication, encryption of files at rest, and alerts when new devices and apps would be linked to your account (once opened). I will deploy monitoring and technologies to detect abusive behavior, and content, that may harm my Services, you, or other end-users.
User Controls: You will be able, subject to completion of my full digital infrastructure, to access your personal information by logging into your account and going to your Account Settings Page. I will also be posting amendment procedures to update any account you may open with me, with regard to your personal or institutional account information.
Retention: When you sign up for an account with me, once my account-opening software is completed, I will retain the information you store on my Services for as long as your account is in existence, or as long as I need it to provide you with the Services. If you cancel your account, I will initiate deletion of this information after sixty (60) days. However, please note that: (a) there may be some latency in deleting this information from my servers and back-up storage; and (b) I may retain this information if necessary to comply with my legal obligations, resolve disputes, or enforce my agreements.
Note: Even though I have detailed clearly the many steps it has taken to provide secure data/item storage and transmission, no data transmission over the internet can be guaranteed to be one hundred percent (100%) secure, and no security system is impenetrable. As a result, while I strive to protect my end-users’ data in accordance with its security steps, processes, and Privacy Policy, there can be no complete assurance of long-term data protection. I reserve the right to carry insurance related to this risk. I cannot insure or warrant the security of any information transmitted to or from my online Services. Therefore, you need to proceed with this understanding.
You hereby understand and agree that all information, data, messages, or other materials transmitted are the sole responsibility of you – the Customer and/or end-user – from whom such material originated. You are entirely responsible for all uploads and/or e-mails transmitted via the Services. Under no circumstances will I be liable in any way for the use of any Services by You, the Customer and/or end-user, including, but not limited to: any errors or omissions in any Services; and/or for any loss or damage of any kind incurred as a result of the use of any Services, e-mailed or otherwise, transmitted via or for the Services.
I recommend that you do not divulge your account access credentials or password(s), once created, to any other entity or person(s). It is important to remember that you should properly log out of your account and close your browser window when finished to ensure that others cannot access the system. If you have any reason to believe that your account is no longer secure (for example, in the event of unauthorized entry to your account), you must then promptly change your account access credentials, and password(s), and notify me of the potential problem.
Around the World: To provide you with the Services, I may store, process, and transmit information in locations around the World—including those outside of your country, and throughout the Universe (referring especially to satellite-based storage). Information may also be stored locally, on the devices you use to access the Services.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield: When transferring data from the European Union, the European Economic Area, and Switzerland, I rely upon a variety of legal mechanisms, including contracts with my customers and affiliates. I comply with the EU-U.S. and Swiss–U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the European Economic Area, and Switzerland to The United States. My current interest is to seek, and obtain, a Privacy Shield Certification. You can also learn more about the definition of a Privacy Shield at https://www.privacyshield.gov.
Changes: If I am involved in a reorganization, merger, acquisition, or sale of my assets, your information may be transferred as part of that deal. I will notify you (for example, via a message to the e-mail address associated with your account, once created) of any such deal, and will outline your choices, if any, in that event.
I may revise this Privacy Policy, from time to time, and will post the most current version on my Personal Website. If any such revision meaningfully reduces your rights, I will notify you.
Your Right to Control and Access Your Information: You have control over your personal information, and how it is collected, used, and shared. For example, you have a right to remove some or all of Your Items in your account (once generated).
Change or Correct Personal Data: Once your account is generated, you will be able to manage your account, and the content contained therein, as well as to edit some of your personal data, through your Account Settings Page.
You, the Customer and end-user, agree to adhere to all terms and conditions of the Services, the current Privacy Policy, and the following.
In consideration for your use of the Services, you further agree to:
(a) Provide true, accurate, current, and complete information as prompted by the Services Application and Registration Form (such information being “Registration Data”); and
(b) Maintain and promptly update the Registration Data, to ensure that the information is accurate, current, and complete.
In the event that the Customer provides any information that is inaccurate, not current, or incomplete, or the Customer’s information becomes suspect, then after making reasonable inquiries, I may suspend or terminate the Customer’s account, and refuse any and all current or future use of the Services, or any portion thereof, to him, her, or it. In addition, in the event that the Customer should provide registration data, or other information, that is inaccurate, fraudulent, or which is not current, the Customer agrees to indemnify me and my affiliates, and to hold them harmless from and against any and all liabilities, damages, losses, or expenses (including reasonable fees for attorneys and other professionals) that it may incur, of any nature, or arising from or related to any claim, demand, action, or proceeding, whether alleged or initiated against me and/or my affiliates, by any third party, based upon the information which you, the Customer, has provided.