Simpson Gumpertz & Heger (SGH) Inc. Website Privacy Notice
Last modified: 23 March 2022
Simpson Gumpertz & Heger (SGH) Inc. and our subsidiaries and affiliates “SGH” or “We”) respect your privacy and commit to protecting it through our compliance with the practices described in this notice.
This notice describes our practices for collecting, using, maintaining, protecting, and disclosing the personal information we may collect from you or that you may provide when you visit our websites or other digital properties, communications, or forms that link or refer to this notice (our “Website”). This notice applies to the personal information collected through our Website, regardless of the country where you are located.
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share information about you. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit.
Please read this notice carefully to understand our policies and practices. By engaging with our Website, you accept and consent to the practices described in this notice. This notice may change from time to time (see Changes to Our Privacy Notice). Your continued interaction with our Website after any revisions indicates that you accept and consent to the changes, so please check the notice periodically for updates.
Information We May Collect About You
We collect and use different types of information from and about you including:
- Personal information that we could reasonably use to directly or indirectly identify you, such as your name, postal address, email address, telephone number, username or other similar identifier, or any other identifier we may use to contact you online or offline (“personal information”). For job or independent contractor applicants, we may collect and use additional personal information that we could reasonably use to directly or indirectly identify you, such as your education and professional background, contract engagement details, and financial information.
- Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
- Information about your internet connection, the equipment you use to access our Website, and usage details.
How We Collect Information About You
We use different methods to collect information from and about you including through:
- Direct interactions. You may give us information about you by filling in forms or by corresponding with us by phone, email or otherwise. This includes information you provide when you sign up for our mailing list, participate using other social media functions on our Website, apply for jobs or other roles, and when you report a problem with our Website.
- Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies (see Cookies and Automatic Information Collection Technologies).
- Third parties or publicly available sources. We may receive information about you from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators.
- Estimate our audience size and usage patterns.
- Store your preferences so we may customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
For information about managing your cookie privacy and security settings, see Your Personal Information Use Choices.
Our Website pages and emails may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording Website content popularity or verifying system and server integrity.
We do not control how these third-party tracking technologies operate or how they may use the collected information. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Personal Information Use Choices.
How We Use Your Personal Information
We use your personal information to offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using information to improve and personalize your experiences. Examples of how we may use the personal information we collect include to:
- Present our Website and provide you with the information, services, and support that you request from us.
- Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.
- Fulfill the purposes for which you provided the information or other purposes that were described when it was collected.
- Notify you about changes to our Website, products, or services.
- Ensure that we present our Website content in the most effective manner for you and for your device.
- Administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
- Improve our Website, products or services, marketing, or customer relationships and experiences.
- Enable your participation in our Website’s interactive, social media, or other similar features.
- Protect our Website, employees, or operations.
We may also use personal information to contact you about our services that may be of interest to you. For more information, see Your Personal Information Use Choices.
We may use non-personal information for any business purpose.
When We Disclose Your Personal Information
We may share your personal information with:
- Any member of our corporate group, which means our subsidiaries and affiliates.
- Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization). We contractually require these third parties to keep that personal information confidential and use it only for the contracted purposes.
- To fulfill the purpose for which you provide it.
- For any other purposes that we disclose when you provide the information.
- With your consent.
We may also disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
- To a buyer or other successor in the event of merger, divestiture, 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, where one of the transferred assets is the personal information we hold.
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- To enforce or apply your obligations under our contracts or other agreements.
- To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
We may share non-personal information without restriction.
Consent to Personal Information Transfer
We are based in the United States. We may process, store, and/or transfer the personal information we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own.
By submitting your personal information or engaging with our Websites, you consent to this transfer, storing, or processing.
Your Personal Information Use Choices
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. We have established the following personal information control mechanisms:
- Promotional Offers from SGH. If you do not want us to use your contact information to promote our own services, or the services of limited third party business partners, such as if we give a joint seminar, you can opt-out by sending us an email with your request to email@example.com. You may also opt-out of further marketing communications by replying to any promotional email we have sent you or following the opt-out links on that message.
Our Website may, from time to time, contain links to and from the websites of our partners or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these third parties.
Our Website is not designed to respond to “do not track” signals received from browsers.
California residents may have additional personal information rights and choices. Please see the Section California Privacy Notice for more information.
Jurisdiction Specific Rights
California Privacy Notice
In addition to disclosures made elsewhere in this Privacy Notice, California law requires businesses to disclose certain information related to our privacy practices. This Section of our Privacy Notice (“California Privacy Notice”) serves to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section.
Our California Privacy Notice supplements the information contained in our Privacy Notice and applies solely to all visitors, users, and others who are residents of the State of California.
Information We Collect
As described in our general Privacy Notice, we collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). For purposes of this California Privacy Notice, personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”), clinical trial data, or other qualifying research data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute. Cal. Civ. Code § 1798.80(e).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Job applicants only
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES
Job applicants only
|J. Non-public education information (per the Family Educational Rights and Privacy Act. 20 U.S.C. § 1232g, 34 C.F.R. Part 99.||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES
Job applicants only
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES
Job applicants only
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or services you purchase.
- Indirectly from you. For example, from observing your actions on our Website.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the purposes described in our general Privacy Notice or as otherwise permitted by the CCPA. In the How We Use Your Personal Information Section above, we describe how we have used CCPA Personal Information in the past twelve (12) months.
Sharing Personal Information
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, SGH has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
We do not sell personal information.
Business Purposes Disclosures
In the preceding twelve (12) months, we have disclosed CCPA Personal Information for a business purpose to the categories of third parties indicated in the chart below.
|Personal Information Category||Business Purpose Disclosures to Vendors, Service Providers, Contractors, and Subcontractors|
Document and project management.
Backup data storage.
Hiring and retaining employees.
Credit checks in limited situations.
|California Customer Records|
|Protected Classification Characteristics Under California or Federal Law|
|Professional or Employment-Related Information|
|Non-Public Education Information Per the Family Educational Rights and Privacy Act, 20 U.S.C. Section 1232g, 34 C.F.R. Part 99|
|Inferences Drawn from Other Personal Information|
Right to Know and Data Portability
California consumers have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- If we disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
California consumers have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “Right to Delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We will delete from our records or deidentify personal information not subject to a lawful exception and will direct our service providers to take similar action.
Subject to some exceptions, California residents have the right not to be discriminated against based on the consumer’s refusal to provide a business with personal information.
Exercising Your Right to Know or Delete
To exercise your rights to know, including your right to request data portability, or delete described above, please submit a request by either:
- Calling us at 781-907-9000.
- Emailing us at firstname.lastname@example.org.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You or your authorized agent may only submit a request to know twice within a 12-month period. Your request to know or delete must:
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- Provide sufficient information, which will likely need to match information we previously collected from you, that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (“Authorized Agent”). In some instances, we may ask you to provide a signed declaration under penalty of perjury that you are the person whose personal information is the subject of the request. For requests seeking particularly sensitive information, we may require additional proof of identification.
- If you would like, you may designate an Authorized Agent to make a request under the CCPA on your behalf. We will deny requests from agents that do not submit proof of authorization from you. If you designate an Authorized Agent to make a request under the CCPA, to verify that an authorized agent has authority to act for you, we may require:
- A copy of a power of attorney or require that you provide the authorized agent with written permission.
- You to verify your own identity with us directly.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it, except for record-keeping purposes. We will delete this information as soon as practicable after complying with the request.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact Nicole Sparks at 781-907-9135 or at email@example.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
The security of your personal information is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal information from loss, misuse, and unauthorized access, use, alteration, or disclosure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.
Children’s Online Privacy
We do not direct our Website to minors and we do not knowingly collect personal information from children under 16 or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal information from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at Nicole Sparks; 781-907-0135; firstname.lastname@example.org.
Changes to Our Privacy Notice
We will post any changes we may make to our privacy notice on this page. Please check back frequently to see any updates or changes to our privacy notice.
If you have any questions or comments about this notice, the ways in which SGH collects and uses your information described here and in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Simpson Gumpertz & Heger
Attn: Marketing Department
480 Totten Pond Road, Waltham, MA 02451
If you need to access this Notice in an alternative format due to having a disability, please contact email@example.com and 781-907-9000.