HGS Partners Privacy Policy

Your privacy is important to us. HGS Partners and its affiliates (collectively “HGS Partners”, “we”, “us”, and “our”) respect your privacy concerns and recognize the importance you place on protecting your Personal Information.

This privacy policy (“Privacy Policy” or “Policy”) applies to your use of our website, as well as your interactions with HGS Partners employees, agents, and contractors (collectively our “Services”). This Policy describes how we collect, use, share, and protect your personal information (“Personal Information” or “Personally Identifiable Information”). This Privacy Policy also explains your rights and choices provided by law and lists multiple ways to contact us for more information or to make a request concerning this Policy or your Personal Information. By providing information to us or by using any of our Services, you indicate that you have read, understood, and agree to the terms and conditions of this Privacy Policy.

Sections

Types of Information We Collect
How We Collect Information
How We Use Your Information
How We Store and Protect Your Information
Linking to Other Sites
How Information is Shared
Choices and Control Over Your Personal Information
Rights of California Consumers
California Notice at Collection
Children’s Policy
Changes to Our Privacy Policy
Willoughby Contact Information

Types of Information We Collect

In order to provide our Services we may need to collection Personal Information from you. The types of information collected will depend on your relationship to HGS Partners. We regularly collect Personal Information from each of these categories:

A. Identifiers
i. Your name, postal address, email address, or phone number

B. Personal Information categories listed in California Civil Code § 1798.80(e)
i. your name, signature, physical description, education, employment, or medical information that is limited to descriptions concerning health symptoms, test results, and vaccination status

C. Protected Classification Information
i. Your age, religion, marital status, gender, or military status

D. Commercial Information
i. Records of your personal property, products or services purchased, and other consumer histories or tendencies

E. Internet or other similar network activity
i. Your interactions with our website (including cookies) and marketing materials

F. Geolocation Data
i. Information collected automatically via our website or shared directly with us by you

G. Professional or Employment Related Information
i. Your current or past professional history

H. Inferences drawn from other Personal Information
i. Your attitudes and abilities

I. Sensitive Personal Information
i. Your social security number, driver’s license, state id, or passport number, financial account information, and racial or ethnic origin.

Personal Information does not include certain types of publicly available information, deidentified data, or aggregated information.

How Information is Collected

We collect Personal Information from different categories of sources:

A. Directly from you
i. When you fill out the “contact us” form on our site, provide information through email or other communications with HGS Partners.

B. Indirectly from you
i. From observing your interaction with our marketing emails, website, or interaction with HGS Partners.

When you visit our website, we utilize cookies (small text files, each containing a string of characters, that are sent to your computer when you visit a website) that are strictly necessary to maintain the site’s functionality. Performance and Targeting cookies are not used on this site.

How and Why We Use Information

We use the Personal Information collected from you (identified in A through I above) in a variety of ways to provide our Services, including:

  • Contacting or meeting with our candidates in person or in other communal settings when they express interest in our services, such as our professional recruiting;
  • Preforming marketing services, such as:
    • sending emails and other marketing communications to keep our past, current, and future clients informed about our latest services, products, and news (you may always choose to opt out of receiving this information by contacting HGS Partners via the instructions contained in the email or by any of the methods listed below in the HGS Partners Contact Information section);
  • To respond to law enforcement requests and as otherwise required by applicable law, court order, or government regulations.

We may also use de-identified and aggregate data about our clients for our own analytical purposes as they relate to our legitimate business needs. We use this and other Personal Information to provide better Services to our current clients and to reach out to potential clients who may benefit from working with us. We continually strive to operate, evaluate, and improve our business practices (including developing new service lines, managing our communications, and evaluating our marketing strategies) so that we may provide optimal Services to our clients.

We will notify you before we collect additional categories of Personal Information or use your Personal Information for a purpose that is different from or in addition to the purposes already stated in this Privacy Policy. Unless you ask us not to, we may contact you in the future to tell you about our Services or to notify you about changes to this Privacy Policy.

How We Store and Protect Information

At HGS Partners, we recognize our responsibility to protect your privacy and Personal Information. We seek to use reasonable organizational, technical, and administrative measures that are designed to safeguard your Personal Information. We store your Personal Information on a secure server and use procedures designed to protect the Personal Information we collect from unauthorized access, destruction, use, modification, or disclosure. In the event that information under our control is compromised as a result of a breach of data security, we will take reasonable steps to investigate the situation, and, where appropriate, notify those individuals whose information may have been compromised and take any additional steps in accordance with applicable laws and regulations.

Linking to Other Sites

Our website may contain links to other websites that are not operated or controlled by Willoughby. These linked websites likely contain their own, different policies regarding the collection, use, and safeguard of your Personal Information. We are not responsible for the privacy practices or content of such linked websites. The links on our website do not imply that we endorse or have reviewed such companies’ privacy policies, if any, nor does a link imply an affiliation with the third party. We strongly encourage you to review the privacy policies of any third party when linking to such websites.

Please note that we are not responsible for the collection, use, or disclosure policies and practices (including the data security practices) of other organizations, such as any other app developer, social media platform provider, or operating system provider, including any information you disclose to other organizations through or in connection with our social media pages.

How Information is Shared

The Personal Information we collect from you is shared in limited circumstances, and we take appropriate steps to safeguard your privacy. With the exception of medical information, we disclose Personal Information (identified in A through I above) with our service providers, contractors, vendors and affiliates, as well as with other parties authorized by you. Information may also be disclosed to other parties as required by law or particular circumstances. We may disclose Personal Information to these groups in order to:

  • Provide our Services;
  • Have them process information on our behalf; or
  • Comply with legal and regulatory requirements.

We do not sell or share our clients’ Personal Information as defined by the California Consumer Privacy Act, Cal. Civ. Code § 1798.140, and have not done so in the preceding 12 months.

HGS Partners has not disclosed Personal Information to third parties, as defined by the California Consumer Privacy Act, Cal. Civ. Code § 1798.140, in the preceding 12 months.

HGS Partners does not use or disclose sensitive personal information for any purpose other than those specified in California Consumer Privacy Act Regulations section 7027(m).

Choices and Control over Your Personal Information

You have several choices available when it comes to your Personal Information, and we will honor the choices you make to protect your privacy.

If you would like to review or request changes to any of your Personally Identifiable Information that we maintain, please contact us using any method of contact information listed below.

You may also contact us at any time to change your subscription preferences to any of our marketing material. Subscription preferences can also be updated by clicking on an “unsubscribe” hyperlink contained in promotional emails sent by us or on our behalf. Please be aware that even if you opt-out of receiving future promotional communications from HGS Partners, you may still receive specific transactional communications that relate to past, present, or future business partnerships with HGS Partners.

California consumers may be offered additional control over their Personal Information as described in the Rights of California Consumers section below.

Rights of California Consumers

Residents of California are offered additional and specific rights as indicated by the California Consumer Privacy Act of 2018 (the “CCPA”). If we have collected personal information because of a written or verbal communication or transaction for services on behalf of a business as part of your employment duties, and such communication or transaction occurs while acting on behalf of a business and solely related to these transactions or services, these rights will not apply to you.

If you are not a California resident, these rights will not apply to you. These rights include:

The Right to Know Your Personal Information

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we may disclose:

A. The categories of Personal Information we collected about you;
B. The categories of sources for the Personal Information we collected about you;
C. Our business or commercial purpose for collecting that Personal Information;
D. The categories of third parties with whom we share that Personal Information;
E. The specific pieces of Personal Information we have about you; and
F. If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

i. Sales –identifying the Personal Information categories that each category of recipient purchased; and
i. Disclosures for a business purpose – identifying the Personal Information categories that each category of recipient obtained.

The Right to Request Deletion of Your Personal Information

You have the right to request that we delete your Personally Identifiable Information that we have collected from you and retained (subject to certain exceptions). Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your request if retaining your Personal Information is necessary to perform any of the following actions, among others:

A. Complete the transaction for which we collected your Personal Information, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
B. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
C. Comply with the California Electronic Communications Privacy Act; or
D. Comply with a legal obligation.

The Right to Correct Inaccurate Personal Information

You have the right to request that we correct inaccurate Personally Identifiable Information that we have collected about you and retained. Once we receive and confirm your verifiable consumer request, we will correct the personal information at issue on our systems.

We will also instruct any service providers or contractors that maintain the personal information at issue, due to their connection with HGS Partners, to make the necessary corrections in their respective systems.

We may deny your request to correct the Personally Identifiable Information if:
A. We are unable to satisfactorily verify your identity in relation to the information maintained;
B. We are unable to determine if the correction is accurate based on surrounding circumstances; or
C. We are unable to reasonably complete the request – you will be provided with an explanation if this is the case.

We may also delete the contested personal information as an alternative if the deletion is not viewed to negatively impact you; or if we receive your consent to the deletion.

The Right to Opt-Out of the Sale or Sharing and the Right to Limit the Use of Your Personal Information

You have the right to direct a business that sells or shares personal information about you to third parties not to sell or share your information. This is often referred to as the right to “opt-out.” You also have the right to request that a business limit the use or disclosure of sensitive personal information collected. This can be referred to as the right to limit.

Some platforms will allow you to set an opt-out preference signal that will then be communicated to a business that sells or shares personal information to inform them of your choice to opt-out.

We do not sell or share your Personal Information to third parties. We also do not use or disclose sensitive personal information for purposes outside of the limited expectations set forth in paragraphs (2), (4), (5), and (8) of subdivision (e) of Section 1798.140 (California Civil Code).

The Right to Non-Discrimination

You have the right to non-discrimination. HGS Partners will not discriminate against you for exercising any of your CCPA rights. We will not:

  • Deny you services;
  • Charge you different prices or rates for services;
  • Provide you a different level or quality of services; or
  • Suggest that you may receive a different price or rate for services.

How to Make a Request

Residents of California may contact us to exercise any of their rights under the CCPA by:

Emailing [email protected]; or
Calling (310) 277-3211

Only you or an agent authorized to act on your behalf may make a request under the CCPA regarding your Personal Information. You may only make a request to know to HGS Partners under the CCPA twice within any 12-month period, and we must be able to verify your identity in order to respond to your request. Your request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information; and
  • Provide sufficient detail that allows us to understand, evaluate, and respond to it.

Verifying a California Consumer Request

To further protect our clients’ privacy and as required under the CCPA, we must verify each request that comes to us under the CCPA before we supply the information or take the action as requested. To verify your request, we may ask you to provide several pieces of Personal Information that we may use to match with your Personal Information that we already maintain. Please note that requests made through an authorized agent are subject to separate verification of the consumer’s identity. We will only use Personal Information provided in a CCPA request to verify the requester’s identity or authority to make such request. If we are unable to verify your identity, we will explain to you why your identity cannot be reasonably verified in light of the nature of your request, and we therefore may not be able to process your original request.

California Notice at Collection

This section serves as the Notice of Collection we are required to provide California Consumers under California law. Information contained in this section is complimentary to the other information within this Privacy Policy.

In the last 12 months we have collected the following categories of personal information, depending on your relationship to us and the Services used:

A. Identifiers (your name, postal address, email address, or phone number);
B. Personal Information categories listed in California Civil Code § 1798.80(e) (your name, signature, physical description, education, employment, or medical information that is limited to descriptions concerning health symptoms, test results, and vaccination status);
C. Protected Classification Information (your age, religion, marital status, gender, or military status);
D. Commercial Information (records of your personal property, products or services purchased, and other consumer histories or tendencies);
E. Internet or other similar network activity (your interactions with our website (including cookies) and marketing materials);
F. Geolocation Data (information collected automatically via our website or shared directly with us by you);
G. Professional or Employment Related Information (your current or past professional history);
H. Inferences drawn from other Personal Information (your attitudes and abilities);
I. Sensitive Personal Information (your social security number, driver’s license, state id, or passport number, financial account information, and racial or ethnic origin).

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you and your interactions with us. For example, you may visit our website, fill out the “contact us” form, or you may have contact with our offices or representatives.

The way we use or disclose personal information will depend on the context of your interactions with us and the particular business services HGS Partners is performing. We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To preform services on behalf of HGS Partners. For example, contacting and meeting with our clients, managing client relationships, marketing communications, and analytic activities.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for any materially different, unrelated, or incompatible purposes without providing you notice. We do not collect sensitive personal information with the purpose of inferring characteristics about a consumer.

How long we keep Personal Information can differ depending on the purpose of collection and your relationship with the company. Generally, once a relationship ends we will retain the Personal Information for a short period before evaluating if the information needs to be retained.

We consider factors such as our legal and regulatory obligations as well as whether the data is needed for internal business purposes when determining how long data is retained. We may also retain Personal Information if it is determined to be necessary due to:

  • a California or Federal regulatory compliance requirement; or
  • exercising, establishing, or defending legal claims.

In the preceding twelve (12) months, we have disclosed the following categories of personal information, as described above in Information We Collect, to preform services on behalf of the business:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category G: Professional or employment-related information
Category I: Sensitive Personal Information.

We disclose your personal information for a business purpose to the following parties:

  • our affiliates;
  • service providers, contractors, and their agents;
  • financial service providers;
  • other parties (including government agencies) as required by law; and
  • other parties to whom you or your agents authorize us to disclose your personal information in connection with the services we provide to you.

In the preceding twelve (12) months, we have not sold or shared any personal information as defined in California Civil Code § 1798.140. When we disclose personal information, including sensitive personal information, for a business purpose, we enter a contract with our service providers and contractors that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We reserve the right to amend this notice at our discretion and at any time. When we make changes to this notice, we will notify by email or through a notice posted on our website homepage.
If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, please do not hesitate to contact us through email at [email protected] or by phone at (310) 277-3211.

Children’s Policy

Our Services are not intended for children under the age of 16 and we do not knowingly or intentionally collect Personal Information from children under 16 online. If we discover that we have inadvertently collected Personal Information from a child under 16 it will be deleted.

Changes to Our Privacy Policy

We may revise this Privacy Policy at any time. We will continue to evaluate this Policy against new technologies and business practices, as well as our clients’ needs and preferences, and we reserve the right to update, change, amend, or modify this Privacy Policy at any time and from time to time without prior notice unless otherwise required by law. Please review this policy periodically.

If we make any material changes to this Privacy Policy (as determined by us), we will post a notice on our website and update the date of the Policy.

This Privacy Policy was last updated on the date indicated below. Your continued use of our Services, including your decision to supply HGS Partners with Personal Information, indicates your agreement with the terms of such revised and then-current Privacy Policy.

HGS Partners Contact Information

If you have any questions or comments about this Privacy Policy and our Information Practices, or if you wish to exercise your rights under any applicable laws, please reach out to a member of our team using any of the following contact methods:
Phone: (310) 277-3211
Email: [email protected]

Last Updated June 14, 2024