Privacy Policy

(United States and Canada)

CRB Group, Inc., Clark, Richardson and Biskup Consulting Engineers, Inc., CRB Builders LLC, CRB Architects-Engineers P.C., CRB Group GmbH, and the subsidiaries and affiliates of our companies (collectively, “CRB,” “we,” “us,” or “our”) developed this Privacy Policy (“Privacy Policy” or “Policy”) to provide you with information concerning our Personal Information practices including the collection, usage, disclosure, and retention practices, as well as our privacy and security practices. This policy does not apply to workforce-related Personal Information collected from employees or similar individuals.

For purposes of this Privacy Policy, the term “Personal Information” means any information relating to an identified or identifiable natural person, or that could reasonably be linked, directly or indirectly, with a particular person or household. “You” and “your” refer to the person reading this Privacy Policy, which may include CRB clients, potential clients, subcontractors, and suppliers, as well as individuals working for CRB’s clients, potential clients, subcontractors, and suppliers; CRB’s job applicants; and individuals that visit our websites, use our applications, or otherwise provide us with Personal Information.  If you reside in Europe, please review our European Privacy Policy.

I. Categories of Personal Information We Collect

We have collected the following categories of Personal Information within the last twelve (12) months or reasonably anticipate collecting the following categories of Personal Information moving forward:

  • Identifiers, such as a real name, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport numbers, or other similar identifiers.
  • Personal Information Categories Listed in California Customer Records Statute, such as a name, signature, social security number, physical characteristics, address, telephone number, education, employment, employment history, insurance policy number, credit bank account number, or any other financial information. Some Personal Information included in this category may overlap with other categories.
  • Characteristics of Protected Classifications under California or Federal Law, such as citizenship, race, gender, or physical or mental disability, or veteran or military status.
  • Commercial Information, such as products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies.
  • Internet or Other Similar Network Activity Information, such as browsing history, search history, or information on your interaction with a website, application, or advertisement.
  • Geolocation Data, such as IP Addresses.
  • Sensory Data, such as audio, electronic, visual, or similar information.
  • Professional or Employment-Related Information, such as occupation or current or past job history.
  • Education Information as Defined in the Family Education Rights and Privacy Act, such as student transcripts, GPA, grades, and academic evaluations.
  • Sensitive Personal Information, such as Personal Information that reveals your social security number, driver’s license number, identification card number, passport number, racial origin, or ethnic origin. CRB does not use or disclose Sensitive Personal Information for purposes other than those specified in Section 7027(m) of the CCPA Regulations.

II. Categories of Sources of Personal Information We Collect

We may collect the above-described categories of Personal Information from one or more of the following sources:

  • Information You Provide. We collect Personal Information that you provide to us, such as when you provide your information to us at a conference, contact us by phone, email or webform; subscribe to a newsletter, marketing email, or other publication; respond to a survey; register for an event; check in as a visitor at our offices; engage us on a project; submit a supplier or subcontractor registration or update; apply for a job through our website.
  • Secure Entrances and Spaces. We may collect Personal Information from cameras at the entrances and exits of some of our buildings and parking structures, in the lobbies and elevators, and at some of our project sites.
  • Automated Information Collection. We use automated data collection technologies for reporting and analysis purposes.  For example, we consider metrics such as how you and others interact with our website and applications, how easy our website is to navigate, and the performance of our marketing efforts.  For additional information, see the Cookies & Similar Technologies section, below.
  • Your Employer. We may receive your Personal Information from your employer if (1) your employer is our client, or (2) your employer is our subcontractor or supplier.
  • State Agencies. We may collect information about you from state agencies providing publicly available information.
  • Social Media Platforms and Networks. We also may collect information made publicly available by you or by other individuals about you from online platforms that connect individuals around common interests and facilitate sharing.  If you connect or interact with us on social media platforms and networks such as LinkedIn, Twitter, or Instagram, for example, by liking our page or sharing something we post, the social media platforms and networks may provide us with information concerning you, such as your name and other Personal Information. In addition, the social media platforms and networks will have access to information about you and your use of the social media platforms and networks. The information that we collect relating to your connections or interactions with us on social media platforms and networks is subject to this Privacy Policy. The information collected by the social media platforms and networks remains subject to the social media platforms and networks’ privacy practices.
  • Industrial Information Resources Databases. We may collect information about you from industry resources.
  • Data Analytics Providers. We may receive information about you from our third-party website analytics services providers who collect and analyze information about your interaction with our websites.
  • Our Other Third-Party Service Providers. We may receive information about you from other third-party service providers, including but not limited to our website hosts and website content management service providers.

III. Purposes for Collecting Personal Information

We may collect the above-described categories of Personal Information for one or more of the following business, commercial, or other purposes:

  • To respond to inquiries about our services and products and answer questions about the same.
  • To send newsletters, marketing emails, or other publications to individuals that subscribe.
  • To connect visitors to their CRB hosts when they arrive, document visits, and enable employees to easily identify visitors in our offices.
  • To provide requested services and products to our clients and collaborate with clients during a project via project management software.
  • To request services and products from our suppliers and subcontractors; assess the risks, qualifications, and capacity of our suppliers and subcontractors; collaborate with our suppliers and subcontractors during a project via project management software; and pay our suppliers and subcontractors for services and products provided.
  • To obtain business insights from surveys, receive feedback on services and products, and to gather information needed to inform decisions about innovation, growth, pricing, and promotions.
  • To control access to and protect the security of CRB’s offices, parking structures, project sites, and other spaces.
  • To investigate any instances of property damage, theft, and other crimes on or near our offices, parking structures, project sites, and other spaces, and to assist law enforcement agencies in their investigations of the same.
  • To provide interactive features of our websites, such as job application forms.
  • To receive job applications; communicate with job applicants about the status of their applications; verify job applicant identity, qualifications, and experience; evaluate job applicant qualifications and experience; and determine whether applicants are a good fit for the position they are interested in.
  • To evaluate potential candidates’ online professional profiles, including information about their qualifications and experience, and determine whether to recruit them for a position at CRB.
  • To evaluate our success in pursuing our goal to be an equal opportunity employer and to report required aggregated information to federal regulators.
  • To meet our regulatory reporting requirements and comply with our legal and regulatory obligations, including those that require employers to maintain specified records.
  • To respond to law enforcement requests, meet our obligations in legal proceedings and government investigations, and otherwise comply with applicable laws, court orders, and government regulations.
  • To provide information pertinent to an actual or potential merger, acquisition, or other reorganization.
  • To protect our legal interests.
  • As necessary or appropriate to protect the rights, property, or safety of CRB, our clients, or others.
  • To audit ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • To help ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.
  • To debug, specifically to identify and repair errors that impair existing and intended functionality.
  • To perform services on behalf of CRB, including maintaining or service customer accounts; providing customer service; processing or fulfilling customer orders and transactions; verifying customer information; processing payments; providing financing; providing analytic services; providing storage; and providing similar services on behalf of CRB.
  • To provide advertising and marketing services to you.
  • To undertake internal research for technological development and demonstration.
  • To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by CRB, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by CRB.
  • As otherwise described by CRB to an individual at or before the time that CRB collects the individual’s Personal Information.

IV. Purposes for Disclosing Personal Information

We may disclose the above-described categories of Personal Information for one or more of the following business or commercial purposes:

  • To audit ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • To help ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.
  • To debug, specifically to identify and repair errors that impair existing and intended functionality.
  • To perform services on behalf of CRB, including maintaining or servicing customer accounts; providing customer service; processing or fulfilling customer orders and transactions; verifying customer information; processing payments; providing analytics services; providing storage; or providing similar services on behalf of CRB.
  • To provide you with advertising and marketing services.
  • To undertake internal research for technological development and demonstration.
  • To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by CRB; and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by CRB.
  • To provide you with magazines, blogs, newsletters, and other publications you subscribe to.
  • To request services and products from our suppliers and subcontractors; pay our supplier and subcontractors for services and goods received.
  • To provide our clients with requested services; manage client expectations and subcontractor obligations.
  • To investigate any instances of property damage, theft, and other crimes on or near our offices, parking structures, project sites, and other spaces, and to assist law enforcement agencies in their investigations of the same.
  • To provide interactive features for our websites, such as customer account portals and job application forms.
  • To verify job applicant identity, qualifications, and experience.
  • To evaluate our success in pursuing our goal to be an equal opportunity employer and to report required aggregated information to federal regulators.
  • To manage our relationships with current and potential clients, and to obtain technical support with respect to client relationship management services.
  • To manage our procurement processes and receive customer support with regard to our contract management systems.
  • To enable us to store and access job applicant Personal Information.
  • To meet our regulatory reporting requirements and comply with our legal and regulatory obligations, including those that require employers to maintain specified records.
  • To respond to law enforcement requests, meet our obligations in legal proceedings and government investigations, and otherwise comply with applicable laws, court orders, and government regulations.
  • To provide information pertinent to an actual or potential merger, acquisition, or other reorganization.
  • To protect and defend our legal interests.
  • As necessary or appropriate to protect CRB’s rights and property, and the rights, property, and safety of CRB’s customers, employees, subcontractors, and other individuals.
  • As otherwise described by CRB to an individual at or before the time that CRB collects the individual’s Personal Information.

V. Recipients of Personal Information

In connection with the purposes set forth in this Privacy Policy, we may disclose your Personal Information to one or more of the following categories of recipients:

  • Our Clients: We may disclose the Personal Information of our suppliers and subcontractors and their employees with our clients in connection with ongoing projects.  If you are interested in information concerning the privacy and security practices of any of those clients, please directly review such client’s privacy policy.
  • Data analytics providers: We may disclose your Personal Information to third-party website analytics services providers who collect and analyze information about your interaction with our websites.
  • Operating Systems and Platforms. We may disclose your Personal Information to software companies that provide us with operating systems and platforms.
  • Social Media Platforms and Networks. Social media platforms and networks may offer functionalities, plugins, widgets, or tools in connection with our Sites (g., to share our products with your friends and followers on social media platforms and networks).  If you choose to use these functionalities, plugins, widgets, or tools, certain information may be disclosed to or collected by such social media platforms and networks and will be subject to such social media platforms and networks’ privacy practices.
  • Other Third-Party Service Providers and Subcontractors that Perform Services on Our Behalf: We may disclose Personal Information to other third-party service providers and subcontractors that perform services on our behalf, including project management, marketing, advertising, website hosting, website content management, client relationship management, procurement contract management, data storage, security, fraud prevention, and legal services.
  • Governmental Entities and Third Parties in Connection with Legal Matters: We may disclose Personal Information to governmental entities, such as regulatory agencies, law enforcement, and judicial authorities, as well as other third parties providing assistance to us or other parties in relevant legal matters (g., attorneys and e-discovery service providers), under any of the following conditions: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, warrant, legal process, or other legal obligation; (c) to enforce or apply any of our terms and conditions, policies, or other agreements; (d) to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; or (e) as necessary to pursue available legal remedies or defend legal claims.
  • Third parties in Connection with a Potential Reorganization: We may disclose Personal Information with a prospective seller, buyer, and any third-party service provider assisting CRB or a prospective seller or buyer in connection with the potential reorganization (g., a law firm assisting CRB) in the event of a potential reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of CRB’s assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.
  • CRB companies: We may also disclose your Personal Information, including certain identifiers, commercial information, and employment or professional information within our corporate group to our affiliates, subsidiaries, or parent companies.

VI. Cookies & Similar Technologies

As you interact with our websites and applications, we, with assistance from third-party analytics service providers, collect Personal Information pertaining to your use of CRB’s websites and the devices and programs from which you access our websites and applications (“Usage Data”) using cookies and similar technologies.

A. What are Cookies?

Cookies are small computer files sent or accessed from your browser or our application on the hard drive of your computer, mobile device, or tablet that contain information about your device, such as your user ID, user settings, browsing history, and activities conducted while browsing websites.

B. How Do We Use Cookies?

Cookies are essential for the effective operation of our websites and applications and help you to navigate our websites and applications.  CRB and its third-party service providers use cookies to monitor your browsing behavior.

The primary purposes for which cookies are used are: (1) For the effective operation of our websites and applications, especially in connection with website navigation and online communications; (2) To monitor and improve the quality and user-friendliness of our website and applications; (3) To monitor the success of our advertising campaigns and marketing-related activities (e.g., promotions); and (4) To assist CRB in detecting and preventing fraud, denial of services attacks, and other malicious activity directed at our websites or through our applications.

C. How Can You Manage Cookies?

If you do not want Usage Data collected through the use of cookies and similar technologies, there is a procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them.  Cookies that are required to enable core site functionality cannot be disabled without causing substantial website functionality issues.  To assist in controlling website-specific cookies, check the privacy and cookie setting in your preferred browser.

We neither have access to, nor does this Privacy Policy govern, the use of cookies and similar technologies that may be placed on your device you use to access our websites by third parties. If you are interested in opting out of tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs.

VII. Third-Party Privacy Practices

Our websites may provide links to other third-party websites as a service to you.  We are not responsible for the privacy practices of such other third-party websites. If you link to such a website through our websites, you should always review any privacy notice that is available for that website.

VIII. Children’s Privacy

Our websites are not directed to individuals under the age of 13.  We do not knowingly collect any Personal Information from users under 13 years of age. No Personal Information should be submitted to our websites by visitors under 13 years of age.  If we learn that we have collected Personal Information from someone under 13, we will take steps to delete the Personal Information as soon as possible.

IX. Protecting Your Personal Information

We implement technical and organizational measures designed to assist in maintaining the security and confidentiality of Personal Information; safeguarding against anticipated threats to the confidentiality, integrity, and availability of Personal Information; and protecting your Personal Information against accidental or unlawful destruction, loss, alteration, and unauthorized access or disclosure.

However, whenever Personal Information is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party.  No system or online transmission of data is completely secure.  In addition to the technical and organizational measures that CRB has in place to protect your Personal Information, you should use appropriate security measures to protect your Personal Information.  If you believe that any Personal Information you provided to us is no longer secure, please notify us immediately at [email protected].

X. Retention of Personal Information

The following chart sets forth the criteria we will use to determine the period of time the categories of Personal Information to be collected by CRB will be retained.

Category of Personal Information (as described in Section I)

Criteria That Will be Used to Determine Period of Time Such Personal Information Will be Retained

  • Identifiers
  • Time period necessary to fulfill the purposes for which your Personal Information was originally collected or received
  • Time period necessary to meet CRB’s legal obligations
  • Personal Information Categories Listed in the California Customer Records Statute
  • Time period necessary to fulfill the purposes for which your Personal Information was originally collected or received
  • Time period necessary to meet CRB’s legal obligations
  • Characteristics of Protected Classifications under California or Federal Law
  • Time period necessary to fulfill the purposes for which your Personal Information was originally collected or received
  • Time period necessary to meet CRB’s legal obligations
  • Commercial Information

 

  • Time period necessary to fulfill the purposes for which your Personal Information was originally collected or received
  • Time period necessary to meet CRB’s legal obligations
  • Internet or Other Similar Network Activity
  • Time period necessary to fulfill the purposes for which your Personal Information was originally collected or received
  • Time period necessary to meet CRB’s legal obligations
  • Geolocation Data
  • Time period necessary to fulfill the purposes for which your Personal Information was originally collected or received
  • Time period necessary to meet CRB’s legal obligations
  • Sensory Information
  • Time period necessary to fulfill the purposes for which your Personal Information was originally collected or received
  • Time period necessary to meet CRB’s legal obligations
  • Professional or Employment-Related Information
  • Time period necessary to fulfill the purposes for which your Personal Information was originally collected or received
  • Time period necessary to meet CRB’s legal obligations
  • Education Information as Defined in the Family Education Rights and Privacy Act
  • Time period necessary to fulfill the purposes for which your Personal Information was originally collected or received
  • Time period necessary to meet CRB’s legal obligations
  • Sensitive Personal Information
  • Time period necessary to fulfill the purposes for which your Personal Information was originally collected or received
  • Time period necessary to meet CRB’s legal obligations

XI. California Notice

A. Third-Party Disclosures and Sharing

We have disclosed the following categories of Personal Information for business purposes within the past twelve (12) months and/or reasonably anticipate disclosing the following categories of Personal Information for business purposes (i.e., purposes for which California privacy law permits service providers and contractors to use Personal Information) or “sharing” (i.e., making available a consumer’s Personal Information to a third party for purposes of cross-context behavioral advertising) to the following categories of third parties:

 Category of Personal Information (as identified in Section I)

Categories of Third Parties to Which Personal Information has been Disclosed for a Business Purpose

 Categories of Third Parties to Which Personal Information has been “Sold” or “Shared”

  • Certain Identifiers
  • Social media platforms and networks
  • Data analytics providers
  • Operating systems and platforms
  • Other third-party service providers that provide services on our behalf
  • Social media platforms and networks
  • Data analytics providers
  • Operating systems and platforms
  • Other third-party service providers that provide services on our behalf
  • Certain Personal Information Categories Listed in the California Customer Records Statute
  • Social media platforms and networks
  • Operating systems and platforms
  • Other third-party service providers that provide services on our behalf
  • Operating systems and platforms
  • Other third-party service providers that provide services on our behalf
  • Characteristics of Protected Classifications under California or Federal Law
  • Other third-party service providers that provide services on our behalf
  • N/A
  • Certain Commercial Information
  • Operating systems and platforms
  • Other third-party service providers that provide services on our behalf
  • Operating systems and platforms
  • Other third-party service providers that provide services on our behalf
  • Certain Internet or Other Similar Network Activity
  • Social media platforms and networks
  • Data analytics providers
  • Operating systems and platforms
  • Other third-party service providers that provide services on our behalf
  • Social media platforms and networks
  • Data analytics providers
  • Operating systems and platforms
  • Other third-party service providers that provide services on our behalf
  • Certain Geolocation Data
  • Social media platforms
  • Data analytics providers
  • Operating systems and platforms
  • Other third-party service providers that provide services on our behalf
  • Social media platforms and networks
  • Operating systems and platforms
  • Other third-party service providers that provide services on our behalf
  • Certain Sensory Data
  • Our third-party service providers that provide services on our behalf
  • Our third-party service providers that provide services on our behalf
  • Certain Professional or Employment-Related Information
  • Our third-party service providers that provide services on our behalf
  • N/A
  • Education Information as Defined in the Family Education Rights and Privacy Act
  • Our third-party service providers that provide services on our behalf
  • N/A
  • Sensitive Personal Information
  • Our third-party service providers that provide services on our behalf
  • N/A

We may share the above-described categories of Personal Information for one or more of the following business or commercial purposes:

  • Performing services on behalf of CRB, including maintaining or servicing customer accounts; providing customer service; processing or fulfilling orders and transactions; verifying client information; processing payments; providing analytics services; providing storage; or providing similar services on behalf of CRB.
  • To help ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.
  • To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by CRB; and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by CRB.
  • To provide you with advertising and marketing services.
  • To provide you with magazines, blogs, newsletters, and other publications you subscribe to.
  • To provide our clients with requested services; manage client expectations and subcontractor obligations.
  • To request services and products from our suppliers and subcontractors; pay our supplier and subcontractors for services and goods received.
  • To manage our relationships with current and potential clients and to obtain technical support with respect to client relationship management services.
  • To manage our procurement processes and receive customer support with regard to our contract management systems.

CRB has no actual knowledge of sharing the Personal Information of consumers (i.e., California residents) under 16 years of age.

B. CCPA Rights

California residents have certain rights under California privacy law, including but not limited to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), which gives California residents (“consumers” or “you”) certain rights and control over Personal Information.  This section of CRB’s Privacy Policy applies solely to our clients, subcontractors, suppliers, and their employees and officers, users of our website, job applicants, and job candidates whose Personal Information we collect who reside in the State of California. If you are a California resident, you have the following privacy rights under the CCPA:

  • Right to Know. You have the right to request that that we disclose the Personal Information we have collected about you, including the categories of Personal Information; the categories of sources from which the Personal Information was collected; the business or commercial purposes for collecting, selling, or sharing Personal Information; the categories of third parties to whom we disclose Personal Information; and the specific pieces of Personal Information we have collected about you.
  • Right to Request Deletion. You have the right to request deletion of Personal Information about you that we have collected, subject to certain exceptions.
  • Right to Request Correction. You have the right to request correction of inaccurate Personal Information that we maintain about you.
  • Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for exercising your rights under the CCPA.

XII. Canada Privacy Rights

Canadian privacy law, including but not limited to the Personal Information Protection and Electronic Documents Act (“PIPEDA”), gives identifiable individuals whose data is protected under Canadian privacy law (referenced in this section as “you”) certain rights and control over Personal Information that we collect, use, or disclose in the course of our commercial activities in Canada.  This section of CRB’s Privacy Policy addresses such rights under Canadian law for such clients, subcontractors, suppliers, and their employees and officers, users of our website, job applicants, and job candidates whose Personal Information we collect.

A. Right to Request Access

You have the right to request access to the Personal Information about you that an organization holds, subject to certain exceptions.

B. Right to Request Correction

After receiving access to your Personal Information that an organization holds, you have the right to request the correction of inaccurate or incomplete Personal Information about you and, in some circumstances, to receive access to the Personal Information after it is amended.  This right is also subject to certain exceptions.

C. Right to Withdraw Consent

You have the right to withdraw your consent to an organization’s collection, use, and disclosure of your Personal Information at any time, subject to contractual and legal restrictions and reasonable notice. If you would like to withdrawal your consent, please contact us at [email protected].

D. Right to Challenge Non-Compliance

You have the right to address a challenge concerning non-compliance with PIPEDA to the organization, and, if the issue is not resolved, to the Office of the Privacy Commissioner of Canada.

XIII. Other Personal Data Rights

If you are located in Europe, you may have privacy rights that are addressed in our European Privacy Policy.  If you reside in other parts of the world, you may have privacy rights under law[s] applicable to your Personal Information.  Please reach out to us if you have any questions about personal data rights using the contact information provided in the How to Contact Us section.

XIV. Consent to Collection, Use, Disclosure, & Processing (Canada)

If you reside in Canada, by providing us with your Personal Information, you generally give us your implied consent to collect, use, disclose, and otherwise process your Personal Information for the purposes identified in this Privacy Policy or otherwise identified by us at the time of collection. By accessing or using our websites or applications, you consent to our collection, use, disclosure, and other processing of your Personal Information during such access and use as described in this Privacy Policy.  In other contexts (e.g., in connection with any sensitive Personal Information processing), we may obtain your express consent to our collection, use, disclosure, and other processing of your Personal Information for particular purposes.

V. Exercising Privacy Rights

In this section, we provide an explanation of our process for individuals to exercise any privacy rights to which they are entitled by law, for designating an authorized agent, and for verifying the identity of individuals who submit privacy right requests.

A. Submitting Requests

To exercise your rights described in this Privacy Policy, please submit a verifiable consumer request by emailing us at [email protected]

  • Submission Contents: Requests to exercise your privacy right(s) should include the following information:
    • Your name;
    • The country in which you currently reside;
    • If you reside in the United States, the state in which you currently reside;
    • Which privacy right(s) you are exercising;
    • Details that will assist us in responding to your request, including:
      • If you are exercising access rights, the information to which you are requesting access;
      • If you are exercising correction rights, the information you believe to be inaccurate or incomplete;
      • If you are exercising deletion rights, the information for which you are requesting deletion;
      • Any other relevant information about your Personal Information and/or the right you are exercising; and
    • A phone number and/or email address at which we can reach you.

B. Designating An Authorized Agent

Only you or a person that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may designate an authorized agent to make a verifiable consumer request on your behalf by submitting such request to CRB via email at [email protected] with “Request for Authorized Agent” in the subject line. Before taking action in response to such a request, we will require your authorized agent to verify such representative’s authority.

C. Identity Verification

Before responding to your request to exercise your right to know, correct, or delete, we must verify your identity through reasonable verification measures.  If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account.  If you are exercising your right to know, correct, or delete your Personal Information, we may require you to re-authenticate yourself before we provide a substantive response to your request to know, correct, or delete your Personal Information.

Our verification processes also may include requiring you to provide answers to questions pertaining to the information we have on file for you (e.g., email address; physical address; phone number); requesting confirmation of the request using the email address we have on file for you; and/or calling the phone number we have on file for you to confirm the request. We may also require you to provide a signed declaration or, if you are an authorized agent submitting a request on behalf of a California resident, signed permission from such California resident.

If we cannot verify your identity based on information we already have, we may request additional information from you.  If this is necessary, we will only use the additional information for purposes of verifying your identity and for fraud-prevention.  If we are unable to reasonably verify your identity (and thus unable to comply with your request), we will advise you why that is the case.

D. Withdrawing Consent

You may withdraw your consent by submitting a request to withdraw your consent using one of the methods for submitting a privacy rights request that are described above. Please note that if you withdraw your consent to certain uses or collection of your Personal Information, we may not be able to provide you with a particular service or product.  We will explain the implications of withdrawal to you after we receive your request.

XVI. Disability Assistance

We are committed to taking steps to help ensure that this Privacy Policy is accessible to everyone.  Individuals with difficulty accessing information in this Privacy Policy are encouraged to contact us by email at [email protected].

XVII. Do Not Track or Other Similar Technologies

We will respond to “do not track” signals or other similar technologies. Although we do not track your online activities over time and across third-party websites or other online services, our website may place analytic or advertising cookies originating from third parties that may be used for such tracking on your computers and devices.   These third parties may collect Personal Information relating to your online activities over time and across different sites and applications when you use our websites in order for us to provide you with content that is likely to be of interest to you.

XVIII. Cross-Border Data Transfers

We may transfer and store your Personal Information on servers outside of your country.  Your Personal Information may be transferred to and processed by CRB and its clients, third-party service providers, subcontractors, and suppliers in the United States or in other countries whose laws may not be as comprehensive and protective as the laws of your country.  For example, personal data stored in the United States may be subject to lawful access requests by U.S. federal and state law enforcement and national security authorities.

XIX. Privacy Policy Updates

We also may update this Privacy Policy from time to time as we add new services or offerings; as we improve our current services and offerings; and as technologies and laws change.  It is our policy to post any changes we make to our Privacy Policy on our websites.  Any changes will become effective thirty (30) days after our posting of the revised Privacy Policy on our websites.  The date this Privacy Policy was updated and the date it became effective are identified at the top of the first page.  If we make material changes to how we treat the Personal Information that falls within the scope of this Privacy Policy, we will notify you by email or through a prominent notice on the homepage of our websites.

XX. How To Contact Us with Questions, Concerns or Compliance Challenges

If you have any questions, concerns, or compliance challenges relating to this Privacy Policy, relevant privacy principles, and/or our privacy practices or if you need any assistance relating to your Personal Information, you may contact our Data Compliance Group by email at [email protected], or by writing to us at the following address:

CRB Group, Inc.
Attention: Data Compliance Group
1251 NW Briarcliff Parkway, Suite 500
Kansas City, Missouri 64116