We may collect the following Personal Data when you visit the Website or otherwise provide us with Personal Data in connection with the Website:
a) Personal Data you provide when you complete forms available on the Website;
(b) Personal Data you provide when you contact us;
(c) Details of visits to the Website, including the volume of traffic received, logs and the resources that you have accessed and the devices you have used to access such information;
(d) Personal Data you provide in connection with your application for employment with Caldwell;
(e) Personal Data related to your attendance at a Caldwell event and/or use of the Caldwell IP LLC Alumni Network; and
(f) Personal Data relating to you or your employees and officers that you provide to us to enable us to provide services to you and to comply with our legal obligations (including with respect to know your customer requirements and anti-money laundering screening).
- Identifiers, such as name, contact details and address (including physical address, telephone number, email address and Internet Protocol address, which we may use to identify your geographic location);
- Professional information, non-public education information and certain information related to protected classification characteristics (e.g., age, race and gender) collected in connection with our recruiting activities or your participation in our alumni network and related events;
- If you are an alumnus or alumna of Caldwell and you elect to use our alumni website, the Website may allow you to provide us with a photo of yourself which constitutes biometric information under applicable privacy laws; and
- Internet or other electronic network activity information, such as information regarding your use of the Website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to your inquiries.
How we obtain your Personal Data
In connection with operating the Website, we obtain your Personal Data from the following sources:
- Information from your communications with us in connection with the Website or other services, events, publications or programs that we are offering, including any updates to such information provided by you;
- Information captured on the Website, including information provided by you through online forms and any information captured via cookies;
- Information that you provide us at the start of our engagement with you, or during the course of us providing services to you;
- Information that you provide us in conjunction with your application for employment; and
- Information that we collect from publicly available sources. This will generally include information collected in an online or offline context.
How we use your Personal Data
We use your Personal Data for one or more of the following business purposes and pursuant to the corresponding legal bases:
|To understand your needs and provide you with better service||(a) Performance of a contract with you
(b) Necessary for our legitimate interests in providing a service to you
|To improve the Website and to notify you about changes to the Website||Necessary for our legitimate interests in providing a service to you and other clients|
|To communicate with you, including responding to requests for information submitted by you through the Website or to notify you of services we provide, events that we are hosting, employment opportunities, or publications that may be of interest to you||(a) Consent provided by you in opting into such communications (where relevant)
(b) Performance of a contract with you
(c) Necessary for our legitimate interests in providing a service to you
|To keep a record of your relationship with us||(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
|To evaluate and respond to your application for employment with Caldwell||(a) Steps taken prior to entering into a contract with you
(b) Necessary for our legitimate interests in providing employment opportunities
|To enable other alumni network members to search for and locate you via our internal alumni directory||Necessary for our legitimate interests in supporting our alumni network|
|To research and analyze users’ demographic characteristics, interests and behavior in an aggregated form in order to better understand and serve our users and improve the Website and its offerings||Necessary for our legitimate interests in supporting our alumni network|
|For ongoing operations, administrative, accounting, reporting, account maintenance and other processes||(a) Necessary for our legitimate interests in providing a service to you
(b) Necessary to comply with a legal obligation
|To audit and verify the quality and effectiveness of the Website, services and compliance||(a) Necessary for our legitimate interests in providing a service to you and other clients
(b) Necessary to comply with a legal obligation
|To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity||Necessary to comply with a legal obligation|
|To generally comply with U.S., state, local and non-U.S. laws, rules and regulations||Necessary to comply with a legal obligation|
Please note that we may process your Personal Data for more than one legal basis depending on the specific purpose for which we are using your Personal Data.
With whom we share your Personal Data
We do not sell or rent any of the Personal Data we collect about you to third parties.
Transfer of Personal Data Under the GDPR
Links to third party websites
Data subject rights under European data protection legislation
Special Categories of Personal Data: We may collect special categories of Personal Data about you for which we act as a data controller when we collect Personal Data in this manner. Special categories of Personal Data may include certain demographic information about you such as race, ethnicity and sexual orientation. For example, we may collect information about your race, ethnicity and sexual orientation when you apply for a job with us if you choose to disclose such information. We may also collect information about prior criminal convictions and offences in connection with your application for employment with Caldwell, and other special categories of Personal Data as part of background checks that we conduct on job applicants and/or clients and as part of providing services on behalf of our clients. If you provide us with, or we collect, any special categories of Personal Data, or criminal conviction data, on yourself, we will separately ask you for consent before we agree to the processing of such Personal Data.
Automated Decision-Making: No automated decision-making, including profiling, is used when processing your Personal Data.
Data Retention: We will retain your Personal Data only for so long as we need the Personal Data for the purposes it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required under applicable law or requested by you. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- Access: You have the right to ask for a copy of the Personal Data that we hold about you free of charge, however we may charge a “reasonable fee” if we think that your request is excessive, to help us cover the costs of locating the Personal Data you have requested. We will respond to your request as soon as possible and (save for in certain circumstances) within one month.
- Correction: If there are any inaccuracies in the Personal Data we hold about you, please contact us and we will correct them.
- Deletion: If you think that we should not be processing your Personal Data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that we restrict our processing of your Personal Data (other than storing it), if: (i) you contest the accuracy of it (unless the accuracy is verified); (ii) you believe the processing is against applicable law; (iii) you believe that we no longer need your Personal Data for the purposes for which it was collected (and so may otherwise amend or delete your Personal Data), but you still need your data to establish, exercise or defend a legal claim; or (iv) you have objected to the processing (as set forth in the bullet immediately below) and we are verifying whether our legitimate grounds to process your Personal Data override your own rights. In such circumstances, we will only process such Personal Data based on your consent (including not deleting it). However, in certain situations, we may override this right to restriction, either with your consent, to establish, exercise or defend legal claims, to protect the rights of others, or for public interests purposes. We will inform you where such exemption applies or where the restriction is no longer available.
- Object: You have the right to object to the processing of your Personal Data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Data which override your rights and freedoms.
- Request the transfer: If you wish to transfer your Personal Data to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means. Please note that this right only applies to automated Personal Data which you initially provided consent for us to use or where we used the Personal Data to perform a contract with you.
- Withdrawal of consent: If you previously gave us your consent to allow us to process your Personal Data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Complaints to Supervisory Authorities: You also have the right to make a complaint at any time to the competent data protection supervisory authority in your jurisdiction if you do not agree with the manner in which we have processed your Personal Data or responded to your requests in relation to your Personal Data. If you are based in: (i) the United Kingdom, this authority if the UK Information Commissioner’s Office (https://ico.org.uk/). We always appreciate the chance to deal with your concerns before you approach any such authority so please contact us in the first instance using the contacts in Section 14 (“Contact”).
You can confirm your Website cookie preferences through the interface in the cookies banner provided on the homepage of the Website. You can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence, or refuse all cookies by turning them off in your browser. Cookies are required to select text size preferences within the Website. If you refuse certain cookies, you may not be able to access certain parts of the Website or use the full functionality of the Website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.
As previously stated, we will also provide you the opportunity to let us know if you do not wish to receive unsolicited direct marketing materials from us.
Our commitment to data security
We consider the protection of Personal Data to be a sound business practice, and to that end we employ commercially appropriate organizational, physical, technical, and procedural safeguards and measures to protect your Personal Data in our possession or under our control, to the extent possible, from unauthorized or accidental access and improper use.
Unfortunately, the transmission of information via the Internet is not completely secure, and we cannot guarantee the security of your Personal Data transmitted to or through the Website; any such transmission is at your own risk. Once we have received your Personal Data, we will use the procedures and security features described above to try to prevent unauthorized access of your Personal Data.
Notice to California residents of certain rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your Personal Data that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing and provide an explanation if we cannot comply with a specific request.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of Personal Data specific to you over the last twelve (12) months. Such information includes:
- the categories of Personal Data we collected about you;
- the categories of sources from which the Personal Data was collected;
- our business or commercial purpose for collecting such Personal Data;
- the categories of third parties with whom we share the Personal Data;
- the specific pieces of Personal Data we collected about you; and
- whether we disclosed your Personal Data to a third party, and, if yes, the categories of Personal Data that each recipient obtained.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
Our commitment to children’s privacy
We do not seek to collect or maintain information (including Personal Data) on the Website from those we know are under the age of 18, and no part of the Website is structured to attract anyone under the age of 13. If we learn we have collected or received Personal Data from an individual under the age of 13, we will delete that Personal Data.
For any questions regarding our processing of your Personal Data, or requests relating to the exercise of your rights under the GDPR, CCPA or other applicable data protection laws, please submit (or have your authorized representative submit) a request using any of the methods set forth below.
Call us using the following toll-free number: +1-617-577-3963.
Email us at the following email address: [email protected].
If you are submitting a request pursuant to the GDPR, CCPA or other data protection laws, we will contact you to confirm receipt of your request and request any additional information necessary to verify your request (which may include verification of the requestor’s identity ourselves or using a third party service). We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such request (for example, the risk of responding to a fraudulent or malicious request), we may request further information in order to verify your request. We also reserve the right to verify your request through a third party verification service. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you satisfy certain requirements set forth in the CCPA for such authorized agent to make a request on your behalf. We may verify such authorized person’s identity using the procedures above.
Updated July, 2022