Delv Privacy Statement

 

Effective as of May 25, 2018. Last updated June 27, 2018

Delv Global Solutions LLC (“Delv”) is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, Delv is committed to the appropriate protection and use of personal information (sometimes referred to as “personally identifiable information” or “PII”) that has been collected by or provided to us through our websites and other online and mobile services that link to or post this Privacy Statement (collectively, the “Online Services”).

Please review this Privacy Statement to learn more about how we collect, use, share and protect the PII that we have obtained. By using the Online Services, you consent to the processing of your information as set forth in this Privacy Statement, now and as amended by us.

 

1. Collection and use of personal information

We and our service providers collect any information that you provide when you use the Online Services. For example, when you fill and submit the contact form, we collect basic information about you such as your first name, last name, email address and demographic or additional optional information you decide to provide. You may also provide us with certain employment information in connection with an application for employment with Delv. In some cases, you may have previously provided your information to Delv (if, for example, you are a former employee).

We use the information we collect from you to provide you with the Online Services; to communicate with you; to operate, maintain, and enhance the Online Services; and to fulfill your specific requests. For example, if you send us an email message through contact form, we will use your email address and other information you supply to respond to your request. If you send us a resume/CV to apply online for a position with Delv, we will use the information that you provide to conduct the recruitment process. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards.

In some cases where you have registered for certain services (for example Newsletter) we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e., where we send an email to the email address provided as part of your registration to confirm a subscription request). Please note that your rights for any particular product or service will be determined by the notice provided with such product or service, and in the event of a conflict between this notice and that notice, the specific notice provided with the product or service shall control.

Delv only collects “sensitive” personal information when the relevant individuals voluntarily provide us with this information, or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person’s race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record. Please use your discretion when providing sensitive information to Delv, and under any circumstances, do not provide sensitive information to Delv, unless you thereby consent to Delv’s use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in Delv databases. If you have any questions about whether the provision of sensitive information to Delv is, or may be, necessary or appropriate for particular purposes, please contact Delv at gdpr@delvglobal.com.

 

1.1. Automatic collection of personal information

In some instances, Delv and its service providers use cookies, web beacons and other technologies to automatically collect certain types of information when you use the Online Services, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience; improve the performance, usability and effectiveness of Delv’s online presence; advertise and market our services; measure the effectiveness of our marketing activities; and generate and analyze statistics about your use of the Online Services.

 

1.1.1. IP addresses

An IP address is a number assigned to your computer or internet-enabled device whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to maintain and improve the Online Services and to generate and analyze statistics about the Online Services and your use of the Online Services.

 

1.1.2. Cookies

Cookies are small text files that are placed on your computer or internet-enabled device by the websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The use of cookies is now standard for most websites. If you are uncomfortable with the use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site.

 

Types of cookies:

There are following types of cookies:

‘Session’ cookies remain in your browser during your browser session only, ie until you leave the website.

‘Persistent’ cookies remain in your browser after the session (unless deleted by you).

‘Performance’ cookies collect information about your use of the website, such as webpages visited and any error messages; they do not collect personally identifiable information, and the information collected is aggregated such that it is anonymous.  Performance cookies are used to improve how a website works.

‘Functionality’ cookies allow the website to remember any choices you make about the website (such as changes to text size, customized pages) or enable services such as commenting on a blog.

 

Use of cookies by Delv:

The following table explains the way in which we use cookies on this website.

 

CookieNamePurposeTypeDuration
Google Analytics_gaThis cookie is typically written to the browser upon the first visit. If the cookie has been deleted by the browser operator, and the browser subsequently visits our website, a new _ga cookie is written with a different unique ID. In most cases, this cookie is used to determine unique visitors to our website and it is updated with each page view. Additionally, this cookie is provided with a unique ID that Google Analytics uses to ensure both the validity and accessibility of the cookie as an extra security measure.Third Party Persistent2 years from set/update
Google Analytics_gatThis cookie is typically written to the browser upon the first visit. If the cookie has been deleted by the browser operator, and the browser subsequently visits our website, a new _gat cookie is written with a different unique ID. In most cases, this cookie is used to determine unique visitors to our website and it is updated with each page view. Additionally, this cookie is provided with a unique ID that Google Analytics uses to ensure both the validity and accessibility of the cookie as an extra security measure.Third Party Persistent1 minute from set/update
Google Analytics_gidThis cookie is typically written to the browser upon the first visit. If the cookie has been deleted by the browser operator, and the browser subsequently visits our website, a new _gid cookie is written with a different unique ID. In most cases, this cookie is used to determine unique visitors to our website and it is updated with each page view. Additionally, this cookie is provided with a unique ID that Google Analytics uses to ensure both the validity and accessibility of the cookie as an extra security measure.Third Party Persistent24 hours from set/update
Cookie Settingsmoove_gdpr_popupWhen this Cookie is enabled, these Cookies are used to save your Cookie Setting Preferences.Third Party Persistent1 year from set/update

 

Managing cookies on your device

We use cookies to personalize content and to provide you with an improved user experience. By using this website or application you consent to the deployment of cookies. You can control and manage cookies using your browser (see below). Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available.

 

Using your browser to control cookies

Most browsers allow you to view, manage, delete and block cookies for a website. Be aware that if you delete all cookies then any preferences you have set will be lost, including the ability to opt-out from cookies as this function itself requires placement of an opt out cookie on your device. Guidance on how to control cookies for common browsers is linked below.

Visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/.

 

Managing cookies using cookies consent manager

You can also adjust all of your cookie settings for our website by using cookies consent manager on our website, where you can turn on/off strictly necessary cookies and Google Analytics cookies.

 

1.1.3. Do Not Track

Our Online Services may not recognize browser-based Do Not Track signals. However, as discussed above under “Cookies,” you may be able to modify your browser settings to block all cookies, or to block “third-party” cookies. Cookies that we set on our Online Services are considered “first-party” cookies. Details on your ability to restrict or change the personal information that we may collect about you are listed below under the Choice and Access sections of this statement.

 

1.1.4. Usage Analytics

Delv uses third party usage analytics tools including Google Analytics. More information about how Google Analytics is used by Delv can be found here: http://www.google.com/analytics/learn/privacy.html

To provide website visitors with more choice on how their data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on.
The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the Online Services or to other web analytics services.

 

1.1.5. Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. Delv only uses web beacons in accordance with applicable laws.

Delv or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to maintain and improve the Online Services.

 

1.1.6. Location-based tools

Delv may collect and use the geographical location of your computer or mobile device, but only with your express consent. With respect to the collection of precise information about the location of your mobile device, once you have consented to the collection you may adjust this consent by managing your Location Services preferences through the settings of your mobile device.  This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

 

1.2. Social media widgets and applications

The Online Services may include functionality to enable sharing via third party social media applications (such as the Facebook Like button and Twitter widget). These social media applications may collect and use information regarding your use of the Online Services (see details on ‘Social Sharing’ cookies above). Please be aware that certain of the personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, the Online Services may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any Delv social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

 

1.3. Children

Delv understands the importance of protecting children’s privacy, especially in an online environment. In particular, our Online Services are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

 

2. Sharing and transfer of PII

We do not share personal information with unaffiliated third parties, except as stated in this Privacy Statement, including as necessary for our legitimate professional and business needs, to carry out your requests, to market our services, as required or permitted by law or professional standards, or otherwise with your consent.

In some instances, Delv may share PII about you with various third-party service providers and vendors working on our behalf. These third parties include providers of administrative, identity management, website hosting, data analysis, data back-up and security management services. Delv requires these entities to safeguard PII in the same manner as Delv.

Delv may also disclose PII in order to respond to lawful requests of government or law enforcement agencies, including to meet national security or law enforcement requirements or where disclosure is required by applicable laws, court orders, or government regulations.

Cross Border Transfer. Delv is a US limited liability partnership and may transfer certain PII across geographical borders to other Delv member firms or to outside companies working with us or on our behalf. Delv may also store PII in a jurisdiction other than where you are based and such jurisdiction may not provide the same level of protection for your personal information as your home country. By providing your information to Delv, you are consenting to this transfer and/or storage of your information across borders.  Each member firm is required to safeguard personal data in accordance with its contractual obligations and data protection legislation applicable to its provision of services. Your personal data will only be transferred if appropriate or suitable safeguards are in place.

 

3. Choices

We may require you to provide certain PII in order for you to receive additional information about our services and events. Delv may also ask for your permission for certain uses of your PII, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in “Cookies” section above, if you wish to prevent cookies from tracking you as you navigate our sites, you may be able to do so by changing your browser settings. Note, however, that some portions of the Online Services may not work properly if you elect to refuse cookies.

 

4. Access

If you have submitted personal information to Delv, under most circumstances you have the right to reasonable access to that data to correct any inaccuracies. You can also make a request to update or remove information about you and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards. To request access to or correction, updating, or removal of your personal information please contact us at: gdpr@delvglobal.com

 

5. Data security and integrity

Delv has and requires its service providers to have security policies and procedures in place to help protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite Delv’s efforts, however, security cannot be guaranteed against all threats. We seek to limit access to your personal information to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information. We also make efforts to retain personal information only for so long as the information is needed for our professional, marketing or analytic purposes or to comply with an individual’s request, or until that person asks that the information be deleted.

 

6. EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

Delv participates in the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding certain personal information received by Delv in the U.S. from European Union member countries and Switzerland.  Please see our https://delvglobal.com/privacy-shield-policy/ for information about Delv’s data practices regarding personal information it receives from European Union member countries and Switzerland pursuant to the respective Privacy Shield frameworks. To learn more about the Privacy Shield program generally, and to view Delv’s certification, please visit https://www.privacyshield.gov/.

 

7. Links to other sites

Please be aware that the Online Services may contain links to other sites. Delv is not responsible for the content or practices of these sites. We encourage users to review the privacy policy of each site visited before disclosing any personal information.

 

8. Changes to this statement

Delv may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how Delv is protecting your information.

 

9. Questions and comments

Delv is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your PII, please contact us at gdpr@delvglobal.com. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

 

10. Contact information:

For complaints, questions or information regarding our Privacy Policy, please contact us at:

Email – gdpr@delvglobal.com

Mail – Delv Global Solutions LLC, 535 Fifth Avenue, New York, New York 10017

We will respond to your complaints or inquiries within a reasonable time but in no event later than 45 days.