Website Terms of Use,
Privacy Policy &
Cookie Policy

1. Agreement to Terms

By accessing or using the website located at https://www.crei.com (the "Site"), operated by CREI, a DBA of a registered Oregon limited liability company ("CREI," "we," "us," or "our"), you ("User," "you," or "your") acknowledge that you have read, understood, and agree to be bound by these Terms of Use ("Terms"). If you do not agree with these Terms, you must immediately discontinue use of the Site.

These Terms constitute a legally binding agreement between you and CREI. We reserve the right to modify these Terms at any time. Material changes will be posted on this page with an updated effective date. Your continued use of the Site after any modifications constitutes acceptance of the revised Terms.

2. Eligibility

The Site is intended for individuals who are at least eighteen (18) years of age. By using the Site, you represent and warrant that you are at least 18 years old and have the legal capacity to enter into these Terms. If you are accessing the Site on behalf of an organization, you represent that you have authority to bind that organization to these Terms.

3. Description of Services

CREI — Capital Returns & Equity Intelligence™ — is a decision intelligence firm that also builds and operates enterprise software and provides AI consultancy services. Our services include:

• Decision Intelligence: Working with boards, CFOs, and institutional decision-makers to pressure-test high-stakes capital allocations until the decision becomes defensible
• Enterprise Software: Developing, deploying, and operating proprietary software solutions for enterprise clients
• AI Consultancy: Providing advisory services related to artificial intelligence strategy, implementation, and integration for organizations

The Site serves as an informational and lead-generation platform for these services. Future features may include user accounts, paid subscription services, software-as-a-service (SaaS) access, interactive forms, and user-generated content areas.

4. User Accounts (Future Feature)

When account registration becomes available, you agree to provide accurate, current, and complete information, maintain the confidentiality of your login credentials, accept responsibility for all activity under your account, and notify us immediately of any unauthorized access. We reserve the right to suspend or terminate accounts that violate these Terms.

5. Acceptable Use Policy

You agree not to use the Site in any manner that:

• Violates any applicable federal, state, local, or international law or regulation
• Infringes upon the intellectual property rights or privacy rights of any third party
• Transmits any material that is defamatory, obscene, threatening, abusive, or otherwise objectionable
• Introduces viruses, malware, or other harmful code
• Attempts to gain unauthorized access to any portion of the Site, its servers, or connected systems
• Engages in data scraping, crawling, or automated data extraction without prior written consent
• Impersonates any person or entity or misrepresents your affiliation with any person or entity
• Interferes with or disrupts the operation of the Site or the servers or networks connected to the Site
• Uses the Site for competitive intelligence purposes or to develop a competing product or service
• Reverse-engineers, decompiles, or disassembles any software, algorithms, or AI models made available through the Site or CREI's services
• Uses any automated means (bots, scripts, spiders) to access, scrape, or interact with the Site or its software without prior written authorization
• Attempts to probe, scan, or test the vulnerability of any system or network connected to the Site, or breaches any security or authentication measures
• Uses CREI's AI tools, outputs, or software to generate content or make decisions that violate applicable law or infringe on third-party rights

6. User-Generated Content

When content submission features are available, users may submit comments, materials, or other content ("User Content"). By submitting User Content, you:

• Grant CREI a non-exclusive, royalty-free, perpetual, irrevocable, worldwide license to use, reproduce, modify, publish, distribute, and display such content in connection with the operation of the Site
• Represent and warrant that you own or have the necessary rights to submit such content and that it does not infringe on any third-party rights
• Acknowledge that CREI may, but is not obligated to, monitor, edit, or remove User Content at its sole discretion

CREI is not responsible for User Content and does not endorse any opinions expressed therein.

7. Intellectual Property

All content on the Site, including but not limited to text, graphics, logos, trademarks (including "CREI" and "Capital Returns & Equity Intelligence™"), images, software, source code, algorithms, models, methodologies, frameworks, data structures, APIs, documentation, and other materials, is the property of CREI or its licensors and is protected by United States and international copyright, trademark, patent, trade secret, and other intellectual property laws.

You may not reproduce, distribute, modify, reverse-engineer, decompile, disassemble, create derivative works of, publicly display, or otherwise exploit any Site content, software, or proprietary materials without the prior written consent of CREI, except as expressly permitted by these Terms or applicable law.

Software and AI Outputs: Any software, tools, models, reports, analyses, or AI-generated outputs provided through CREI's services remain the intellectual property of CREI unless expressly assigned in a separate written agreement. Client-specific deliverables and their ownership terms are governed by individual engagement agreements.

8. Paid Subscription and SaaS Services (Future Feature)

CREI may offer paid subscription services, software-as-a-service (SaaS) products, and premium AI consultancy access in the future. When available, the following terms will apply:

• Pricing, billing frequency, and payment terms will be disclosed before purchase
• Automatic renewal terms and cancellation procedures will be clearly stated
• Service-level agreements (SLAs), uptime commitments, and support terms will be published for SaaS offerings
• Refund policies will be published in connection with any paid service offering
• CREI reserves the right to modify pricing with reasonable advance notice
• Software access licenses are non-transferable and subject to acceptable use restrictions

9. Third-Party Links and Content

The Site may contain links to third-party websites, resources, or content. These links are provided for convenience only. CREI does not endorse, control, or assume responsibility for any third-party content, products, services, or practices. Your use of third-party websites is at your own risk and subject to the terms and policies of those websites.

10. Disclaimers

CREI does not warrant that the Site or any software will be uninterrupted, error-free, secure, or free from viruses or other harmful components. CREI does not guarantee the accuracy, completeness, or timeliness of any information, analysis, model output, or AI-generated content on the Site.

AI and Software Disclaimer: AI-generated outputs, analyses, models, and software tools provided by CREI are intended to support, not replace, human judgment and decision-making. These outputs may contain errors, inaccuracies, or limitations. Users should independently verify all AI-generated outputs before relying on them for any decision with legal, financial, or operational consequences. CREI makes no warranty that AI outputs are free from bias, hallucination, or error.

11. Limitation of Liability

Without limiting the foregoing, CREI shall not be liable for any decisions made, actions taken, or losses incurred in reliance on information, analyses, AI outputs, or software tools provided through the Site or CREI's services.

CREI's total aggregate liability for any claims arising under these Terms shall not exceed one hundred U.S. dollars ($100.00), or the amount paid by you to CREI in the twelve (12) months preceding the claim, whichever is greater.

12. Indemnification

You agree to indemnify, defend, and hold harmless CREI and its officers, directors, members, employees, agents, and affiliates from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising out of or related to your use of the Site, your violation of these Terms, your violation of any applicable law, or your infringement of any third-party rights.

13. Governing Law and Dispute Resolution

These Terms shall be governed by and construed in accordance with the laws of the State of Oregon, without regard to its conflict-of-laws principles.

Any dispute, claim, or controversy arising out of or relating to these Terms or the use of the Site shall first be submitted to good-faith mediation. If mediation is unsuccessful, the dispute shall be resolved by binding arbitration administered in Portland, Oregon, in accordance with the rules of the American Arbitration Association (AAA). Judgment on the arbitration award may be entered in any court of competent jurisdiction.

Notwithstanding the foregoing, either party may seek injunctive or equitable relief in a court of competent jurisdiction in Multnomah County, Oregon.

14. Termination

CREI reserves the right to suspend or terminate your access to the Site at any time, for any reason or no reason, with or without notice. Upon termination, all provisions of these Terms that by their nature should survive (including, without limitation, intellectual property provisions, disclaimers, limitations of liability, and indemnification) shall survive.

15. Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. The invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving the original intent.

16. Entire Agreement

These Terms, together with the Privacy Policy and Cookie Policy, constitute the entire agreement between you and CREI with respect to your use of the Site and supersede all prior or contemporaneous communications and proposals, whether oral or written.

17. Contact Information

For questions regarding these Terms, please contact:

18. Information We Collect

18.1 Information You Provide Directly

When you fill out forms, create an account, subscribe to services, or otherwise interact with us, we may collect:

• Full name
• Email address
• Phone number
• Company name and title
• Mailing or business address
• Financial information (when relevant to engagement inquiries)
• Any other information you voluntarily provide through forms or correspondence

18.2 Information Collected Automatically

When you visit the Site, we and our third-party service providers automatically collect certain information, including:

• IP address (which may be anonymized or truncated depending on your jurisdiction)
• Browser type, version, and language
• Operating system and device type
• Pages visited, time spent on pages, clickstream data, and referring URLs
• Geographic location (derived from IP address)
• Unique device identifiers

18.3 Information from Third-Party Tools

We use the following third-party analytics and tracking services, which may collect information through cookies, pixels, and similar technologies:

• Google Analytics: Collects website traffic data including page views, session duration, bounce rate, user demographics, and acquisition sources. Google Analytics may use cookies to track user behavior across sessions.
• Factors AI: Provides visitor intelligence and behavioral analytics to help us understand how organizations interact with our Site, including firmographic data, page engagement patterns, and visitor journey mapping.
• Additional Tools: We may implement additional analytics, advertising, and marketing tools such as Meta Pixel, LinkedIn Insight Tag, HubSpot, Hotjar, or similar services. Each tool's data practices are governed by its own privacy policy.

19. How We Use Your Information

We use collected information for the following purposes:

• To operate, maintain, and improve the Site, our software products, and our services
• To respond to inquiries, engagement requests, and customer service needs
• To deliver and support enterprise software and AI consultancy services
• To send transactional communications (e.g., confirmations, updates, service notifications)
• To send marketing and promotional communications (with your consent where required)
• To personalize your experience on the Site
• To analyze Site usage, trends, and visitor behavior for business improvement
• To detect, prevent, and address fraud, security issues, or technical problems
• To train, improve, and refine AI models and software products (using aggregated or de-identified data only, unless otherwise agreed in a separate engagement agreement)
• To comply with legal obligations and enforce our Terms of Use
• To facilitate potential future paid subscription services

20. Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data under the following legal bases:

• Consent: Where you have given explicit consent (e.g., subscribing to a newsletter, accepting non-essential cookies).
• Legitimate Interests: For analytics, Site improvement, fraud prevention, and direct marketing to existing contacts, where our interests do not override your fundamental rights.
• Contractual Necessity: To perform obligations under an engagement or subscription agreement.
• Legal Obligation: To comply with applicable laws, regulations, or legal processes.

21. How We Share Your Information

We do not sell your personal information. We may share personal information in the following limited circumstances:

• Service Providers: We share information with trusted third-party service providers who perform services on our behalf (e.g., hosting, analytics, email delivery, payment processing). These providers are contractually obligated to protect your data.
• Legal Compliance: We may disclose information when required by law, regulation, court order, or governmental authority.
• Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, personal information may be transferred as part of that transaction.
• With Your Consent: We may share information for other purposes when we have obtained your explicit consent.

22. International Data Transfers

CREI is based in Portland, Oregon, United States. If you access the Site from outside the United States, your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction.

For transfers of personal data from the EEA, UK, or Switzerland to the United States, we rely on the following safeguards:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• The EU-U.S. Data Privacy Framework, UK Extension, and Swiss-U.S. Data Privacy Framework, where applicable
• Binding corporate rules or other approved transfer mechanisms where necessary

23. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy. Specific retention practices include:

• Contact and inquiry form data: retained for the duration of the business relationship plus three (3) years
• Analytics data: retained in accordance with the retention settings of each analytics tool (typically 14–26 months for Google Analytics)
• Account data: retained for the life of the account plus three (3) years after closure
• Marketing communication records: retained until you unsubscribe, plus a suppression record to honor your opt-out

When data is no longer needed, it will be securely deleted or anonymized.

24. Your Privacy Rights

24.1 Rights for All Users

Regardless of your location, you have the right to:

• Opt out of marketing communications at any time by clicking the unsubscribe link in any email or contacting us
• Request information about the data we hold about you

24.2 California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights under the CCPA/CPRA:

• Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You may request that we delete personal information we have collected from you, subject to certain legal exceptions.
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Opt Out of Sale/Sharing: We do not sell your personal information. If this changes, we will provide a "Do Not Sell or Share My Personal Information" link.
• Right to Limit Use of Sensitive Personal Information: If we collect sensitive personal information, you have the right to limit its use.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise these rights, contact us at andrew@crei.com. We will verify your identity before processing your request and respond within 45 days.

24.3 EEA, UK, and Swiss Residents (GDPR)

If you are located in the EEA, UK, or Switzerland, you have the following rights:

• Right of Access: Request a copy of your personal data we hold.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure ("Right to Be Forgotten"): Request deletion of your personal data.
• Right to Restrict Processing: Request that we limit the processing of your personal data.
• Right to Data Portability: Request a machine-readable copy of your personal data.
• Right to Object: Object to the processing of your personal data based on legitimate interests or for direct marketing.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time.
• Right to Lodge a Complaint: You have the right to file a complaint with your local data protection supervisory authority.

To exercise these rights, contact us at andrew@crei.com. We will respond within 30 days.

24.4 Oregon Residents

Under Oregon's consumer privacy laws, Oregon residents have the right to access, correct, and delete personal data, as well as the right to opt out of the processing of personal data for targeted advertising, the sale of personal data, or profiling. To exercise these rights, contact us at andrew@crei.com.

24.5 Other Jurisdictions

We respect the privacy rights of individuals worldwide. If you are located in a jurisdiction that provides specific data protection rights (including but not limited to Brazil under the LGPD, Canada under PIPEDA, Australia under the Privacy Act, or other applicable laws), you may contact us to exercise any applicable rights under your local law.

25. Children's Privacy

The Site is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will take immediate steps to delete such information. If you believe a child has provided us with personal information, please contact us at andrew@crei.com.

26. Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit (TLS/SSL), access controls, and regular security assessments.

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

27. Do Not Track Signals

Some web browsers transmit "Do Not Track" (DNT) signals. At this time, the Site does not respond to DNT signals. However, you can manage your cookie preferences through the cookie consent mechanism on the Site or through your browser settings.

28. Global Privacy Control (GPC)

We honor Global Privacy Control (GPC) signals as a valid opt-out request under the CCPA/CPRA and other applicable laws. If your browser sends a GPC signal, we will treat it as a request to opt out of the sale or sharing of personal information.

29. What Are Cookies

Cookies are small text files placed on your device when you visit a website. They are widely used to make websites work efficiently, provide information to website owners, and enable certain features. Similar technologies include pixels (also called web beacons), local storage, and scripts.

30. Types of Cookies We Use

30.1 Strictly Necessary Cookies

These cookies are essential for the Site to function properly. They enable core functionality such as security, session management, and accessibility. These cookies do not require consent under applicable law.

30.2 Analytics and Performance Cookies

These cookies help us understand how visitors interact with the Site by collecting information about pages visited, time on site, errors encountered, and other usage metrics. We use:

• Google Analytics: Uses cookies (e.g., _ga, _gid, _gat) to track user sessions, page views, and engagement. Data may be transferred to Google servers in the United States. We have enabled IP anonymization where applicable.
• Factors AI: Uses tracking technologies to identify organizational visitors and analyze site engagement patterns for business intelligence purposes.

30.3 Functional Cookies

These cookies enable enhanced functionality and personalization, such as remembering your preferences, language selection, or region.

30.4 Marketing and Targeting Cookies (Future)

We may in the future implement cookies from advertising platforms (e.g., Meta Pixel, LinkedIn Insight Tag) to deliver targeted advertising and measure campaign effectiveness. When implemented, these cookies will be subject to your consent.

31. Cookie Consent

When you first visit the Site, you will be presented with a cookie consent banner that allows you to accept or reject non-essential cookies. You may modify your cookie preferences at any time through the cookie settings link available on the Site.

For visitors from the EEA, UK, and Switzerland, non-essential cookies will not be placed until you provide affirmative consent (opt-in), in compliance with GDPR and the ePrivacy Directive.

For visitors from California, you may opt out of cookies used for cross-context behavioral advertising via the cookie settings or by sending a GPC signal.

32. Managing Cookies Through Your Browser

You can control and delete cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, and set preferences for specific websites. Please note that disabling cookies may affect the functionality of the Site.

33. Google Analytics Opt-Out

You may opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-on.

34. CCPA/CPRA Disclosure Table

The following table summarizes the categories of personal information we collect:

35. Data Protection Officer / Privacy Contact

For all privacy-related inquiries, requests, or complaints, please contact:

We aim to respond to all privacy requests within 30 days (GDPR) or 45 days (CCPA/CPRA).

36. Email Marketing (CAN-SPAM / GDPR Compliance)

When email marketing becomes active, we will comply with the CAN-SPAM Act, GDPR, and other applicable laws by:

• Only sending marketing emails with your prior consent (opt-in) where required
• Including our physical mailing address in every commercial email
• Providing a clear and functional unsubscribe mechanism in every email
• Honoring unsubscribe requests within 10 business days
• Never using deceptive subject lines or misleading header information

37. Accessibility

CREI is committed to ensuring that the Site is accessible to all users, including those with disabilities. We strive to conform to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. If you experience any accessibility barriers on the Site, please contact us at andrew@crei.com so we can address your concerns.

38. California "Shine the Light" Law

Under California Civil Code Section 1798.83, California residents may request information regarding the disclosure of personal information to third parties for direct marketing purposes. As stated above, we do not currently disclose personal information to third parties for their direct marketing purposes.

39. Nevada Privacy Rights

Under Nevada Revised Statutes Chapter 603A, Nevada residents have the right to opt out of the sale of their covered information. We do not currently sell covered information as defined under Nevada law. If you are a Nevada resident and wish to submit an opt-out request, please contact us at andrew@crei.com.

40. Changes to This Policy

We may update this Privacy Policy and Cookie Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will post any changes on this page with an updated effective date. For material changes, we will provide prominent notice on the Site or by email (where applicable). Your continued use of the Site after the effective date of any changes constitutes your acceptance of the revised policies.

41. Contact Us

If you have questions, concerns, or requests regarding these Terms of Use, Privacy Policy, or Cookie Policy, please contact: