THE BROOKS GROUP’S PRIVACY STATEMENT
Last Modified: February 14, 2019
Williams T. Brooks and Associates d/b/a The Brooks Group (“The Brooks Group,” “TBG,” “ we,” “us,” or “our,” as applicable) values the privacy of our users, customers, and partners. TBG respects your privacy and is committed to using responsible practices in the collection, maintenance, and use of your information. This Privacy Statement, as modified from time to time, describes our practices in connection with information collected through our www.brooksgroup.com website (together with all subdomains, related websites, and related mobile device applications, the “Website”). This Privacy Statement applies only to information we obtain from you when you are online while visiting or using the Website. It does not apply to information we have obtained or may obtain offline through other traditional means.
If you are in the European Union, TBG will be the data controller responsible for the collection and use of your Personal Information. Where Personal Information is provided by a customer in connection with our Website, TBG is the data controller responsible for processing Personal Information. If you have a query about how your Personal Information is being used, you can contact the data controller through the Global Privacy Officer whose contact details appear below.
As a general principle, information you provide to us will only be used or shared by TBG as outlined in this Privacy Statement. By visiting or using the Website, you agree to the practices and policies set forth in this Privacy Statement. If you do not agree to the terms of this Privacy Statement, you may not use the Website.
1. What information do we collect and process?
We collect two basic types of information from you in conjunction with your use of the Website– Personal Information and non-Personal Information.
“Personal information” is any information that can individually identify you and includes, as an illustrative example and without limitation, your name, postal address, email address, telephone number, etc.
“Non-Personal Information” includes information that does not personally identify you, but may include, as an illustrative example and without limitation, tracking and usage information about your location, use of the Website and the Internet, etc.
There are a number of circumstances in which you voluntarily supply us with your Personal Information. The following lists the most common ways in which we collect your Personal Information:
- When you register for any of TBG’s trainings or workshops;
- When you register for any of TBG’s seminars or symposiums;
- When you sign up to receive information or related services from us;
- When you request further information from TBG;
- When you leave a message for TBG through TBG’s Website;
- When you submit questions, comments, or feedback through the Website or otherwise; or
- Any other place on the Website where you knowingly volunteer Personal Information.
Social Media Sites
When you interact with an TBG account on or through a social media platform, such as Facebook, Twitter, or LinkedIn, we collect the Personal Information that you make available to us on that page or account, including your user ID and/or username, and any information you have made public in connection with that social media service. Please note, however, that we will comply with the privacy policies of the corresponding social media platform and we will only collect and store such Personal Information that we are permitted to collect by these social media platforms.
Children’s Online Privacy
TBG respects the privacy of children, and we are committed to complying with the Children’s Online Privacy Protection Act (COPPA). We do not intentionally collect Personal Information from children. If you are under the age of thirteen (13), you may not register for any services provided on the Website. If we learn that a child under 13 has provided Personal Information to us without verification of parental consent, we will take commercially reasonable steps to delete that information.
If you are under 16 years of age and reside in the European Union, you must provide an email address for your parent or legal guardian, and before you can access or use the Website, TBG must receive your parent’s or legal guardian’s express consent. You will not receive access or the ability to use the Website, and we will not collect additional Personal Information from you, until we receive your parent’s or legal guardian’s consent. Your parent or legal guardian may revoke consent at any time, and TBG will take reasonable steps to delete all Personal Information collected from you. TBG will also provide your parent or legal guardian with the ability to request to review your Personal Information, prohibit further collection of your Personal Information, and delete, or instruct the deletion of, your Personal Information.
Some information is automatically received and sometimes collected from you when you visit or use the Website. The following lists the most common information that is automatically received or collected:
- The name of the domain and host from which you access the Internet, including the Internet Protocol (IP) address of the device you are using and/or the IP address of your Internet Service Provider (ISP);
- The type and version of Internet browser software you use and your operating system;
- Websites visited before or after you visit our Website;
- The date and time you access the Website, the length of your stay, and the specific pages that you access while visiting the Website; and
- Information concerning the country of origin of your device and the language(s) used by it.
We use this information to monitor the usage of our Website, assess performance, ensure technological compatibility with your device, and understand the relative importance of the information provided on the Website. We may also use this data to conduct statistical analyses on visitors’ usage patterns and other aggregated data.
When you interact with the Website, we automatically receive and record information on our server logs from your browser, including your IP address, “cookie” information, and the page you requested.
Cookies and other tracking technologies (such as pixels and beacons) are comprised of small bits of data that often include a de-identified or anonymous unique identifier. Websites, apps and other services send this data to your browser when you first request a web page and then store the data on your computer so the website can access information when you make subsequent requests for pages from that service. We may use these technologies to collect and store information about your usage of the Website (such as the pages you have visited, content you have viewed, search queries you have run, and advertisements you have seen), which information is then used to understand your preferences so as to enable us to provide you with improved services in future visits, and to compile aggregate data about site traffic and interactions so that we can offer better experiences and tools in the future.
Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information. Please note that by blocking any or all cookies, you may not have access to certain features, content, or personalization available through the Website.
We utilize email tracking systems that provide us with data such as who opened or forwarded an email, the time it was opened, and whether the reader clicked certain links within the email.
We, as well as third-party vendors acting on our behalf (such as AdRoll), may use first-party cookies and third-party cookies, or other third-party identifiers to gather anonymous analytics and statistics about our Website and hot it is being used by our visitors so we can improve our Website. Our web server storage logs may collect the domain names, internet protocol addresses, the types of web browsers, and certain data of visitors to the Website.
Data about your activities online may be collected for use in providing advertising tailored to your individual interests, either by us, our affiliates, or third parties. We may work with third parties such as network advertisers and ad exchanges to serve advertisements across the internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party websites and viewing of ads and of our content.
We and these third-party vendors may use third-party technologies together with our own first party technologies in order to analyze ad impressions, your use of ad services, and interactions with these ad impressions and ad services. The information collected may also include information about your visits to our Sites, include the pages you have viewed and what content you have seen. These third-party tracking technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the effectiveness of the advertisements that have been delivered to you.
You can opt out of certain advertising by visiting the Network Advertising Initiative consumer opt out page at http://optout.networkadvertising.org/, by visiting AdRoll opt out page available at https://app.adroll.com/optout, or by visiting the Digital Advertising Alliance’s opt-out page at https://www.aboutads.info/choices. Please note, at this time we do not respond to browser-based “do not track” signals.
Email and Other Communications
We may contact you by email or other means at an email address that you have provided to us. For example, we may send you information about TBG’s services or promotional offers. If you do not want to receive email from us, please let us know through the “unsubscribe” feature included in our communications.
2. How do we use your information?
We use the information we collect from you and about you to help us personalize and continually improve your experience with the Website. You have no obligation to provide us with any of your information, but you may not be able to use or access certain portions of the Website if you do not provide us with your Personal Information (and you cannot use our Website without agreeing to the terms of this Privacy Statement).
As non-limiting examples, we use the information we collect from and about you in the following ways:
- Providing the features, products and services you request : We may use the information we collect about you to fulfill your requests for, and enable your use of, our features, products and services.
- Registration and promotions : We may use your information to register you for certain features, products and services in line with your chosen marketing preferences.
- To communicate with you and provide you with information : We may use your information to communicate with you, to respond to your questions or comments, to provide you with updates and news, or to alert you when job vacancies that fit your profile arise (in the event that you submit your resume). We also may use your information to provide you with personalized content and information, and to send you brochures, samples, offers, and other information our company.
- When we perform our obligations under a contract with you : We may use your information when you work for us either as an employee or a service provider or apply for a job with us as necessary in connection with your contract of employment or services agreement. If you are a customer, client, or a user of our services we will use your Personal Information to carry out our obligations under the contract that we have with you.
- To deliver to you relevant advertising : We may purchase and use opt-in e-mail lists to contact potential customers who we believe may be interested in products or services from TBG. We will honor opt-out requests and ask those providing lists to give us assurances that e-mail contact information is provided only for those consumers who have expressed a desire to receive offers and information by e-mail. We also may use demographic and preference information to allow advertising related to TBG products and services to be targeted to the users for whom they are most pertinent. This is designed so that users will see advertising that is most likely to interest them, and advertisers can display their ads to people who are most likely to be receptive.
- To provide you with other offers : Sometimes we will make offers and information available to you through the mail. For example, when customers place an online order or sign up for to receive information online we may add them to the list to receive information by mail. We may also use lists we have received from third parties or public sources to send you this information, and, as is routinely done in the mailing list business, may exchange names and addresses (but not e-mail addresses absent consent) of our customers with companies who may also contact you by mail. You may “opt-out” of receiving offline communications from us any time.
- To improve our websites, features, products and services : We may use the information that we collect to improve TBG’s product offerings, services, as well as our websites and features.
We will store your information only for as long as we need to use your information for the above purposes.
3. How do we share and disclose your information?
We will only share Personal Information as provided in this Privacy Statement, and within our company and corporate affiliates. We do not and will not sell or trade your Personal Information to any third party outside of TBG.
We may make your information available to certain third-party service providers, such as contractors or vendors, who help us manage or provide services offered on our Website, such as hosting, analytics, customer service, etc. We may need to share your Personal Information with them, but we require that all of our service providers keep Personal Information confidential and not disclose it to third parties and not use it for any other purpose.
We may also use or disclose your Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Website; (b) respond to requests from public and government authorities; (c) protect and defend our rights or property, the Website or our users; or (d) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, the users of the Website, or the public.
Merger, Sale, Or Bankruptcy
If we sell all or part of our business, or make a sale or transfer of our assets, or are otherwise involved in a merger or transfer of all or a material part of our business, or are involved in a bankruptcy, TBG may transfer your information to the party or parties involved as part of that transaction.
If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of Personal Information we have shared with third parties, if any, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request to the contact information provided below. California law also permits residents of California to opt-out of TBG’s disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes at any time by submitting a request in writing to the contact information provided below. Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.
How Information is Stored and Processed
Personal information collected on our Website, or received by TBG from you or third parties, may be stored and processed in the United States or any other country where we or our service providers maintain facilities.
The servers and databases in which information is be stored may be located outside the country from which you accessed the Website, and in a country that does not have the same privacy laws as your country of residence. The Personal Information you provide us may be transmitted abroad, but we will collect, process and use Personal Information only in accordance with this Privacy Statement.
International Transfer of Information
If you choose to provide us with Personal Information, we may transfer that information to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world in accordance with legal requirements. TBG uses European Union Commission Standard Contractual Clauses for data transfers from the European Union to countries outside the European Economic Area.
Employment-related information and queries may be transferred to TBG. By visiting this Website and submitting information, you consent to such collection, processing, transfer and/or storage of your Personal Information.
4. How do we secure your information?
We are committed to ensuring that your information is secure. We use commercially reasonable efforts to protect your Personal Information collected, used, stored, shared, or transferred through the Website from access, loss, misuse, alteration, or destruction by any unauthorized party. Please understand, however, that no transmission of data over the internet or any other public network can be guaranteed to be 100% secure. We do not promise, and you should not expect, that your Personal Information or private communications will always remain private. You are also responsible for taking reasonable steps to protect your information against unauthorized disclosure or misuse such as by maintaining the confidentiality of your username and password, and logging out of your account when not using the Website.
5. Links to or from other websites
This Privacy Statement applies solely to information collected by, or on behalf of, TBG. Please note that the Website may link to other websites and online services operated by third parties. These websites and applications operate independently from us, and we do not control their privacy policies, which may be different from ours. TBG is not responsible for the data collection, use, disclosure, or storage practices (or any action or omission) of companies or organizations to which our Website may provide links. We encourage users to be aware when they leave our Website and to read the privacy policies of any third-party website, application, or other platform that requests or collects Personal Information from or about you.
6. Notice to non-U.S. users
As the Internet is a global environment, collecting and processing Personal Information may involve the transmission of this data internationally, including into and/or outside of the United States. Therefore, by communicating electronically with us, you acknowledge and agree to your personal data being processed in this way.
Specifically, if you are located outside of the United States, please be aware that by using the Website, your Personal Information may be transferred to the United States or other third-countries, the privacy laws of which may be deemed by your country to have inadequate data protection. If you are located outside of the United States and voluntarily submit Personal Information to us, you thereby consent to the general use of such information as provided in this Privacy Statement and to the transfer of that information to, and/or storage of that information in, the United States or other third-countries.
If you reside in the European Union, you have certain rights under the European Data Protection Regulation (“GDPR”), including:
- The right to be informed of the Personal Information we collect and how we process and use that data;
- The right to request access to your Personal Information;
- The right to request that inaccurate Personal Information be rectified, or completed if incomplete;
- The right to request erasure of your Personal Information;
- The right to restrict our processing or use of your Personal Information;
- The right to obtain and reuse your Personal Information for your own purposes;
- The right to object to our processing or transferring your Personal Information;
- The right to withdraw your consent for us to use your Personal Information; and
- The right to lodge a complaint with a supervisory authority under the GDPR.
We have a legitimate interest in collecting and processing your information for the purposes we have outlined in this Privacy Statement and so that we can optimize your experience with the Website. We retain and store your Personal Information only for as long as we have a legitimate business purpose to do so and in accordance with our data retention policies and this Privacy Statement.
In response to receiving a request for one of the rights set forth above, TBG will timely comply with the request within the time periods set forth in the GDPR for each right. Several of the above rights are not absolute and apply only in certain circumstances. TBG will comply with requests for those rights as set forth in the GDPR. We are intent on resolving any issues relating to our handling of your Personal Information, and you may contact us at any time regarding any questions or concerns.
We do not make any decisions about you based on automated processing of your Personal Information.
7. Changes to Privacy Statement
We reserve the right to revise this Privacy Statement from time to time in our sole discretion. We will post and maintain the most recent version of the Privacy Statement on the Website. We may not notify Website visitors of any such revisions by email, phone, or other personal contact. You are responsible for reviewing this Privacy Statement upon each visit to the Website. You can determine if the Privacy Statement has been revised since your last visit by referring to the “Last Modified” date at the top of the Privacy Statement.
8. Contact Us
We are committed to working with you to resolve any complaints you may have regarding this Privacy Statement or the treatment of your Personal Information. If you have any questions about this Privacy Statement or its implementation, please contact us:
By Mail: The Brooks Group
Attn: Global Privacy Officer
301 N. Elm Street, Suite 900
Greensboro, NC 27401
United States of America
By Email: email@example.com