Privacy Statement

Privacy Policy

Effective Date: May 25, 2018

This Privacy Policy covers Borelli Strategies, LLC (“Borelli Strategies”) policies on the collection, use, and disclosure of Personal Data/Personally Identifiable Information (as defined by applicable law and hereinafter collectively referred to as “Personal Data”) when visitors and Subscribers (collectively “Users”) access (“Site”).

Borelli Strategies, LLC. is an Ohio LLC  with offices in the United States. Borelli Strategies collects Personal Data from its users around the world and processes, transfers and stores data within the United States.

  1. What Information Is Collected by Borelli Strategies And How Is It Used?

Email Addresses & Contact Information Users may subscribe to our newsletters and may unsubscribe at any time through the opt-out link contained within those communications.

  1. Is Information Collected By Or Disclosed To Third Parties? 

Borelli Strategies does not sell, rent, or lease Personal Data to any third parties.  However, Personal Data is shared with third parties as follows: 

Anonymous Data – Analytics: Borelli Strategies uses third party analytics services to learn how Users behave on so that we can review and improve our Services:

  • Google Analytics: Google Analytics is a web analytics tool collects information anonymously. It provides a report to Borelli Strategies with website trends without identifying individual visitors.  Google Analytics collects anonymized information in accordance with their Privacy Policy. However, if you do not want your Personal Data to be used by Google Analytics, you may opt-out by installing Google Analytics Opt-out Browser Add-on.

Third Party Advertising/Re-Targeting Services: When accessing, third party advertising services may place a cookie on your browser, which may be used to target relevant advertisements to you when you visit third party websites.  Users may opt-out from receiving targeted advertisements by visiting the (1) Network Advertising Consumer Opt-Out page, (2) Digital Advertising Alliance Opt-Out page, and/or (3) the opt-out provisions pertaining to the applicable advertising services/retargeting provider.

Social Plug-Ins:  Users may follow Borelli Strategies and/or share information on FacebookTwitterGoogle and LinkedIn. Users should click on the hyperlinks for each site to review the applicable privacy policies for more detail about information collected from these sites.

Payment Processing Information: Borelli Strategies does not itself store debit or credit card information on its servers.  Borelli Strategies utilizes a third-party payment processor, PayPal, to manage and process payments in order to guarantee the security of Subscriber’s Personal Data.  Subscribers should review PayPal’s Privacy Policy for more information on their data collection practices.

Other Potential Third Party Disclosures: Personal Data may also be disclosed to third parties to serve our legitimate business interests as follows: (1) as required by law, such as to comply with a subpoena, or similar legal process, (2) if Borelli Strategies is involved in a merger, acquisition, or sale of all or a portion of its assets, (3) to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (4) enforce our agreements with you, and/or (5) investigate and defend ourselves against any third-party claims or allegations. We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law.

  1. How Does Borelli Strategies Comply With The Children’s Online Privacy Protection Act and GDPR Regulations Relating to Children?

We do not knowingly collect Personal Data from anyone under the age of 18.  If a parent or guardian becomes aware that his or her child (a) under the age of 16 in applicable EU Member Countries, or (b) under the age of 13 in the U.S. and applicable EU Member Countries,  has provided us with Personal Data without their consent, he or she should contact Borelli Strategies at We will delete such Personal Data from our files within a commercially reasonable time, but no later than required under the applicable law relating the child’s country of residence.

  1. How Long Does Borelli Strategies Retain Personal Data Collected? 

Personal Data obtained from Site visitors will be maintained as long as it is necessary to provide requested communications and information-based services or until a Visitor exercises its right to opts-out of requested communications or information-based services.  Anonymized and Pseudo-anonymized data will be retained as long as Borelli Strategies determines such data is commercially necessary for it legitimate business interests.

  1. EU General Data Protection Regulation (“GDPR”) Notices

Data Controller.  The information that we collect, process and/or use is controlled by Borelli Strategies Lyndhurst, Ohio 44124. You may contact us at any time by emailing us at

We will only collect and process Personal Data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, and “legitimate interests.” Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.  If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at

Users within the EU may email Borelli Strategies at in order to exercise their GDPR rights to:

  • Access, review, restrict processing of, or otherwise request erasure of your Personal Data;
  • Obtain the identity of the source of any Personal Data collected;
  • Request correction of any errors contained within your Personal Data;
  • Request transfer your Personal Data to another service provider;
  • Object to the manner in which your Personal Data is processed; or
  • Lodge a complaint with a supervisory authority.

Where we rely on your consent to collect Personal Data, you may withdraw your consent either through the opt-out links provided in this Privacy Policy or through the contact information contained within this Section.

For all GDPR-based requests made pursuant to this section, Borelli Strategies will (a) respond as required under applicable law, (b) provide a copy of any requested Personal Data in a structured, commonly used and machine-readable format, and (c) transmit such Personal Data to another service provider without restriction in accordance with applicable law.

  1. Privacy Shield Notice For Users In The European Union

Borelli Strategies complies with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively.

Certification. Borelli Strategies has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. (collectively, the “Privacy Shield Principles”).  If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit

Accountability for Onward Transfer.

Borelli Strategies requires that its integrated service providers that have access to personal information from EU consumers have either self-certified to the Privacy Shield Principles, are subject to the EU Privacy Directive, or enter into a written agreement with us that requires them to provide at least the same level of privacy protection as is required by the relevant Privacy Shield Principles. Borelli Strategies is potentially liable if such third-party service providers process your personal information in a manner that is inconsistent with the Privacy Shield Principles.

Access. You may ask to review and correct the personal information that we maintain about you by sending a request to

Complaints.  In compliance with the EU-US Privacy Shield Principles, Borelli Strategies commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Privacy Shield policy should first contact Borelli Strategies at or by mail to: Borelli Strategies – 1408 Beaconfield Rd. Lyndhurst, Ohio 44124

  • No Cost Dispute Resolution. In the event complaints cannot be resolved by Borelli Strategies,  they will be referred to the Council of Better Business Bureaus (“CBBB”), a non-profit organization based in the United States which provides an alternative dispute resolution mechanism to resolve EU Privacy Shield complaints.  Borelli Strategies will cooperate with the CBBB during the dispute resolution process relating to complaints brought under Privacy Shield. These recourse mechanisms are available at no cost to you.  For more information on how EU Consumers may file a complaint, see Better Business Bureau Privacy Shield Dispute Resolution Process.
  • FTC Jurisdiction. The Federal Trade Commission has jurisdiction over Borelli Strategies compliance with this Privacy Policy and the EU-US Privacy Shield Framework.
  • Privacy Shield Panel – Binding Arbitration. As a last resort, privacy complaints that remain unresolved after pursuing these and other channels may be subject to binding arbitration before the Privacy Shield Panel to be created jointly by the US Department of Commerce and the European Commission and/or the Swiss Government, as applicable to the dispute.  
  1. What Is Borelli Strategies Security Policy? 

We have implemented reasonable administrative, technical and physical security measures in accordance with the Borelli Strategies Security Policy to protect your personal information against unauthorized access, destruction or alteration. However, although we endeavor to provide reasonable security for information we process and maintain, no security system can ever be 100% secure.

In addition, Borelli Strategies utilizes a PCI-DSS compliant third party payment processor, PayPal, to ensure the security of Subscriber’s Personal Data. Subscribers should review PayPal Privacy Policy for more information on their security practices.

  1. How Does The Respond To “Do Not Track” Signals?

“Do Not Track” is a feature enabled on some browsers that sends a signal to request that a website disable its tracking or cross-Platform user tracking. At present, the site does not respond to or alter its practices when a Do Not Track signal is received.

  1. How Will I Be Notified Of Changes To Your Privacy Policy? 

If we make material changes to our Privacy Policy, we will notify you by (1) changing the Effective Date at the top of the Privacy Policy, (ii) and sending an email to all active email subscribers. Express consent will be obtained when required for any material changes in Borelli Strategies collection and use practices.

  1. Contact Us

If you have any questions regarding your Personal Data or about our privacy practices, please contact us at: Borelli Strategies, Attention: Privacy Department, Lyndhurst, Ohio 44124 or at