Portman Square Group California Consumer Privacy Act (CCPA) Policy
This privacy policy and notice for California residents applies solely to visitors, users, and individuals, who reside in the State of California (“consumers” or “you”). We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA). The terms “business,” “business purpose”, “personal information”, “processing”, and “service provider” have the meanings giving to them in the CCPA.
Our Role
Portman Square Group LLC (“Company”, “PSG”, “we” or “us” “our”) may collect and use consumer personal information for its commercial and business purposes and related operational purposes. With respect to these activities, PSG may have direct responsibilities as a business subject to the CCPA. For example, for certain activities related to direct interaction with consumers who have a direct relationship with PSG, interacting with prospective/current clients, marketing, website and web application use, engaging vendors, and interacting with visitors/users of our Website. In these cases, this privacy policy is applicable.
PSG also collects information in its capacity as a service provider to our clients, providing valuation, corporate finance advisory, governance, risk, investigations, disputes consulting and related services. In that case, PSG receives personal information from our clients where we have no direct relationship with the individuals whose personal information we process, and information is provided to us solely for the business purpose of providing those services. If you are a customer or other user associated with one of our clients on whose behalf we have collected or processed your information, this privacy policy does not apply to you, and if you have questions or wish to exercise your rights relating to your personal information (such as information, access or deletion), please contact that client directly.
Categories of Personal Information We Collect
The specific personal information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual.
In the past 12 months, we have collected, used, and disclosed to third parties for business purposes, the following categories of personal information relating to California residents covered by this policy:
Sources of Personal Information We Collect
Information directly from you, the consumer, that you choose to provide, when you interact with us, for example, when you communicate with us by phone, email or otherwise, register for an event, subscribe to marketing or other communications or inquire about or purchase a product or service.
Information we automatically collect when you interact with our website, content or emails such as your IP address and the pages you visited, and when you use our services, we may collect information on how you use those services. Please see our Website Use and Cookies Policy for additional information.
Information provided by our clients in order for us to provide specific services as a service provider, or information from third parties, acquired at the direction of our clients in order to provide the services.
Information from other sources, including service providers or publicly available sources.
Business Purposes
We collect personal information to offer and administer our services and products. These include valuation, corporate finance advisory, governance, risk, investigations, disputes consulting, and related services. We use personal information for the following business purposes:
To provide the products or perform services for clients pursuant to a written agreement, including contacting you in the course of our ordinary commercial relationship, verifying client information, processing payments, or similar activities as needed to provide services for or on behalf of our clients.
For marketing purposes. For example, we may use your information to further discuss your interest in the services and to send you information regarding PSG such as information about promotions, events, products or services. You may opt-out of receiving marketing communications and updates at any time.
To improve PSG's communications with you. Emails sent to you by PSG may include standard tracking, including open and click activities. PSG may collect information about your activity as you interact with our email messages and related content in order to verify or maintain the quality of our communications, or improve, upgrade, or enhance the services we provide.
For operating and improving PSG' website and web applications and your customer experience, including debugging to identify and repair errors that impair existing intended functionality or to verify or maintain the quality of our website, and to improve, upgrade or enhance the website services. For example, we may collect and analyze data on your use of our website and process it for the purpose of improving our online experience.
For security purposes, including detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
For other business purposes, which will be disclosed at the time we collect personal information.
Disclosure/Sharing of Personal Data
In the preceding 12 months, we have not sold any personal information.
We share personal information for business purposes with the following categories of third parties:
Our affiliates, as needed to operate our business and provide services.
Service providers, such as vendors, consultants and other service providers who perform certain services on behalf of PSG, in which case we enter a contract that describes the purpose of processing and requires the recipient to not use it for any purpose except performing the contract.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Your Rights
Subject to the CCPA and other applicable laws, you have the following rights concerning your data processed by PSG:
Access: You have the right to request to access the personal information that PSG holds about you, including categories of information collected, categories of sources from which the information is collected, our business purpose for collecting information, and categories of third parties with whom we share your information.
Deletion: You can request that PSG erase your personal data.
Non-discrimination: PSG will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA.
Contact Us
Please contact us if you wish to exercise your rights under CCPA:
Email: dataprotection@portmansquaregroup.com
In Writing: PSG Office of Data Compliance, 9 East 45th Street, 5th Floor, New York, NY 10017