Privacy Policy

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This privacy notice for Russell Square Consulting, Inc. (“we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:
  • Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hrdept@russellsquareconsulting.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

4. HOW LONG DO WE KEEP YOUR INFORMATION?

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

6. DO WE COLLECT INFORMATION FROM MINORS?

7. WHAT ARE YOUR PRIVACY RIGHTS?

8. CONTROLS FOR DO-NOT-TRACK FEATURES

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

10. DO WE MAKE UPDATES TO THIS NOTICE?

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
  • names
  • phone numbers
  • email addresses
  • mailing addresses
  • job titles
  • contact preferences
  • contact or authentication data
  • personal identifiers
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
  • information revealing race or ethnic origin
  • social security numbers or other government identifiers
  • credit worthiness data
  • student data
  • health data
  • financial data
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

    • 3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

    In Short: We may share information in specific situations described in this section and/or with the following third parties.
    We may need to share your personal information in the following situations:
    • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

    4. HOW LONG DO WE KEEP YOUR INFORMATION?

    In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
    We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
    When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

    5. HOW DO WE KEEP YOUR INFORMATION SAFE?

    In Short: We aim to protect your personal information through a system of organizational and technical security measures.
    We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

    6. DO WE COLLECT INFORMATION FROM MINORS?

    In Short: We do not knowingly collect data from or market to children under 18 years of age.
    We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hrdept@russellsquareconsulting.com.

    7. WHAT ARE YOUR PRIVACY RIGHTS?

    In Short: You may review, change, or terminate your account at any time.
    Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
    However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
    If you have questions or comments about your privacy rights, you may email us at hrdept@russellsquareconsulting.com.

    8. CONTROLS FOR DO-NOT-TRACK FEATURES

    Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

    9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

    In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
    California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
    If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

    CCPA Privacy Notice

    The California Code of Regulations defines a “resident” as:
    (1) every individual who is in the State of California for other than a temporary or transitory purpose and
    (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
    All other individuals are defined as “non-residents.”
    If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

    What categories of personal information do we collect?

    We have collected the following categories of personal information in the past twelve (12) months:

    Category

    Examples

    Collected

    A. Identifiers
    Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
    YES
    B. Personal information categories listed in the California Customer Records statute
    Name, contact information, education, employment, employment history, and financial information
    YES
    C. Protected classification characteristics under California or federal law
    Gender and date of birth
    YES
    D. Commercial information
    Transaction information, purchase history, financial details, and payment information
    NO
    E. Biometric information
    Fingerprints and voiceprints
    NO
    F. Internet or other similar network activity
    Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
    NO
    G. Geolocation data
    Device location
    YES
    H. Audio, electronic, visual, thermal, olfactory, or similar information
    Images and audio, video or call recordings created in connection with our business activities
    NO
    I. Professional or employment-related information
    Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
    YES
    J. Education Information
    Student records and directory information
    NO
    K. Inferences drawn from other personal information
    Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
    NO
    L. Sensitive Personal Information
    Account login information, contents of email or text messages, debit or credit card numbers, drivers’ licenses, passport numbers, racial or ethnic origin, social security numbers, state id card numbers, health data and precise geolocation
    YES
    We will use and retain the collected personal information as needed to provide the Services or for:
    • Category A – While they are employed with us and 4 years after termination.
    • Category B – As long as they are hired with us and 4 years after their termination.
    • Category C – While they are employed with us and 4 years after their termination.
    • Category G – As long as the user has an account with us
    • Category I – While they are employed with us and 4 years after their termination.
    • Category L – While they are employed with us and 4 years after their termination.
    Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.
    We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
    • Receiving help through our customer support channels;
    • Participation in customer surveys or contests; and
    • Facilitation in the delivery of our Services and to respond to your inquiries.

    How do we use and share your personal information?

    More information about our data collection and sharing practices can be found in this privacy notice.

    We do not use or disclose sensitive Personal Information outside of the permitted purposes set forth under Section 7027(m) of the California Consumer Privacy Act Regulations.

    We may share information about you, including your Personal Information, with third parties in certain circumstances, including:

    Within Our Corporate Organization. With affiliated businesses within our corporate organization, or companies within our corporate family and our current and future parents, affiliates, subsidiaries, franchisees, and/or other companies under common control and ownership.

    With Service Providers.  With service providers, who may have access to or need to process your Personal Information for employment purposes or as otherwise required by law. These services may include, among other things, monitoring and surveillance, providers offering services to make background checks, to create or maintain our databases, to prepare and distribute communications, to respond to inquiries, to process payroll payments, to process authentication and log-in information in our internal information systems, backup, and storage. These third-party service providers may have access to or process your Personal Information for the purpose of providing these services for us. We do not permit our third-party service providers to use the Personal Information that we share with them for their own commercial purposes.

    Legal or Regulatory Purposes: We share information with governmental and regulatory entities as necessary to fulfill our legal obligations.

    We may disclose your Personal Information  to third parties in limited circumstances such as (i) to comply with our legal and regulatory obligations, (ii) to make or defend legal claims, (iii) to protect against the fraudulent activity of the account holder and/or others, (iv) to enforce agreements we entered into with you, (v) for internal operations (including, but not limited to, research, statistics, review of our company’s practices under the authorization of a state or national licensing board, or as necessary to properly respond to an inquiry or complaint from such a licensing board or organization); and (vi) to disclose as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to protect our operations or those of any of our affiliated parties; (c) to protect our rights, privacy, safety or property, and/or that of our affiliated parties, users  or others; and/or (d) to allow us to pursue available remedies or limit the damages that we may sustain; (iv) in conjunction with a prospective purchase, sale, or merger of all or part of our company, provided that we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the transaction.

    We may aggregate, de-identify, and/or anonymize any information to the extent that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties.

    RETENTION

    We will retain your Personal Information for as long as is necessary for purposes for which it was collected.  The precise period will depend on the reason why it was collected.  Those periods are also based on the requirements of applicable data protection laws, applicable legal and regulatory requirements, and periods relating to the commencement of legal actions.

    We will retain your employment related data for at least the period of your employment with us and three years thereafter to comply with the applicable laws.

    We delete unsuccessful applicant’s data three years after the decision not to proceed with employment was made.

    However, please note we may continue to store your personal data if doing so is necessary for us to fulfil our legal obligations.  We may be required to keep your information for as long as necessary (i) to comply with our legal and regulatory obligations, (ii) to make or defend legal claims, (iii) to protect against the fraudulent activity, to disclose as we believe to be necessary or appropriate: (a) under applicable law; (b) to protect our operations and/or those of any of our affiliated parties; (c) to protect our rights, privacy, safety and/or property, and/or that of our affiliated parties, users or others; and/or (d) to allow us to pursue available remedies or limit the damages that we may sustain.

    YOUR RIGHTS

    This section generally describes your rights with regard to your Personal Information and explains how to exercise those rights.

    • Access To Your Personal Information. You may request access to your Personal Information or confirmation that we have information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
    • Changes To Your Personal Information. We rely on you to ensure that the Personal Information we maintain about you is accurate. If you believe we have incorrect information about you, please submit a request to correct as described below.
    • Deletion Of Your Personal Information. You may request that we delete your Personal Information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purpose. 
    • Objection to Certain Processing. You may object to our use or disclosure of your Personal Information by contacting us as described below.
    • Right to Limit Use of Sensitive Information. This right is limited to sensitive Personal Information used for the purpose of inferring characteristics about an individual. We do not collect sensitive Personal Information, nor do we use sensitive Personal Information for the purpose of inferring characteristics about an individual.
    • Right of Non-Discrimination and Non-Retaliation. We will not discriminate against you because you made any of these requests.
    • Right to appeal any decision or indecision related to the exercise of any right the consumer is granted under the applicable state law.

    HOW TO EXERCISE MY RIGHTS

    If you would like to exercise any of these rights (including the right to appeal), please contact us:

    We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes.  We may need to take reasonable steps to verify your identity prior to responding to certain of your requests. The verification steps will vary depending on the sensitivity of the Personal Information.

    Your request must:

    • Provide sufficient information for us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative of such person; and Describe your request with sufficient detail for us to properly understand, evaluate, and respond to it.

    Authorized Agent. You may designate an authorized agent to submit a request on your behalf to access or delete your Personal Information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

    RESPONSE TIMING AND FORMAT

    We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at hrdept@russellsquareconsulting.com.

    We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

    If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

    We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

    CHANGES TO OUR PRIVACY POLICY

    We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Company’s  HRIS system.

    CONTACT US

    If you have any questions about the collection and processing of your Personal Information or about security of your Personal Information, please visit our website http://www.russellsquareinc.com or contact Human Resources.

    Phone: +1 (800) 349-0516

    Email: hrdept@russellsquareconsulting.com

    Postal Address: 41391 Kalmia Street, Suite 130 Murrieta, CA 92562

    Attn: Stephanie Sanchez (Human Resources Department)