Last Updated: January 14, 2021.
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.
Use of information
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.
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.
- Sale or Bankruptcy
In addition, we may disclose information about you:
- 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.
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
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.
If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.
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.
Leavitt Partners retains personal data, as necessary, for the duration of the relevant business relationship.
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)
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 legal@LeavittPartners.com. 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.
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 legal@LeavittPartners.com to unsubscribe from all Leavitt Partners’ communications.
Your California privacy rights
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 Legal@LeavittPartners.com , 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.
Leavitt Partners, LLC
299 South Main Street
Salt Lake City, UT 84111