U. S. Residents Privacy Policy

This U.S. Residents Privacy Policy describes Ferguson Partners' (“Company,” “we,” “us,” or “our”) practices regarding the collection, use, and disclosure of the personal information of U.S. residents (“Consumers”), describes the rights of Consumers under the California Consumer Privacy Act (“CCPA”) and other similar state laws, and explains how Consumers may contact Ferguson Partners to exercise those rights, if applicable. This policy supplements the Ferguson Partners Privacy Policy, which can be found here.

Consumer Rights

This section describes certain rights of Consumers. For information on how Consumers may contact Company to exercise these rights, if available, please see the section below entitled, “How to Submit a Request.”

Right to Know

A Consumer may have the right to request that a business disclose, over the last 12 months, 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, selling or sharing 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 or shared about the Consumer and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared.
  • The categories of personal information that the business disclosed about the Consumer for a business purpose.

Right to Request Deletion

A Consumer may have the right to request that a business delete any personal information about the Consumer which the business has collected from the Consumer, subject to certain exceptions. 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 Request Correction

A Consumer may have the right to request correction of inaccurate personal information held by the business.

Right to Opt-Out of Sale or Sharing of Personal Information

A Consumer may have the right to direct a business that sells or shares (for targeted advertising) personal information about the Consumer to third parties not to sell or share the Consumer’s personal information. To opt-out of the sale or share of personal information by Company, you may go to the Company’s Do Not Sell My Personal Information web page.

Right to Limit the Use of Sensitive Personal Information

A Consumer may have the right to limit how we use and disclose your sensitive personal information. At any time, on request, you can restrict our use and disclosure of sensitive personal information to just the permitted purposes under the CCPA by going to the Company’s Limit the Use of Sensitive Personal Information web page. Sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not subject to the right to limits its use and disclosure.

No Discrimination

A Consumer has the right not to be discriminated against because the Consumer exercised any of the Consumer’s rights.

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 applicable 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:

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 [email protected]. We may also verify the identity of your authorized agent.

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.

In certain circumstances, you may be able to appeal a refusal to take action on a request.  To request an appeal, contact us at [email protected].

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:

  • Identifiers: 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.
  • Customer records: 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.
  • Protected classification characteristics: 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: including your current employer, title, and location.
  • Non-public education information: including grades and transcripts.
  • Inferences: including, 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.
  • Sensitive personal information: certain data elements we collect may be deemed “sensitive personal information,” including government identification, e.g., social security number, passport number, driver’s license number, and your username and password to access your account.

Company collects the personal information described above from the following categories of sources:

Directly from you, for example when you provide us with your resume or participate in a survey.

Indirectly from you, for example by observing your interactions with our networks, websites, marketing content, or computers.

From third parties, for example:

  • Publicly-available sources, such as social media sites
  • Paid-subscription databases
  • Association membership lists
  • Market references and assessment providers
  • Company’s clients

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
  • To protect the rights, privacy, safety, or property of you, us, or others

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 or shared (targeted advertising) the following categories of Personal Information about Consumers in the twelve (12) months prior to the Effective Date of this Policy:

  • Identifiers
  • Customer records
  • Protected classification characteristics
  • Professional or employment-related information
  • Non-public education information
  • Inferences
  • Sensitive personal information

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:

  • Identifiers
  • Customer records
  • Protected classification characteristics
  • Professional or employment-related information
  • Non-public education information
  • Inferences
  • Sensitive personal information

Retention of Information

Company will generally retain personal information about you for so long as we have a legal or business purpose for it or a legal requirement to maintain it.  The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you (for example, for as long as you are a client with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
  • Whether there is a legal or ethical obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

California's "Shine the Light" Law

In addition to the rights described above, California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year.

To make such a request, please send an email to [email protected].

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, [email protected], +1 (312) 368-0569.

Last updated: May 9, 2023.

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