PRIVACY POLICY
Last Updated: January 14, 2021.
Leavitt Partners, LLC and its subsidiaries and affiliates (collectively, “Leavitt Partners”, “us” or “we”) understand that your privacy is important to you. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Privacy Policy describes how we handle and protect your personal data in connection with Leavitt Partners’ business activities, client services, and on websites, applications, and communications that post a link to this Privacy Policy (collectively, “the Sites”), in our capacity as data controllers.
Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.
Please see our Terms of Use for more information about our online terms and policies in general.
Information we collect
Leavitt Partners collects personal data in the course of its business activities, including in connection with some client services. We also collect personal data on certain areas of the Sites when you create a user profile, register for Leavitt Partners’ newsletters, view white papers, and/or alerts, sign up for conferences and events, and/or participate in public user posting areas (such as bulletin boards, discussion forums and surveys). The personal data collected varies and may include information that you provide, such as your name, title, company, industry type, mailing address, e-mail address, telephone number and/or fax number.
We may also automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include IP addresses, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and/or other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected may be associated with a unique identifier as well as with any other personal data you have provided.
Leavitt Partners may also collect personal data about you from third parties, such as data brokers or aggregators, in the course of its business activities including in connection with some client services. This includes demographic, professional and other information that is publicly available online, including information you choose to make public through social media platforms and other public online forums. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities (e.g., analysis of recruiting practices across an industry, detecting fraud patterns in connection with financial transactions). We will always seek to confirm that the third party has provided transparent information about its use of this data, including its disclosure to third parties like Leavitt Partners in compliance with applicable law.
Google Analytics
We use a tool called “Google Analytics” to collect information about use of this Site. Google Analytics collects information such as how often users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics only to improve this Site. Google Analytics collects only the IP address assigned to you on the date you visit this Site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this Site by disabling cookies on your browser. Site users who do not want their data collected with Google Analytics can install the Google Analytics opt-out browser add-on from Google.
Use of information
Leavitt Partners uses your personal data to fulfill your requests for information, process your requests to participate in conferences and events, personalize content that you view or receive on the Sites, evaluate and improve our services, distribute newsletters and alerts to you, analyze the Sites’ performance and functioning, publish your letters to the editor or comments, prevent fraud, enforce our terms of use, comply with all applicable laws and corporate reporting obligations, enforce Leavitt Partners’ agreements, and accomplish other purposes you may initiate or request. In some situations, the collection of personal data may be required for the operation of the Sites, or we may use it in the course of our business activities, including in connection with some client services.
We may combine and/or analyze personal data to evaluate and offer content and services most relevant to you. We may keep any of your personal data on file and use it to contact you.
Leavitt Partners and its service providers may use first- and third-party Cookies and Other Tracking Technologies, including web beacons, to manage our Sites and our services and collect analytics about how you use them. Leavitt Partners and its service providers may collect information about whether you open or click any links in the knowledge, research or event communications that we send to you. The information provided throughout this Privacy Policy about cookies also applies to these other tracking technologies. Please refer to the above for more details regarding our use of Cookies, including Google Analytics.
Our Sites do not track you by collecting personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.
The legal basis by which we process your personal data
Our processing of your personal data for the purposes mentioned above is based:
- in part, on our legitimate interests in promoting and protecting Leavitt Partners, building and maintaining relationships. recruitment, and providing our services;
- in part, on your consent, for example if you create a user profile, or register for our newsletters or alerts, or download White Papers, or for business purposes that support web operations such as understanding and enhancing the quality of your experience on our websites;
- in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.
Disclosure of personal data: data recipients and international data transfers
Personal data collected in the course of Leavitt Partners’ business activities, including in connection with some client services, as well as on the Sites may be transferred from time to time to Leavitt Partners’ subsidiaries and affiliates and their personnel across our organization, as well as to our third-party service providers located in multiple states and possibly other countries, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Sites may be viewed and hosted by Leavitt Partners and our third-party service providers anywhere in the world.
Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by Leavitt Partners’ subsidiaries, affiliates and third-party service providers, including the transfer of your personal data to countries other than the one in which you reside. By using any of the Sites and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information if applicable.
Leavitt Partners will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows:
- By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
- Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, recruitment, email delivery, hosting services, customer service, and marketing assistance.
- Marketing Communications
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
- Online Postings
When you post comments, contributions or other content to the Site, your posts may be viewed by all users and may be publicly distributed outside the Site in perpetuity.
- Affiliates
We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
- Sale or Bankruptcy
If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline to honor commitments we made in this Privacy Policy.
In addition, we may disclose information about you:
- To enforce our Terms of Use;
- To protect our property, services and legal rights;
- To prevent fraud against Leavitt Partners, our subsidiaries, affiliates and/or business partners;
- To support auditing, compliance, and corporate governance functions; or
- To comply with any and all applicable laws.
User forums
You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. Leavitt Partners is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.
Link to third party sites
Leavitt Partners may provide links to third-party websites or information as a service to our users. If you use these links, you will leave the Leavitt Partners site. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by Leavitt Partners of the third party, the third-party website, or the information contained therein, and Leavitt Partners shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.
Social Networking
The Sites may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube, with Leavitt Partners.
The information available in your public profile varies based on the social network and your settings, but may include your email address, real name, profile picture, gender, and location. If we receive any information from your social network account in accordance with the social network’s terms of use and this Privacy Policy, we will only utilize it in accordance with this Privacy Policy, our Terms of Use, and/or we will specifically inform you of any additional uses to which we may utilize the same. Please refer to the privacy settings in your social network account for information about what data is shared with Leavitt Partners and other connected applications and to manage the data that is shared through your account, including information about your activities using our Sites.
If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.
Security
Leavitt Partners has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized Leavitt Partners’ personnel and third-party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions however, Leavitt Partners cannot guarantee that unauthorized persons will not obtain access to your personal data.
Data retention
Leavitt Partners retains personal data, as necessary, for the duration of the relevant business relationship.
We may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, or comply with our information management policies and schedules. If you request that we delete your personal data, Leavitt Partners will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Rights” section of this Privacy Policy.
Children
The Sites are not designed for or directed at children 16 years of age or younger, and Leavitt Partners does not intentionally collect or maintain personal data about anyone under this age.
Leavitt Partners’ Recruitment Portal (Paycor)
Leavitt Partners utilizes Paycor for recruitment purposes (“Leavitt Partners’ Recruitment Portal”). Through the Leavitt Partners’ Recruitment Portal, you can apply for positions with Leavitt Partners that might be of interest. The Paycor Privacy Policy describes more in detail how Leavitt Partners, our subsidiaries and affiliates, and third-parties handle and protect the personal data that we collect in connection with the recruitment process.
Your Rights
Where granted by applicable law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.
If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at [email protected]. To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.
In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.
Unsubscribe
If you have registered for Leavitt Partner’s newsletter or alerts, or you receive invitations to survey or events from Leavitt Partners and you prefer not to receive future email communications from us, please follow the instructions on the page of the Site or email where you have provided such information, subscribed or registered, or write to [email protected] to unsubscribe from all Leavitt Partners’ communications.
Your California privacy rights
If you are a California resident under the age of 18, and a registered user of any of the Sites where this Privacy Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to [email protected]. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
As required by the California Consumer Privacy Act (CCPA), this Privacy Policy describes the categories of personal data collected, processed, and disclosed by Leavitt Partners, the categories of sources for that data, and the business or commercial purposes for which that data is collected, processed, and disclosed.
In addition, under California law, you may have the right (up to two times in any 12-month period) to request more information about Leavitt Partners’ collection, use, disclosure, and sale of personal data about you including:
- The categories of personal data about you that we have collected in the preceding 12 months and the categories of sources of that information,
- The categories of sources from which we have collected that information in the preceding 12 months,
- The commercial or business reason(s) we have collected, used, disclosed, or sold that information, and
- The categories of third parties to whom we have disclosed or sold that information in the preceding 12 months.
- In addition, upon receipt of a verifiable request from you establishing your identity, you may have the right to know about the specific pieces of personal data that we have collected about you and/or shared with third parties in the preceding 12 months.
You may also have the right to request deletion of personal data about you that we have collected or maintain, which we will honor subject to certain limitations set forth in California law.
If you are a California consumer and you or your authorized agent would like to exercise your privacy rights, please contact us at [email protected] , or call us at +1-801-538-5082. When we process your request, we require you to provide certain personal data about you in order to verify your identity in accordance with requirements under CCPA. This may include your first and last name, email address, physical address, telephone number, and information about your relationship with us or other information needed to verify your identity. Leavitt Partners will not discriminate against you based on your exercise of any of these rights.
Consent; changes to Privacy Policy
By using the Sites, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the Sites. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our Sites.
Contact us
If you have any questions about our Privacy Policy, please contact us at:
Leavitt Partners, LLC
Legal Department
299 South Main Street
Suite 2300
Salt Lake City, UT 84111
+1 801-538-5082