Lehrer Cumming Privacy Policy

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This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in U.S. privacy law and information security standards, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. This policy also addresses Lehrer Cumming’s adherence to the California Consumer Privacy Act (CCPA). Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect, or otherwise handle your Personally Identifiable Information in accordance with our website.

What personal information do we collect from people who visit our website?

When completing a contact form on our site, you may be asked to enter your name, email address, phone number, or other details that help us improve your experience.

When do we collect information?

We collect information from you when you fill out a form or enter information on our site.

How do we use your information?

We use your information in the following ways:

  • To provide more relevant and helpful responses to your service requests.
  • To follow up with you after correspondence.
  • To improve our website in order to better serve you and other visitors.

How do we protect your information?

Our website only provides articles and information, and therefore does not request secure information from visitors. We do not take payment information or ask for credit card numbers, and we do not utilize vulnerability scanning. We do use regular malware scanning and utilize an SSL certificate.

Do we use ‘cookies’?

We use cookies for tracking purposes. Please see subsection titled “Google.”

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.

If you turn cookies off, all features that make your site experience more efficient will still function properly.

Third-party disclosure

We do not sell, trade, or otherwise transfer your Personally Identifiable Information to outside parties.

Third-party links

We do not include or offer third-party products or services on our website.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users and can be viewed here: https://support.google.com/adwordspolicy/answer/1316548?hl=en

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

  • Demographics and Interests Reporting

We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie), as well as other third-party identifiers, to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Opting out

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt-out page or by using the Google Analytics Opt-out Browser add-on.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly what information is being collected and the individuals or companies with whom it is being shared. See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:

Users can visit our site anonymously. Once this privacy policy is created, we will add a link to it on our home page or, at a minimum, on the first significant page after entering our website. Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above. You will be notified of any Privacy Policy changes on our Privacy Policy page. You can change your personal information by emailing us.

How does our site handle Do Not Track signals?

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

It is important to note that we do not allow third-party behavioral tracking.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission — a U.S. consumer protection agency — enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under the age of 13 years old.

Fair Information Practices

The principles outlined in the Fair Information Practices form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practices and how they should be implemented is critical in complying with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices, we will take the following responsive action, should a data breach occur:

We will notify users via in-site notification within seven business days.

We also agree to the Individual Redress Principle, which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

  • Send information and respond to inquiries and/or other requests or questions.
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CAN-SPAM, we agree to the following:

  • We will not use false or misleading subject lines or email addresses.
  • We will identify the message as an advertisement in some reasonable way.
  • We will include the physical address of our business or site headquarters.
  • We will monitor third-party email marketing services for compliance, if one is used.
  • We will honor opt-out/unsubscribe requests quickly.
  • We will allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at info@ccorpusa.com.

Also, you can follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

California Consumer Privacy Act of 2018

The California Consumer Privacy Act of 2018 grants to a consumer various rights with regard to personal information relating to that consumer that is held by a business, including the right to request a business to delete any personal information about the consumer collected by the business, and businesses are required to comply with a verifiable consumer request to that effect. The Act also requires a business that collects personal information about a consumer to disclose, on its website or in its online privacy policy or policies, the consumer’s right to delete said personal information.

The sections below outline the categories of information that are collected by Lehrer Cumming, the manner in which the information is used, and the steps required to review and request the removal of an individual’s personal information from Lehrer Cumming’s systems and databases. Although Lehrer Cumming shares selected personal information with certain service vendors as necessary for specified business purposes as set forth in our written agreements with such service vendors, Lehrer Cumming NEVER sells information collected on its customers to other companies or individuals.

Types of Information Collected

The table below outlines the types of information collected by Lehrer Cumming, where and how the information is collected, and the purpose for its use.

Categories & Types of Information Where and How Collected Usage
DIRECT FROM CONSUMER
Full name Online through Lehrer Cumming’s contact form To communicate effectively and accurately with the person submitting the contact request.
Company Online through Lehrer Cumming’s contact form To understand whether someone is affiliated with a current client, partner, or affiliate, which then helps us communicate more effectively and accurately.
Email address Online through Lehrer Cumming’s contact form To communicate effectively and accurately with the person submitting the contact request.
JOB APPLICANTS
Name, contact information Online through our career opportunities portal accessed here: https://careers-cummingcorporation.icims.com/jobs/ To be able to contact the applicant
Race/ethnicity information Online through our career opportunities portal accessed here: https://careers-cummingcorporation.icims.com/jobs/ To comply with EEO reporting requirements
Information on work history and education Online through our career opportunities portal accessed here: https://careers-cummingcorporation.icims.com/jobs/ To be able to assess qualification for the role
Information concerning any criminal conviction or similar matters appearing on a background check report Online through our career opportunities portal accessed here: https://careers-cummingcorporation.icims.com/jobs/ To assess suitability for hiring
Information on work history and education Online through our career opportunities portal accessed here: https://careers-cummingcorporation.icims.com/jobs/ To be able to assess qualification for the role
INDEPENDENT CONTRACTORS
Name, contact information To be able to contact the contractor
Social security number To administer employment relationship and establish right to work in U.S.
License plate of vehicle Parking administration
Bank details Invoice/accounts payable administration
Image of face, audio of voice (photo for company directories) To monitor adherence to company policies
Username and password to company network and other systems, if applicable To administer contractual relationship
Online and other activity on company-owned computer and mobile devices, if applicable To monitor adherence to company policies

Request to Know

To view any of your personal information from the above categories that may be contained in our system, please email us at info@ccorpusa.com, or file a request through our online form here. You will be required to provide your full name and email address for verification purposes. We will acknowledge receipt of your request within 10 days and results from our search will be provided within 45 days. The requested information will only be provided if both your full name and email address align with the information included in our system.

Request to Remove

The California Consumer Privacy Act of 2018 grants individuals the right to have their personal information removed from our system. In a similar manner to the process for reviewing your information above, you may also request to have any or all of your personal information completely removed from our system. Please contact us at info@ccorpusa.com  or file a request through our online form here to request the removal of your information. We will acknowledge receipt of your request within 10 days and the requested information will be removed within 45 days. The request will only be executed if both your full name and email address align with the information included in our system. You will be notified by email once the information has been removed.

Nondiscrimination

Lehrer Cumming does not discriminate against consumers exercising their CCPA rights. We will not charge a different price, deny services, or impose penalties on a consumer who exercises his or her rights under the CCPA.

For More Information

For more information onLehrer Cumming’s policies surrounding the review and removal of personal information under the California Consumer Privacy Act of 2018, please contact Terry McDonald at tmcdonald@ccorpusa.com.

Contacting Us

If there are any questions regarding our privacy policy, you may contact us using the information below.

Lehrer Cumming
888 Seventh Avenue, 2nd Floor
New York, NY 10019
United States
info@ccorpusa.com

Last updated on 2020-02-05

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