We value your
Last updated: September 15, 2023
This Policy explains how we collect and use personal information when you contact us through our website www.hallorancg.com (our “Website”), our practices for collecting, using, maintaining, protecting, and disclosing that information, and the rights you have regarding that information. Please read this Policy carefully to understand our policies and procedures regarding your information and how we will treat it. If there are any terms in this Policy that you do not agree with, please discontinue use of our Website immediately. By accessing or using our Website, you agree to this Policy. This Policy may change from time to time (see How We Make Updates to our Policy). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates. If you have any questions or concerns about this Policy or our practices with regards to your personal information, please contact us using the contact information provided at the end of this Policy.
TABLE OF CONTENTS
- WHAT INFORMATION WE COLLECT
- HOW WE USE YOUR INFORMATION
- CIRCUMSTANCES UNDER WHICH WE DISCLOSE YOUR INFORMATION TO OTHER PARTIES
- CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
- HOW LONG WE KEEP YOUR INFORMATION
- HOW WE KEEP YOUR INFORMATION SAFE
- YOUR PRIVACY RIGHTS
- CONTROLS FOR DO-NOT-TRACK FEATURES
- HOW WE MAKE UPDATES TO OUR POLICY
- CONTACT INFORMATION
1. WHAT INFORMATION WE COLLECT
The personal information that we collect depends on the context of your interactions with us and our Website, the choices you make, and the features you use. The types of information we have collected over the last 12 months, the sources from which we have collected it, and the reasons for collecting it are shown in this chart:
Category of Information
Sources of Information
Business Purpose for Collecting
(such as name, email address, job title, company name, contact preferences, IP address)
- Joint marketing partners
- Public databases
- Data brokers
- To provide the services you request
- To send you updated information about our services
(such as purchase history)
- To provide the services you request
- To help us understand our customer needs and improve our website and business services
Internet or other electronic network activity
(such as browsing history and search history)
- Internet service providers
- Our operating system
See detail regarding “Information Automatically Collected” below
- Internet service providers
Information Automatically Collected
We automatically collect certain information when you visit, use, or navigate our Website. This information does not reveal your specific identity (like your name or contact information), but may include the information described below and other technical information. This information is primarily needed to maintain the security and operation of our Website and for our internal analytics and reporting purposes.
The type of information we collect automatically includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in our Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
- Device Data. We collect device data about the computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information.
- Location Data. We collect location data, such as information about your device’s location. Location data can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access our Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device.
2. HOW WE USE YOUR INFORMATION
We use the personal information that we collect for a variety of business purposes, as described below:
- To provide services. We use your information to respond to questions you send us and to provide services you request.
- To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial that includes any information that identifies you, we will obtain your consent to use that information. We may use your testimonial without obtaining your consent if it does not contain any personally identifiable information. If you wish to update or delete your testimonial, please contact us using the contact information provided below and be sure to include your name, testimonial location, and contact information.
- To request feedback. We may use your information to request feedback and to contact you about your use of our Website.
- To send administrative information to you. We may use your contact information to send you information about changes to our terms, conditions, and policies.
- To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies. We may use your information if we believe you are not complying with this Policy or other terms and conditions that apply to your interactions with us.
- To comply with legal and regulatory requirements. We may use your information to comply with legal or regulatory requirements, such as responding to a subpoena or other legal request.
- To send you marketing and promotional communications. We and our third-party marketing partners may use your personal information for our marketing purposes, including for developing and sending you personalized content and advertising. You can opt-out of our marketing communications as described in the section of this Policy captioned “Your Privacy Rights.”
3. CIRCUMSTANCES UNDER WHICH WE MAY DISCLOSE YOUR INFORMATION TO OTHER PARTIES
During the last 12 months, we have disclosed the types of personal information listed in the chart in Section 1 of this Policy to the service providers and vendors who help us operate and improve our Website and services, which include data analytics providers, information technology providers, and website hosting providers. When we believe it is necessary or appropriate to do so, we may also disclose personal information to government authorities, internet service providers, and in response to a subpoena or court order. We make these disclosures for one or more of the following business purposes:
- To provide you with requested information and other useful content;
- To facilitate your movement through our Website;
- To help us offer you a personalized experience on our Website (for example, in order to provide you with specific resources applicable to your industry)
- To offer, operate, evaluate, and improve our Website and our business;
- In connection with our security and compliance programs;
- To comply with law; and
- To communicate with you.
We take the following factors into account when considering a disclosure of your personal information:
- Your Consent: We may disclose your personal information to another party if you have given us specific consent to do so or to use your personal information for a specific purpose that requires such disclosure.
- Our Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Our Legitimate Business Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- The Role of Service Providers: We may disclose your personal information to contractors and service providers who we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- Certain Types of Corporate Transactions: We may disclose or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Halloran does not sell personal information and does not share information with third parties for purposes of cross-context behavioral advertising.
We use two types of cookies. “Session” cookies expire at the end of your browser session. They allow us to remember your actions during a browser session. “Persistent” cookies are stored on your device, allowing us to remember your preferences and actions when you return to our Website on subsequent occasions. The cookies we place on your device are called “first party cookies.”
In addition to first party cookies, we allow other parties (“third parties”) to set cookies on our Website. Third party cookies may enable the third party’s functionality or features on our Website.
5. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
- Internet Browser Settings – Some internet browsers allow you to change your cookies settings through an “Options” or “Preferences” menu. Please note that certain features or functionality of our Website may become unavailable if you set your preferences to block all cookies.
- Promotional Offers from Halloran. If you do not wish to have your email address/contact information used by Halloran to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to email@example.com. If we have sent you a promotional email, you may click the unsubscribe option at the bottom of the email or email us at firstname.lastname@example.org asking to be omitted from future email distributions.
6. HOW LONG WE KEEP YOUR INFORMATION
We will only keep your personal information for as long as we need it for the purposes described in this Policy, unless a longer retention period is required by law (such as tax, accounting or other legal requirements). Nothing in this notice requires us to keep your personal information for any minimum period of time.
If we have no continuing legitimate business need to keep your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further use until it can be deleted in the normal course of business.
7. HOW WE KEEP YOUR INFORMATION SAFE
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we collect. However, despite our efforts to secure your information, no transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized persons will not be able to defeat our security and improperly collect, access, steal, or modify your information. Transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
8. YOUR PRIVACY RIGHTS
You have certain rights regarding the personal information we collect or maintain about you.
Accessing your information: You have the right to know what personal information we have collected about you. We will provide the information in a format that is easily understandable and, to the extent technically feasible, in a structured, commonly used, machine-readable format that can be transferred to another entity at your request.
Correcting your information: You have the right to ask us to update or correct inaccurate personal information.
Deleting your information: You have the right to ask us to delete the personal information we have collected from you. Except as otherwise required by applicable law, we have the right to retain information we need in order to complete a transaction with you or for other legitimate purposes.
Submitting requests to access, correct, or delete your information: You can submit a request for access to or correction or deletion of your information online by submitting this form or by contacting us through any of the methods shown in the “Contact Information” section at the end of this Policy, including by calling us using our toll-free number. You may authorize a third party to submit any of these requests on your behalf; however, as described in the next paragraph, we may ask for confirmation of your authorization. There is no charge for submitting any of these requests. We will not discriminate against you in any way for submitting a request or exercising any of your other rights under applicable law.
If you ask us to disclose, correct, or delete your personal information, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We may ask you to provide information so that we can match it with information you have previously provided to us or we may contact you through a communication method (such as phone, text, or email) that you have previously provided to us. We may also use other verification methods. If you have authorized someone else (an “authorized agent”) to ask us to disclose, correct, or delete your personal information on your behalf, we may request that you identify yourself directly or confirm that you have authorized the agent to submit the request on your behalf.
In addition to the rights described above, you can manage the information we collect and use about you in the following ways:
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by using the contact information provided below. You will then be removed from the marketing email list, but we may still communicate with you for other non-marketing purposes, such as to respond to service requests.
Opting out of cookies: You can opt out of some cookies and other tracking technologies as described above in the section of this Policy captioned “Choices About How We Use and Disclose Your Information.”
Withdrawing consent: If we are relying on your consent to collect or use your personal information, you have the right to withdraw your consent at any time. Please note however that withdrawing your consent will not affect the lawfulness of our use of your information before the withdrawal, nor will it affect the use of your personal information conducted in reliance on grounds other than consent.
If you live in certain regions, you may have additional rights under applicable data protection laws.
If you have any questions or comments about your privacy rights, you may contact us using any of the methods described in the “Contact Information” section at the end of this Policy.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because no uniform technology standard for recognizing and implementing DNT signals has been finalized, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.
Our Website is not directed to persons under the age of 18 and we do not knowingly collect personal information from anyone under the age of 18. If you are a parent or guardian of a minor and become aware that your child has provided us with personal information, please contact us using the contact information provided at the end of this Policy and we will take reasonable steps to remove such information promptly.
12. HOW WE MAKE UPDATES TO OUR POLICY
We may update this Policy from time to time. When we update the Policy, we will change the date shown at the beginning of the Policy and post the updated Policy on our Website. We encourage you to check back frequently for current information on how we are protecting your information. By continuing to use our Website after a Policy update, you agree to the privacy practices described in the updated Policy.
13. CONTACT INFORMATION
If you have questions or comments about this Policy, the ways in which Halloran collects and uses your information described in this Policy, your choices and rights regarding such use, or wish to exercise your privacy rights, please contact us at:
Toll-free telephone number: 1-800-220-5086
Halloran Consulting Group, Inc.
Attn: Data Protection Officer
22 Thomson Place
Boston, MA 02210
Online Form to access, correct, or delete personal information