1. What is Collected

The personal information we gather depends on your association with Wellesley Cove Group and the activities you participate in. When you engage in activities, we and our third-party providers may collect personal information. If you're a business client, we may collect personal information during our engagement to provide you with products and services, and we'll abide by our contract or engagement letter with your entity. For other cases, we may gather personal information directly from individuals participating in our activities. Please refer to Section 6 for Additional Data Subject Notices, which apply to Firm Personnel, California and Virginia residents, and individuals outside the U.S.

We may gather various categories of personal information about you, including:

• Identifiers like your real name, alias, postal address, unique personal identifier, online identifiers (such as IP address, email address, or telephone number), account number, name and password, Social Security number, driver's license number, passport number, or other similar identifiers.

• Commercial information such as records of your personal property, purchased or considered products/services, account balances or activity, bank account information, credit applications and checks, or other purchasing or consumer history/tendencies.

• Information about your internet activity, like cookie identifiers, browser type, ISP, device platform/characteristics, or other settings.

• Geolocation data based on your IP address, cell network, or other similar location data.

• Audio, electronic, or visual information like records of customer service calls or video surveillance.

• Professional or employment-related information such as your professional licenses, current or previous employers, job titles and responsibilities, assets and income, or other work-related history or prospective employment/contract with our firm.

• Education information like academic records, degrees, or educational history.

• Biometric information like fingerprints, facial scans, voice recognition, genetic information, or other similar biometric identifiers.

• Inferences about you based on other personal information we've collected, like preferences or characteristics.

• Information related to protected characteristics under federal or state law, such as gender, race and ethnicity, nationality, marital status, military service or veteran status, or date of birth.

• Other personal information not listed above, including your signature, physical description or characteristics, insurance information, or any other financial, medical or health insurance information.

 

1.1 Personal Information Provided by You

We collect personal information that you voluntarily provide, such as when you subscribe to a newsletter or participate in a survey. For instance, if you attend a firm-sponsored event, we may collect your business contact details, including your name, title, employer, work email address, mailing address, and phone number.

 

1.1.1 Sensitive Personal Information

We collect sensitive personal information only when you provide it voluntarily. The definition of "sensitive personal information" may vary by law and may include details such as race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, biometrics, precise geolocation, sexual orientation, or criminal record. Please use your discretion when providing sensitive personal information to WCG or permitting WCG to use such information. Only provide sensitive personal information to WCG if you consent to its use for WCG's business purposes.

 

1.2 Information We Collect

In some cases, we and our third-party providers use cookies, web beacons, wayfinding technology, and other tracking technologies to collect certain types of personal information when you engage in Activities (e.g., web-based or mobile applications) and through messages that we may exchange or collaboration platforms.

 

1.2.1 Types of Information We Collect

IP Addresses. We collect your IP address when you engage in an Activity online. An IP address is a number assigned to your Internet-enabled device, such as a computer or mobile device, when you access the Internet. It enables computers and servers to recognize and communicate with each other.

 

• Cookie Data. We gather various types of information via cookies or similar web tracking technologies. Please refer to Section 9, our Cookie Policy, for more information.

• Location Information. We may collect your geographic location from your Internet-enabled device (e.g., via tracking beacons, Bluetooth, or Global Positioning System technology) in connection with certain Activities. We do this only if you have not disabled the sharing of such information via your device. You can usually manage the location services preferences on your device to enable or disable sharing of this information. If you disable location services, some features of our Activities may not be available.

 

1.2.2 How We Collect Personal Information

• Cookies. We use cookies to identify you online and gather certain information. For more information, please refer to our Cookie Policy.

• Web Beacons. We may use web beacons to gather certain information. A web beacon is a small image file on a web page that can be used to collect certain information from your Internet-enabled device, such as an IP address, the time the content was viewed, web browser type, and the existence of cookies previously set by the same server. You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address, but cookie information will not be recorded. If you opt to render some web beacons unusable, some features of our Activities may not be available.

• Social Media Applications. Our online Activities may allow you to share information between third-party social media platforms (e.g., Facebook and LinkedIn) or use your social media platform credentials to log into and access our online Activities. These social media platforms may collect and use personal information about your use of our online Activities. Any information you provide through a social media platform may be collected and used by the provider of that social media platform and may be subject to their privacy practices. We do not have control over, or responsibility for, those providers, or their use of your information.

• Analytics Tools. We use third-party usage analytics tools as part of online Activities, including Google Analytics, which may be subject to Google's privacy policies.

 

To give visitors more choice in how their data is collected by Google Analytics, Google has created the Google Analytics Opt-out Browser Add-on. This Add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Add-on does not prevent information from being sent to us or other web analytics services.

 

In some of our online activities (e.g., newsletters), we and third-party providers operating on our behalf may monitor recipient actions such as email open rates through embedded links within the messages. To unsubscribe from receiving certain publications or from all WCG communications, please visit the subscription Preference Center.

 

1.3 Do Not Track and Global Privacy Control Signals

Our online activities may not recognize all web browser-based “Do Not Track” or opt-out preference signals such as the Global Privacy Control. You may modify your Internet-enabled device’s web browser settings to block all cookies or “third-party” cookies. Cookies set by us on our online activities are considered “first party” cookies. Opt-out preference signals may only apply to information collected and used from that particular browser or device. Opting out on a particular device may not opt you out of information collection on other devices or limit cross-device sharing on those other devices. For each device and browser, you may need to individually set your preference signals to opt-out.

 

1.4 Children

WCG recognizes the importance of protecting children's privacy. Our activities are not intentionally designed for or directed at children under the age of 18. It is our policy not to knowingly collect or maintain personal information about anyone under the age of 18, except as required by applicable law or professional standards and with permission from a child’s parent or legal guardian.

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2. How Personal Information is Used

We use the personal information we collect to enable you to engage in activities, customize your online experience, improve the performance, usability, and effectiveness of our activities, advertise and market our activities, measure their effectiveness, and generate and analyze statistics about your engagement. If we provide specific terms for a particular request, product, or service, those terms apply, and in the event of a conflict between those terms and this Privacy Statement, the specific terms control. We use your information when you permit us to use it or when such information is required or permitted by law or professional standards.

 

2.1 Participation in Activities and Business Purposes

We use the personal information we collect to enable you to engage in activities, communicate with you, provide you with information about our products and services, comply with applicable laws and regulations, operate, maintain and enhance our activities, and fulfill your specific requests. We use location data we gather to provide you with information about our activities, products, and services that may interest you and to improve our location-based activities, responses to requests, products, and services. We use data from monitoring recipient actions, such as email open rates, to gauge user interest and maintain and improve our online activities. We may use personal information in an aggregated or deidentified form for our legitimate business purposes, including research and development.

 

2.2 Advertising

WCG may engage in Targeted Advertising, which refers to ads targeted to you based on your web browsing and app usage across websites or applications. This may involve partnering with Advertising Providers who use cookies and tracking technologies to gather information about your online activities and deliver personalized ads based on your interests and browsing history. If you wish to restrict the use of this information or opt out of receiving Targeted Advertising, please refer to the Sale or Sharing of Personal Information section.

 

2.3 Data Retention

WCG only retains personal information for as long as necessary to fulfill its intended purpose, which includes meeting business needs, legal requirements, professional standards, or an individual's request. The retention period may vary depending on the firm's retention policies.

 

3. Disclosure of Personal Information

3.1 Business and Marketing Purposes

WCG may disclose personal information to third parties as necessary to fulfill your requests, for our legitimate professional and business needs, and to market our products or services, including joint marketing with other third parties, in compliance with applicable law or with your consent. We require our third-party partners to protect your personal information in the same manner as we do. We may also share aggregated or deidentified information with certain third parties, such as reports on user demographics and traffic patterns.

 

3.1.1 Legal Purposes

We have a legitimate interest in delivering effective information and services to you, improving our site and user experience, fulfilling our contractual obligations, complying with legal and regulatory requirements, providing high-quality services, preventing criminal activities, safeguarding our people, assets, and information, and managing events and recruitment processes. For certain purposes, such as background checks for employment, we may need your consent to process your personal information.

 

3.2 Sale or Sharing of Personal Information

WCG does not sell or share personal information collected through our online activities for monetary consideration. However, we may be deemed as selling or sharing limited personal information for non-monetary consideration to certain third parties, such as our Advertising Providers and analytics tool providers, under applicable law. This sharing is limited to our online activities, and you can opt-out of such sharing by submitting a Data Privacy Request through our website.

 

3.3 Legal Disclosure

Under certain legal circumstances, we may disclose personal information to comply with requests from government or law enforcement agencies, in line with national security or law enforcement requirements, or when necessary to adhere to applicable laws, court orders, government regulations, or professional rules.

 

3.4 Corporate Transactions

If there is a change in ownership of WCG or its assets due to a merger, acquisition, or sale of assets, information owned or controlled by WCG may be transferred to another company. This includes information collected by WCG, which may be shared in the context of corporate transactions such as acquisitions, mergers, sales, liquidation, assignment, or transfer of assets. Such disclosures may be required for data privacy or security audits, or to investigate or respond to a complaint or security threat.

 

3.5 Social Media

When you use social media platforms or integrated third-party provider tools to share personal information or interact with these features, those providers may collect and use such information according to your account settings, including sharing it with the general public. Your use of social media platforms and tools is subject to the privacy policies of those providers. WCG also features Social Media Features on our online Activities, which may include blogs, forums, and crowd-sourcing applications, where personal information that you provide may be shared with other users of that Social Media Feature.

 

3.6 Cross-Border Collection and Transfer

WCG may collect personal information from you if you are located outside the U.S. while using our services, and may transfer such information to WCG International, member firms affiliated with WCG International, or third-party providers working on our behalf. Likewise, we may receive personal information transferred from WCG International, member firms affiliated with WCG International, or an unaffiliated third party. Personal information may also be stored in a jurisdiction other than your home country, which may not provide the same level of protection for your personal information. Each WCG Member Firm affiliated with WCG International is required to protect personal information according to its contractual obligations and applicable data protection legislation. Safeguards will be in place before any personal information is transferred.

 

4. Choices and Data Privacy Requests

At WCG, we value your privacy and understand the importance of protecting your personal information. To receive additional information about our activities, we may require you to provide certain personal information, and we may ask for your permission to use your personal information for certain purposes. If you have previously opted into any activities, you may unsubscribe at any time, and we will promptly remove your personal information upon your request.

If you have submitted personal information to us, you have the right under applicable law to request reasonable access, correction, deletion, or opt-out of any sale or share of your personal information. We will make reasonable and practical efforts to comply with your request, as long as it is consistent with applicable law, our contractual requirements, our record retention policies, and professional standards. To make a Data Privacy Request, please use our webform, or email us at communications@wellesleycove.com

Your browser or device may also be configured to automatically opt you out of certain sales or sharing activities and set your cookie preferences.

 

5. Data Security

We take data security seriously and have policies and procedures in place to protect your personal information from unauthorized loss, misuse, alteration, or destruction. We also require our third-party providers to similarly safeguard your personal information. While we seek to limit access to your personal information to those who have a need to know, we cannot guarantee security against all threats.

 

6. Additional Data Subject Notices

6.1 California Residents

If you are a California resident, you have certain rights under the California Consumer Privacy Act ("CCPA"). Personal information, as defined in the CCPA, includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

 

6.1.1 Sources of Personal Information Collection

We collect personal information from various sources, including but not limited to applications and forms, collaboration platforms, communications and interactions, and in-person events or meetings. These sources include our clients and customers, prospective clients and customers, subsidiaries, affiliates, joint ventures, and other companies, service providers, unaffiliated third parties with which we have a business relationship and/or promotional and joint-marketing partners, social media platforms providers, online communities and forums, online advertising providers and partners, current and former employees, partners and principals, contractors, job applicants, government entities and databases, and publicly available sources.

 

6.1.2 Purposes of Personal Information Collection

We use personal information for various purposes, such as administering, maintaining, and improving our activities, assessing third-party providers and service providers, auditing and compliance with policies, procedures, laws, regulations, and/or professional standards, billing, payment and fulfillment, customer and client communications and relationship management, financial reporting and accounting, general business administration, health, safety, and wellness of our workplace, facilities, and workforce, internal analytics and benchmarking, marketing our activities and the products and services of WCG, or other third parties, protecting against fraud and other malicious or illegal activity, including for anti-money laundering and know-your-client checks, provision and performance of services, and systems and data security.

 

6.1.3 Categories of Third Parties with Whom Personal Information is Shared

We may disclose personal information to various categories of third parties, such as our affiliates, technical and operational service providers and business partners, marketing, advertising, and analytics providers, government entities, and professional service firms.

 

We engage third parties to perform certain functions on our behalf, and we may disclose personal information to our third-party business partners and service providers to maintain and operate our websites and provide, improve, and personalize our services, including to fulfill requests for services and for other technical and processing functions. We may also share personal information with service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal, or fraudulent activity or other threats.

 

We may share personal information with third-party providers for marketing, advertising, and analytics purposes, and with government entities and agencies, regulators, law enforcement, and other third parties to provide our services, comply with applicable laws and regulations, respond to legal process, and establish or exercise our legal rights or for fraud- or crime-prevention purposes. We may also share personal information with other professional service firms in connection with our legal, regulatory, and professional obligations and to establish or exercise our rights and defend against claims. Additionally, subject to applicable law, we reserve the right to transfer some or all personal information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets.

 

6.1.4 California Residents' Privacy Rights

As a California resident, you have the following privacy rights that you may exercise:

Right to Know: You have the right to know the following personal information that we have collected in the last 12 months:

• Categories of personal information collected or maintained about you

• Categories of sources from which the personal information was collected

• Business or commercial purpose for collecting the personal information

• Categories of personal information disclosed for a business purpose

• Categories of third parties to whom the personal information was disclosed

• Categories of personal information sold or shared

• Categories of third parties to whom the personal information was sold or shared

• Specific pieces of personal information collected or maintained about you

Right to Correct: You have the right to correct any personal information we maintain about you.

Right to Delete: You have the right to request the deletion of any personal information we have collected from you.

Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to limit or restrict the use of Sensitive Personal Information we have collected or maintained about you for the purpose of inferring characteristics.

Right to Opt Out of Sale or Sharing: You have the right to opt out of the sale or sharing of your personal information.

To exercise any of these rights, you may contact us by submitting a Data Privacy Request through our webform, or emailing us at communications@wellesleycove.com

We will respond to your authorized and verified request as soon as practicable and as required by law. However, please note that some exclusions and exceptions may apply under applicable laws and our record retention policies. In certain circumstances, we may be unable to fulfil your request.

If we have received your personal information through our business clients or where we are operating as a service provider, we may refer you to the business with whom you have a direct relationship in order to implement your request, pursuant to applicable law.

You may also authorize someone to exercise these rights on your behalf, or if we have collected information about your child under 16, you may exercise these rights on their behalf.

 

6.2 Virginia Residents' Privacy Rights

The Virginia Consumer Data Protection Act (VCDPA) provides specific rights to Virginia residents with regards to their personal information. The following sections detail your VCDPA rights and our personal information practices, as appropriate.

For the purposes of this Privacy Statement, "personal information" refers to "personal data" that can be linked or reasonably linked to an identified or identifiable natural person.

 

Virginia residents may be able to exercise the following privacy rights:

Right to Know. To confirm whether or not we process your personal information and to access such personal information.

Right to Correct. To correct inaccuracies in the personal information we collect from you;

Right to Delete. To delete personal information provided by you or obtained about you;

Right to Opt Out of Targeted Advertising, Sale, or Profiling. To opt out of the processing of your personal information for purposes of (i) targeted advertising, (ii) the sale of personal information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Appeal. To appeal our denial of your request(s).

To exercise any of your rights, please contact us by:

• Submitting a Data Privacy Request through our webform;

• E-mailing us at communications@wellesleycove.com

We will respond to authorized and verified requests as soon as practicable and as required by law, including any reason for denying or restricting a request. Please note that if we have received your personal information through our business clients or where we are otherwise operating as a processor, we may refer you to the controller with whom you have a direct relationship to implement your request, as required by applicable law.

You may authorize someone to exercise the above rights on your behalf. If we have collected information about your minor child, you may exercise the above rights on their behalf.

The above rights are subject to various exclusions and exceptions under applicable laws, and under certain circumstances, we may be unable to implement your request.

If you wish to appeal our denial of a request, you may email communications@wellesleycove.com to reconsider your submission.

Please note that WCG does not "sell" (as such term is defined under the VCDPA) any personal information for monetary consideration.

 

6.3 Privacy Notice for Non-U.S. Residents

WCG's activities in the U.S. are not directed towards individuals located outside the country. However, in certain circumstances, WCG may interact with or collect personal information from non-U.S. individuals. This information is typically collected directly through WCG's activities or transferred to WCG from WCG International, a member firm, or an unaffiliated third party outside the U.S. We receive this information based on a contractual or legitimate interest basis, and its transfer is subject to foreign regulator-approved standard contractual clauses or another lawful basis.

For information about notices and rights regarding non-U.S. residents, please refer to our Notice of Processing.

 

6.4 Firm Personnel

This Privacy Statement does not govern the privacy practices of current or former WCG partners, employees, interns, or individuals engaged through third parties. The collection and processing of their personal information are subject to WCG's Firm Personnel Data Privacy Notice and other firm policies.

 

7. Privacy Shield

WCG complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework for the collection, use, and retention of personal information from the European Union, United Kingdom, and Switzerland, as applicable to the U.S. However, following recent decisions invalidating the adequacy of Privacy Shield, WCG no longer relies on it for cross-border transfers of personal information. Instead, we rely on direct collection or other bases, such as standard contractual clauses.

 

8. Links to Other Sites

WCG's activities may contain links or references to Other Sites maintained by WCG or unaffiliated third parties. These sites are not governed by this Privacy Statement, and their content and privacy practices are not the responsibility of WCG. We encourage you to review the applicable privacy notices of Other Sites before disclosing personal information.

 

9. Cookie Policy

As part of our online Activities, we may install cookies on your Internet-enabled device to enhance your experience. These cookies do not contain personal information or identify you in any way.

For some Activities, a notification banner may require your consent to collect cookies. If you decline, your device will not be tracked for marketing activities, but "user-input" cookies may still be necessary for functionality. You may clear your cookies to revoke it.

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While most web browsers accept cookies, you may be able to adjust your settings to refuse or delete them. However, this may impact the functionality of our online Activities. Whenever you engage in our online Activities, cookies may be placed on your Internet-enabled device to remember your device and serve additional purposes. These cookies do not disclose your personal information or identify you.

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10. Changes to this Privacy Statement

We may modify this Privacy Statement from time to time to reflect our current personal information practices. The "updated" date at the top of the page will be revised to indicate changes. We recommend that you periodically review this Privacy Statement to stay informed of our personal information practices. Your continued use of the Activities after an update indicates your consent to the updated terms.

 

11. Questions and Comments

If you have any questions or comments about this Privacy Statement or our privacy practices, or if you have concerns about compliance with this Privacy Statement, please contact us at communications@wellesleycove.com via email.