Effective Date: October 1, 2021
IF YOU ARE SITUATED IN THE EU/UK/SWITZERLAND OR A RESIDENT OF CALIFORNIA OR NEVADA, PLEASE SEE THE SECTIONS “ADDITIONAL EU UK/SWITZERLAND DISCLOSURES”, “CALIFORNIA CONSUMER RIGHTS” OR “NEVADA PRIVACY RIGHTS” FOR SPECIFIC DISCLOSURES WITH RESPECT TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
- We collect Personal Information from you directly that identifies you as an individual when it is voluntarily provided by you, such as your name and email address.
- We automatically collect browsing information and other information from you that does not directly identify you as an individual, but may identify your device, such as information about your browsing activities and information about the devices you use to access our Website.
- You can access, delete and control certain uses of your information as set forth in the “California Consumer Rights” and “Additional EU/UK/Switzerland Disclosures” sections below.
- Information about our data collection during the prior 12 months is further described below. We intended to collect the same data going forward.
|Sources of such|
|Purposes for the Collection|
of such Personal Information
|Categories of Third Parties With Whom We Share Personal Information|
|Contact information and other personal identifiers such as your name, email address, job title, company name and mailing address.||We collect such information directly from you when you subscribe to receive our email alerts and updates and when you contact us directly with inquiries.||We use such information to add you to our mailing list, fulfill event registration requests and to respond to your direct inquiries.||We share such information with our service providers, such as those who provide us email delivery services.|
|Online identifiers such as IP host address and your Internet service provider.|
Browsing history and other internet activity such as web pages viewed on the Website, browser type, links clicked within the Website, date and time that you visited the Website, the websites you visited before visiting the Website and the search queries you made on the Website.
|We collect such information from you, automatically, when you visit and use our Website.||We use such information to help us administer the Website, to better understand how our Website is being used, to improve and enhance our Website, to assist in anti-fraud monitoring and to customize your experience on the Website.||We share such information with our service providers, including providers of the following services: website hosting, data analysis, infrastructure provision, information technology services and our third-party contractors.|
|Demographic information||We collect such information from you, automatically, when you visit and use our Website.||We use such information to help us administer the Website, to better understand how our Website is being used, to improve and enhance our Website, to assist in anti-fraud monitoring and to customize your experience on the Website.||We share such information with our service providers, including providers of the following services: website hosting, data analysis, infrastructure provision, and information technology services; and our third-party contractors.|
Personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Information We Collect From You:
When using the Website, in order to utilize some of the services that may be available, such as signing up for email alerts or registering for events, you may be asked to provide, or you may choose to provide, certain personally identifiable information about yourself, such as your name and email address. Your provision of such information to us is completely voluntary. In addition, we may also collect information from you automatically, such as IP host addresses, web pages viewed, browser type, referring pages, usage and browsing habits and similar data.
We will only use your Personal Information as described herein, unless you have specifically consented to another type of use, either at the time the Personal Information is collected from you or through some other form of consent from you or notification to you:
- We may use your Personal Information to respond to your inquiries or requests.
- We may permit our vendors and subcontractors to access and process your Personal Information, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.
- We may disclose Personal Information as required by law or legal process.
- We may disclose Personal Information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the terms or policies for our services.
- We may transfer your Personal Information in connection with the sale, merger, reorganization or change of control of Davis+Gilbert Risk Management or as part of a bankruptcy proceeding.
- We may use and disclose Aggregate Information for any number of reasons.
Cookies and Similar Technologies:
When you visit our Website, we may track information about your visit and store that information in web server logs, which are records of the activities on our Website. The servers automatically capture and save the information electronically. Examples of the information we may collect include: your unique Internet protocol address; the name of your Internet service provider; the town/city, county/state and country from which you access our Website; the kind of browser or computer you use; the number of links you click within the Website; the date and time of your visit; the web page from which you arrived to our Website; the pages you viewed on the Website; and certain searches/queries that you conducted via our Website. The information we collect in web server logs helps us administer the Website, analyze its usage, protect the Website and its content from inappropriate use and improve the user experience.
Sharing of Personal Information:
The chart above lists the categories of third parties with which we may share your Personal Information for a business or commercial purpose. We do not share your Personal Information in a manner that constitutes a “sale,” as defined by the CCPA.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for business purposes:
- Personal identifiers
- Personal information covered by the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Internet or other similar network activity
This Website may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Website. These social media platforms collect information pursuant to their own policies. We do not control their practices, so you should read their policies on their sites. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services, you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
Your Choices, Rights and the Opt-Out Process:
You may opt-out of receiving commercial emails from us at any time by contacting us at email@example.com. Please note that there might be a brief delay between when you submit your request to opt-out of such emails and when it is processed and reflected in our systems; accordingly you may continue to receive communications from us for a limited time after you unsubscribe.
You can set your browser to notify you when you receive a cookie, flush any cookies that may already be on your computer and/or device or refuse to accept cookies. You should understand that some features of many sites may not function properly if you don’t accept cookies. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected.
Subject to local law, you may also have certain rights regarding information that we have collected and that is related to you. See “Additional EU/UK/Switzerland Disclosures”, “California Consumer Rights” and “Nevada Privacy Rights” below for more information on your additional rights over the collection, use and disclosure of your information under those jurisdictions.
California Consumer Rights
If you are a California resident (“California Consumer”), under CCPA, you have specific rights regarding your Personal Information. This section describes the rights that you have under CCPA or similar laws under your jurisdiction (if any) and explains how to exercise those rights.
Right to Know About Personal Information Collected, Disclosed or Sold
As a California Consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Access and Deletion Rights”), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:
- The categories of Personal Information we collected about you.
- The categories of sources from which the Personal Information is collected.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access and Deletion Rights”), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. However, we maybe retain Personal Information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions in accordance with applicable laws, set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.
Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a request to us by emailing us at firstname.lastname@example.org.
Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the Personal Information or an authorized representative of that person. For more information about verification, see “Response Timing and Format” immediately below.
Response Timing and Format
We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing. In order to protect the security of your Personal Information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. The method used to verify your identity will depend on the type, sensitivity and value of the information, including the risk of harm to you posed by any authorized access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the Personal Information that we already have.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with a request, or cannot fully comply with a request, the response we provide will also explain the reasons we cannot comply.
No Sales of Personal Information
We do not share your Personal Information in a manner that constitutes a “sale,” as defined by the CCPA.
We will not discriminate against you for exercising any of your CCPA rights.
Nevada Privacy Rights
If you are a Nevada resident, you have the right to request that we do not sell (as defined by N.R.S. 603A) certain personal information that we have collected, or may collect, from you. We do not “sell” your personal information as defined by N.R.S. 603A, however, if you would like to make such a request you may do so by contacting us at email@example.com.
Additional EU/UK/Switzerland Disclosures
Grounds for Using Your Personal Data:
We rely on the following legal basis to process your Personal Information:
- It may be necessary for us to use and disclose your Personal Information for the performance and fulfillment of the contract between us and to provide you with our services;
- We may use and disclose your Personal Information where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests;
- If you specifically consent to certain uses of your Personal Information, we may use your Personal Information in a manner consistent with that consent; and
- We will also process, transfer, disclose and preserve Personal Information when we have a good faith belief that doing so is necessary.
Data Subject Rights
If you are located in the European Union, United Kingdom or Switzerland with rights under the General Data Protection Regulation (“GDPR”) or comparable national laws, you have the right to withdraw previously provided consent for our processing of your Personal Information by contacting us at firstname.lastname@example.org. Such individuals also have the following rights:
- Right to access – This right allows individuals to obtain confirmation that his or her Personal Information is being process and allows individuals to request details of the processing of his or her Personal Information, including, without limitation, categories of recipients to whom the Personal Information have been or will be disclosed and purposes of processing.
- Right to rectify – This right allows individuals to rectify any inaccurate Personal Information about him or her.
- Right to restrict processing – This right allows individuals to block or suppress processing of Personal Information under certain circumstances.
- Right to be forgotten – This right is also known as the “right to erasure.” It is an individual’s right to have Personal Information erased or to prevent processing in specific circumstances.
- Right of data portability – This right allows individuals to move, copy or transfer Personal Information from one place to another in a secure manner without interrupting the integrity and usability of the information.
- Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
If you have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority.
We have put in place reasonable physical, electronic and managerial procedures to safeguard the information we collect; however, due to the inherent open nature of the Internet, we cannot guarantee that all information will be free from unauthorized access by third parties, such as hackers, and your use of the Website demonstrates your assumption of this risk.
If you provide us with Personal Information through the Website, we retain your information for as long as necessary for our business purposes. This may include, but is not limited to, retaining such information to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Information, we may continue to retain and use Aggregate Information previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.
Links to Other Websites:
This Website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of other websites and by linking to such websites we are not endorsing their content or practices. We encourage you to be aware when you access any such third-party links and to read the privacy policies of each website that you access.
Cross Border Transfers:
Our servers are maintained in the United States of America (“USA”). By using the Website, you freely and specifically give us your consent to export and store your Personal Information in the USA. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA. We may transfer Personal Information from the European Economic Area, United Kingdom and Switzerland to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. Personal Information of European Union residents will be transferred in compliance with the requirements of the GDPR.
For questions or concerns relating to privacy, we can be contacted at: email@example.com.