How do we use this information?

To Whom We Disclose Information

We will not sell your personal information, except in the event of that our company undergoes a merger, corporate restructuring, or a sale of all or substantially all of our assets. 

However, we may share your information with our consultants for the purpose of them providing services to us, for Site improvement and to understand our audience.  Also note that Google collects information about you, as stated above, and we do not control such collection of data, or what Google does with your data once they collect it. 

What about sensitive personal data?

We do not collect sensitive personal data through this Site. If we do seek to collect such data, we will ask you to consent to our proposed uses of the data. We ask that you not send us any sensitive information through the Site. If you decide to send us such information, by providing us with such unsolicited sensitive personal data, you consent to our using the data subject to applicable law as described in this Privacy Policy. The references to "sensitive personal data" are to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent. These categories comprise personal identity numbers, personal data about personality and private life, racial or ethnic origin, nationality, political opinions, membership of political parties or movements, religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, genetic code, addictions, sexual life, property matters or criminal record (including information about suspected criminal activities). 

Mail Choice/Opt-out

What about data security?

Your California Privacy Rights

We do not use cookies at this time, but we reserve the right to use them, and if so to track your movement through our website through their use. Please check back to review this policy often, to confirm whether we have begun to use cookies or not. 

Currently, various browsers offer a do-not-track (“DNT”) option that is designed to send a signal to websites visited by the user about the user's DNT preference. You can usually access your browser's DNT option in your browser's preferences.  While some industry groups have indicated a desire to develop a DNT technology standard, no standard has been adopted to date. Without an industry standard for DNT, users cannot know how any given company or browser will comply with DNT signals.  Given the lack of a standard at this time, we do not comply with DNT signals from your browser at this time.

We may track your activities online across websites and over time.

Third Party Links and Services

This Site contains third party links that can be used to access certain services provided by third parties.  This Privacy Policy does not address data collection or processing by any of those service providers. 

Privacy Statement Changes

If you have any questions please contact us.

European Union Addendum to Privacy Policy

This Addendum to our Privacy Policy applies to you only if accessing the Site from within the confines of the European Union.   THIS ADDENDUM TO THE PRIVACY POLICY DOES NOT APPLY TO ANY PERSON LOCATED WITHIN THE UNITED STATES OF AMERICA OR ANY OF ITS TERRITORIES, OR ANY COUNTRY OUTSIDE THE EUROPEAN UNION OR THE UNITED KINGDOM.

Additional Information requirements pursuant to Art. 13 GDPR (EU General Data Protection Regulation)

This privacy policy addendum applies solely to our processing of the personal data of data subjects who are in the European Union, where they use, browse or interact with, our Site.  

It is important that you read this privacy policy together with any other privacy policy, privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. 

Controller

Data Privacy Manager  

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy addendum. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data protection manager using the details set out below:

Full name of legal entity: BLACKWELL BUSINESS PARTNERS, LLC / New York, NY

Data Privacy Manager: Jonathan Friedsham

Email address: privacy@blackwellbusinesspartners.com 

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymized data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

•  Identity Data includes first name, last name and title.
•  Contact Data includes email address and mailing address.
•  Technical Data may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
•  Usage Data includes information about how you use our Site.
•  Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Please note that when using our Site, you may have the option to log into a client portal or make a payment to us.  If you make use of such portions of our Site, you will be accessing portals offered by our third party service providers.  All such third parties are our processors or sub-processors and act pursuant to our direction with respect to your personal data.  However, we do not control what information they may collect from you to allow them to make their services available, such as Technical Data or Usage Data.  This privacy policy does not apply to collection or processing of your personal data by such parties.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect through the Site any special categories of personal data (as defined in the GDPR) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences through the Site.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. 

How is your personal data collected?  

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us through any feature of the Site.

Automated technologies or interactions.  We do not use cookies on our Site at this time.  However, if we implement the use of cookies, we may automatically collect Technical Data about your equipment, browsing actions and patterns, through the use of such cookies, server logs and other similar technologies.   Please check back often to confirm whether cookies are implemented in the future. 

Third parties or publicly available sources. We receive personal data about you from various third parties and public sources as set out below: 

•  Contact Data, from our payment processors (when you choose to make a payment by following the link available on the Site).

How we use your personal data

We will only use your personal data that we collect on or through the Site when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

•  Where we need to perform the contract we are about to enter into or have entered into with you.
•  Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
•  Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us through the “unsubscribe” feature in any marketing communication we send you.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data collected from or through the use of the Site, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us 

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you (which we may use for marketing purposes). 

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for their marketing purposes. 

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.

Cookies

We do not use cookies on our Site at this time.  Please check back often to confirm whether we have begun to use them.  If we do, we will update this policy to notify you.

If we implement cookies, you can set your browser to refuse some of them, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of some websites may become inaccessible or not function properly.  

Note that you may not be able to refuse all data collection even by setting your browser cookies settings, and that some collection of Technical and Usage Data may continue. 

Also, note that we use the following analytics service providers, who also collect Technical and Usage Data based on your use of our Site.  The analytics providers listed below are independent controllers of that data, and use it for their own purposes.  You specifically grant your consent to such data collection and usage.

Change of purpose 

We will only use your personal data collected on the Site for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data for the purpose of providing our services and making the Site available to you, including the following:

•  Internal Third Parties as set out in the Glossary. 
•  External Third Parties as set out in the Glossary.
•  Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We contract with our third-party service providers to require that they do not use your personal data for their own purposes and to authorize them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Whenever we transfer your personal data out of the European Economic Area (“EEA”), we will endeavour to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

•  We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. 

Data security

We have in place security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

Data retention

We have implemented measures designed to ensure that we not retain your personal data longer than is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  Note, however, that if we have a legitimate interest in retaining the data, or if we are required to do so by applicable law, we will retain the data in accordance with our data retention plans and policies.

In some circumstances we may choose to anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.  

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

None.   

External Third Parties

•  Service providers acting as processors. A list of such parties is available upon reasonable request.
•  Google LLC collects data as set forth in this policy, and is an independent controller of such data.
•  Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers.
•  Regulators and other authorities acting as processors or joint controllers based in the United States who require reporting of processing activities in certain circumstances.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.