Privacy Policy

Last Modified: August 22, 2023

Introduction

Gordon Brothers Group, LLC, along with its affiliates and subsidiaries (“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 when you visit the website www.gordonbrothers.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

California Consumer Privacy Act. If you are a California resident, please review the Additional Privacy Information for California Residents section below for important information about how we use, collect and disclose information about California residents and your rights under the California Consumer Privacy Act (CCPA).

GDPR. We have also developed and posted a GDPR Privacy Notice, which is available [here]. Our GDPR Privacy Notice contains additional information about how Gordon Brothers’ US processes personal information that is subject to EU data protection laws (including those implementing the EU General Data Protection Regulation, or “GDPR.”)

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.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Gordon Brothers or any third party; or
• Any third party, including through any application or content (including advertising) that may linked to or be accessible from or on the Website.

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 information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not register on the Website, use any of the interactive or public comment 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 username 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:

101 Huntington Ave Suite 1100
Boston, MA 02199
[email protected]
+1 888 424-1903

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information“);
• That is about you but individually does not identify you; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

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.

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 subscribing to our services, posting material, signing up for our mailing lists, register for events that we host or sponsor or requesting further services. We may also ask you for information when you enter a contest 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.
• Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

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 may include personal information, or 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.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Website and our emails 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).

How We Use Your Information

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 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 goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form). For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

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 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.
• 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 Gordon Brothers Group, LLC, along with its affiliates and subsidiaries’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Gordon Brothers Group, LLC, along with its affiliates and subsidiaries 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 agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Gordon Brothers Group, LLC, along with its affiliates and subsidiaries, our customers, or others.

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. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by emailing your opt-out preference to [email protected].

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: [email protected]. However, please know we do not currently sell data triggering that statutes’ opt-out requirements.

International Transfers

Gordon Brothers is a global company; when you submit personal information to us, or when others provide personal information to us, we will receive it and process it in the United States and in other locations where we are located or where we have service providers. In order to provider services, we also may need to transfer your personal information to locations in other jurisdictions.

If you are based within European Economic Area (EEA) please note that where necessary to deliver the services, we will transfer personal information to countries outside the EEA. Countries outside the EEA may not provide an adequate level of protection to your personal information, which is why the Gordon Brothers’ entities have signed a data sharing agreement, based on the EU standard contractual clauses, to provide appropriate safeguards and an adequate level of protection for personal information.

You have a right to obtain details of the mechanism under which your personal information is transferred outside of the EEA; you may request such details by contacting us at [email protected].

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 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:

101 Huntington Ave Suite 1100
Boston, MA 02199

[email protected]

or via our toll-free number:

+1 888 424-1903

To register a complaint or concern, to review the personal information we have collected about you via the Website, or request that we update or delete it, please contact us at the email address or toll-free number above.

Additional Privacy Information for California Residents

In this section, we provide additional information to California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”). This section does not apply to publicly available information lawfully made available by state or federal government records, deidentified information, aggregate consumer information, or other personal information that is exempt under the CCPA (such as information covered by the Health Insurance Portability and Accountability Act).

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about California residents in the prior 12 months (from the Last Updated date above), and the rights California residents have under the CCPA regarding this personal information.

• Categories of personal information that we collect and disclose

The table below identifies the categories of personal information (as defined by the CCPA) that we have collected about consumers in the prior 12 months, as well as how we have disclosed such information for a business purpose (subject to our applicable legal and ethical obligations). For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the Use of Personal Information and and the Disclosure of Personal Information sections above.

 

In addition to the above, we may disclose the personal information that we collect to others, as necessary to comply with applicable laws or our legal and ethical obligations. We do not sell personal information about California residents, including those we have actual knowledge are younger than 16.

• Categories of sources of the personal information that we may collect

As further described in the Information We Collect section above, we may collect personal information directly from individuals, as well as from third parties* and other sources:

• Service providers*
• Judicial and quasi-judicial bodies*
• Regulatory and government entities*
• Affiliates*
• Legal support firms*
• Clients*
• Parties and related parties in legal matters*
• Public sources and records
• Social networks

*Additional information about the categories of third parties listed above:

• Service providers: includes vendors, service providers, and content providers, as well as our professional advisors (such as lawyers and accountants) and our professional indemnity insurers.
• Judicial and quasi-judicial bodies: such as courts, arbitral bodies and tribunals.
• Regulatory and government entities: government, administrative, law enforcement and regulatory agencies; tax authorities; corporate registries; and other public agencies or authorities.
• Affiliates: our affiliates and subsidiaries.
• Legal support firms: other law firms, consultants and professional advisors that we work with to provide our services to a particular client.
• Clients: our clients, with respect to, the relevant services we provide to them.
• Parties and related parties in legal matters: other parties in transactions in which we have been engaged as a service provider, to the extent required or necessary for our provision of services.

• CCPA Rights

In general, California residents have the following rights with respect to their personal information:

• Do-not-sell (opt-out): to opt-out of our sale of their personal information. We do not sell personal information about California consumers, including those we have actual knowledge are younger than 16.
• Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
• Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
  • categories of personal information collected
  • categories of sources of personal information
  • categories of personal information about them we have disclosed for a business purpose or sold
  • categories of third parties to whom we have sold or disclosed for a business purpose their personal information
  • the business or commercial purposes for collecting or selling their personal information
  • a copy of the specific pieces of personal information we have collected about them
• Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

• Submitting CCPA Requests

California residents may submit CCPA requests to know (access) and requests to delete their personal information through one of the following methods:

• Online by emailing [email protected]
  • By phone at +1 888 424-1903 (toll free)

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must provide your name and contact information to verify your request. In some cases, we may request additional information to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us by email at the above link; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.