Privacy Policy
Effective Date: 1 January 2023
Scope
This Privacy Policy explains how we collect, use, share, store and otherwise process your personal data when you use our Site, our publications and our events. It also explains your rights under applicable data protection laws, including the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).
Reference in this Privacy Policy to “personal data” means any information relating to an identified or identifiable individual, such as name, contact details, and bank account details. Personal data does not include data from which an individual can no longer be identified, such as anonymized data.
To the extent the GDPR applies to the processing of your personal data and you are a visitor to the Site, the data controller for your personal data will be Newman Watson LLP (“NW”), unless we advise you otherwise. The data controller decides how personal data about you is used.
Information We Collect
During the course of providing professional services, including the browsing of its Site, NW may collect certain personal data. The types of personal data collected, and the purposes for which NW collects and process such data, depends on the nature of your interaction with us. In addition to the Automatically Collected Data described below, you may provide personal information if you use the Site to opt into certain marketing activities, if you use the Site to apply for a position with the firm or if you use the site to provide information requesting the firm contact you. You are not required to provide any personal information to access the publicly available portions of this website.
This Privacy Policy describes when we process your personal data for our legitimate interests, what these interests are and your rights. We will not use your personal data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law. “Legitimate interests” means our interests in conducting our business and managing and delivering the best services to you. Below please see the potential information that may be collected by NW and, per the GDPR, the legal basis under which we are allowed to use your personal data.
Information Collected When You Browse or Actively Interact with the Site
NW may collect personal data when you browse or otherwise interact with its Site. This includes information obtained through the use of Cookies. Please read our Cookie Policy to learn more about how we use cookies. Depending upon how you browse or interact with the Site, you may provide Automatically Collected Data or personal information you actively provide such as your name, title, gender, contact information and a description of yourself. Automatically Collected Data is data collected through the use of cookies and may also include Log Data. Log Data includes your IP address, browser type and setting and the data and time of your request. Log Data is information your browser automatically sends whenever you visit the Site. NW may then process this information it collects for various reasons such as getting to know those that visit its Site, administering services for and improving the Site, responding to your communications and certain statistical analytics.
Personal Data Provided by Actively Opting-In for Marketing Purposes
Should you provide personal data so that NW will include you in the provision of certain marketing materials, update or invitations to events, NW may process that data based upon that consent. Such data could include your name, title, gender, contact information, the company you work for, the position you hold and preferences with relation to such contact. Should you provide information based upon such consent, we will store that information until you notify us that you no longer wish to receive such communications or until we determine such information is no longer accurate.
Personal Data Provided by Applying for a Position with NW through its Site
Should you apply for a position with the firm through the Site, NW may have access to your CV or Resume. This may include past employers, relevant skills/experience and contact information for yourself. You may also provide information related to any special requirements you may require as part of the position, relating to a disability or health issue. NW may process this information based upon your consent in providing it as the parties go through the application or hiring process. NW may also process that data based upon its legitimate interests in fulfilling its staffing requirements and ensuring potential employees are qualified for the positions for which they are being chosen. Finally, NW may process the information provided based upon a legal obligation to verify your right to work or when required by law.
What If You Do Not Provide the Personal Data We Request?
Should NW need your personal data to comply with legal obligations or to perform under the circumstances above, failure to provide scuh data may impact our ability to provide our services.
Transferring Information including International Data Transfers
For the purposes described herein, we may transfer your personal data to an office or a third party, including a transfer outside of the European Economic Area (defined as the EU Member States plus Iceland, Liechtenstein and Norway) or Switzerland to a jurisdiction not subject to an adequacy decision of the European Commission. If the recipient is not located within a country considered to be ensuring an adequate level of protection, NW will execute data transfer agreements pursuant to standard contractual clauses of the GDPR to ensure appropriate safeguards for such transfers. When we transfer your personal data to other third parties we will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure the integrity and protection of your personal data wherever processed. We may use various third parties to operate the website, including, for example, our providers of professional, consulting, marketing and communications and development services. NW may disclose your personally identifiable information to such entities, and these parties may access, process and store such data, solely as needed for them to perform their specific tasks pursuant to our instructions and subject to the terms of this policy.
Transfers Required by Law or Pursuant to a Change in Rights or Control
Additionally, NW may disclose personal data as required by law or when we believe that such disclosure is necessary in connection with a judicial proceeding or to comply with a court order, law or regulation applicable to us or the Site; or as NW may determine to be necessary to protect our property or assert our legal rights or to protect the property or safety of another person.
Finally, NW may disclose and transfer personal data to a third party: (a) if we assign our rights regarding any of the information to a third party or (b) in connection with a corporate merger, consolidation, restructuring, sale of certain of our ownership interests, assets, or both, or other corporate change, including without limitation, during the course of any due diligence process.
In both of the above cases, when we transfer your personal data to other third parties we will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure the integrity and protection of your personal data wherever processed. If the recipient is not located within a country considered to be ensuring an adequate level of protection, NW will execute data transfer agreements pursuant to standard contractual clauses of the GDPR to ensure appropriate safeguards for such transfers.
Retaining Your Personal Data
NW shall retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws or until you withdraw your consent (where applicable). To determine the appropriate retention period for your 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 use your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
We do not collect more personal data than we need to fulfil our purposes stated in this Privacy Policy. We may retain your personal data for an additional period to the extent deletion would require us to overwrite our automated disaster recovery backup systems or to the extent we deem it necessary to assert or defend legal claims during any relevant retention period.
Your Rights in Relation to Your Personal Data under GDPR
Subject to the applicable provision of the GDPR, you have the following rights with respect to your personal data:
If we rely on your consent to process your personal data, to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place before withdrawal of your consent.
To access your personal data (commonly known as a “data subject access request”) along with certain other details in relation to its processing (if you require additional copies, we may need to charge a reasonable fee).
To rectify your personal data if it is inaccurate or incomplete.
To have your personal data erased if it is no longer necessary for the purposes for which it was processed; you have withdrawn your consent where previously given and there is no other legal ground for processing; you object to its processing for direct marketing purposes; or you object to the processing of your data based on a legitimate interest (described above) and there is no other overriding legitimate grounds for processing; or you consider it to have been unlawfully processed.
To have the processing of your personal data restricted in certain circumstances, such as if you contest its accuracy or object to us processing it.
To have your personal data transferred to another company in a commonly used format, if you consented to give your personal data to us or it was provided to us as necessary in connection with our contract with you and if the processing is carried out by automated means.
To object to the processing of your personal data, and we will cease processing it if (a) we are relying on a legitimate interest to process your personal data, unless we demonstrate compelling legitimate grounds for the processing or (b) we are processing your personal data for direct marketing.
To lodge a complaint with your national data protection authority if you have a concern about our privacy practices, including the way we handle your personal data.
Your Rights in Relation to Your Personal Data under CCPA
The CCPA provides certain privacy rights and protections to California consumers. Details may be found at https://oag.ca.gov/privacy/ccpa . NW does not intend to retain, use, or disclose any Personal Data that, under CCPA, constitutes “personal information” for any purpose other than for the specific purposes discussed herein, including for direct marketing, or as otherwise permitted by CCPA, including retaining, using, or disclosing the information for a commercial purpose (as defined in CCPA). NW will not sell any personal information of California consumers, nor retain, use or disclose such information for any purpose other than for the specific purpose provided under the Agreement. NW’s access to the personal information of California consumers does not constitute part of any consideration exchanged between NW and you should we enter into an agreement for services.
Data Security
To prevent unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and to ensure the correct use of information, NW employs physical, technical and administrative procedures to safeguard its Site and the Personal Data it collects online. However, transmission of information through the internet is not secure. Although we seek to protect your information as described above, we cannot guarantee the security of any information you transmit to the Site or to us, and you transmit such information at your own risk.
Personal Data of Children
Our Site is not directed to children who are under the age of 13 and is directed to adults only. NW does not knowingly collect personal data from children under 13. IF YOU ARE UNDER THE AGE OF 13, PLEASE DO NOT PROVIDE NLG ANY PERSONAL INFORMATION. If you have reason to believe that a child under the age of 13 has provided personal data to NW through the Site please contact us and we will delete that information from our databases.
Links To Third Party Sites
Our Site may contain links to other sites operated by third parties “Third-Party Sites”. NW is not responsible for information on these Third-Party Sites, nor for services or products offered by them. By providing these links we do not endorse these Third Party Sites. Use of these Third Party Sites, including transmitting your personal data to them, is at your own risk. The information that you share with these sites will be governed by the specific privacy policies and terms of service of these Third Party Sites and not by this Privacy Policy. Please contact those sites directly for information on their privacy practices and policies.
Changes to this Privacy Policy
NW reserves the right to amend this Privacy Policy from time to time to ensure it provides an appropriate level of protection to your personal information and to keep current with industry standards. Any such changes will be posted on this Site and will be effective upon posting. Check this page to make sure you’ve reviewed our current policy.
How to Contact Us
If you have any questions about our Privacy Policy, or if you would like to access personal data we hold about you or exercise your other rights under the applicable law, please contact us at Newman Watson, 1337 Massachusetts Ave. #281, Arlington, MA 02476.
Please also refer to our Cookie Policy, which explains the use of cookies via our Site.