This Public Privacy Policy of Core BTS, Inc., dba NRI (“Core”, “Core BTS”, or “NRI”) describes the privacy and data security principles followed by Core BTS regarding the personal information of individuals who visit our network of websites, as well as the personal information of our customers (“covered individuals”). Personal information includes any data by which an individual can be identified or located (for instance, a person’s name, address, phone number of email address). This Public Privacy Policy will help you understand how we collect and use the personal information you share with us, and it describes your choices regarding use, access, correction, and deletion of any personal information you share with us. By using or accessing the Core websites, you are accepting the practices described in this Public Privacy Policy.

This Public Privacy Policy also describes how Core handles customer information and services data (defined below) to which Core may have access as we perform services on behalf of our customers. This Public Privacy Policy applies to the collection, storage, security, processing, transfer, use of, and access to personal information, customer data, and services data concerning covered individuals, except where a written contract with a covered individual defines different requirements.

This policy does not apply to third-party websites, products, or services even if they link to our services, and you should consider the privacy practices of those third parties carefully. By using our websites and our services, you authorize the collection, use, storage, sharing, and disclosure of your personal information as described in this Public Privacy Policy and any applicable updates. If you do not agree with the data practices described in this Public Privacy Policy, you should not use our websites or services.

Important Notice to Users Outside the United States

Our websites and services are operated in the United States (unless specified otherwise in a customer contract). If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through our website or in connection with the provision of our services (unless specified otherwise in a customer contract), you consent to this transfer.

Personal Information Collected and How it is Used

We collect and use your personal information to provide our products and services, as well as products and services of our suppliers and licensors, to you and to operate and improve our sites and services. We will only use your personal information in ways outlined in this Public Privacy Policy.

Depending on how you use our websites and our services, we may collect the following types of information and use it in this manner:

Accessing Our Website – Log Files

Like most websites, our site automatically collects and uses the data contained in log files. Information in log files may include your computer’s IP (internet protocol) address, your ISP (internet service provider), the web browser you used to visit our site, the time you visited our site, which web pages you visited, and other anonymous site usage data. Every computer with internet capability is given a number that serves as that computer’s IP address. When you request a page from any site within the Core network of websites, our web servers automatically recognize your IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed our websites. We use this information to examine traffic in aggregate, investigate misuse of Core’s websites, detect fraud, and cooperate with law enforcement.

Information You Provide

We offer access to some information and services without a charge, but for you to learn more about our products, services and support we ask that you complete a registration form called “We’re Listening”, “Course Enrollment”, “Speak with an Expert” Or “Request More Info.” In this instance, we ask you to provide the following personal information:

• First and last name;
• Company and title;
• Email address; and
• Phone number.

You may also voluntarily provide us personal identifiable information if you use our online “chat” function, email us directly with questions, or if you complete our “Post Project In-take or other forms.” If you are a client using our support services, you may access the “client portal” on our website by submitting your username and password.

We communicate with you through email and notices posted on a Core website. Examples of email notices include: (1) welcome and engagement messages following your registration on a Core website, meant to inform you how to best use our services, and keep you apprised of new features; (2) service messages addressing service availability, security, and other issues about the functioning of Core’s products and services; and (3) promotional emails, which may contain promotional information about Core or about our business partners. You may change your email and contact preferences, or any other personal information, at any time by notifying Core as explained in more detail at the end of this policy under “Your Privacy Rights Opting Out of Marketing And Transfers; Accessing, Updating And Deleting Information”. If we use your information in a manner different than the purpose for which it was collected, we will ask for your consent before such other use. As a reseller of Microsoft, Cisco, and other products and services, we may provide your personal information to them and our other partners or vendors for marketing purposes or purposes to effectuate our relationships with our partners and vendors, however we will not sell or rent your personal information to any third party without your consent. We provide you with tools to opt out of marketing from us or certain transfers of your information. You can learn about this in the “Your Privacy Rights: Opting Out of Marketing And Transfers; Accessing, Updating And Deleting Information” section of this Public Privacy Policy.

Terms & Conditions – SMS Messaging

By engaging with NRI’s services, including support and identity verification processes, you agree to the following SMS terms:

1. Assumptive Opt-In: If you or your organization has provided a mobile number to NRI, you are considered to have consented to receive SMS messages related to service delivery, including identity verification.
2. Message and Data Rates May Apply: Standard text messaging and data charges may apply per your carrier’s plan.
3. Message Frequency May Vary: You will receive messages only as needed for identity verification or support purposes.
4. Opt-Out Instructions: To stop receiving messages, text STOP or BLOCK.
   • Opt-Out Confirmation: “You have successfully unsubscribed and will no longer receive SMS messages from NRI.”
5. Help/Support Access: For assistance, contact us at support@nri-na.com or call 866.661.7787.

Cookies and Other Technologies

When you visit a Core website we may, or our advertising partners may, send one or more “cookies” to your computer. Third-party websites you access through our websites may also send cookies to your computer. A cookie is a small piece of data that is sent to your browser from a web server and stored on your computer’s hard drive. We use cookies to improve the quality of our services and store your user preferences or log-in information, as well as for marketing purposes. Cookies are also used to analyze trends, administer our websites, track users’ movements around our websites, and gather demographic information about our user base. You can choose whether to accept cookies by changing your browser settings (see below). You can reset your browser to refuse all cookies or allow your browser to show you when a cookie is being sent. If you choose not to accept cookies, your experience at our site and other websites may be diminished and some features may not work as intended.

What types of cookies do we use and how do we use them?

• Essential website cookies: These cookies are strictly necessary to provide you with services available through a Core website, and to use some of a website’s features, such as access to secure areas.
• Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our websites but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.
• Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our websites are being used or how effective our marketing campaigns are.
• Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.
• Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our websites through third party social networking and other websites. These cookies may also be used for advertising purposes too.

How can I control cookies?

You have the right to decide whether to accept or reject some cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links shown below.

You can set or amend your web browser controls to accept or refuse certain cookies. If you choose to reject cookies, you may still use our websites though your access to some functionality and areas of our websites may be restricted. How you can refuse cookies through your web browser controls vary from browser-to-browser, accordingly, you should visit your browser’s help menu for more information.

In addition, most advertising networks offer you a way to opt out of targeted advertising.  If you would like to find out more information, please visit https://www.aboutads.info/choices/. You may also opt out of behaviorally targeted ads by clicking here: https://preferences.truste.com/ (or if located in the European Union, by clicking here: https://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.

Global Privacy Control (GPC)

We recognize and honor the Global Privacy Control (GPC) signal as a valid request to opt out of sharing of your personal information. When you visit our website using a browser or extension that transmits a GPC signal, we will treat that signal as an opt-out request for the device and browser from which it is sent. No separate request or account login is required for a signal properly received by us to take effect.

Other Tracking Technologies – Web Beacons

Cookies are not the only way to recognize or track visitors to a website. We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage our websites by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages or in emails and are about the size of the period at the end of this sentence. We use clear gifs or pixels in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our customers’ personal information.

Links to Other Sites

This Public Privacy Policy applies to our websites and offered products and services only. Although we may provide links to internet sites or resources administered by third parties, we do not exercise control over any third-party sites, or the third-party products or services offered on such sites. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We cannot protect the privacy of the information you share with any such third party, and we suggest that you review their applicable privacy policies. We may present links in a format that enables us to keep track of whether third-party links on our website have been followed. We use this information to determine which sites are being accessed and how often, and to improve our services.

Other Requested Information

We may request your name, e-mail address or mailing address for the purpose of conducting a contest, promotion or survey, or providing additional services (for example, subscriptions to e-mail newsletters, promotional announcements, or information about seminars). When making such a request, we will indicate the purpose of the inquiry. Information gathered for this purpose may be used for other purposes consistent with the terms of this Policy. Information you elect to provide will be treated as a communication of your intent to rescind any previously received opt-out notices to us that precede your submission of the information.

Potential Disclosure of Your Information

We will disclose personal information and an IP address consistent with the terms outlined in this Policy, or when we have your consent, or when we have the good-faith belief that such action is reasonably necessary to:

1. Satisfy any applicable law, regulation, legal process or enforceable governmental request;
2. Protect and defend the security of Core’s websites and related properties, or visitors to Core’s websites and related properties;
3. Enforce our Terms of Use, including investigation of potential violations thereof;
4. Identify persons who may be committing a fraud or otherwise violating the law; and
5. Cooperate with investigations of purported unlawful activities.

Some of our services may be co-branded and offered in conjunction with another company. If you register for or use such services, both Core and the other company may share information collected in conjunction with the co-branded services. Such co-branded service offerings may have their own privacy policies, which we ask that you review before using the applicable services.

Security of Your Information

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. Other than as set forth in the last sentence in this paragraph, we restrict access to personal information to our Team Members, contractors, agents and authorized third parties who need to know the information to operate, develop or improve our services. These individuals are bound by confidentiality obligations. As noted above in the section entitled “How we and others may communicate with you using the information you provide”, we may provide your contact information to our partners for marketing purposes.

Data Integrity

We process personal information only for the purposes for which it is collected and in accordance with this Public Privacy Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services or as otherwise permitted under this Public Privacy Policy.

AI Chatbots

Our AI-powered chatbots are provided as an optional service to enhance your experience and assist with general inquiries. Please note the following important information about your use of this feature:

• No Confidential Data: Do not share or input any confidential, proprietary, or sensitive information (including personal data, financial details, health information, or customer-specific data) when using the chatbot.
• No Guarantee of Privacy or Security: Communications with the chatbot are not intended to be secure or private, and any data entered into the chatbot is specifically excluded from all confidentiality and other protections afforded by this Policy.
• No warranty:  Core disclaims all warranties for information provided by a chatbot. Information provided by a chatbot should be independently verified for accuracy and should not be relied upon independently as accurate.
• Consent to Use: By interacting with the chatbot, you acknowledge and consent to the collection and use of data of all data in any manner by Core, its affiliates, and any third parties.

California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
If you are a resident of California, you may contact us with regard to the rights listed below for managing your personal data. All information that is collected is maintained for the duration of the relationship plus up to 36 months of inactivity. Data requests may be submitted online or by mail and will be responded to within 10 days and completed within 45 days. Internal procedures existing to verify your identity (or verification of an agent acting on your behalf) prior to taking any action. No fee shall be charged relating to these data requests. Should a request be declined, an appeal can be made utilizing the methods listed below.

Online data request submission form:
Data Rights Request Form

Data requests may be submitted via mail to:

NRI
Attn: Privacy
8335 Allison Pointe Trail, Suite 240
Indianapolis, IN 46250

Right to Know or Access: You have a right to request access to the personal data we may hold on you. Your data will be provided in a portable and readily usable format.

Right to Opt-In/Opt-Out of Sale or Sharing of Personal Data: You have the right to opt-out of sale or sharing of personal data we may hold on you. You can exercise this right at any time by submitting the data request form. Exercising this right will exclude you from any sale, disclosure, or sharing of your personal information.

Right to Deletion: You also have the right to ask us to delete personal data we may hold on you or restrict how it is used. There may be exceptions to the right to deletion for specific legal reasons which, if applicable, we will set out for you in response to your request.

Right to Correct: You can request the correction of any personal information that may be inaccurate.

Right to Non-Discrimination: We will not discriminate against you for exercising any of your California Consumer Privacy Act rights.

Right Regarding Automated Decision Making and Profiling: Should automated decision making technology be deployed for a task with your personal information, you will be notified before its use has occurred. You can opt out of the application of such technology.

Your Privacy Rights: Opting Out of Marketing and Transfers; Accessing, Updating And Deleting Information

We want to communicate with you only if you want to hear from us. If you wish to opt out of receiving our marketing efforts or our sharing of information with third parties for their marketing efforts, you may do so, at any time by clicking “unsubscribe” in any email you receive from us and following the instructions on the screen, or by responding to a marketing email and including “Remove” in the subject line. Please be aware that you cannot opt out of receiving our service messages.

Please note that, from time to time, personal information collected from you may be processed and stored by us or our partners in jurisdictions in which disclosure may be compelled by governments, law enforcement agencies and regulatory bodies of those jurisdictions as required or permitted by the laws and courts of those jurisdictions. Depending on the laws of the applicable jurisdiction, we may not be allowed to provide notice to you of such required disclosure.

We may also share your personal information and other information with entities controlling, controlled by, or under common control with us. If some or all of our business assets are sold or transferred, we would transfer your information to the buyer or transferee and, for due diligence purposes, to its professional advisors under an obligation of confidentiality.

Changes to this Policy

We may change our Public Privacy Policy from time to time. If we do make changes, we will post any policy changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. If we make what we believe are any material changes that impact our use of your personal information, we’ll let you know by (ii) posting our updated policy on this page and referencing the material changes, or (ii) sending you an email or similar message about the changes. We encourage you to check back regularly and review any potential updates. Your continued use of our websites will be subject to the terms of the then-current Public Privacy Policy.