Effective November 1, 2022
- What personal information we collect about you from your use of the Site, why we collect it, who we share it with, and how long we keep it;
- How we use your personal information;
- How we protect your personal information; and
- Your legal rights related to the personal information we collect about you, including how to access and update your personal information.
- Please note that some of the provisions in this Policy will only apply to you if you are based in the European Economic Area (“EEA”).
- What Information We Collect About You
- Children’s Privacy
- How And Why We Use Your Information
- Cookies And Other Information Processing Technologies
- Who We Share Information With, And Why
- Transfer And Storage Of Your Information
- Securing Your Information
- Your Rights With Respect To Your Personal Information
- How Long We Retain Your Information
- Third Party Links On This Site
- Additional Information
WHAT INFORMATION WE COLLECT ABOUT YOU
Personal Information You Provide Voluntarily
Certain parts and functionality of our Site may ask you to provide information voluntarily. Galbraith collects and maintains personal information you provide to us when you:
- subscribe to Galbraith’s newsletter through the Site; or
- otherwise send us information through the Site.
The information we ask you to provide through the Site may include your name, e-mail address, phone number, address and other information you provide to us when you communicate with us through the Site.
You are never under any obligation to provide us your personal information
If you choose not to provide us your personal information, you can still browse the Site; however, you will not be able to use certain other services offered through the Site. Any personal information that we ask you to provide, and the reasons why we ask you to provide it, will be clear to you at the point we ask you to provide the information. In general, unless otherwise stated, the information you will be asked to provide is needed to provide you with the requested services and content through the Site.
When you visit and interact with the Site, we automatically collect and store certain information from your computer or device. In some countries, including those in the European Economic Area (“EEA”), and under certain laws, some of this automatically-collected information may be considered personal information. Automatically-collected information as described in this section allows us to better understand the visitors to our Site, where they come from, and what content on the Site is of interest to them. We use this information for our internal analytics purposes, to diagnose problems with our servers, and to improve the quality, performance and functionality of the Site and its relevance to our visitors.
The information we automatically collect when you visit the Site informs us about the device(s) you use to access the Site, as well as your usage of the Site, and may include: the internet protocol (“IP”) address from your computer or device, unique device identifiers, broad geolocation data (country or city level), the registered domain or home server you use, the date and time you access the Site, the type of device or computer, the web browser type and language, the type of operating system your computer uses, the website address you navigated to the site from, search terms, search results, and similar information regarding the interaction between the Site and your computer, such as pages visited and links clicked.
We use “cookies” and other website tracking technologies, such as “pixel tags”, to gather clickstream data and information about how visitors navigate the Site.
Our Site may provide features that allow you to register, sign-in to, “like”, “follow”, or otherwise interact with Galbraith via third party social media services, including, but not limited to, Facebook, Twitter, LinkedIn, and Pinterest, among others. These features may enable integration and/or access to your social media accounts. We do not control these social media services or your profiles on these services, and we do not establish privacy settings or rules for how your personal information on these services will be used. If you choose to sign-in to or submit information through any of these social media services, your personal information will be subject to the applicable social media service’s terms and conditions and your current privacy settings on such social media service. By accessing any social media service, you will be assuming the risk that the personal information you provide on that service may be viewed and/or used by third parties for any purpose.
Our Site is not directed at children under 16, and we do not knowingly (i) collect any personal information from children under 16; (ii) permit submission of personal information by anyone under age 16; or (iii) contact children under age 16 for marketing purposes. If we learn that we have received information from a child under age 16, we will use that information only to respond to directly to that child (or a parent or legal guardian of that child) to inform him or her that he or she cannot use the Site, and we will then delete that information from our files. If you are under age 16, you should not use this Site and you should not send us personal information about yourself. If you believe we might have information from or about a child under age 16, please contact us.
HOW AND WHY WE USE YOUR INFORMATION
Legal Basis for Processing Your Information
Our legal basis for collecting and using information from you will depend on the information concerned and the specific context in which we collect it.
We use the information that you disclose to us and automatically-collected information for the reasons described in this Policy. But generally, we will only collect personal information from you (i) where we need the personal information to perform a request for you, (ii) where the processing is in our legitimate interests, such as monitoring and improving the Site, and not overridden by your data protection interests or fundamental rights and freedoms, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. Additional details about how we use the information we collect are described below:
- To improve Site performance and user experience: We use the information you voluntarily provide to us, as well as automatically-collected information, to customize and tailor your experience using the Site. We also use the information collected through the Site to analyze trends and statistics, as well as to update and improve our Site and the services that we provide.
- To comply with our legal obligations: In certain situations we may use the information you voluntarily provide to us, as well as automatically-collected information, to help prevent fraudulent activity, as well as for preventing, investigating and detecting crime, fraud, or anti-social behavior, including working with law enforcement agencies. We also may use this information to comply with our legal and regulatory obligations, including under applicable data protection laws.
- For marketing purposes: If you request to be put on our newsletter, or otherwise provide your consent to receive marketing messages from us, we may use the information you voluntarily provide to us, as well as automatically-collected information, to send you announcements and other materials from time-to-time. More information about our marketing and advertising practices through the Site is described under the “Cookies And Other Information Processing Technologies” section, below, as well as in our Cookie Notice.
COOKIES AND OTHER INFORMATION PROCESSING TECHNOLOGIES
Marketing and Advertising. As Galbraith may use, or allow third parties to place, pixels, or transparent GIF files, to help manage online advertising for the Site. These technologies are provided by Galbraith’s advertising partners, to enable them to recognize a unique cookie on your Web browser, which in turn enables Galbraith to learn which advertisements bring users to the Site. We use this information to make our Site and services more interesting and useful to you. These advertising partners are not allowed to use information collected from the pixels for any reason except on our behalf, and they are required to keep that information confidential.
Analytics and Security. For analytical and security purposes we also use other tracking technologies on the Site such as server and application logs, which may record information such as internet domain and host names, IP addresses, browser software and operating system types, clickstream patterns, and dates and times that the Site is accessed.
Newsletter: As described above, if you request to be put on our newsletter, we will use the information that you give us to send you announcements and other materials from time to time. Each e-mail you receive from us will give you the option to unsubscribe from our newsletter. If you no longer wish to receive email communications from us, please click on the “unsubscribe” link provided in each email. Alternatively, you may email Galbraith at email@example.com. Please be sure to include in such email your full name, email address and specify what type of information you do not want to receive. If you request that we not contact you for marketing purposes (either by using the opt-out mechanism or contacting us), there may be occasions where we still contact you for non-marketing purposes relating to your other use of the Site.
WHO WE SHARE YOUR INFORMATION WITH AND WHY
We may disclose aggregated non-personal information about our Site visitors. This is information that does not identify you or any individual.
Purchasers or Successors in Interest
TRANSFER AND STORAGE OF YOUR INFORMATION
Your use of the Site may involve your personal information being transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
SECURING YOUR INFORMATION
We use commercially reasonable efforts to maintain the security, integrity, and privacy of any personal information you choose to give us and of automatically-collected information. We have security technology and procedures in place to try to ensure that all information stored on our database is secured against unauthorized access and use. For example, Galbraith uses firewalls and other security measures on this Site. You should not send us financial information or other sensitive information via email, and you should not attempt to place orders with us through this Site or via email, as this is not secure. In the event of an unauthorized use of your credit card, you should contact your card issuer immediately.
Information that you voluntarily make available for viewing by third parties online – for example in connection with postings, reviews, discussion forums or other community or social networking areas of our Site – can be seen, collected and used by others besides us. We are not responsible for any unauthorized third-party use of such information, and we are not responsible for maintaining the confidentiality of such information. We cannot control how users store, transfer, or use information gathered from our Site, so you should ensure that you do not post sensitive information to public areas of the Site.
YOUR RIGHTS WITH RESPECT TO YOUR INFORMATION
If you are a resident in certain territories (such as, but not limited to, the European Economic Area), subject to applicable local law, you have the following data protection rights:
- If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time as described in the “Updating & Correcting Personal Information” heading below.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information, or request portability of your personal information. You can exercise these rights by contacting us at firstname.lastname@example.org.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right at any time as described in the “Advertising and Marketing” section above, or by contacting us at email@example.com.
- If we collect and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You can exercise these rights by contacting us at firstname.lastname@example.org.
- If you are a resident of the European Economic Area, you have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area are available here.)
Your California Privacy Rights
California Civil Code § 1798.83 permits Site users who are California residents to request certain information regarding Galbraith’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or write to us at the address set forth below.
Updating & Correcting Personal Information
Site visitors may update or correct the personal information that they have provided to Galbraith by sending an email to firstname.lastname@example.org. Please note that some services offered through the Site may not function properly if we remove any or all of your personal information. If you want to ask us to delete your information from our database, please contact us at email@example.com. Please be aware, however, that if you update, modify or delete any information collected through our Site, we may retain residual information about you in backup and/or archival copies of our database.
Further, we may retain your information to comply with our retention practices described below. Finally, note that we may not accommodate a request to change or delete your information from our database if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Before responding to your request, we may ask you to verify your identity and/or provide further details about your request.
We provide the ability to opt out of marketing communications and to change or modify your personal information, regardless of your residency, as described in the sections above.
HOW LONG WE RETAIN YOUR INFORMATION
We will retain your personal information until you ask us to remove it from our databases, but otherwise for only as long as we need it to carry-out the purposes for which we collect and use it. Please note that it may be impossible to remove some information, such as information that may reside in backup files. We may also retain automatically-collected information even after you request that we remove your information from our database, for use in the aggregate and to analyze and improve our Site. Further, even after you request that we remove your information from our databases, we may retain personal information and automatically-collected information to comply with applicable laws, rules, regulations, or guidelines; to prevent fraudulent activity; to protect ourselves against liability; to resolve disputes; and to permit us to pursue available remedies and limit any damages that we may sustain.
When we have no ongoing legitimate business need to process your personal information, we will either delete it or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
THIRD PARTY LINKS ON THIS SITE
Our Site may contain links to websites operated by third parties that are not under our control or supervision. We are not responsible for the privacy practices of these websites. These websites may have their own cookies, privacy policies and customer service policies, or no policies at all. We encourage you to read the privacy policies of the other websites to see how your personal information will be handled on the third-party sites before providing them with your personal information or continuing to use the third-party websites and services. We are not, and shall not be deemed to be, responsible or liable for the privacy practices of such third parties, and your use of such websites is at your own risk.
Effective Date and Modifications
Questions or Comments