Welcome to the CTI Group website, operated by CTI Group (Holdings), Inc., (“CTI”) and located at https://enghousenetworks.com/ctigroup/ (the “Site”). This Privacy Statement addresses CTI’s practices regarding information collected from visitors of the Site and only addresses information collected directly through or from the Site – it does not address or govern any information gathering, use, or dissemination practices related to information collected from the visitor (sometimes referred to as a “visitor,” “you” or “your”) other than directly through or from the Site, such as from telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media. CTI can be contacted at info@ctigroup.com, or by telephone at (317) 262-4666. This Privacy Statement is incorporated into CTI’s Terms and Conditions by reference, as if set forth fully therein, which must be reviewed and accepted by you. The Site is not intended for children under the age of 18. It does not knowingly collect personal information online from visitors in this age group.

CTI Group Inc. complies with the US-EU Safe Harbor framework as set forth by the US Department of commerce regarding the collections, use, and retention of personal information from the European Union member countries. CTI has certified that it adheres to the Safe Harbor Privacy principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view CTI Group’s certification, please visit http://www.export.gov/safeharbor/ 

1. Collection of Personal Information from Site Visitors. Except as specifically set forth herein, CTI may collect

(a) the e-mail addresses of users that communicate with CTI via e-mail;

(b) information knowingly provided by the user in online informational sections, registration, or membership forms; and

(c) financial information provided by a user, including credit card number and billing address in order to process credit card payments to CTI. Such financial information, while collected by CTI, is stored and maintained by its third-party payment processing center for the purpose of processing payments and conducting related transactions. Specifically, and in order to register and/or to purchase certain services of the Site, you may be required to provide additional personal information about you and your company, such as your name, address and other relevant personal information. If you do not wish to provide such information to the Site, you will be unable to register and/or to obtain products or services from the Site. When a visitor performs a search within the Site, CTI may record information identifying the visitor or linking the visitor to the search performed and recording information related to the search request. 

2. Use of Personal Information Collected. Personal information collected by CTI may be used by CTI for limited purposes, including recordkeeping, editorial and feedback purposes, content improvement, or to customize the content and layout of the Site. Individually identifying information, such as names, postal and e-mail addresses, phone numbers, and other personal information which visitors voluntarily provide to CTI, may be added to CTI’S databases and used for future contact regarding Site updates and new services. 

From time to time, CTI may need to contact you for registration-related activities (e.g., renewal notices, etc.). You agree that CTI may use your personal information for such membership-related contact with you. CTI may also desire to contact you for market research purposes or to provide you with marketing information CTI believes would be of particular interest. You will have the option of not being contacted by CTI and opting-out of such contacts by setting the appropriate option in your profile. 
3. Disclosure of Personal Information to Third Parties. Except as specifically set forth herein, any personal information that you provide to CTI on the Site will not be disclosed to other third-party entities. Identifiable and non-identifiable user information and data may be disclosed or distributed to another party with which CTI enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase, or to a third party pursuant to a subpoena, court order, or other form of legal process, in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process, or if determined by CTI in its sole judgment that such disclosure or distribution is appropriate to protect the life, health, or property of CTI or any other person or entity. Please be advised that the confidentiality of any communication or material transmitted to CTI via the Site or Internet electronic mail cannot be guaranteed, including, for example, personal information such as your address or name. 
4. Security Measures and Communicating with CTI. CTI has implemented physical, electronic and procedural security features that are designed to prevent the unauthorized release of or access to personal information. Despite CTI’S efforts to protect your personal information, the confidentiality of any communication or material transmitted to or from CTI via this Site or via e-mail cannot be and is not guaranteed. You acknowledge that the technical processing and transmission of the Site content may be transferred unencrypted and involve (a) transmissions over various networks and (b) changes to conform and adapt to technical requirements of connecting networks or devices. Accordingly, CTI is not responsible for the security of information transmitted via the Internet. Instead of communicating with CTI via e-mail or the Internet, visitors can contact CTI by regular mail at 333 North Alabama Street, Suite 240, Indianapolis, IN, 46204-1767, or by phone at (317) 262-4666. 
5. Access to and Ability to Correct Personal Information; Opt-Out Right. Upon your request via postal mail, e-mail, or telephone, CTI will provide you with a summary of any personal information retained by CTI that has been voluntarily provided by you to CTI through online forms, registration forms, surveys, e-mail, or another online avenue. You may modify, correct, change or update your personal information by contacting CTI via postal mail, e-mail, or telephone at the addresses or numbers above. Except as necessary to obtain the services or information requested, You may opt out of having your personal information, which has been voluntarily provided to CTI through online forms, membership or registration forms, e-mail, or another online avenues, prospectively retained by CTI or used by CTI for secondary purposes, by contacting CTI via postal mail, e-mail, or telephone at the addresses set out above. This provision does not apply to collection of the type of Web browser of the visitor to the Site or to information provided or collected that does not meet the description in this Section 5. 
6. Right to Change Privacy Statement. CTI may change this Privacy Statement at any time. Notice of any new or revised Privacy Statement, as well as the location of the new or revised statement, will be posted on the Site for at least twenty (20) days after the change. It is the obligation of visitors returning to the Site to learn of changes to the Privacy Statement since their last visit. Any change to this Privacy Statement shall be effective as to any visitor who has visited the Site before the change was made. 
Dated: May, 2014
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