ORC – Website Privacy Notice
Last updated October, 2023
This Privacy Notice describes the information collection, use, retention and sharing practices of O.R. Colan Associates, LLC (“ORC”, “we”, “us”, “our”) and its affiliates and subsidiaries when you interact with us through our website, www.orcolan.com (the “Website”), or other digital products on which this Privacy Notice appears (collectively, the “Services”).
PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG
We collect personal information, which is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you, when you:
- Contact us via the Website. When you contact us through the Website, for example, to submit questions regarding our technology solutions, we collect, from you, your personal identifiers (first and last name, email address, and telephone number). We use this personal information to respond to your questions or inquiries, troubleshoot where necessary, and address any issues you have with the Services.
- Submit a referral to our ORC Referral Program. When you submit a referral to our ORC Referral Program, we collect, from you, your personal identifiers (first and last name, email address, and telephone number) and the personal identifiers (first and last name, email address, and telephone number) of your referral along with their professional or employed-related information (resume). We use this personal information to assess and manage referrals, and, in the event of successful placement of your referral, pay to you the $500 referral payment. For more information on how we handle applicant personal information, please see our Applicant Privacy Notice.
- Apply for employment. When you apply for employment with ORC on our Website, we collect, from you, your personal identifiers (first and last name, email address, telephone number, physical address) and your professional or employment-related information (resume and cover letter), and any additional information you choose to include in your application. We use this personal information to assess and manage your application and to communicate with you about your application. For more information on how we handle applicant personal information, please see our Applicant Privacy Notice.
- Interact with us at in-person promotional events. When you interact with us at in-person promotional events (e.g., trade shows, etc.), we may collect, from you, your personal identifiers (first and last name, email address, and telephone number). We use this information to communicate with you after the event and to send you additional information, if requested.
- Fan Pages. When interacting with our Fan Pages, we collect, from you, your personal identifiers (first and last name and profile picture) as well as any information that you provide when interacting with our Fan Pages (e.g. commenting, sharing and rating). We use this information to advertise our products, for events and invitations, and to communicate with users via the contribution and comment function. Because our Fan Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit. The content posted on our Fan Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please contact us here.
- Community Management. With the help of a third party, we collect, from you, your contact, including “likes”, shares, messages and other interactions with the content, in order to analyze and evaluate how our content is perceived, to learn from it, and to improve our public relations efforts. We use this information to create advertisements that match our Fan Page and to disseminate them via Facebook based on demographic data.
- Aggregate data. We aggregate the data we collect for benchmarking purposes and for internal analytics.
ORC will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.
We retain personal information for purposes of compliance with our legal obligations, exercising or defending legal claims, and meeting our safety and security commitments.
HOW WE SHARE YOUR PERSONAL INFORMATION
A. General Sharing
ORC shares personal information in the following instances:
- In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
- For legal purposes. We share your personal information where we are legally required to do so, such as in response to court orders, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of service or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations.
B. Sharing in the Last Twelve (12) Months
For a business purpose. In the preceding twelve (12) months, ORC has disclosed the following categories of personal information for a business purpose to the following categories of third parties:
- We have disclosed your internet or other electronic network activity information related to Services to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair the Website and platform errors.
- We have disclosed your internet or other electronic network activity information related to Services to our IT support to update, improve, and maintain the Website and platform.
C. Sale of Personal Information
In the preceding twelve (12) months, ORC has shared your internet or other electronic network activity information collected via cookies and other tracking technologies with our data analytics providers described in PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG. Such sharing may be deemed a sale under the CCPA (“California Consumer Privacy Act”) or sharing under the CPRA. To opt out of this sale or sharing, please visit Do Not Sell or Share My Personal Information.
YOUR INFORMATION CHOICES
You have the following choices with respect to your personal information:
- Correct or View Your Information. You may access your account to correct or view certain personal information you have provided to us and which is associated with your account.
- Opt Out of Google Analytics. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser, which can be accessed here.
- Opt Out of Advertising Cookies. To set your cookie preferences or opt out of the sale or sharing of your information via cookies, please visit Do Not Sell or Share My Personal Information. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an “opt-out cookie” on your device. The “opt-out cookie” is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.
RIGHTS OF CALIFORNIA RESIDENTS
The California Privacy Rights Act (“CPRA”) entitles California residents to certain rights. To the extent the CPRA applies to our processing of your personal information, you are entitled to the following rights:
- Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort. You may only make a request for access twice within a 12-month period.
- Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking be deleted, we would not be able to delete the information until we are legally permitted to delete it.
- Right to Opt Out of Sale/Sharing. You have the right to opt out of the sale or sharing of your personal information to third parties. ORC does not have actual knowledge that it sells or shares personal information of minors under the age of sixteen (16) years. We only sell or share personal information under CPRA via cookies. Our use of third-party cookies may be deemed a sale or sharing under the CCPA/CPRA. To opt out of the sale or sharing of your personal information through cookies, please visit Do Not Sell or Share My Personal Information.
- Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, opt out, correct, or limit use of sensitive personal information under the CPRA.
- Right to Correct. You have the right to correct inaccurate personal information that we collect or maintain.
- Right to Limit Use of Sensitive Personal Information. You have the right to limit the use of your sensitive personal information when such use goes beyond that which is necessary for providing the Services or certain other permissible purposes like fraud, customer service or quality control. Sensitive information includes Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin. ORC does not use sensitive information collected through the Services in this manner.
To exercise your right to know, access or delete your personal information, you may submit a request via our Contact Us page, or by calling us toll-free at 704-529-3115. To opt out of the sale or sharing of your personal information via cookies, please visit Do Not Sell or Share My Personal Information. To opt out of the sale of your personal information for marketing purposes, you may submit a request via our Contact Us page, or by calling us toll-free at 704-529-3115. When submitting your request, please describe the nature of your request and the nature of our relationship with you.
For requests submitted via telephone, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.
Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
DO NOT TRACK
We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
We implement and maintain reasonable security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.
The Services are not intended for individuals under the age of eighteen (18) years. If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete the personal information. If you believe we have personal information on individuals under the age of eighteen (18), please contact us at the contact information provided below.
CHANGES TO THIS PRIVACY NOTICE
We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and obtain your consent, if required.
If you have any questions or concerns regarding this Privacy Notice, please contact our Corporate Office via telephone at 704-529-3115 or send us a message via Contact Us.