Applicability of this policy
This policy applies to visitors to the www.citrincooperman.com website (the “Site”) when accessed from within the United States of America. If you are present in the European Union when you access the Site, please refer to the European Union Privacy Addendum.
Information We Collect
We collect information about you when you voluntarily submit it to us. 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).
How do we use this information?
We analyze the information you provide to us to determine how we can tailor CitrinCooperman.com to make it more effective. We may use your information collected through the Site to send you information about topics we think may be of interest to you, and to send you any information you have requested from us. We may also use data for other purposes, which we would describe to you at the point we collect the information.
To Whom We Disclose Information
We will not sell your personal information, except in the event of that our company undergoes a merger, corporate restructuring, or a sale of all or substantially all of our assets.
However, we may share your information with our consultants for the purpose of them providing services to us, for Site improvement and to understand our audience. Also note that Google collects information about you, as stated above, and we do not control such collection of data, or what Google does with your data once they collect it.
What about sensitive personal data?
Visitors who no longer wish to receive updates or notifications or change the frequency of such communications may choose to do so by contacting Citrin Cooperman at info@CitrinCooperman.com. All notification emails and newsletters include the instructions for opting-out of those communications in the future.
What about data security?
We endeavor to take reasonable steps to maintain the security of your data collected through CitrinCooperman.com. You should understand 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.
Citrin Cooperman is invested in protecting the privacy of our clients’ data. To that end, we have agreed to comply with the EU-U.S. Privacy Shield Framework maintained by the United States Department of Commerce. This Framework contains requirements pertaining to the proper collection, use and retention of personal data transferred from the EU to the U.S.
In compliance with the Privacy Shield Principles, Citrin Cooperman commits to resolve complaints about our collection or use of your personal information. EU individuals can find all information required pertaining to our compliance with the Privacy Shield principles, and for information about how to contact us with respect to Privacy Shield concerns, here: Privacy Shield policy.
Your California Privacy Rights
Individual customers who reside in California and have provided their personal information to us may request information about our disclosures of certain categories of such information to third parties for their direct marketing purposes. Such request must be submitted to us at the following address: Privacy@citrincooperman.com. Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
Currently, various browsers offer a do-not-track (“DNT”) option that is designed to sends a signal to websites visited by the user about the user's DNT preference. You can usually access your browser's DNT option in your browser's preferences. While some industry groups have indicated a desire to develop a DNT technology standard, no standard has been adopted to date. Without an industry standard for DNT, users cannot know how any given company or browser will comply with DNT signals. Given the lack of a standard at this time, we do not comply with DNT signals from your browser at this time.
We may track your activities online across websites and over time.
Third Party Links and Services
Privacy Statement Changes
If you have any questions please contact us.
Additional Information requirements pursuant to Art. 13 GDPR (EU General Data Protection Regulation)
Citrin Cooperman & Company, LLP, is the controller, and responsible for this Site.
Data Privacy Manager
Full name of legal entity: Citrin Cooperman & Company, LLP
Data Privacy Manager: Thomas Titus
Email address: Privacy@CitrinCooperman.com
290 W. Mt. Pleasant Avenue
Livingston, NJ 07039
Telephone number: +1 (973) 218-0500
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymized data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We do not collect through the Site any special categories of personal data (as defined in the GDPR) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences through the Site.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us through any feature of the Site.
Third parties or publicly available sources. We receive personal data about you from various third parties and public sources as set out below:
How we use your personal data
We will only use your personal data that we collect on or through the Site when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us through the “unsubscribe” feature in any marketing communication we send you.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data collected from or through the use of the Site, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register your interest in our services
Performance of a contract with you
To manage our relationship with you which will include:
(b) Asking you to leave a review
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you (which we may use for marketing purposes).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for their marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.
Note that you may not be able to refuse all data collection even by setting your browser cookies settings, and that some collection of Technical and Usage Data may continue.
Also, note that we use the following analytics service providers, who also collect Technical and Usage Data based on your use of our Site. The analytics providers listed below are independent controllers of that data, and use it for their own purposes. You specifically grant your consent to such data collection and usage.
Change of purpose
We will only use your personal data collected on the Site for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data for the purpose of providing our services and making the Site available to you, including the following:
We contract with our third-party service providers to require that they do not use your personal data for their own purposes and to authorize them to process your personal data for specified purposes and in accordance with our instructions.
Whenever we transfer your personal data out of the European Economic Area (“EEA”), we will endeavour to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have in place security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have implemented measures designed to ensure that we not retain your personal data longer than is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Note, however, that if we have a legitimate interest in retaining the data, or if we are required to do so by applicable law, we will retain the data in accordance with our data retention plans and policies.
In some circumstances we may choose to anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
External Third Parties
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data 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.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw y