Whether you’re a Client, vendor, or business partner this notice explains how and why we collect and use individuals’ data. It also outlines your rights on how to obtain, review, or withdraw your data. We may change this Privacy Notice from time to time. Any such changes will be posted on this page and any material changes will be made prominent. We encourage you to review this page from time to time.
1. Privacy Notice
This Privacy Notice is applicable to the processing of all personal data of Business Contacts of Criser, Gough and Parrish, LLC (together ‘CGP’). ‘Business Contact’ or ‘you’ means each individual whose personal data is processed by CGP in the scope of delivering services to clients, recipients of commercial messages for CGP, receiving services from vendors, and providing services together with business partners. This includes people working at CGP as consultants or employees of third parties providing services to CGP.
2. Use of your information
2.1. When you visit or submit inquiries from crisergoughparrish.com, you may be asked to provide certain information about yourself including your name and contact details. We may also collect information about your usage of our website as well as information about you from messages you post to the website and email or letters you send to us. CGP protects your personal data in line with applicable laws and our data privacy policies. We also take appropriate technical and organizational measures to protect your data against unauthorized or unlawful processing, and against accidental loss, destruction, damage, alteration, disclosure or access. Your information may also be used for:
- Assessment and acceptance of a client, conclusion, and execution of agreements with clients, vendors, and business partners. This purpose includes processing of personal data that is necessary in connection with the assessment and acceptance of clients, vendors, and business partners, including confirming and verifying the identity of relevant Business Contacts (this may involve the use of a credit reference agency or other third parties), conducting due diligence and screening against publicly available government and/or law enforcement agency sanctions lists (e.g. for compliance requirements). This purpose also includes the processing of personal data necessary to conclude and execute agreements with clients, vendors, and business partners, including required screening activities (e.g. for access to CGP’s premises or systems), delivery of customer services, and to record and financially settle delivered services to and from CGP.
- Development and improvement of CGP’s services. This purpose addresses the processing of personal data that is necessary for the development and improvement of CGP services and for research and development. This includes processing of Business Contact personal data for surveys and reviews.
- Relationship management and marketing. This purpose includes processing of personal data that is necessary for activities such as maintaining and promoting contact with clients, suppliers and business partners via marketing communications, account management, customer services, execution and analysis of market surveys and marketing strategies.
- Business process execution, internal management and management reporting. This purpose includes processing of personal data that is necessary for the management of company assets, conducting audits and investigations, finance and accounting, implementing business controls, providing central processing facilities for efficiency purposes and managing mergers, acquisitions and divestitures. This purpose also includes processing personal data for management reporting and analysis, archiving and insurance, legal or business consulting and preventing, preparing for or engaging in dispute resolution.
- Health, safety, security and integrity purposes. This purpose includes the processing of personal data that is necessary for the protection of the rights, interests and assets of CGP and its employees, clients, suppliers and business partners and activities such as those involving health and safety. It also includes the authentication of client, vendor, or business partner status and access rights.
- Compliance with the law. This purpose includes the processing of personal data that is necessary for the performance of a task carried out to comply with a legal obligation to which CGP is subject, including the disclosure of personal data to government institutions or supervisory authorities in relation thereto.
- Protection of the vital interests of Business Contacts. This purpose includes the processing of personal data that is necessary to protect the vital interests of you as our Business Contact.
3. Type of personal data we may collect
- Your personal details: including work email address, work telephone number and work address; private email address, private telephone number, home address; job function or position; job history; picture or video.
3.2. In the course of your business relationship with CGP, CGP may need to collect certain data viewed as ‘sensitive’ because they reveal intimate characteristics, such as religion, ethnicity, criminal acts, or health. Such sensitive data shall only be used within the strict limits set out by applicable local law. Such sensitive data processing activities conducted by CGP may, in accordance with applicable local requirements, include the following:
- Your image may be processed by CGP in as far as necessary for identification or future reference purposes, for site access and security reasons and for the identification and authentication of clients, vendors, or business partners.
- Data relating to criminal behavior, criminal records or proceedings regarding criminal or unlawful behavior may be processed by CGP in as far as necessary for assessment and acceptance of clients, suppliers or business partners, for the protection of the rights, interests and assets of CGP, its employees and clients, suppliers and business partners and to comply with applicable legal obligations.
- Physical or mental health data may be processed by CGP in as far as necessary for the assessment and acceptance of a client, vendor, or business partner, the execution of an agreement with a client, vendor, and business partner, compliance with CGP’s duty of care towards clients, vendors, and business partners and for the protection of your vital interests.
- Personal data on religion or beliefs may be processed by CGP in as far as necessary to accommodate specific services for a client, including dietary requirements or religious holidays.
3.3. CGP will usually obtain personal data from you directly or via the relevant client, vendor, or business partner. Your personal data may also be obtained by CGP via public sources, including sanction lists, trade registers and online social media like LinkedIn.
4. How long do we use your information?
4.1. In general, CGP will retain your personal data for the duration of your business relationship with CGP (e.g. during the time CGP services are delivered to your employer and you are our Business Contact or during the time that CGP sends you commercial messages you are interested in, such as newsletters) and with a maximum of 36 months thereafter.
4.2. CGP deviates from these retention periods if your personal data is relevant for legal obligations. In such cases, CGP will retain your personal data for the period as required by that legal obligation (e.g. for the time CGP needs to keep a record of its financial transactions based on tax legislation for the time CGP needs to keep a record of its activities in the scope of screening against publicly available sanction lists).
4.3. CGP will also deviate from these retention periods if CGP has a pressing interest to keep your personal data longer (e.g. in case of ongoing or expected litigation).
5. Disclosure of personal information
5.1. Access to your personal data is only authorized to the extent such access is necessary to serve the intended purpose and for the respective staff to perform their job. Those that are authorized to access your personal data may include the CGP point of contact and CGP personnel.
5.2. From time to time, CGP may need to make personal data available to unaffiliated third parties, such as service providers (companies that provide products and services to CGP such as payment providers, IT systems suppliers), professional advisors (such as accountants, auditors, or lawyers), public and governmental authorities (entities that regulate or have jurisdiction over CGP such as regulatory authorities, law enforcement, public bodies and judicial bodies), or in the context of corporate transactions (in connection with any proposed or actual reorganization, merger or sale). CGP will put in place agreements with third party service providers and professional advisors to protect your data protection interests.
5.3. Due to the nature of CGP’s operations, CGP needs to disclose personal data to its own personnel and departments. Some of the unaffiliated third parties may also be located outside of your home jurisdiction. Where such data transfer takes place in a country that has a different data protection regime, CGP will ensure that the international data transfer will not negatively affect the level of protection of your personal data. Where required, CGP will inform you of any additional details on the international data transfer.
5.4. In case the recipient of the personal data is based outside the EEA in a country that is not considered to have a level of data protection adequate to the EU, CGP will ensure that this transfer is based on appropriate safeguards including EU Model Clauses or Binding Corporate Rules.
6.1. CGP will take appropriate technical, physical, and organizational measures to protect personal data from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure acquisition or access, that are consistent with applicable privacy and data security laws and regulations. This will include requiring service providers to use appropriate measures to protect the confidentiality and security of personal data.
7. Access and updating
7.1. You have the right to request an overview of your personal data processed by or on behalf of CGP. If the personal data is incorrect, incomplete, or not processed in compliance with applicable law, you have the right to have this personal data rectified, deleted, or restricted (all as appropriate). You also have the right to object to the processing of your personal data (as appropriate). You can exercise your right by contacting the CGP at [email protected] If you currently receive marketing emails from us, you can manage your subscription by clicking on the “Manage Communication Preferences” links contained within our emails. Alternatively, please contact [email protected] with your request.
7.2. For data protection or privacy-related complaints, you also have the right to file a complaint with the applicable supervisory authority.
7.3. If the processing of your personal data was based on consent, you have the right to withdraw such consent at any time. Such withdrawal will not affect the lawfulness of the processing based on consent before the withdrawal.
7.4. If you are based in the EU, you also have the right to data portability, meaning that a copy of your personal data provided by you to CGP will, at your request, be transferred to you in a common machine-readable format or transmitted to a third party without hindrance.
Effective June 1, 2018