Privacy
Privacy Policy
Effective date: July 28, 2026
This Privacy Policy explains how The CBI Group (“we,” “us,” or “our”) collects, uses, stores, and protects personal data when you visit The Legal Operating Memoranda at memo.curtisbatterton.com, subscribe to our newsletter, download subscriber resources, or contact us.
1. Who we are
The data controller for this site is:
Curtis Batterton Inc. (d.b.a. The CBI Group), an Illinois corporation
2045 W Grand Ave Ste B #776967
Chicago, Illinois 60612-1577
USA
United States
Email: privacy@curtisbatterton.com
Website: memo.curtisbatterton.com
If you are in the European Economic Area, the United Kingdom, or another jurisdiction with privacy rights, you may have specific legal rights described below.
2. What personal data we collect
We collect only the personal data needed to operate the site, manage subscriptions, provide downloads, communicate with readers, secure the site, and understand how the site is used.
| Situation | Personal data we may collect |
|---|---|
| You visit the site | IP address, browser type, device information, approximate location, pages viewed, referral source, log data, cookie or session information |
| You subscribe | Email address, name if provided, subscription status, signup source, confirmation status, newsletter preferences |
| You access subscriber resources | Membership status, tags or labels related to the resource, access or download activity where available |
| You open or interact with emails | Delivery status, opens, clicks, unsubscribe status, email preferences where available |
| You contact us | Name, email address, message content, and any information you choose to include |
| You purchase something, if paid products are added later | Payment status, billing details handled by the payment provider, transaction metadata, subscription tier |
Do not send confidential legal matter information, privileged information, sensitive personal data, or proprietary business information unless we have separately agreed in writing to receive it.
3. How we use personal data
We use personal data to:
- send newsletters and subscriber emails;
- confirm subscriptions and manage member accounts;
- provide access to subscriber-only downloads;
- respond to messages and requests;
- manage unsubscribe and email preference requests;
- secure, maintain, and troubleshoot the site;
- understand site and newsletter performance;
- prevent spam, abuse, unauthorized access, and misuse;
- comply with legal obligations;
- keep basic business and administrative records.
4. Legal bases for processing
Where GDPR or similar laws apply, we rely on the following legal bases:
| Purpose | Legal basis |
|---|---|
| Sending newsletters and marketing emails | Consent |
| Managing your subscriber account and access to downloads | Contract or steps taken at your request |
| Responding to your messages | Legitimate interests or steps taken at your request |
| Site security, abuse prevention, troubleshooting, and basic analytics | Legitimate interests |
| Keeping legally required records | Legal obligation |
| Managing paid subscriptions, if added later | Contract and legal obligation |
You can withdraw consent for newsletter emails at any time by using the unsubscribe link in an email or contacting us.
We keep a record of when and how you gave consent, including the date and the form used, so we can demonstrate it if asked.
5. Newsletter and subscriber downloads
When you subscribe, we use your email address to send you the newsletter and provide access to subscriber-only content or downloads.
Some downloadable resources are available only to subscribers. We may use subscription status, tags, or labels to provide access and understand which signup forms or resources are effective.
You can unsubscribe at any time. If you unsubscribe, you may lose access to subscriber-only resources.
6. Cookies and similar technologies
This site may use cookies, session storage, or similar technologies to:
- keep you signed in;
- support member access;
- remember preferences;
- protect the site from spam, abuse, or unauthorized access;
- understand basic site performance.
If we use optional analytics, advertising, tracking, or embedded media tools, we will describe them here and, where required, request consent before using them.
Current analytics setup: Ghost native analytics; Kit email engagement tracking (opens, clicks).
7. Service providers
We use service providers to operate the site, deliver email, host content, secure the site, and manage subscriptions.
These may include:
| Provider category | Purpose |
|---|---|
| Ghost or Ghost hosting provider | Website publishing, membership management, newsletter features, hosting |
| Email delivery provider | Sending newsletters, confirmation emails, and subscriber messages |
| Domain/DNS provider | Domain management and routing |
| Security or infrastructure provider | Site security, uptime, and performance |
| Analytics provider, if used | Understanding site and newsletter performance |
| Payment provider, if paid products are added later | Processing payments and subscriptions |
Specific providers currently used:
- Website platform/hosting: Ghost(Pro)
- Email delivery: Ghost
- Analytics: Ghost
- Payments, if applicable: Stripe
- Email marketing, forms, and resource delivery: Kit (Kit.com, formerly ConvertKit)
Service providers may process personal data only as needed to provide their services to us.
8. International transfers
Some service providers may process or store personal data outside your country, including outside the European Economic Area.
Where required, we rely on appropriate safeguards such as adequacy decisions, standard contractual clauses, data processing agreements, or other lawful transfer mechanisms.
9. How long we keep personal data
We keep personal data only as long as needed for the purposes described in this Privacy Policy.
In general:
- newsletter subscription data is kept while you remain subscribed;
- unsubscribe records may be kept to ensure we do not email you again improperly;
- contact messages are kept as long as needed to respond and maintain reasonable business records;
- technical logs are kept for a limited period for security and troubleshooting;
- payment or tax records, if any, are kept as required by law.
You may request deletion of your personal data, subject to legal, security, or administrative retention requirements.
10. Your privacy rights
Depending on where you live, you may have the right to:
- access the personal data we hold about you;
- correct inaccurate or incomplete personal data;
- request deletion of your personal data;
- restrict or object to certain processing;
- withdraw consent where processing is based on consent;
- request a copy of your personal data in a portable format;
- complain to a data protection authority.
To exercise your rights, contact us at privacy@curtisbatterton.com.
For EU readers, you may contact your national DPA and the Autoriteit Persoonsgegevens.
11. Email preferences and unsubscribe
Every marketing or newsletter email includes an unsubscribe link or similar mechanism. You can use that link to stop receiving newsletter emails.
You may also contact us at privacy@curtisbatterton.com to request help with your subscription, preferences, or deletion request.
12. Security
We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.
No website, email system, or online service is completely secure. You are responsible for using a secure email account and protecting your login links or access credentials.
13. Children
This site is intended for adults and business readers. It is not directed to children, and we do not knowingly collect personal data from children.
If you believe a child has provided personal data to us, contact us so we can review and delete it where appropriate.
14. Third-party links and embeds
This site may link to or embed content from third-party websites, platforms, or services. Those third parties have their own privacy practices and policies.
We are not responsible for the privacy practices of third-party websites or services.
15. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The updated version will be posted on this page with a new effective date.
If we make material changes, we may provide additional notice where appropriate.
16. Contact
For privacy questions or requests, contact:
The CBI Group
Email: privacy@curtisbatterton.com
Website: memo.curtisbatterton.com