Last Updated: 6/21/2018
WHO WE ARE
Graham Allen Partners’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites is governed by the privacy statements of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.
Users may be subject to different protection standards and broader standards may therefore apply to some. In order to learn more about the protection criteria, Users can refer to the applicability section.
WHAT WE COLLECT
We get information about you in a range of ways.
Information You Give Us. We collect your name, email address as well as other information you directly give us on our Site through Contact Forms. When you register for or attend corporate events, the Company will ask you to provide basic contact information, billing information, and information on your participation in the events on the Company’s Web sites.
Information We Get From Others. We may get information about you from other sources. We may add this to information we get from this Site.
Information Automatically Collected. We automatically log information about you and your computer. For example, when visiting our Site, we log your computer operating system type, browser type, browser language, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site.
Cookies. We may log information using “cookies”. Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
USE OF PERSONAL INFORMATION
We use your personal information as follows:
We use your personal information to operate, maintain, and improve our sites, products, and services.
We use your personal information to respond to comments and questions and provide customer service.
We use your personal information to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
THE PURPOSES OF PROCESSING
The Data concerning the User is collected to allow the Company to provide its Services, as well as for the following purposes: Analytics, Managing contacts and sending messages and Contacting the User.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Company to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Site, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Contacting the User
Mailing list or newsletter (this Site)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Site. Your email address might also be added to this list as a result of signing up to this Site or after making a purchase or registering for an event.
Personal Data collected: email address, first name and last name.
Contact form (this Site)
By filling in the contact form with their Data, the User authorizes this Site to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email address, first name and last name.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
SHARING OF PERSONAL INFORMATION
We may share personal information as follows:
We may share personal information with your consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
We may share personal information for legal, protection, and safety purposes.
We may share information to comply with laws.
We may share information to respond to lawful requests and legal processes.
We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
We may share information with those who need it to do work for us.
We may also share aggregated and/or anonymized data with others for their own uses.
HOW LONG WE RETAIN YOUR DATA
Personal Information shall be processed and stored for as long as required by the purpose they have been collected for.
Personal Information collected for purposes related to the performance of a contract between the Company and the User shall be retained until such contract has been fully performed.
Personal Information collected for the purposes of the Company’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Company within the relevant sections of this document or by contacting the Company.
The Company may be allowed to retain Personal Information for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Company may be obliged to retain Personal Information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
THE RIGHTS OF USERS
Users may exercise certain rights regarding their Data processed by the Company.
Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Company to find out which rights apply to them.
In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Information.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Company, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Company will not process their Data for any purpose other than storing it.
Have their Personal Information deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Company.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Information is processed for a public interest, in the exercise of an official authority vested in the Company or for the purposes of the legitimate interests pursued by the Company, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Information be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Company is processing Personal Information for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Company through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Company as early as possible and always within one month.
APPLICABILITY OF BRAODER PROTECTION STANDARDS
Applicability of Broader Protection Standards
While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Information is subject to broader protection standards.
Such broader protection standards apply when the processing:
is performed by an Company based within the EU;
concerns the Personal Information of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
concerns the Personal Information of Users who are in the EU and allows the Company to monitor such Users’ behavior taking place in the EU.
INFORMATION CHOICES AND CHANGES
Information Choices and Changes
Our marketing emails tell you how to “opt out”. If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt out of our sharing with others, and update your personal information.
You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.