This California Residents Privacy Policy describes Ferguson Partners’ (“Company,” “we,” “us,” or “our”) practices regarding the collection, use, and disclosure of the personal information of California residents (“Consumers”), describes the rights of Consumers under the California Consumer Privacy Act of 2018 (“CCPA”), and explains how Consumers may contact Ferguson Partners to exercise those rights. This policy only applies to the personal information of Consumers (i.e., California residents).
Consumer Rights
This section describes certain rights of Consumers under the CCPA. For information on how Consumers may contact Company to exercise these rights, please see the section below entitled, “How to Submit a Request.”
Right to Know
A Consumer has the right to request that a business disclose what personal information it collects, uses, discloses or sells. Specifically, a Consumer may request that a business that collects personal information about the Consumer disclose to the Consumer the following:
- The categories of personal information it has collected about that Consumer.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting or selling personal information.
- The categories of third parties with whom the business shares personal information.
- The specific pieces of personal information it has collected about that Consumer.
A Consumer may request that a business that sells the Consumer’s personal information, or that discloses it for a business purpose, disclose to that Consumer:
- The categories of personal information that the business collected about the Consumer.
- The categories of personal information that the business sold about the Consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
- The categories of personal information that the business disclosed about the Consumer for a business purpose.
Right to Request Deletion
A Consumer has the right to request that a business delete any personal information about the Consumer which the business has collected from the Consumer. To request deletion of your personal information, you may go to the Company’s Delete My Personal Information web page. If it is necessary for Company to maintain the personal information for certain purposes, Company is not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.
Right to Opt-Out of Sale of Personal Information
A Consumer has the right to direct a business that sells personal information about the Consumer to third parties not to sell the Consumer’s personal information. To opt-out of the sale of personal information by Company, you may go to the Company’s Do Not Sell My Personal Information web page.
No Discrimination
A Consumer has the right not to be discriminated against because the Consumer exercised any of the Consumer’s rights under the CCPA. Company may charge a Consumer a different price or rate, or provide a different level or quality of goods or services to the Consumer, if that difference is reasonably related to the value provided to the Consumer by the Consumer’s data.
How to Submit a Request
To exercise the rights described above, you must submit a verifiable Consumer request to us by contacting Company at the toll-free number or webform below and providing the requested information. You may submit a verifiable Consumer request through any of the following methods:
You may call +1 (844) 961-1606.
You may submit a request online at https://www.fergusonpartners.com/contact-us/request-to-know/
You may submit a request as frequently as you would like, but we are not required to respond to requests to provide personal information to you more than twice in any 12-month period.
To submit a verifiable Consumer request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors. We may also require you to provide a written declaration that you are who you say you are. Once we receive your request, we will contact you if we need further information to verify your identity.
You may designate an authorized agent to make a request on your behalf by submitting a request via email to privacy@fergusonpartners.com.
If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.
How we collect, use and share personal information of Consumers
The Company has collected the following categories of Personal Information about Consumers in the twelve (12) months prior to the Effective Date of this Policy:
Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Characteristics of protected classifications under California or federal law (Race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, gender identity and gender expression).
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a Consumer’s interaction with an Internet Web site, application, or advertisement.
Professional or employment-related information.
Education information.
Inferences drawn from any personal information to create a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Company collects the personal information described above from the following categories of sources:
- Publicly-available sources, such as social media sites
- Paid-subscription databases
- Association membership lists
- Consumers directly
- Third parties, such as market references and assessment providers
- Survey participants
- Clients
- Company’s website
Company collects the personal information described above for a variety of business purposes. Company uses the personal information to:
- To perform and provide executive search, compensation consulting, leadership consulting, management consulting, survey and other services
- To conduct compensation studies and other research and analysis, including the creation of de-identified data for such research and analysis
- To inform clients, candidates, and other Consumers about Company’s services and offerings
- To operate and improve our website
- To improve our service offerings
- To communicate with Consumers about potential opportunities
- To respond to your inquiries
- To provide you with information and updates about our Services, new offerings and events
- To conduct Company’s internal operations, including our legal, human resources, risk management, marketing and security functions
Company may share the personal information described above with the following categories of third parties:
- Clients and prospective clients
- Company’s vendors and service providers that help us operate our business
- With third parties in connection with potential or actual sale of our company or any of our assets, in which case personal information held by us about our users may be one of the transferred assets
- To law enforcement or other third parties where we are required to do so by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us
Company has sold the following categories of Personal Information about Consumers in the twelve (12) months prior to the Effective Date of this Policy:
Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Characteristics of protected classifications under California or federal law (Race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, gender identity and gender expression).
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a Consumer’s interaction with an Internet Web site, application, or advertisement.
Professional or employment-related information.
Education information.
Inferences drawn from any personal information to create a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Company has disclosed the following categories of Personal Information about consumers for a business purpose in the twelve (12) months prior to the Effective Date of this Policy:
Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Characteristics of protected classifications under California or federal law (Race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, gender identity and gender expression).
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a Consumer’s interaction with an Internet Web site, application, or advertisement.
Professional or employment-related information.
Education information.
Inferences drawn from any personal information to create a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal Information of Minors
Company does not sell Personal Information about minors under the age of 16.
Contact for More Information
If you have any questions or concerns about Company’s privacy policy and practices, please contact Joseph A. Venzon, Chief Administrative Officer, jvenzon@fergusonpartners.com, +1 (312) 368-0569.
Last updated: August 10, 2020.