Tiberend Strategic Advisors: Legal Risks & Redlines in Privacy Policy Compliance | Erayaha

## When Privacy Policies Fall Short: A Case Study on Tiberend Strategic Advisors

Imagine facing a €20 million GDPR fine or a class-action lawsuit costing upwards of $5 million—all due to overlooked clauses in your website’s privacy policy. Our analysis of Tiberend Strategic Advisors, Inc.'s terms reveals several high-impact legal and logical risks that could expose the company to significant regulatory and financial consequences if left unaddressed.

1. Ambiguity in Data Collection and Use The policy states, "We only have access to/collect information that you voluntarily give us via email or other direct contact from you." This language is ambiguous regarding what constitutes "other direct contact" and lacks specificity about the types of data collected and the legal basis for processing, as required under GDPR and CCPA. This exposes the company to regulatory scrutiny and potential fines of up to 4% of annual revenue.

Legal Analysis

high Risk

Removed

Added

We only have access to/collect information that you voluntarily give us via emailand process personal data only for specified, explicit, and legitimate purposes as outlined in this policy, in accordance with applicable laws including GDPR and CCPA. Data is collected solely with your informed consent or other direct contact from youlawful basis as required by law.

Legal Explanation

The original clause is vague and fails to specify the types of data collected, the purposes, or the legal basis for processing, which are required under GDPR and CCPA. The revision clarifies these points, improving enforceability and compliance.

2. Insufficient Disclosure of Data Subject Rights While the policy mentions that users can "see what data we have about you, if any," it does not provide a clear, actionable process for exercising rights such as access, rectification, deletion, or objection, as mandated by GDPR (Articles 12-23) and CCPA. This omission could result in regulatory penalties and reputational harm.

Legal Analysis

high Risk

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Added

You can do the following at any timemay exercise your rights to access, rectify, erase, restrict processing, object to processing, and data portability as provided by applicable privacy laws (e.g., GDPR, CCPA) by contacting us via the email address or phone number at the bottom of this page: See what data we have about you, if anydetails below. Change/correct any data we have about youWe will respond to all requests within the legally mandated timeframe. Have us delete any data we have about you. Express any concern you have about our use of your data.

Legal Explanation

The original clause does not reference the full spectrum of data subject rights or provide a clear process or timeframe for response, as required by GDPR Articles 12-23 and CCPA. The revision ensures compliance and transparency.

3. Vague Cookie Usage and Consent Mechanism The clause, "We use 'cookies' on this site... Usage of a cookie is in no way linked to any personally identifiable information on our site," fails to address the need for explicit consent and opt-out mechanisms for non-essential cookies, as required by the ePrivacy Directive and CCPA. Non-compliance can lead to fines of up to $7,500 per violation under CCPA.

Legal Analysis

medium Risk

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Added

We use “cookies” and similar technologies on this site. A cookie is a small digital file that is stored in your web browser to help us improve your access to our site and identify repeat visitors to our site. For instanceWhere required by law, when we use a cookie to identifyobtain your explicit consent for non-essential cookies and provide you, you would not have to log in with a password more than once, thereby saving time while on our site. Cookies can also enable usclear mechanism to track and targetopt out. Detailed information about the intereststypes of our users to enhance the experience on our site. Usage of a cookiecookies used, their purposes, and your choices is available in no way linked to any personally identifiable information on our siteCookie Policy.

Legal Explanation

The original clause does not address the need for explicit consent or provide an opt-out mechanism, as required by the ePrivacy Directive and CCPA. The revision ensures compliance and reduces regulatory risk.

4. Lack of Third-Party Data Sharing and International Transfer Safeguards The policy states, "We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request," but does not specify safeguards for third-party processors or cross-border data transfers. This creates exposure to regulatory action if data is transferred outside the US without adequate protection, a key GDPR requirement.

Legal Analysis

high Risk

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Added

We willdo not share your personal information with any third party outside of our organization, other thanparties except as necessary to fulfill your request, e or as required by law.g. Where third-party service providers are used, we ensure they are contractually obligated to ship an orderprotect your data and comply with applicable data protection laws, including requirements for international data transfers.

Legal Explanation

The original clause lacks detail on third-party safeguards and international data transfer compliance, exposing the company to regulatory action. The revision adds necessary legal protections and transparency.

Conclusion: Proactive Legal Safeguards Are Essential Our examination shows that even well-intentioned privacy policies can contain critical gaps with severe financial and reputational consequences. Addressing these issues with precise, compliant language is not just best practice—it’s a business imperative.

How confident are you that your privacy policy would withstand a regulatory audit?
What would a major data breach or compliance fine mean for your business’s bottom line?
Are your contracts and policies evolving with the latest legal standards?

This analysis is for educational purposes only and does not constitute legal advice. For actual legal guidance, consult with a licensed attorney. This assessment is based on publicly available information and professional legal analysis. See erayaha.ai’s terms of service for liability limitations.