Privacy Policy

Schellman Compliance, LLC and its subsidiaries, divisions, affiliates, and related entities ("we," "us," or "Schellman") recognize the importance of protecting the privacy of your personal information and want you to be familiar with how we collect, use and disclose the information you provide by engaging our services on the website, mobile website, social media site, software, email exchanges, mobile apps, and other online services on which this Privacy Policy is posted, including but not limited to any services, features, pages, and functions contained or offered therein, and any transactions, orders, sales, purchases, or acquisitions of goods, products, or services (the “Service”).

Your use of the Service is conditioned on your agreement with this Privacy Policy and our Terms of Use. Please read the Privacy Policy and Terms of Use carefully before using our Service or making any transaction, order, or purchase. By making any transaction, order, or purchase or by visiting or otherwise using the Service in any manner, you acknowledge and accept without limitation or qualification, that you have read and understood the Privacy Policy and Terms of Use and you agree to be bound by them.

This Privacy Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Privacy Policy. To the extent any translated versions of this Privacy Policy conflict with the English language version, the English language version of this Privacy Policy shall control.

If you have any questions or comments about the Privacy Policy or our privacy practices, please contact us by email at privacy@schellman.com.

Collection of Personal Information

Schellman will collect personal information from you directly when you interact with our Service, contact us for any reason, use our services, create an account, subscribe to any service including our blog, share reviews, sign up to receive offers or emails from us, join our mailing list, submit resumes or work history, or retain our services.

When you use our Service we collect certain information about you automatically through our use of cookies (more information about our use of cookies follows later in this Privacy Policy) and similar technologies such as standard internet log information and usage information, including your IP address, browser type and language, access times, location, usage data, and referring website addresses.

We collect the following categories of personal information: (1) contact information including your name, email address, street address, city, state, zip code; (2) authentication information, including the user name and password that you use to register an account; (3) comments, reviews, suggestions; (4) personal characteristics including gender, race/ethnicity, and nationality; (5) personal preferences including service preferences, online preferences, and interests; (6) professional and employment information including details contained in your resume or CV or other information you may choose to voluntarily submit to us in connection with your application; (7) online behavior information including online activity, preferences, and time spent viewing features; and (8) IP address or mobile network information.

We take commercially reasonable measure to ensure we collect and process the minimum amount of personal information from you that is necessary to conduct our business, provide you with web-based and mobile applications, communicate with you, customer support, user verification, provide you with information on our services and content, website maintenance and improvements, and comply with legal requirements.

Use and Disclosure of Information

Schellman may store and use your personally identifiable information for (i) product or service fulfillment, (ii) voluntary marketing, promotional, and advertising purposes, such as to inform you of products or services available from us, (iii) internal operations, such as improving your customer experience – this includes auditing current interactions and optimizing user experience, (iv) detecting security incidents, protecting against malicious, deceptive activity, and taking all necessary and appropriate steps to mitigate current and future risk; (v) debugging and repairing internal information technology as necessary; (vi) undertaking internal research for technological development and demonstration; and (vii) to share with trusted third party service providers to help us perform activities to improve your customer experience with your consent.

Third parties are prohibited from using your personally identifiable information beyond providing services to us and are required to maintain the information’s confidentiality and privacy. Schellman does not trade, rent, or sell your personal information to third parties.

We may also share or disclose your personal information for the following limited purposes:

• With Schellman & Company, LLC as necessary to evaluate and perform services and related activities.
• With third party service providers who perform services and functions on our behalf to support our interactions with you. These service providers may assist with technical operation of our Service, provide analytics, process orders, transactions and payments, or provide customer service. We may also share non-identifying information, such as aggregate statistics or usage information, with third parties.
• As required by applicable law, statute, rule, regulation or professional standard, or through subpoena, search warrant or other legal process.
• For regulatory compliance purposes.
• When explicitly requested or consented to by you.
• When required to deliver publications or reference materials requested by you.
• For administrative or maintenance purposes related to the Service.
• With third party providers to deliver gifts and other items to you as a gesture of goodwill and appreciation.

Unless otherwise required by law, the personal information we collect will only be retained for so long as the information is needed for our professional, marketing, or analytic purposes or to comply with your request, or until you ask for the information be deleted.

As with any other business, Schellman may merge with or be purchased by another company. If Schellman is acquired, the company that acquires us would have access to the information maintained by us, including personally identifiable information, but would continue to be bound by this Policy unless and until it is amended.

Children’s Privacy: No Users Under Eighteen Years of Age

Schellman’s Services are not targeted for use by children. Schellman will never knowingly request or collect personal information from any child. If you are under eighteen years old, please do not provide your information through our Service. Upon notification that a child has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records. If you believe we might have any information from a child, please contact us at privacy@schellman.com.

In addition, if you are a California resident under the age of eighteen, while we do not allow users under the age of eighteen and you should notify us so we may delete your information, specifically, you may request us to remove content or information posted on our websites or stored on our servers by (a) submitting a request in writing to privacy@schellman.com, and (b) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed. However, please note that we are not required to erase or otherwise eliminate content or information if (i) other state or federal laws require us or a third party to maintain the content or information; (ii) the content or information was posted, stored, or republished by another user; (iii) the content or information is anonymized so that the minor cannot be individually identified; (iv) the minor does not follow the instructions posted herein on how to request removal of such content or information; or (v) the minor has received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or information.

Security

The security and confidentiality of your personal information is important to us. We follow reasonable commercial standards for organizational, technical, and administrative measures to protect the personal information submitted to us, both during transmission and once it is received.

Please be advised, however, that while we take reasonable security measures to protect your personal information, such measures cannot be guaranteed to be secure. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your personal information.

The security of your account relies on your protection of your user profile information.

You are responsible for maintaining the security of your user profile information, including your password and for all activities that occur under your account. You may not share your password with anyone.

We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information to login to your account. Any email or other communication purporting to be from one of our websites requesting your password or asking you to provide sensitive account information via email, should be treated as unauthorized and suspicious and should be reported to us immediately. If you believe someone else has obtained access to your password, please change it immediately.

If you believe any personal information you have submitted to us is unsecure or that someone has accessed your account, please notify us immediately at privacy@schellman.com.

Unsubscribe

If you no longer wish to receive emails from us, you may opt-out of receiving such emails by following the unsubscribe instructions contained in any such email or by contacting us at privacy@schellman.com with the subject “unsubscribe.”

Request to Access, Know, and Delete

You may obtain certain information and access upon request, and you may also request deletion of certain information (any such request is hereinafter defined as a “Consumer Request”). This Privacy Policy outlines how you can request the information and what you can receive.

If you would like to submit a Consumer Request, you can contact Schellman at privacy@schellman.com, or call us toll-free at 1-866-254-0000.

If you choose to submit a Consumer Request, you must provide us with enough information to identify you and enough specificity on the requested data. We will only use the information we receive to respond to your request and for compliance and legal purposes. Schellman will not be able to disclose information if it cannot verify that the person making the Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf.

“Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by applicable law.

Request to Access.
You may submit a Consumer Request to obtain a copy of or access to the personal information that Schellman has collected on you.

Request to Know.
You may submit a Consumer Request to receive information about Schellman’s data collection practices. You may request information on the categories of personal information (as defined by law) Schellman has collected about you; the categories of data collection sources; Schellman’s business or commercial purpose for collecting or selling personal information; the categories of third parties with whom Schellman shares personal information, if any; and the specific pieces of personal information we have collected about you.

Please note that the categories of personal information and sources will not exceed what is contained in this Privacy Policy. Additionally, Schellman is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. Schellman is also not required to reidentify personal information if it is not stored in that manner already, nor is it required to provide the personal information to you more than twice in a twelve-month period.

Request to Delete.
You may request that Schellman delete your personal information. Subject to certain exceptions set out below we will, on receipt of a verifiable Consumer Request, delete your personal information from our records and direct any service providers to do the same.

Please note that we may not delete your personal information if it is necessary to:

• complete the transaction for which the personal information was collected;
• provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• detect security incidents, protect against malicious, deceptive activity, and take all necessary and appropriate steps to mitigate current and future risk;
• debug and repair internal information technology as necessary;
• undertake internal research for technological development and demonstration;
• exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• comply with the California Electronic Communications Privacy Act or any other law;
• engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• comply with an existing legal obligation; or
• otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Schellman may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.

Do Not Track Signals & Cookies

Currently, we do not respond to “Do Not Track,” “DNT,” or similar signals.

We may use cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your online activity and interactions with our Service which allows us to keep track of analytics and certain statistical information that enables us to improve our services and provide you with more relevant content and advertising.

Some of the cookies we use arenecessary to enable you to move around the Service and use its features. We also usefunctional cookiesto record information about the choices you have made and to allow us to tailor the Service to our users; for example, to remember your language or region or that you have already completed a survey. This information is usually anonymized and is not used for any other purpose. We may also use analytic services to help us understand how effective our content is, what interests our users have, and to improve how the Service works. In addition, we use web beacons or tracking pixels to count visitor numbers andperformance cookiesto track how many individual users access the Service and how often. This information is used for statistical purposes only and it is not our intention to use such information to personally identify any user.

Most web browsers are set to accept cookies by default but will allow you to see what cookies you have, delete them on an individual basis, or block cookies from particular or all websites (“opting out”). Please note that if you choose to remove, reject, or opt-out from cookies, this could affect the availability and functionality of the Service.

Special Notice for Nevada Residents

Schellman does not sell, rent, or lease your personally identifiable information to third parties. However, if you are a resident of Nevada and would like to submit a request not to sell your personally identifiable information, you may do so by contacting us by email at privacy@schellman.com.

Third Party Links

The Service may link to third party owned or operated websites including, but not limited to social media websites, as a convenient method of accessing information that may be useful or of interest to you. This Privacy Policy and the practices we follow do not apply to the linked websites. We are not responsible for the content, accuracy, or opinions expressed on any linked website or for the privacy practices or security standards used by third parties on such linked websites.

Consent to Processing and International Transfer

The Service is controlled and operated by us from the United States. Schellman may process, transfer, and store your information on servers located in a number of countries, including the United States. As a result, your personal information may be subject to data protection and other laws that may differ from your country of residence. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate. By using the Service, or by providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside or are a citizen.

Updates

We may update this Privacy Policy at any time by publishing an updated version here. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the website or sending you an email. You are bound by any changes to our Privacy Policy once you use the Service after such changes have been posted. Please review the “Last Updated” legend at the top of this page to see when this Privacy Policy was last revised.