JeffreyM Privacy Policy

Diversity and Inclusion

 

JeffreyM Consulting, LLC believes that diversity and inclusion is necessary in order to achieve and sustain excellence. We are committed to a work environment in which the wide array of contributions from all staff, employees and clients, that result from a diverse and inclusive workplace, allows us to be more effective. By recruiting and retaining a diverse employee base, we can best promote our values of excellence. These values are recognized and supported by JeffreyM Consulting, LLC leadership at all levels. 

Consistent with our commitment to diversity and inclusion, JeffreyM Consulting, LLC provides equal employment opportunity (EEO) to all persons regardless of age, color, national origin, citizenship status, physical or mental disability, race, religion, creed, gender, sex, sexual orientation, gender identity and/or expression, genetic information, marital status, veteran status, or any other characteristic protected by federal, state or local law. JeffreyM Consulting, LLC provides reasonable accommodations for qualified individuals with disabilities.

 

Corporate Social Responsibility Report

JeffreyM Consulting, LLC earned a 2019 EcoVadis sustainability rating Bronze medal in recognition of CSR achievement.

JeffreyM Consulting, LLC earned a 2020 EcoVadis sustainability rating Silver medal in recognition of CSR achievement.

 

This material references GRI Standards GRI 101: Foundation 2016; GRI 102: General Disclosures 2016; GRI 103: Management Approach 2016, for each Standard used: GRI 205: Anti-corruption 2016; GRI 302: Energy 2016; GRI 303: Water and Effluents 2018; GRI 305: Emissions 2016; GRI 401: Employment 2016; GRI 404: Training and Education 2016; GRI 405: Diversity and Equal Opportunity 2016; GRI 406: Non-Discrimination 2016; GRI 413: Local Communities 2016; GRI 418: Customer Privacy 2016

 

ENVIRONMENT

All companies leave some environmental impact, and at JeffreyM Consulting, LLC taking responsibility and mitigating the impact of our operations is of utmost importance. Not only to further the environmental efforts of our clients’ in which we partner with, but to ensure JeffreyM is mindful with the decisions we make daily. 

To bring company awareness, as well as fresh ideas to how we can minimize this impact, we have put together a CSR Committee who meet quarterly. As a result of these meetings, we have implemented a Conservative Energy Use Policy which encourages all employees to make every effort to reduce energy consumption and requires all equipment purchased to have an Energy Star rating. We have also purchased Electricity Usage Monitor Voltage Meters to use within our office space, so that we can report on and monitor our energy usage, and use it to pinpoint areas in which we can conserve energy and reduce emissions. We have also since partnered with a third-party IT company who ensures that our IT infrastructure is energy efficient, and we partner with a local IT recycling company to ensure our expired equipment is responsibly recycled. 

JeffreyM Consulting, LLC headquarters is located within leased space at One Union Square at 600 University Street in downtown Seattle. Union Square has engaged with green building practices for both buildings and have earned LEED EB Platinum designation, the highest award for LEED EB Building Certification. Union Square has taken a holistic approach to green programs and energy efficiency, based on the implementation of an in-house commissioning agent over the last 20 years whose job is to ensure all systems are commissions on an on-going basis. This allows tenant comfort levels to be exceeded while adhering to strict efficiency levels throughout the properties. In terms of LIGHTING, the majority of lighting systems have been retrofitted with high efficient LED lighting. A supplemental lighting management system is used for automation of light levels in all public areas. Union Square’s BAS (Building Automation System) uses complex strategies to provide tenants with a total comfort control system, while carefully monitoring energy usage. Union Square also offers a comprehensive RECYCLING program for their tenants. In terms of WATER, all restrooms have been retrofitted with low flow fixtures and low flow sink aerators. Union Square complies with all Seattle ENERGY code standards. Energy conservation is also dictated through automation of lighting and overtime air, in addition to overall HVAC operation. Further, the energy management BAS system is a comprehensive control system that utilizes complex algorithms to provide optimal start during periods of off-peak energy consumption. This provides intelligent warm-up/cool-down of occupied spaces to further reduce the building’s carbon footprint under all conditions. Both Union Square buildings are Energy Star certified. Two Union has an Energy Star score of 93, One Union has an Energy Star score of 98. Union Square adheres to the ASHRAE Standard 62.1, ventilation for acceptable indoor AIR QUALITY. Union Square utilizes high efficient filtration approaching Merv 13 in arrestance ratings. Both buildings maintain minimum outdoor primary air and required air change levels dictated by ASHREA. Union Square has also partnered with Carbon Solutions Group, and purchased renewable energy certificates in an effort to support RENEWABLE ELECTRICITY generation.

JeffreyM Consulting, LLC also has office space leased within the Plaza Building at 10900 8th Street located in the central business district of Bellevue. Plaza Center is a LEED-EBOM GOLD certified building, with an ENERGY Star rating of 86. All of Plaza Center’s employees, vendors and contractors are required to know and follow LEED guidelines, and are provided a Tenant Handbook in which these guidelines and required practices are outlined (ex: “turn off all lighting and equipment when leaving for the day”). These “green” building upgrades have increased energy efficient and improved tenant comfort. The Plaza Buildings promote a whole-building approach to sustainability, including low/no-VOC paint, carpet, and adhesives, 100% low energy T-* bulbs in lights fixtures and a high performance “green cleaning” program. The Plaza Buildings offer a comprehensive RECYCLING program, including recycling options for printer cartridges, batteries and equipment. Building management supplies all tenants with COMPOST BINS. The Plaza Buildings utilize GREEN CLEANING practices, including the use of environmentally safe cleaning products and methods. 

LABOR PRACTICES

At JeffreyM Consulting, LLC, we are in the people business. We service 125+ clients, with 300+ consultants across the globe. From our humble beginnings in Jeffrey McCannon’s garage to the full-fledged staffing firm we are today, transparency and client/employee experience have always been at the forefront of what we do. We are committed to providing robust benefits and transparent compensation to our employees, while ensuring our commitment to diversity and inclusion and fair pay practices is demonstrated within our policies and internal processes, as well as reinforced through our workplace policies trainings. 

Our employees receive generous compensation packages, including healthcare and pre-tax savings options, access to an employer-matched 401(k) retirement program, paid parental leave, generous PTO, pre-tax commuter & parking programs, a robust equipment loan program, and full-time IT support. We also offer personal and professional development opportunities through in-person trainings, a learning management system, and performance review opportunities. With many of our consultants now working remotely all over the world, we have also implemented Remote Work perks. We also have implemented a financial wellness program in which we currently have partnerships with cell phone discount plans, and partner with a mortgage company to offer home buying workshops and benefits when purchasing a home. In addition, both buildings in which we lease office space offer free (Plaza Center) or affordable at $60/year (Union Square) Fitness Centers available to our employees, enhancing their wellness options.

We have a dedicated HR team who consistently review our benefits offerings, obtain employee feedback, support employees throughout their employment experience, discuss accommodation options for both employees and potential employees, and ensure employees are trained on these policies and procedures in which we are committed to.

Beyond our internal processes, JeffreyM Consulting, LLC is passionate about our community. Our long-standing relationship with WE.org in the Seattle community has allowed thousands of youth to take advantage of Seattle We Day annually. WE.org empowers youth to do service locally and globally.

In addition, JeffreyM has been involved with Fred Hutchinson Cancer Research Center as a sponsor and annual advocate at their fund-raising events.  Fred Hutchinson Cancer Research Center is dedicated to the elimination of cancer and related diseases.

JeffreyM also has a passion for the environment and works with the Seattle Aquarium in conserving our marine life in the state of Washington; through fundraising and employee programs.  

FAIR BUSINESS PRACTICES 

Our business is based on the reputation of both those we both employ internally and those we employ who provide services to our clients. We are relied upon to ensure that we are as open and honest as we can be and that our employees feel happy, confident and supported in everything that they do.

Employees and staff are trained on anti-corruption and bribery issues, IT security, data protection and confidentiality per policies provided during onboarding and through annual training programs. We partner with a third-party IT company who ensure our customer, employee and client data are protected from unauthorized use or disclosure by ensuring robust security measures are in place within our IT systems and processes.

Business ethics concerns should be reported directly to our Director of Human Resources, Michelle Ruane at micheller@jeffreym.com. 

SUSTAINABLE PROCUREMENT

We are aware that our impact on CSR issues can be addressed by assessing where our resources come from, how they are made, and what CSR efforts are being made by those companies providing resources to us. 

As a small/medium business servicing the consultancy business model, we do make every effort to purchase products and use services that are sustainable in nature. Printer paper is from recycled sources and should only be used when digital is not an option, we rent offices in LEED certified buildings, and we have implemented measures with our IT company to ensure the use of off-premise cloud services for the majority of our needs. Our office computers are low emission, all-in-one devices - power-star rated and recycled at the end of their lifecycle. Office products and provisions are ordered through companies with robust CSR efforts.

 

Privacy Policy

Privacy Policy Updated April 1, 2020

OVERVIEW

JeffreyM Consulting, LLC ("Company" or "We") respects your privacy and we are committed to protecting it through our compliance with the terms of our Privacy Policy. Please review our Privacy Policy carefully to understand how we collect, use, protect or otherwise handle your Personally Identifiable Information (PII). PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.

This policy describes the types of information we may collect from you or that you may provide when you visit or utilize the services of our website(s), including without limitation www.jeffreym.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

If you do not agree with our practices, your choice is not to use our Website. By accessing or using the Website, you agree to this privacy notice. Your use of the JeffreyM Consulting, LLC website and/or provision of your PII to JeffreyM Consulting, LLC constitutes your consent to the use, storage, processing and transfer of that information in accordance with this privacy policy. This notice may change from time to time, in which the date at the top of this page will be revised. Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the notice periodically for updates. 

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

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. 

·         Information that you provide by applying to jobs on our Website, including but not limited to information that you provide by filling in the application form and/or documents you directly upload, such as a resume.

·         Information you provide when you report a problem with our Website, in which we may also ask you to provide further information.

·         Records and copies of your correspondence (including email addresses), if you contact us.

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:

·         Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information other than your IP address and is retained for the duration of one week.

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.

THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications on the Website are served by third-parties. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website to apply for a job or to send us a message. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

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, or services that you request from us.

·         To respond to your questions or messages submitted via the online message form.

·         To contact you regarding jobs you have applied for via our website, or future jobs in which we may proactively contact you. 

·         To fulfill any other purpose for which you provide 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.

DISCLOSURE OF YOUR INFORMATION

We may disclose personal information that we collect or you provide as described in this privacy notice:

·         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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by JeffreyM Consulting, LLC about our Website users is among the assets transferred.

·         To fulfill the purpose for which you provide it. For example, if you give us an email address to share content to a third-party, we will transmit the contents of that email and your email address to the recipients.

·         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.

·         If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of JeffreyM Consulting, LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

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.

ACCESSING AND CORRECTING YOUR INFORMATION

You can send us an email at privacy@jeffreym.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

CHILDREN UNDER THE AGE OF 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information, personal or otherwise, to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features/services, register on the Website, make any purchases through the Website, use any of the interactive 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 user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@jeffreym.com.

YOUR CALIFORNIA PRIVACY RIGHTS

For California Residents Only. The California Consumer Privacy Act of 2018 (CCPA) provides California residents with specific rights regarding their personal information. We adopt this notice to comply with the CCPA and any terms defined in the CCPA have the same meaning when used in this notice. 

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, JeffreyM Consulting, LLC’s website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

Yes, when provided by You.

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

No

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

No

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

No

G. Geolocation data.

Physical location or movements.

No

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

I. Professional or employment-related information.

Current or past job history or performance evaluations.

Yes, when provided by You.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

No

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No

Personal Information does not include:

·         Publicly available information from government records.

·         Deidentified or aggregated consumer information.

·         Information excluded from the CCPA’s scope, like:

o   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;

o   personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

JeffreyM Consulting, LLC obtains the categories of personal information listed above from the following categories of sources:

·         Directly from you. For example, from forms you complete or applying to jobs posted on our website.

·         Indirectly from you. For example, your IP address is collected and maintained for one week.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

·         To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request information or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to apply for a job, we will use that information to consider you for the applied for position. We may also save your information to contact you about future positions that you may be a fit for.

·         To provide, support, personalize, and develop our Website, products, and services.

·         To create, maintain, customize, and secure your application/candidate profile with us.

·         To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

·         To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

·         To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

·         As described to you when collecting your personal information or as otherwise set forth in the CCPA.

·         To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of JeffreyM Consulting, LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by JeffreyM Consulting, LLC about our Website users is among the assets transferred.

·         JeffreyM Consulting, LLC will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

JeffreyM Consulting, LLC may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract 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 share your personal information with the following categories of third parties:

·         Service providers.

Disclosure of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

·         Category A: Identifiers.

·         Category B: California Customer Records personal information categories.

·         Category I: Professional or employment-related information.

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

·         Service providers.

Access to Specific Information and Data Portability Rights

The CCPA provides consumers (California residents) with specific rights regarding their personal information. You have the right to request that JeffreyM Consulting, LLC 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 request, we will disclose to you:

·         The categories of personal information we collected about you

·         The categories of sources for the personal information we collected about you

·         Our purpose for collecting that personal information

·         The categories of third parties with whom we share that personal information

·         The specific pieces of personal information we collected about you (data portability request)

Deletion Request Rights

You have the right to request that JeffreyM Consulting, LLC delete any of your personal information that we 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 deletion request if retaining the information is necessary for us or our service provider(s) to:

·         Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

·         Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

·         Debug products to identify and repair errors that impair existing intended functionality.

·         Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

·         Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

·         Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

·         Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

·         Comply with a legal obligation.

·         Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by e-mailing us at privacy@jeffreym.com. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

·         Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

·         Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response to the e-mail that you contact us with, or by mail or another contact method, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. 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.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

·         Deny you services.

·         Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.

·         Provide you a different level or quality of services.

·         Suggest that you may receive a different price or rate for services or a different level or quality of services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

YOUR EUROPEAN PRIVACY RIGHTS

For European Residents Only. If you are based in the EU, in certain circumstances, you have rights under the GDPR in relation to your Personal Information. We adopt this notice to comply with the General Data Protection Regulation (GDPR) and any terms defined in the GDPR have the same meaning when used in this notice.

As the controller that is responsible for your Personal Information, it is important to us that your Personal Information is protected, private and secure. By accessing or using the Website, including purchasing or obtaining our products or services through the Website, you agree to this Notice. If you do not agree with the terms of this Notice, do not use the Website or provide any information to us.

Information We Collect

·         Personal Information” means information that identifies you or another person as an individual such as your name, mailing address, email address, telephone number, IP address, location or any other identifier by which you or any other individual may be contacted online or offline.

·         Non-Personal Information” means information that does not identify you as an individual, such as your browser type, your internet connection, the URL of the previous website you visited, the equipment you use to access the Website, and details about how you use the Website.

The following are categories of information that we may collect (a) when you provide it to us; (b) automatically through the Website or (c) through third-parties:

·         “Account Info”: information provided by you when you contact us or apply for a job with us such as your name, email, birth date, gender, postal code, and country. 

·         Technical Data”: information about your technology such as your IP address, browser type and version, time zone settings and location, browser plug in types and versions, operating system and platform, and other devices you use to access the Website.

·         Voluntary Data”: information that you provide to us, feedback you provide about our services or the Website.

We do not collect any “Special Categories” of Personal Information about you (such as race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, information about your health, and genetic and biometric data.)

How We Collect Your Information

We may collect information (a) when you provide it to us; (b) automatically through the Website; and (c) through third-parties.

a.       Information You Provide to Us. When you use the Website, you may choose to provide us with both Personal and Non-Personal Information, including when you:

o   Visit the Website.

o   Purchase or obtain our products or services.

o   Complete and submit forms on the Website.

o   Contact us.

o   Report a problem with the Website or our products.

b.       Information We Collect Automatically

o   As you use and interact with the Website, we may automatically collect Technical, Usage and/or Marketing Data such as details regarding your IP address. If you do not want us to collect this information you may contact us at the contact information in the Introduction. You should understand that by opting-out of the collection of certain Personal Information, it may prevent us from providing certain products or services to you, and could affect your ability to use all of the features of the Website.

·         Tracking Technologies. The technologies we use for automatic information collection may include “cookies.”   A cookie is a small file placed on your browsing device. It may be possible to refuse to accept cookies by activating the appropriate setting on your computer, tablet, or smartphone.  However, if you select this setting you may be unable to access certain parts of our Website

·         Third-Party Use of Cookies and Other Tracking Technologies. Some content on the Website, including certain Website capabilities, may be served or performed by third-parties. These third parties may use cookies or other tracking technologies to collect information about you when you use the Website or purchase or acquire our products or services. We do not control these third parties' tracking technologies or how they may be used.  If you have any questions, you should contact the responsible provider directly.

·         Do Not Track. Do Not Track is a privacy preference that you can set in your web browser. When you turn on the Do Not Track signal, your browser sends a message to websites requesting them not to track you. For information about Do Not Track, visit www.allaboutdnt.org. At this time, we do not respond to Do Not Track browser settings or signals. In addition, we may use other technology that is standard on the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the Website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

c.       Information We Collect from Third Parties. We may receive Personal Information about you from various third parties as set out below:

o   Service Providers

Why We Collect Your Personal Information

We process your Personal Information only for fair, lawful and legitimate reasons. We may collect information (a) when you provide it to us; and (b) automatically through the Website. The table below listing the categories of Personal Information, the purpose for processing such Personal Information, and on what legal basis:

Purpose

Personal Information

Lawful Basis to Process Information

To register you as a new client or employee

(a)    Identity 

(b)    Contact

Performance of a contract with you

To manage our relationship with you which will include:

(a)    Notifying you about changes to our terms or privacy policy

(b)    Notifying you about other or future job positions

(c)     Asking you to leave a review or take a survey

(a)    Identity 

(b)    Contact 

(c)     Profile 

 

(d)    Marketing and Communications

(a)    Performance of a contract with you 

(b)    Necessary to comply with a legal obligation

(c)     Necessary for our legitimate interests (to keep our records updated)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  

(a)    Identity

(b)    Contact

(c)     Technical

(a)    Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b)    Necessary to comply with a legal obligation

To make suggestions and recommendations to you about services or other job positions that may be of interest to you

(a)     Identity 

(b)     Contact 

(c)      Technical 

(d)     Usage 

(e)     Profile 

(f)       Marketing and Communications

Necessary for our legitimate interests (to develop our services and grow our business)

 

We use Personal Information for a number of legitimate interests, including to provide and improve our services, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. More detailed information about these legitimate interests is set out below.

Disclosure of Your Information

We disclose your Personal Information to the following categories of recipients:

·         Service Providers: to contractors, service providers, data processors, and other third-parties we use to support our business. These parties are bound by contractual obligations to keep your Personal Information confidential and use it only for the purposes for which we disclose it to them.

·         Business Partners or Affiliates: other companies in the Company Group including affiliates, subsidiaries, advisors, partners and consultants who are bound by confidentiality obligations and security measures.

·         Business Transfers: to a buyer or successor in the event of a merger, reorganization, dissolution, or other sale or transfer of some or all of our business or assets. 

·         Law Enforcement: to third-parties such as law enforcement, government entities, courts, or other third parties as required or allowed by applicable law when requested. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

·         Controller Interest: If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of JeffreyM Consulting, LLC, its affiliates, customers, users or others such as fraud agencies.

International Transfers

We are located outside of the European Economic Area (EEA). As a result, when you provide Personal Information to us, that Personal Information is transferred outside of the EEA in order for us to be able to receive and access it. We will only do this with your consent. 

We use external third parties that are based outside the EEA that process your Personal Information in order to carry out activities specified in this Policy. This includes third parties in the following countries: the United States of America. Whenever we transfer your Personal Information to one of these third parties, we ensure that at least one of the following safeguards are implemented:

·         We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission. 

·         Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Information the same protection it has in Europe. 

·         Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Information shared between the Europe and the US. 

·         Please contact us our privacy team at privacy@jeffreym.com if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.

Your Choices and Opting Out

We may periodically send you email messages describing information, updates, or communications regarding open job positions related to the Website or our services. 

You can “opt-out” of receiving emails from us at any time by following the instructions included in your email, by sending a reply stating your request, or by sending an e-mail to privacy@jeffreym.com, and we will make the requested changes. Whether you opt-out of receiving emails or not, we reserve the right to email or otherwise contact you with respect to important information, notices, or updates relating to our services.

Data Retention

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.  

Your Legal Rights

You have the right to request that JeffreyM Consulting, LLC disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable request, you have the following rights under the GDPR in relation to your Personal Information:

·         Right to Access: You can request a copy and review the Personal Information we process about you. 

·         Right to Rectification: You can request to amend or update your Personal Information that is inaccurate or incomplete. 

·         Right to Erasure: You can request that we delete your Personal Information where there is no good reason to continue processing it or if it was collected unlawfully. We may not always be able to comply with your erasure request for specific legal reasons, which will be notified to you.

·         Right to Restrict: You can request that we temporarily or permanently stop processing all or some of your Personal Information if: (a) you want us to establish the accuracy of the Personal Information; (b) where the use is unlawful but you do not want it erased; (c) where you need us to hold it for legal purposes; or (d) you have objected to the use of your Personal Information but we need to verify if we have overriding legitimate reasons for processing the Personal Information. 

·         Right to Object: You can object to us processing your Personal Information on grounds relating to your particular situation. You have the right to object to your Personal Information being processed for direct marketing purposes.

·         Right to Data Transfer: You can request a copy of and transfer your Personal Information in electronic format to you or a third-party. This right only applies to automated information that you consented to us processing or where we used the Personal Information to perform a contract with you. 

·         Right Not to Be Subject to Automated Decision Making: You have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. 

·         Withdraw Consent: You have the right to withdraw your consent for us to process your Personal Information. (This does not affect the lawfulness of processing your Personal Information prior to the withdrawal of your consent.)

You may contact our privacy team at privacy@jeffreym.com to exercise any of your legal rights. If you are ever not satisfied with our response or believe that your Personal Information is being processed unlawfully, you may contact or lodge a complaint with the competent supervisory authority or seek other remedies under applicable law. 

Data Security

We have put in place appropriate security measures to prevent your Personal Information from accidentally being lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected Personal Information breach and will notify you of such as soon as possible.   

CONTACT INFORMATION

To ask questions or comment about this privacy notice and our privacy practices, contact us at privacy@jeffreym.com. 

 

Privacy Statement

Privacy Statement Updated April 1, 2020

Data Collected on Behalf of Clients

OVERVIEW

Your privacy is important to us. This privacy statement explains the personal data JeffreyM occasionally collects for our clients, how we process it, and for what purposes.

PERSONAL DATA WE COLLECT

We may collect data from you on behalf of clients.  The data we collect depends on the requirements of a client-initiated project and the choices you make, including your consent and privacy preferences. We may also obtain data about you from third parties.

CONSENT

You have choices when it comes to the data you share. When we ask you to provide personal data, you can always consent or decline. 

HOW YOUR DATA MAY BE USED

Your data will only be used as required to perform the project that our client has engaged us on. 

HOW YOUR DATA WILL BE STORED

We will mark your data as client personal data and store it in our secure data repository.  Access will be restricted to project team members who need to see it.

HOW LONG IT WILL BE RETAINED

We will only retain your data as long as it is required to perform the project unless you consent to have it stored for longer in anonymized format.

YOUR RIGHTS

You have the right to access, delete, edit, export, restrict and object to processing of your personal data.  Please see below for contact details

MAKING A PERSONAL DATA ACCESS REQUEST OR A COMPLAINT

To make a personal data access request, please contact our Information Security Officer (ISO), Michelle Ruane – Director of Human Resources, at micheller@jeffreym.com or 206.258.4972.

CONTACT

info@jeffreym.com
(206) 258-4972
600 University St, Suite 601
Seattle, WA 98101
New Penderel House,
4th Floor 283-288
High Holborn London WC1V 7HP, UK
Privacy Policy &
CSR