Last Updated: January 1, 2023
The Information We Collect
In the course of providing the Services, SGC collects or receives the following types of information directly from you or in your interactions with our Services. In the preceding 12 months, we have collected, and will continue to collect, the following categories of personal information:
- Personal identifiers: name, contact details, identifying information of beneficiaries, IP address, social security number (if provided), account and password information for applications used by the company.
- Protected class information: race, ethnicity, gender, gender identification, and veteran status.
- Financial information: bank account or credit card information to process payments.
- Internet or other electronic activity information: information about your computer, mobile device, browser, and cookie information.
- Professional information: records regarding your work location, job title, and seniority (if provided).
- Audio & Video information: recordings of calls made to customer support or your local representative; security camera footage if you visit one of our physical locations.
Additional information about our data collection practices follows.
We collect contact information through our Services, which typically includes your name, email address, phone number, address and zip code, and any information you provide when using the “Contact Us” function. We use such contact information for purposes such as providing you with information about the Services, putting you in touch with our local offices, responding to your inquiries or providing you the Services.
Email Communications and Newsletters
You may choose to provide us with personal information in an email or written message to us when using, providing or inquiring about our Services or by submitting your information in a “Contact” section of the Website. We use this information to respond to your messages, fulfill your requests, or to register you for the Services you have purchased, and we may use it to market or promote relevant services to you. If you sign up for an email newsletter, you have the option to unsubscribe at any time. Any information you choose to provide regarding special interests may be used for marketing and promotional purposes. By providing this information, you may receive occasional email messages from SGC or an affiliated organization.
Cookies and Device Identifiers
We may collect information using “cookie” and other similar tracking technologies. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will remember information about your use and enable us to track and target your interests and to personalize your experience on our Website For example, we may use these technologies to:
- collect information about how visitors use the Website (for example, which pages they visit, which links they use, and how long they stay on each page);
- support the features and functionality of the Website;
- personalize a visitor’s experience when they use the Website; and
- improve our marketing efforts, including targeted advertising.
We may use both session cookies and persistent cookies. A session cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. The information we collect using cookies and similar technologies may or may not be directly identifying of you, but we may link it to personal information that you provide. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit our Website, you may be unable to use all of the functionality of the Website if your browser rejects cookies.
Information from Your Computer or Mobile Device
When you access the Website through your computer or mobile device, we may automatically collect certain information from and/or about your device, such as IP address, your approximate geographic location, access dates and times, information about your approximate location (as determined through your IP address), hardware and software information, mobile and computer or hardware device information. This information allows us to understand how you’ve used the Website, and other actions you have taken in connection with your use of the Website. We automatically collect log data when you access and use the Website.
You may provide payment information, including credit card or financial account information, to pay for our Services through the Website. This information is used only to fulfill the transactional purpose for which you submit it to us and may be processed by a third-party vendor on our behalf. We use a third-party payment processor to take payment for our Services.
Additional Sources of Information
You may provide additional information to us when you request information about our Services. We may receive this information from you through email, the Website, or over the phone. This information may be combined with other information received through the various channels through which you interact with us.
For information about Google Analytics, please visit https://www.google.com/analytics
Third-Party Advertising Tools
When you use our Website, third parties may deliver cookies or other tracking technologies to your computer or mobile device for the purpose of tracking your online behaviors across nonaffiliated websites, and to deliver targeted advertisements on other nonaffiliated websites.
Purpose for Collection and How We Use Information
We use the information we collect to provide you Services, enhance your experience on our Website, to improve our Services, and for marketing and promotional efforts.
Purpose for Collection and Our Use of Information
We may use the information we collect, including personal information, for the following purposes:
- to provide the information, content and Services you request;
- for security or fraud prevention purposes;
- to provide you with effective customer service;
- to manage customer relationship information, including records of Services provided;
- to provide you with a personalized experience when you use our Website;
- to contact you with information and notices related to your use of our Services;
- to better understand your needs and interests;
- to improve the content, functionality and usability of this Site;
- to improve our Services;
- to improve our marketing and promotional efforts; and
- for any other purpose identified in an applicable privacy notice, click-through agreement, or other agreement between you and us.
Please see “Your Choices” below for information about the choices you have about the ways we use the information we collect about you.
In an ongoing effort to better understand our users and the Services, we might analyze your information in aggregate form to operate, maintain, manage, and improve the Services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners and to other third parties for other lawful purposes.
Third-Party Data Sharing and Disclosure
Compliance with Law or Protection of Rights
We may contemplate, for strategic or other reasons, selling, buying, merging, or otherwise reorganizing our businesses. In negotiating with a third party about entering into such an arrangement, we may need to disclose your personal information. In such cases, we will take reasonable measures to protect the personal information we disclose, for example, by requiring a prospective partner or purchaser to sign a non-disclosure agreement limiting the use and protecting the confidentiality of the information.
We may transfer the information you submit on or through our Services, including personal information, to a partner or buyer or other successor in the event of a merger, divestiture, transfer of control, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SGC, a subsidiary, or an affiliated company about our Website’s users is among the assets transferred.
We may from time to time retain third-party vendors in order to help us manage our Website and Services and allow us to better serve our visitors and customers. These may include third-party vendors we engage to analyze the information we collect for marketing or similar purposes.
We may also share information, including personal information, to third-party vendors to help us provide the Services. For example, we may use a cloud-service provider to host information we collect or other aspects of our Services. Such vendors have access to personal information for a limited purpose and for a limited period of time.
Disclosure of Personal Information For Business Purposes in the Past 12 Months
We do not disclose personal information to third parties for their own direct marketing purposes, but we do disclose personal information to third parties for our own business purposes. The following chart describes the categories of personal information we have disclosed to third parties for a business purpose in the past 12 months:
|Categories of Individuals’ Personal Information||Categories of Third Parties With Which We Shared Personal Information for a Business Purpose|
|Personal identifiers: name, contact details, identifying information of beneficiaries, IP address, social security number (if provided), account and password information for applications used by the company||Service providers that assist in providing customer relationship functions; facilitate scheduling and email communications; provide security services and cloud-based data storage, assist with other IT-related functions; host or facilitate teleconferencing or video conferencing services; provide legal and accounting services|
|Protected class information: race, ethnicity, gender, gender identification, and veteran status||Service providers that assist in providing customer relationship functions; provide legal services|
|Financial information: bank account or credit card information||Service providers that assist in payment processing|
|Internet or other electronic network activity information: device and browser type, browsing and search history on our Website, and information regarding interaction with our Website and our advertisements||Service providers that provide security services and cloud-based data storage, host our Website and assist with other IT-related functions, and provide analytics information|
|Professional information: records regarding your work location, job title, and seniority||Service providers that assist in providing customer relationship functions; facilitate scheduling and email communications; provide workplace analytics; provide legal and accounting services|
|Audio or video information: recordings of calls made to customer support or your local representative; security camera footage if you visit one of our physical locations; video conferencing||Service providers that assist in providing customer support functions; physical security-monitoring service providers; video conferencing service providers|
Rights Specific to California Residents
No Sale of Personal Information
We do not sell the personal information of our Website visitors or customers and we do not sell the personal information of minors.
Your Right To Request Disclosure of Information We Collect and Share About You
We are committed to ensuring that you know what personal information we collect. To that end, you can ask us for any or all of following types of information regarding the personal information we have collected about you prior to our receipt of your request:
- Specific pieces of personal information we have collected about you;
- Categories of personal information we have collected about you;
- Categories of sources from which such personal information was collected;
- Categories of Personal Information that the business sold or disclosed for a business purpose about the consumer;
- Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting your personal information.
Your Right To Request Deletion of Personal Information We Have Collected About You
Upon your request, we will delete the personal information we have collected about you, except for situations where the CCPA authorizes us to retain specific information, including when it is necessary for us to provide you with Services that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us. We will act on your deletion request within the timeframes set forth below.
Exercising Your Rights and How We Will Respond
To exercise your access or deletion rights, or to ask a question about your data subject rights, contact us at +1 833 527 2436 or firstname.lastname@example.org. If you use the e-mail option, please include “CCPA Rights Request” in the subject line of the e-mail.
We will first acknowledge receipt of your request within 10 business days of receipt of your request. We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances.
If we expect your request is going to take us longer than normal to fulfill, we will let you know.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
Our Commitment to Allowing You to Exercise Your Rights – Non-Discrimination
If you exercise any of the rights explained in this Policy, we will continue to treat you fairly. If you exercise your rights under this Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.
Verification of Identity – Access or Deletion Requests
We will ask you for identifying information and attempt to match it to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. We will notify you to explain the basis of the denial.
You may designate an agent to submit requests on your behalf. The agent must be a natural person or a business entity that is registered with the California Secretary of State.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process. Specifically, if the agent submits requests to access, know or delete your Personal Information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
How We Protect Your Information
Our servers are located in the US and elsewhere. Please be aware that your information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Services, you do so at your own risk.
We do not control how third parties use your information, but you can opt out of certain third-party activities at the links below.
To opt out of Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout.
To opt out of certain ad functions, please visit: https://youradchoices.com/control.
Do Not Track Mechanisms
SGC does not respond to “Do Not Track” settings or other related mechanisms at this time.
How To Contact Us
Stephen Gould Corporation
Attn: Legal Department
35 S Jefferson Road
Whippany, New Jersey 070981