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Last modified: February 1, 2023

Introduction

Pearl Meyer & Partners, LLC (“Pearl Meyer” or “Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide to us when you visit the website www.pearlmeyer.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.
  • In email, text, and other electronic messages between you and this Website.
  • Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

It does not apply to information collected by:

  • Our third party payments processor, Authorize.net. Authorize.net’s privacy policy is available here: https://usa.visa.com/legal/privacy-policy.html.
  • Any other third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
  • Information we collect from you offline through our consulting engagement. That information is subject to Pearl Meyer’s February 1, 2023 Privacy Policy.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at dataprivacy@pearlmeyer.com.

Information We Collect About You and How We Collect It

We collect several types of information from you, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number, the times you visited the Website, and any other identifier by which you may be contacted online or offline (“personal information”);
  • That is about you but individually does not identify you, such as what portion of our Website you have browsed;
  •  About your internet connection, the equipment you use to access our Website, including your browser or device type, unique device identifier, and IP address, and usage details; and/or
  • Information you have provided to us offline through our consulting engagement with you.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, purchasing a product or requesting further services. We may also ask you for information when you fill out a survey, or promotion sponsored by us, and when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
  • Your search queries on the Website.
  • Information you provide to us through our consulting engagement with you.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

How We Use Your Information

Subject to the terms of this Privacy Policy, we use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To send you information about our company, our thought leadership content, and keep you informed of services in which you might be interested.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

Subject to the terms of this Privacy Policy, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Pearl Meyer’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Pearl Meyer about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Pearl Meyer, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third Party Advertising. We do not share your personal information with unaffiliated or non-agent third parties for promotional purposes.
  • Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or by sending us an email stating your request to dataprivacy@pearlmeyer.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

Accessing and Correcting Your Information

You will be asked to opt-in and subscribe to receive future communications from us regarding our services and products when completing a form on the Pearl Meyer website. You may elect to discontinue use of our service as a “registered member.” To opt-out of future communications, you may click “Unsubscribe” in marketing emails at any time or contact us at dataprivacy@pearlmeyer.com to unsubscribe from our registered user database.

Further, at any time after you have submitted personally identifiable information to us, you may contact us at dataprivacy@pearlmeyer.com to:

  • Access: You may request access to information we have collected regarding you or your company. We will respond to your request as soon as possible and (except for in certain circumstances) within one month.
  • Correction: You may notify us of changes to your information if inaccurate or it needs to be updated.
  • Deletion: You may elect to have information we have collected on you deleted from our registered user database.
  • Restriction: You may request that we stop processing your personal information (other than storing it), if: (i) you are verifying the accuracy of it; (ii) you believe the processing is against the law; (iii) you believe we no longer need your information for the purposes identified to you; or (iv) you are verifying whether our legitimate grounds to process your personal information, override your own rights.
  • Transfer: If you wish to transfer your information to another organization as a data controller and certain conditions are satisfied, you may ask us to do so, and we will send it directly if we have the technical means.
  • Withdraw Consent: If you previously gave us your consent to process your personal information for a particular purpose, you can contact us to let us know that you withdraw that consent at any time.

If you request any such changes, we will contact you by email to confirm those changes.

We do not carry out any automated processing, which may lead to an automated decision based on your personal information.

This site contains links to other sites. No information collected on the Pearl Meyer site is shared with or provided to these other sites. Pearl Meyer is not responsible for the privacy practices or the content of such websites. Please see our website terms of use for more information about our online terms and policies.

We will retain your personal information for the period necessary to fulfil the purposes outlined, unless a longer retention period is required or permitted by law. This period will be seven (7) years from the original date of collection unless contractual requirements, litigation requirements, or governmental requests dictate otherwise. When we no longer need your personal information, we will securely delete or destroy it.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit Your California Privacy Rights and Notice at Collection for California Consumers.

Your Colorado, Connecticut, Nevada, and Virginia Privacy Rights

If you are a resident of Colorado, Connecticut, Nevada, or Virginia (or other states with privacy laws that emerge and are relevant from time to time) this section supplements the above Pearl Meyer Website Privacy Policy. Colorado, Connecticut, Nevada, and Virginia, residents who wish to exercise their sale opt-out rights under the Colorado Privacy Act, Connecticut Data Privacy Act, Nevada Revised Statutes Chapter 603A, or Virginia Consumer Data Protection Act by:

Submit a request to opt-out by emailing dataprivacy@pearlmeyer.com with the subject line “Sale Opt-out” or by calling us at (508) 460-9600. However, please know we do not currently sell data triggering that state law opt-out requirement.

If you are not a resident of Colorado, Connecticut, Nevada, or Virginia (or other states as applicable from time to time), this section does not apply to you and you should not rely on it.

Data Security

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: dataprivacy@pearlmeyer.com or write us at:

Attn: Pearl Meyer Privacy Officer

Pearl Meyer & Partners, LLC

112 Worcester Street, Suite 302

Wellesley, MA 02481

Your European Privacy Rights

Location

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), this section supplements the above Pearl Meyer Website Privacy Policy. Our processing of personal data of people who are in the EEA is governed by the European Union’s General Data Protection Regulation (the “GDPR”). Our processing of personal data of people who are in the UK is subject to the Data Protection Act 2018, which incorporates the GDPR as the UK GDPR. We will refer to the GDPR and the UK GDPR collectively as the “GDPR.”  If you are not a located in the EEA or UK, this section does not apply to you and you should not rely on it.

The GDPR requires us to provide certain information to you about your personal information.

Data Controller

The data controller for this website is Pearl Meyer & Partners, LLC.

Purposes of the Processing

The Pearl Meyer Website Privacy Policy above describes the personal information that we collect, use, share, or otherwise process and the purposes for that processing in the course of operating our business (other than in the course of our consulting engagement, which is subject to a separate agreement). Personal information gathered through cookies and similar tracking technologies is used for the purposes described above.

Lawful Basis for the Processing

Generally, we process personal information provided by visitors through our website or other interactions with us on the basis of our legitimate interests in conducting our business as a provider of information concerning pay programs. We may also process personal information on other bases permitted by the GDPR and applicable laws, such as when the processing is necessary for us to comply with our legal obligations.

Categories of Personal Information

The categories of personal information that we process are described above.

Recipients of Your Personal Information

We use service providers and contractors to manage our website and provide related services. Our service providers and contractors have entered into contracts with us that restrict what they can do with your personal information. If you would like specific information about our service providers and contractors who have received your information, please contact us at dataprivacy@pearlmeyer.com with the subject line: “Request for My Personal Information.” and we will provide that information to you. We may also disclose your personal information to other categories of third parties described above.

Consent to Transfers of Personal Information outside of the European Economic Area (EEA)

Pearl Meyer’s administrative offices are based in the USA which is where we process personal information collected through our website. When you provide personal information to us, we request your consent to transfer that personal information to the USA. The USA does not have an adequacy decision from the European Commission, which means that the Commission has not determined that the laws of the USA provide adequate protection for personal information. Although the laws of the USA do not provide legal protection that is equivalent to EU data protection laws, we safeguard your personal information by treating it in accordance with the Pearl Meyer Website Privacy Policy.

Retention Period for Personal Information

We delete the personal information described above within a reasonable period after we no longer need to use it for the purpose for which it was collected (or for any subsequent purpose that is compatible with the original purpose). This does not affect your right to request that we delete your personal data before the end of its retention period. We may archive personal data (which means storing it in inactive files) for (7) seven years prior to its final deletion, as part of our ordinary business continuity procedures.

Your Data Subject Access Rights

You have the right to request access to your personal data, to have your personal data corrected, restricted or deleted, to withdraw any consent that you have given to the processing of your personal data (without affecting the lawfulness of the processing prior to your withdrawal of consent) and to object to our processing of your personal data. You also have the right of data portability in certain circumstances, which means that you can request that we provide you (or a third party you designate) with a transferable copy of personal information that you have provided to us. Your rights may be subject to various limitations under the GDPR. If you wish to exercise any of these rights, please contact us at dataprivacy@pearlmeyer.com with the subject line: “Request for My Personal Information.”

The Right to Lodge a Complaint with a Supervisory Authority

You have the right to file a complaint concerning our processing of your personal data with your national (or in some countries, regional) data protection authority. The EU Commission has a list here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. The data protection authority for the United Kingdom is the Information Commissioner’s Office.

Absence of Statutory or Contractual Requirement or other Obligation to Provide any Personal Data

Users of the Pearl Meyer website are under no statutory or contractual requirement or other obligation to provide personal information to us, but it will not be possible to receive communications from us or register for our events without doing so.

Last modified: February 1, 2023

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