Last Updated: 6.9.2023
Information We Collect
We collect information about you when you voluntarily submit it to us and from other sources as part of promoting and providing our services. Throughout our Site, we provide the opportunity to register for our communications, and we may offer other interactive features (e.g., asking you to participate in an online survey, register for a webinar or live event, or initiate an application for employment).
The types of personal information we collect and share depend on the nature of the relationship you have with Citrin Cooperman and the requirements of applicable laws. We collect and use personal information of:
- Our clients and potential clients when providing services or informing them of our services;
- Our service providers and suppliers as we arrange and pay for products and services;
- Job applicants and visitors to our websites and locations; and
- Our affiliates and partner organizations who assist in delivering our products and services.
The types of personal information we collect may include:
- Identity and Contact Data: including names, titles, mailing address, phone numbers, email address or online usernames, government-issued identification numbers, and images;
- Financial and Commercial Data: including salary and income information, property ownership, investment holdings, financial account or policy names or account numbers;
- Professional and Employment-Related Information: including non-public education information, academic records, employment history, disciplinary records;
- Sensitive Personal Information (also “special categories” or “protected classification”): including health information including medical records, health insurance information, biometrics, disability, geolocation, race and sensory (audio/visual) data;
- Internet Activity, Technical Data and Usage Information: including IP address, login credentials, device fingerprints, behavioral inferences;
- Marketing and Communications Data: including professional contact details, business sector and interest demographics and marketing-willing status indicators.
We will specify which of these types of data we use at the point we begin to collect this information from you. For instance, if you are a client of Citrin Cooperman and have signed an Engagement Letter with us, we provided a Privacy Notice along with such Engagement Letter, the terms of which apply to all personal information related to same.
How We Collect Personal Information
Direct interactions. You may give us your Identity and Contact Data, Financial and Commercial Data, and Special Categories/or Sensitive Personal Information by filling in forms, as part of the employment application process, requesting or obtaining our services, or by corresponding with us through any means.
Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:
- Affiliates and service providers may collect and provide us your Identity and Contact, Internet Activity, Technical Data, and Usage Information Financial and Commercial Data, and Marketing and Communications Data.
- When you use the customer portal on our Site or other access portals, we may collect personal information such as Identity and Contact Data, Internet Activity, Technical Data and Usage Information, Commercial Data, and Marketing and Communications Data.
- When we provide our services, we collect personal information which may include Identity and Contact Data, Internet Activity, Technical Data and Usage Information, Marketing and Communications Data, Commercial Data, and Sensitive Personal Information.
Cookies and Use of Automated Data Collection and Tracking Technologies
We use automated data collection methods consistent with the provisions of this policy. We and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site (“Usage Information”). This Usage Information may be stored and/or accessed from your computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include details about the Device you are using, how you came to our Site and how you navigate around our Site.
We may use various automated methods and technologies such as cookies and web beacons to store or collect Usage Information (collectively, “Tracking Technologies”).
We may use Tracking Technologies for a variety of purposes, including:
- To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality;
- To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
- To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site, keeping track of your specified preferences; and
- To deliver content relevant to your interests on our Site and third-party sites based on how you interact with our advertisements and/or content.
We also obtain analytics services from Google LLC (“Google”) through use of their Google Analytics. In order for Google to provide this service to us, they place a cookie or cookies on your Device which allows Google to track certain information about you, your technology or activities online, such as your geographic location, the IP address from which you connected to the Internet, information about your Device, your browser and your Internet provider. We do not control such data collection or how Google uses the data they collect.
How or Why Do We Use Personal Information?
To the extent permitted by applicable law, we may use personal information to further our legitimate business interests or to comply with a legal obligation, including completing an employment or services contract with you. The basis on which we use personal information depends on our relationship with the individual and the nature of the information we are using. Purposes for which we may use personal information include the following:
- Communicating with you about the products we offer, activities we engage in and topics we think may be of interest to you as well as for responding to requests, inquiries, comments, and suggestions from you.
- Operating, securing, and improving our business (including both physical premises digital environments).
- Analyzing and enhancing our communications and strategies (e.g. effectiveness of emails or our websites and mobile applications). We may also analyze information collected through Tracked Technologies to evaluate your engagement with us through the Site.
- Developing and personalizing customer relationship management activities, including the delivery of programs and materials, as well as surveys and market research.
- Facilitating and improving our recruitment activities such as processing employment applications, evaluating a job candidate, conducting background checks, analyzing trends, and monitoring recruitment statistics.
- Staffing, facilitating, delivering and managing our services to our clients.
- Evaluating and engaging with our service providers and business partners.
- Complying with regulatory monitoring and reporting obligations as well as responding to disclosure requests of a court or law enforcement authority of competent jurisdiction.
We will specify the purpose and basis on which we intend to use personal information when we collect or begin using the personal information.
Sensitive Personal Information: We do not use or disclose your sensitive personal information for purposes that are not necessary in order to provide our products and services as are reasonably expected by an average consumer requesting those goods and services.
To Whom We Disclose Information
We need to disclose your personal information to various parties in the course of our business including:
- Third party suppliers, service providers, affiliates, and business partners to assist us in meeting business operations needs and to deliver our services and functions;
- Regulators worldwide, as required by law, including in connection with monitoring and review of our services and business practices;
- As required by law or the direction of a court of competent jurisdiction, including to comply with a legal obligation, defend our rights or protect against legal liability, prevent fraud and act in urgent circumstances to protect the personal safety of users, or the public; and
- If we sell or buy any businesses or assets or merge any business into or with that of another person, we may disclose your personal information to the prospective counterparty in such transaction and such data may be one of the assets transferred in such transaction.
A list of such parties is available upon reasonable request using the details in the Contact Us section of this policy.
Note that some of the Tracking Technologies providers we use on the Site may collect information about you, and we do not control such collection of data, or what such providers do with your data once they collect it.
Except in the event that our company undergoes a merger, corporate restructuring, or the sale of all or substantially all of our assets, we will not sell your personal information in exchange for money.
However, in the process of setting cookies and Tracking Technologies, to provide Citrin Cooperman with certain analytics services on our Site, some service providers (e.g. Google) may retain such analytics data for their proprietary purposes including for cross context behavioral advertising. Since the retention of analytics data may impact the price of the analytics services to Citrin Cooperman, it may be deemed a Sale of Personal Information. You have the right to opt out of this type of sale or sharing of your personal information to third parties and we have provided opportunities on the Site for you to exercise this right including a link on our homepage and a further link in the Contact Us section of this policy as well as by contacting us using details in the Contact Us section.
How We Respond to Do Not Track Signals
Do Not Track (“DNT”) or “Global Privacy Control,” is a preference setting offered by various internet browsers whereby a signal is automatically sent by the browser to each website visited requesting that the user’s activities are not tracked by that website and that the website does not enable onward tracking to other websites. You can usually access your browser’s DNT option in your browser’s preferences. If that occurs, the website visited will not recognize you upon return to that website, save your passwords or usernames, and some other features of a website may become unavailable or not function properly. We have configured our Site with the intent that it honors DNT signals from most browsers. When a user’s browser is set to DNT, we will disable cookies related to marketing and targeting.
International Transfers of Personal Information
When we no longer need personal information, or in any event, after legal authority to retain it has expired, we will destroy personal information in accordance with local law and pursuant to our relevant procedures.
Rights to Access and Control Your Personal Information
You are provided certain rights over your personal information that enable you to access and control the use of any personal information about you that we collect and use.
We reserve the right to verify the identity of the individual and to verify the authority of any designated representative (“authorized agent”), in connection with any requests regarding personal information, to help ensure that we provide the information to individuals to whom the information pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information.
Your rights to access and control your personal information include the following:
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to continue to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that it is complete and accurate and that we are lawfully collecting, using and disclosing (together “processing”) it. This access request will include a list of the types of personal data we have collected and to which third parties we have Sold or Shared your personal data over at least the last 12 months.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. In certain cases we may not be able to comply fully or at all with your correction request, and if so, we will notify you of the reasons for this.
- Object to processing (also known as the right to opt-out) of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing. In certain cases we may not be able to comply fully or at all with your request on reasonable grounds provided the processing does not negatively impact your privacy rights, and if so, we will notify you of the reasons for this.
- You also have the right to object where we use your personal information for direct marketing purposes. This includes your right to request that your Personal Information not be Sold to or Shared with third parties for their own proprietary purposes including for cross-context behavioral advertising, which is the targeting of advertising to a consumer based on that consumer’s personal information from a number of sources. If you wish to modify your preferences in respect to updates or notifications, or the mailing lists you subscribe to, you can modify your preferences on our Site. All commercial and marketing communications (e.g. notification emails and newsletters) include instructions for opting-out of those communications in the future.
- Request erasure of your personal information. You can request we delete personal information where you do not believe there is reason for us continuing to process it, or where you believe we collected or are using it unlawfully, where erasure is required by law or where you have opted-out of our processing. In certain cases we may not be able to comply fully or at all with your correction request for legal reasons, and to the extent we are permitted to, we will notify you of the reasons for this.
- Request restriction of processing of your personal information. You can request we suspend or limit processing of your personal information only to that which is legally necessary or is strictly necessary to continue orderly business operations. Restricted processing may occur where we are verifying whether we are able to comply with your correction, opt-out or erasure request or where you believe it is in your interests not to erase the personal information.
- Request the transfer (also known as the right of portability) of your personal information to you or to a third party you have chosen. To the extent it is technically feasible we can provide your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided to us to use or where we used the information to perform a contract with you.
Exercising your data access rights
To exercise any of the rights described herein, please contact us using the details provided in the Contact Us section. We will acknowledge your request within 5 days and will complete our response to your request within 30 days unless we agree a different response period with you or a different response period is permitted or required under applicable law.
If you would like an authorized agent to exercise these rights on your behalf, you (or the authorized agent) must provide a written request including your full name and all contact details (e.g. email address, mailing address) that we have in our records and with which we can authenticate you, as well as (if applicable) the relationship or services obtained from Citrin Cooperman. The written request must include the full name and preferred contact details of the authorized agent. We may deny a request from an agent who cannot meet these requirements.
When submitting a request, please describe your relationship with us and your request in sufficient detail to allow us to properly understand, evaluate, and respond to it. We may need to verify your identity before processing your request, which may require us to request additional personal information from you.
We will never discriminate or retaliate against you for exercising any of these rights. However, please note that if the exercise of your rights limits our ability to process personal information, we may not be able to provide our products to individuals who exercise these rights, or to otherwise engage with such individuals going forward.
If you believe that we have not respected your rights outlined herein or we have breached a relevant law and wish to make a complaint, please contact us using the details below detailing the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.
If you believe we have not dealt with your complaint adequately, you also have the right to contact a regulatory body or data protection authority in relation to your complaint.
What about Data Security?
We maintain reasonable technical, administrative, and organizational measures to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification of personal information collected through CitrinCooperman.com. You should understand however, that the open nature of the Internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended.
We do not target any of our products or services at children under the age of 16, and we do not knowingly collect personal information about children under 16. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us using the details in the Contact Us section and we will endeavor to delete that information from our databases.
Third Party Links and Services
If you have any questions or would like to exercise your data access rights, please contact us:
Email address: Privacy@CitrinCooperman.com
Citrin Cooperman Privacy Officer
50 Rockefeller Plaza,
New York, NY 10020
Toll Free Telephone Number: (888) 450-2221