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Privacy & Cookie Policy

Privacy Policy

Your privacy is important to The Bertram Group (“we”, “our” “us”), and we recognize the importance of protecting the privacy of information you share with us. This Privacy Policy, together with our Terms of Use and Conditions, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. By using our website which links to this Privacy Policy (“Site”), you acknowledge receipt of this Privacy Policy and the use and disclosure of the information you provide to us in accordance with this Privacy Policy. 

We do update this Privacy Policy from time to time so please review this Privacy Policy regularly. If we materially alter our Privacy Policy, we will notify you of such changes by posting a notice on our Site. Your continued use of the Site will be deemed your acknowledgement of receipt of the updated policy.    

Website Privacy Notice
Please read this Privacy Policy carefully to fully understand how we collect, share and protect information about you.  This Privacy Policy is incorporated into and is a part of the Terms of Use and Conditions of our Site. To access the Terms of Use and Conditions, click here

In order to deliver personalized and relevant information to you through our Site and otherwise, we collect certain information from you, a user of the Site. 

Information We Collect
In operating our Site, we may collect and process the following data about you:

  1. Details of your visits to our Site and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data, including your IP address, the date and time you accessed or left the Site and which pages you viewed.  Some parts of our Site use cookies and other technologies to collect this information in an anonymized manner about your general Internet usage.  See our Cookie Policy to learn more. 

  2. Information provided to us when you communicate with us for any reason (for example, to contact us through our “Contact Us” link, you must provide your name, e-mail address, telephone number and your question(s) and/or comment(s)). 

  3. Information provided to us if you choose to submit information related to career counseling, including your name, e-mail address, telephone number, your comment(s) and/or question(s), and your resume, grades, activities, school interests and objectives. 

  4. Information provided to us that may be considered sensitive in nature (e.g., therapeutic information) if you choose to submit such information to us.

  5. Any of the foregoing information that you provide to us as the parent or legal guardian of a minor child.

Please note that by providing and submitting your telephone number to The Bertram Group, including a mobile telephone number, you agree that a representative of The Bertram Group can contact you at that telephone number, potentially using automated technology (including text/SMS messaging) or a prerecorded message. Your consent is not an obligation to use or receive any of our services. 


Purposes of Processing:
The Bertram Group processes personal information, as necessary to pursue our legitimate business and other interests, for the following reasons:

  • to provide services to you and to communicate with you;

  • to manage, administer and improve our business and client engagements and relationships, including payment for our services and for marketing, business development and analysis purposes;

  • if  you receive or have in the past received our services, or if you have expressed an interest in our services, we may also use your personal information to provide our newsletter and other communications about services we think may be of interest to you;

  • to manage our information technology and to ensure the security of our systems;

  • to establish, exercise and/or defend legal claims or rights and to protect, exercise and enforce our rights, property or safety;

  • to conduct compliance activities such as audit and reporting, assessing and managing risk, maintenance of accounting and tax records;  

  • to investigate and respond to complaints or incidents relating to us or our business, to maintain service quality and to train staff to deal with complaints and disputes; and

  • to comply with laws and regulations.

You may choose to exclude yourself from any mailings by contacting us at the contact information below.

E-mail
We don’t not sell, trade or rent e-mail addresses to other organizations, or use or disclose them for marketing purposes, except as described below. We  may generate e-mail for the following types of communication:

  1. Notification e-mail to which the individual may subscribe and unsubscribe.

  2. Transactional e-mail, which is the result of our providing services to you.

  3. Relationship e-mail, which is sent as an informational service because of a relationship with us.

  4. Commercial e-mail or newsletter, which is sent to promote our services and developments and articles of interest in our field (You may opt not to receive this type of e-mail).

  5. Correspondence from our staff as a result of a communication initiated by a member or customer.

E-mail that has a provision for opt-out will include instructions on how to do so. All inquiries regarding subscription-based e-mails should be directed to us at the contact information below).

Use of Your Information 
The information that we collect and store relating to you is primarily used to enable us to provide our services to you in the best possible manner.  In addition, we may use the information for the following purposes:

  1. To provide you with information relating to our services;

  2. To provide third parties with statistical information about the users of our Site;

  3. To monitor and conduct an analysis of our Site traffic and usage patterns;

  4. To analyze trends.

Security 
To secure your information, we have put in place commercially reasonable physical, technical, and administrative procedures to safeguard and secure the information we collect on our Site. 

Specifically, the website resides behind a firewall and uses SSL (Secure Sockets Layer, the industry-standard security protocol used to communicate with browsers) to transmit personal information. Data is strongly encrypted during transmission to ensure that personal and payment information is secure. Industry-standard data encryption techniques are used to protect personal information on computers. SSL-capable browsers typically have a symbol on the browser window to indicate when they are in a secure mode. In addition, the URL will begin with “https:” for all browsers.

Nonetheless, the transmission of information via the Internet is not completely secure, and therefore we cannot guarantee the security of data sent to us electronically on our Site, and transmission of such data is therefore entirely at your own risk. 

Disclosing Your Information 
Where applicable, we may disclose your personal information to any affiliated business entities or third parties necessary to provide services to you.  This includes, where applicable, our subsidiaries, our holding company and its other subsidiaries (if any), as well as third parties involved in the administration and operation of our services. We may also disclose your information to other third parties: 

  1. Where we sell any or all of our business and/or our assets to a third party.

  2. Where we are legally required to disclose your information.

  3. When we are contractually obligated to disclose it.

  4. With educational institutions, business partners and third-party business providers who use or may have access to your personal information as part of the services being provided to you, this includes companies that provide us with technical support or data hosting;

  5. To auditors, contractors or other advisors auditing any of our business processes.

Third-parties may also act on our behalf to collect and use data that assists in the hosting, maintenance, and improvement of this Site.  

We require third party service providers who process information on our behalf, to provide adequate safeguards for your personal information (e.g., restriction of their access, use and disclosure of personal information, solely to meet their contractual obligations in the performance of the specific functions described above).  A copy of these safeguards may be made available by writing to us at the address provided in the Contact Us section below.

This Site is hosted and maintained within the United States.

Third Party Website and Interaction 
By accessing other third party websites through our Site, you are acknowledging the terms and privacy policies of those websites.  We do not accept any responsibility or liability for their policies whatsoever as we have no control over them. 

Retention
Information collected through this Site will be retained in accordance with applicable law. Please contact us if you have any questions.

Your rights in connection with your Personal Information

Under certain circumstances, and as required by law in the EU, you have the right to:

  • Request access to your personal information. This enables you to receive a copy of the personal information we hold about you.

  • Request correction of any incomplete or inaccurate personal information that we hold about you.

  • Request erasure of your personal information when there is no need for us continuing to process it or you have exercised your right to object to processing (see below).

  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.

  • Request the restriction of processing of your personal information to suspend the processing, for example if you want us to verify its accuracy or the reason for processing it.

  • Request the transfer of your personal information to another party.

If you want to exercise any of these rights, please contact submit your request to the contacts named in the Contact Information section of this Privacy Policy. Valid requests will be honored within 30 calendar days of request. This 30-day period may be extended for another 2 months for complex requests with notification of the reasons for the extension to you.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. In addition, there may be requests that we are unable to process because of other legal requirements.  If a request is denied, we will notify you of the reason.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Users of Age 16 or Older Only
Our Site is designed and intended for those who are 16 years of age or older, who are generally adult parents or legal guardians of minor children. By using our Site, you affirm that you are at least 16 years of age or older.  We are not liable for any damages that may result from a user’s misrepresentation of age. 

No one under age 16 is authorized to submit or post any information, including personally identifying information, on our Site. Under no circumstances may anyone under age 16 use our Site.  If Parents or legal guardians of children under 16 cannot agree to these Terms on their behalf. An account will be blocked if we believe it is the account of a children under 16. We may require further verification from you to confirm your age and geographic location.


Cookie Policy

What are Cookies and How We Use Cookies

Cookies consist of pieces of text stored on the hard drive of your computer, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.  Cookies are used by many websites and can do a number of things.

The Bertram Group (“we”, “our” “us”) uses cookies, as almost all websites do, to help provide you with the best experience we can.

Some cookies are generally considered essential. Essential cookies are necessary for the website to function, to provide the information you request.  These cookies cannot be switched off because the website wouldn’t work properly. However, these cookies do not store any personal data.

Other cookies are considered non-essential, including cookies used for analytics, or from advertisers or third parties. We do use cookies to track our users across time and across our website. Specifically, we use Google Analytics. For more information on how the Google Analytics cookie works click here.  These cookies, allow us to count visits and traffic sources, so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the website. However, all information we collect from our non-essential cookies is aggregated and therefore anonymous. We do not have any cookies from advertisers or third parties.

All computers have the ability to decline cookies. This can be done by activating the setting in your browser, which allows you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our website.


Contacting Us
We welcome any queries, comments, complaints or requests you may have regarding this Privacy Policy.  Please do not hesitate to contact us at:

The Bertram Group 
8 Wright Street, Suite 107,
Westport, Connecticut 06880
info@thebertramgroup.com 
(203) 255-2577

If you are located in the EU, you have the right to lodge a complaint with an EU Supervisory Authority. However, if you have a complaint regarding the processing of your personal information we request that you first contact us and we will reply on timely basis.

Effective Date:  August, 2018