Last updated: 02/13/2019
We at Rabin Strategic Partners Inc, DBA Rabin Martin (“Rabin Martin”) respect your concerns about privacy. This Online Privacy Notice applies solely to information we obtain through the website on which a link to this Online Privacy Notice appears (“Site”). This Online Privacy Notice describes the types of information we obtain through the Site, how we may use the information, with whom we may share it and the choices you may have regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about your information and our privacy practices.
Information We Obtain
We may obtain the following categories and types of personal information when you choose to provide it through our Site or communicate with us using the contact details published on our Site:
• Contact information — such as your name, postal address, email address and telephone number;
• Site information — personal information you provide on or through our Site; and
• Biographical information — such as information about your education, work and military history, legal work eligibility status, and other information relevant to specific jobs for which you may apply.
In addition, when you visit our Site, we may collect certain information by automated means, such as cookies and web beacons. The information we obtain in this manner may include IP address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, and dates and times of website visits. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website and other actions taken on such website. As the visitor clicks through the website, a record of the action may be collected and stored. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Site.
An example of such third party is Google Analytics, which we use to collect and analyze demographic and other information, and through which Google will collect certain information to be used according to Google’s privacy practices. To opt-out of the use of Google Analytics, click here.
To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.
How We Use the Information We Obtain
We use the information we obtain through the Site to:
• respond to and communicate with you about your requests, questions and comments;
• operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analysing and enhancing our products, services and Site; and performing accounting, auditing, billing, reconciliation and collection activities);
• perform data analyses and other processing (including market and consumer research and trend analysis);
• protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
• comply with and enforce applicable legal requirements, relevant industry standards and our policies.
In addition, we use information collected online through cookies, web beacons and other automated means for purposes such as (i) customizing our users’ visits to our Site and (ii) providing services to you. We also use this information to help diagnose technical and service problems, administer our Site, identify users of our Site, and gather demographic information about our users. We use clickstream data to determine how much time users spend on web pages of our Site, how users navigate through our Site, and how we may tailor our Site to better meet the needs of our users.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
Information We Share with Third Parties
We do not sell or otherwise share personal information about you, except as described in this Online Privacy Notice.
• We share personal information with third parties who perform services on our behalf. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
• We also share the personal information we obtain with our affiliates and subsidiaries for the purposes described in the section of this Online Privacy Notice called “How We Use The Information We Obtain.”
• We may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
• We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, bankruptcy or liquidation).
We offer you certain choices about how we communicate with you and what information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the “How To Contact Us” section of this Online Privacy Notice.
We have put in place reasonable physical, electronic and managerial procedures to safeguard the information we collect; however, due to the inherent open nature of the Internet, we cannot guarantee that all information will be free from unauthorized access by third parties, such as hackers, and your use of the Site demonstrates your assumption of this risk.
We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for satisfying any legal, accounting or reporting requirements or to comply with our data retention practices.
Users from the European Union and Switzerland
If you are located in the European Union with rights under the General Data Protection Regulation (“GDPR”), the following additional sections apply:
- To the extent that Rabin Martin is subject to the laws of the European Union and Switzerland when processing personal data (“Personal Data”), it shall be the “data controller” under such laws.
- Grounds for Using Your Personal Information: we rely on the following legal basis to process your personal information:
• It may be necessary for us to use and disclose your personal information for the performance and fulfilment of the contract between us and to provide you with our services;
• We may use and disclose your personal information where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests;
• If you specifically consent to certain uses of your personal information, we may use your personal information in a manner consistent with that consent; and
• We will also process, transfer, disclose and preserve personal information when we have a good faith belief that doing so is necessary.
- If applicable pursuant to the GDPR, you have the right to withdraw previously provided consent for our processing of your personal information by contacting us at firstname.lastname@example.org. Such individuals also have the following rights:
• Right to access — This right allows individuals to obtain confirmation that his or her personal information is being process and allows individuals to request details of the processing of his or her personal information, including, without limitation, categories of recipients to whom the personal information have been or will be disclosed and purposes of processing.
• Right to rectify — This right allows individuals to rectify any inaccurate personal information about him or her.
• Right to restrict processing — This right allows individuals to block or suppress processing of personal information under certain circumstances.
• Right to be forgotten — This right is also known as the “right to erasure.” It is an individual’s right to have personal information erased or to prevent processing in specific circumstances.
• Right of data portability — This right allows individuals to move, copy or transfer personal information from one place to another in a secure manner without interrupting the integrity and usability of the information.
• Right to object to processing— This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
To exercise any of the following rights, you may contact us at email@example.com.
Some of the personal information we collect about you through the Site will be transferred to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Online Privacy Notice and will comply with applicable legal requirements.
Consistent with Privacy Shield Principles, Rabin Martin may transfer personal information to a third party. We will only disclose an individual’s personal information to third parties under the following conditions:
• Rabin Martin maintain written contracts with third parties and require that these third parties provide at least the same level of privacy protection and security as required by the Privacy Shield Principles. Third parties are obliged to notify Rabin Martin if they make a determination that they can no longer meet their obligations, and our written contracts provide that when such a determination is made, the third-party ceases processing or takes other reasonable and appropriate steps to remediate.
Rabin Martin remains responsible and liable under the Privacy Shield Principles if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield Principles, unless Rabin Martin proves that it is not responsible for the matter giving rise to the damage.
In compliance with the Privacy Shield Principles, Rabin Martin commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact Rabin Martin at: firstname.lastname@example.org
If an individual has an unresolved complaint or concern that is not addressed satisfactorily, that individual may contact our U.S. based independent alternative dispute resolution provider (free of charge), Judicial Arbitration and Mediation Services (JAMS). Please contact or visit JAMS here for more information or to file a complaint: www.jamsadr.com/international-mediation-rules.
You may have the option, under certain conditions, to select binding arbitration for complaints regarding Privacy Shield Panel compliance not resolved by any of the mechanisms listed above. For further information, please visit this section of the Privacy Shield website: www.privacyshield.gov/article?id=ANNEX-I-introduction.
Rabin Martin is also subject to the investigatory and enforcement powers of the U.S. Federal trade Commission.
Links to Other Websites
Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Rabin Martin. Linked websites typically have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with Rabin Martin, any use of those websites, or the privacy practices of those websites.
Updates to Our Online Privacy Notice
This Online Privacy Notice may be updated periodically. We will post a prominent notice on our Site to notify you of any significant changes to our Online Privacy Notice and indicate at the top of the notice when it was most recently updated.
How to Contact Us
If you have any questions about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by email at email@example.com or write to us at:
104 W. 40th Street, 3rd Floor
New York, NY 10018
WEBSITE TERMS AND CONDITIONS OF USE
By accessing the Site, you are agreeing to be bound by these Terms and Conditions of Use, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this web site are protected by applicable copyright and trade mark law.
2. Use License
a. Permission is granted to temporarily download one copy of the materials (information or software) on Rabin Martin web site for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:
i. modify or copy the materials;
ii. use the materials for any commercial purpose, or for any public
(commercial or non-commercial);
iii. attempt to decompile or reverse engineer any software contained
on Rabin Martin web site;
iv. remove any copyright or other proprietary notations from the
v. transfer the materials to another person or “mirror” the materials
on any other server.
b. This license shall automatically terminate if you violate any of these restrictions and may be terminated by Rabin Martin at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.
The materials on Rabin Martin web site are provided “as is”. Rabin Martin makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties, including without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. Further, Rabin Martin does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its Internet web site or otherwise relating to such materials or on any sites linked to this site.
In no event shall Rabin Martin or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption,) arising out of the use or inability to use the materials on Rabin Martin’s Internet site, even if Rabin Martin or a Rabin Martin authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.
5. Revisions and Errata
The materials appearing on Rabin Martin web site could include technical, typographical, or photographic errors. Rabin Martin does not warrant that any of the materials on its web site are accurate, complete, or current. Rabin Martin may make changes to the materials contained on its web site at any time without notice. Rabin Martin does not, however, make any commitment to update the materials.
7. Governing Law
Any claim relating to Rabin Martin web site shall be governed by the laws of the State of Tennessee without regard to its conflict of law provisions.
8. How to Contact Us
If you have any questions about this Website Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by:
• sending an email to firstname.lastname@example.org; or
• calling us on: 212-365-7460; or
• sending us a letter with Attention to DPO to 104 W 40th Street, 3rd Floor, New York, NY 10018