Privacy Policy

Last Updated: April 2024

Stephen Gould Corporation (“SGC,” “we,” or “us”) welcomes you. Our collection and use of information from visitors to our website located at https://www.stephengould.com (the “Website”) and customers of our services (together with the Website, the “Services”) is subject to the following privacy policy (the “Privacy Policy”), which may be updated by us from time to time without notice to you. By accessing or using the Services, you agree to be bound by this Privacy Policy and the accompanying Terms of Use. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy, you may not access or use the Services.

If you accept or agree to this Privacy Policy on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that company or other legal entity to the Agreement and, in such event, “you” and “your” will refer and apply to that company or other legal entity.

This Privacy Policy does not cover the personal information we collect about employees and independent contractors, or job applicants. Our job application portal is managed by a third-party vendor. Please refer to our Job Applicant Privacy Notice on our Website for information about our data practices with regard to the job application process.

The Information We Collect

Notice at Collection: Personal 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.
• Sensitive personal information: race, ethnicity

Additional information about our data collection practices follows.

Contact Information

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.

Payment Information

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.

Third-Party Analytics

We may use one or more third–party analytics services (including Google Analytics) to evaluate your use of the Website by compiling reports on activity (based on their collection of: IP addresses, Internet service providers, browser types, the sections of the Website that were visited, amount of time spent on a particular page, number of links clicked, search terms and other similar usage data) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data.

By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website.

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, including to prevent any activities that violate our Terms of Use or other contracts, or that are illegal;
• 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 monitor and improve the content, functionality and usability of this Site;
• to monitor and improve our Services;
• to monitor 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.

Aggregate Data

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.

Use or Disclosure of Sensitive Personal Information

We do not use or disclose sensitive personal information to create profiles about or infer characteristics about individuals, or for any purposes other than providing our Services.

Notice at Collection: Categories of Personal Information We Sell or Share or Use for Targeted Advertising

When we engage in digital advertising, we may sell the following categories of personal information (according to the broad definition of “sell” under select state privacy laws), share them for purposes of cross-context behavioral advertising, or use them for targeted advertising: personal identifiers (including IP address, mobile advertising IDs) and internet or other electronic activity information.

These categories of personal information are sold to, or shared for cross-context behavioral advertising or targeted advertising with advertising networks and other companies that facilitate or engage in digital advertising. We engage in such sales and sharing to facilitate personalized advertising. We do so by allowing third-party cookies or other tracking technologies to be placed on our website that may collect information about your online activities over time and across different websites or applications.

To opt out of such sales and sharing of personal information, click here.

Notice at Collection: Retention Periods

We retain the categories of personal information we collect for the length of time necessary to provide our Services and to comply with legal obligations or to protect our legal rights.

Third-Party Data Sharing and Disclosure

Compliance with Law or Protection of Rights

We may disclose information we collect, including your personal information, when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose your personal information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Services; to enforce or apply any applicable terms of use or other agreements; or to protect our own rights or property, or the rights, property, or safety of others.

Business Negotiations

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.

Business Transfers

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.

Vendors

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 contract with third parties who use cookies to collect information on our behalf. These parties maintain their own confidentiality and security standards. We may contract with companies or others to provide certain services, including payment services, data management and promotional services. We provide these service providers with the information they need to perform these services.

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:

Business Purposes for Such Disclosures

We disclosed the aforementioned categories of personal information to the categories of third parties identified above for the following purposes: to manage customer, supplier and vendor accounts and relationships; to process payments; to verify customers’ identities; to provide you with Services; to engage in advertising and marketing; to operate our IT systems and secure our systems; to prevent fraud and other illegal activities; and to obtain professional advice about legal and accounting matters.

Rights Specific to California Residents

If you are a California resident, you have certain rights granted by the California Consumer Privacy Act (“CCPA”) and described in this section of the Privacy Policy.

No Sale or Sharing of Personal Information of Minors

We do not knowingly sell or share for cross-context behavioral advertising the personal information of minors.

Your Rights

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 and subject to exceptions in the law, we will delete the personal information we have collected from you.

Your Right to Request to Correct Personal Information We Hold About You
You have the right to request that we correct personal information we hold that you believe is not accurate. We will take steps to determine the accuracy of the personal information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the personal information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct to assist us in evaluating the request.

Your Right to Ask Us Not to Sell or Share Personal Information We Have Collected About You
With respect to those categories of personal information that we sell to third parties or share with third parties for the purpose of cross-context behavioral advertising, you have the right to opt out of such sales and sharing.

Please refer to the “Your Choices” section in this Privacy Policy for information about how our Website responds to global opt-out signals.

Exercising Your Rights and How We Will Respond

To exercise your access, deletion, or correction rights, or to ask a question about your data subject rights, submit your request through the webform,
https://privacyform.stephengould.com, or contact us at 833-527-2436.

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.

You can direct us not to sell your personal information or share it for purposes of cross-context behavioral advertising here. For such requests, we will comply no later than 15 business days after receipt of your request.

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 Honoring Your Rights
If you exercise any of the rights explained in this Policy, we will continue to treat you fairly.

Verification of Identity – Access, Deletion, and Correction 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.

Authorized Agents
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

SGC takes very seriously the security and privacy of the personal information that it collects pursuant to this Privacy Policy. Accordingly, we implement reasonable security measures designed to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and to comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our systems or the systems of the third parties with which we may share your information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Children

We do not knowingly collect personal information from children under the age of 13 through the Services. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at privacyadministrator@stephengould.com and we will endeavor to delete that information from our databases.

Non-US Residents

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.

Your Choices

Opt-Out Links

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 and Similar Opt-Out Signals

SGC does not respond to “Do Not Track” settings or other related mechanisms at this time. We recognize the Global Privacy Control signal.

An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.

We recognize the Global Privacy Control signal and do so at the browser level. This means that if the signal is sent through a specific browser, we will recognize it for that browser only, and only with respect to the identifiers for that browser. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information (https://globalprivacycontrol.org/).

Changes To This Privacy Policy

This Privacy Policy is effective as of the last updated date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. By accessing the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information collected is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

How To Contact Us

If you have questions about this Privacy Policy, or require a copy of this policy in an alternative accessible format, please email our Privacy Administrator at privacyadministrator@stephengould.com with “Privacy Policy” in the subject line, or at the contact us at the following address:

Stephen Gould Corporation
Attn: Legal Department
5 Giralda Farms
Madison, NJ 07940

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