As used in this Policy, the term: (a) “Affiliate” means, as to any person or entity, any other person or entity that, directly or indirectly, is in Control of, is Controlled by or is under common Control with such person or entity; (b) “Control” means the possession, directly or indirectly, of the power to direct or cause the direction of the management, policies or activities of the person or entity in question, whether through ownership of voting securities, by contract or otherwise; (c) “Concentric Parties” means Concentric and all of its Affiliates; and (d) “Personal Information” means any combination of information, in the possession of or likely to come into the possession of a Concentric Party that can be used to identify, contact, or locate a discrete individual. For purposes of clarification, any information which cannot be used to identify a discrete individual (such as aggregated statistical information) is not Personal Information.
PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
The Concentric Parties collect, use, and disclose your Personal Information in its normal course of business for the following purposes:
- Establishing and maintaining communications with you;
- Where you have requested information from any of the Concentric Parties, assisting you in the completion of your request and the assessment of your eligibility for any such request;
- Responding to your inquiries about the Concentric Parties’ services, information, or opportunities for employment;
- Managing, and making available information about, services you have obtained from a Concentric Party (if applicable);
- Managing, and making available information about, your relationship with a Concentric Party (if applicable);
- Allowing the Concentric Parties to notify you of certain products or services offered by one or more Concentric Parties;
- Meeting legal, security, processing, and regulatory requirements;
- Protecting against fraud, suspicious or other illegal activities; and
- Compiling statistics for analysis of the Sites and our business.
WHAT INFORMATION WE COLLECT/GENERATE
The information gathered and/or generated by the Concentric Parties about you falls into four categories: (1) information voluntarily supplied by visitors to a Site; (2) information you provide to a Concentric Party not using a Site; (3) information generated by a Concentric Party about you; and (4) tracking information gathered as visitors navigate through the Sites.
Information voluntarily provided by you
When using the Sites or doing business with a Concentric Party, you may choose to provide a Concentric Party with information to help one or more Concentric Parties serve your needs. The Personal Information that we collect will depend on how: (1) you choose to use the Sites; and (2) what Personal Information you share with a Concentric Party outside of the Sites.
- Where you request information from a Concentric Party
If you request information from a Concentric Party, we require you to submit your name, e-mail address, the name of your organization, and any other necessary contact information so we may send you the material you have requested, and to enable us to identify if you are an existing service provider, client, or candidate of a Concentric Party.
- Where you register with a Concentric Party and/or request services
If you register with a Site, or request a service available on a Site, we may ask you for your name, e-mail address, country, telephone number and the reason for your communication, as well as information about your position and organization and such other information as is reasonably necessary so that we can provide you with the requested information or service. On the data submission form, we will indicate by way of an asterisk, which information is optional and which information is mandatory. This information can include:
- Information you provide on applications or other forms, which may include your name, address, email address, and credit card numbers;
- Information we acquire from and/or transfer to other persons (such as government agencies, background screening companies, your insurer, your bank, or your employer) to verify your identity and the accuracy of the information you have provided and for other related purposes;
- Information related to any Concentric request for proposal; or
- Information about you received from a Concentric Party, another intermediary, a third-party providers and others which are necessary for the provision of our services.
Any Personal Information that you send us will be used for the purpose indicated on the applicable Site or in this Policy.
- Where you provide a Concentric Party information not through a Site
If you obtain services from a Concentric Party or are an applicant for employment of a Concentric Party: (1) you may provide such Concentric Party with Personal Information about yourself; or (2) the Concentric Party may generate Personal Information about you.
- Where you submit content
Finally, if you submit content regarding any of the information that you view on a Site (e.g. a response to an RFP), we will ask for your name and e-mail address, so that, if you choose, we can update you by e-mail when the content is acted upon. You should be aware that the information you provide there will be made publicly available to Concentric Party employees and potentially other users of a Site.
Website Navigational Information
As you navigate a Site, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on a Site (such as the web pages viewed, and the links clicked).
Session cookies: These are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
Persistent cookies: A persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
First-party cookies: The function of this type of cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between a Concentric Party’s servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
Third-party cookies: The function of this type of cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the third-party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.
The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, the Sites are not compatible with DNT.
For information on all of these categories of cookies, and for more information generally on cookies please refer to www.aboutcookies.org.
These cookies allow our Sites to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced features. For instance, a Site may be able to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access our Sites. These cookies can also be used to remember changes you have made to text size, font, and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing a video or commenting on an article. The information these cookies collect is usually anonymized. They do not gather any information about you that could be used for advertising or remember where you have been on the internet.
These cookies collect information about how visitors use a Site, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to a Site, all of which enables us to see how visitors use a Site in order to improve the way that the Site works. The information these cookies collect is normally anonymous and is used to improve how our Sites works. However, some of these cookies may include Personal Information.
Please consult your web browser’s ‘Help’ documentation or visit www.aboutcookies.org. for more information about how to turn cookies on and off for your browser.
These cookies are used to deliver content relevant to your interests on a Site and third-party sites based on how you interact with our advertisements or content.
- Web Beacons
A Site may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of a Site and interaction with e-mails from a Concentric Party. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications. We may use information from web beacons in combination with other data we have about our clients to provide you with information about one or more Concentric Parties and our services. We will conduct this review on an anonymous basis.
- IP Addresses
When you visit our Sites, we collect your Internet Protocol (“IP”) addresses to track and aggregate non-Personal Information. For example, we use IP addresses to monitor the regions from which users navigate the Sites. IP addresses will be stored in such a way so that you cannot be identified from the IP address.
DISCLOSURE OF INFORMATION TO OTHERS
Third parties to whom we generally disclose information are required by law or a contract with us, to keep your Personal Information confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances and generally for purposes as follows:
- To provide the information or services you have requested from us;
- To respond to your inquiries for employment with Concentric or an Affiliate;
- To notify you or allow our Affiliated companies to notify you of certain products or services offered by our affiliated companies;
- To process transactions through data processing service providers.
In the normal course of performing services for our clients, Personal Information may be shared among Concentric Parties for talent acquisition, research and statistical purposes, system administration, joint marketing, providing you services or information, and crime prevention or detection.
Because a number of the service providers we use are located in the United States, your Personal Information may be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under US laws.
In addition, generally, we provide your Personal Information to our lawyers, accountants, tax consultants and employees for the purpose of conducting our business and providing you with information. Our service suppliers adhere to the same protections regarding the collection, use, and retention of data as we do.
As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if a Concentric Party itself or substantially all of a Concentric Party’s assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third-party purchaser in these circumstances.
Other Legally Required Disclosures
The Concentric Parties reserve the right to disclose, without your prior permission, any Personal Information about you or your use of a Site if the Concentric Party has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of a Concentric Party, a Concentric Party’s employees, other users of a Site, or the public; (b) enforce the terms and conditions that apply to use of a Site; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process, or governmental request.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what personal information the operator disclosed to third parties for direct marketing purposes, for the preceding calendar year; and the addresses and names of such third parties. Concentric does not share any personal information collected from this site with third parties for their direct marketing purposes.
We have in place reasonable safeguards appropriate to the sensitivity of the information we maintain. Safeguards will vary depending on the sensitivity, format, location, amount, distribution, and storage of the Personal Information. They include physical, technical, and managerial measures to keep Personal Information protected from unauthorized access. Note that due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information disclosed over the Internet, and the Concentric Parties expressly disclaim any such obligation.
Our knowing about changes to some of your Personal Information (e.g. email address) may be key to effectively communicating with you at your request. If any of your details change you can update us by e-mailing us at email@example.com. Please keep us informed of changes to your Personal Information.
If you have any questions or concerns about how your Personal Information is handled by the Concentric Parties, please let us know by writing or sending an email to us at:
Concentric Energy Advisors, Inc.
293 Boston Post Road West, Suite 500
Marlborough, MA 01752
If there is any material change to your rights under this Policy, Concentric will provide you with notice of such change 30-calendar days prior to the changes going into effect. As part of this notice, Concentric may post a notice of the change on a Site in a clear and conspicuous manner for the 30-calendar day notice period. Concentric may also communicate the change via email or postal mail if this is the way that Concentric normally corresponds with you. Please note that your continued use of a Site once this 30-calendar day period is over indicates your agreement to the changes which were the subject of the notice.
Last Updated: 9/14/18