Privacy Policy

What is Personal Information?  This Privacy Policy applies solely to the collection and use of personal information. Personal information is any information that identifies or relates to an identifiable natural person.  This includes information such as name, mailing address, email address and telephone number.  Personal information does not include aggregated or anonymized data.

Information You Provide Directly to Us.  When you access certain parts of the Website or engage our Services, you may directly provide personal information to Wolf-Gordon, including contact information such as name, email, mailing address and phone number.  For example, you may provide us with this information when subscribing to a newsletter or other publication that we offer, by using our Contact Us page, or engaging with our Services (such as requesting or purchasing our products). 

Information Collected Automatically.  When you access and use the Website or engage with our emails, Wolf-Gordon may use various analytics tools and cookies to automatically collect usage information such as IP address, web browser information, mobile device unique number, mobile software and hardware information, pages or areas visited within the Website, what time said pages and areas are visited and email links opened. Please see our Cookies Notice here for more information on our use of cookies.

Customer Information.  If you are a customer, you may provide us certain personal information if you make any purchases with Wolf-Gordon.  For example, if you purchase any products from us, we may collect contact information that may include name, mailing address, email and phone number.  The Services may use certain third party payment processors (“Payment Processors”) to process personal financial information such as name, phone number, address, postal code, and credit card or bank account information for the purposes of allowing customers to make these purchases.  This information is provided directly to such Payment Processors by customers, and Wolf-Gordon does not store this information on its servers or computer systems. Such information is used solely for the purpose of allowing customers to make purchases.

Recruiting Information.  If you apply for a job with our organization, including through any careers page of the Website, discuss a potential job opportunity with us or attend one of our recruiting events or interviews, we may collect information such as name, phone number, email address, educational background and job history (or other curriculum vitae information).  This information may be collected in a variety of ways, including directly from you or via a third party such as a recruiting agency, educational institution, prior employer, professional reference or credentialing and licensing organization.

Social Media.  When you engage with one of our social media pages, we may collect information about you, including from tracking pixels. These pixels provide non-identifiable and anonymous data (e.g., demographic information) regarding how users interact with such pages.  You may opt out of this tracking in some cases by changing the privacy settings on your social media account.  For information on LinkedIn’s privacy settings, see https://www.linkedin.com/psettings/.  For information on Facebook’s privacy settings, see https://www.facebook.com/help/213802165366955/?helpref=related_articles.  For information on Instagram’s privacy settings, see https://help.instagram.com/196883487377501.  For information on X’s (formerly Twitter) privacy settings, see https://twitter.com/settings/account/personalization.  For more information on Pinterest’s privacy settings, see https://help.pinterest.com/en/article/your-privacy-and-data-settings. 

Information from Public Sources.  We may collect your personal information from publicly available sources such as public governmental databases.  Note that if you post personal information to a publicly available portion of the Website or via our social media pages, you understand and acknowledge that such information may be made available to other users or the general public.  We may combine personal information collected from public sources with other personal information we receive or collect. 

Information from Private Sources.  We may collect your personal information from various private sources outside of Wolf-Gordon, including governmental entities. We may combine personal information collected from private sources with other personal information we receive or collect.

We and our service providers may use your personal information for a variety of purposes permitted under applicable law, including the following business purposes:

• To provide you with Services and otherwise respond to your inquiries and requests.
• To provide you with marketing materials, newsletters, publications, and events that you have requested, enrolled in or opted into.
• To improve or modify the Services.
• To analyze the effectiveness of our Services and our marketing efforts.
• To meet legal and regulatory requirements and to respond to legal orders.
• To keep records of our interactions with you.
• For auditing purposes.
• To monitor for fraud.
• To monitor for and debug technical issues.
• To monitor for security events (including cybersecurity issues).
• For any other purpose with your consent. 

In each case, we will use your personal information only to the extent: (i) we have your consent to use such information for a given purpose; (ii) it is necessary to perform a contract between you and Wolf-Gordon; (iii) it is necessary to comply with a legal obligation; and/or (iv) it is necessary for the purpose of Wolf-Gordon’s or a third party’s legitimate business interests (provided that such interests are not in conflict with your rights under applicable law).

We do not sell or rent your personal information to third parties for monetary or other valuable consideration and have not done so in the prior twelve (12) months since the effective date of this privacy policy.  We disclose personal information within Wolf-Gordon, with service providers who enable us to provide Services, in connection with a Transaction (defined below) or if otherwise required to do so under applicable law or legal process.  Our service providers may include:

• Website providers or hosts
• Cloud service providers (or other data storage providers)
• Various information technology (IT) support vendors
• Software and other technology service providers (such as Payment Processors)
• Marketing firms
• Insurance agencies
• Accounting firms
• Consulting firms
• Business partners 

We may disclose your personal information if we have a legal obligation to do so, including if needed to:

• Comply with applicable law.
• Respond to or cooperate with requests from governmental entities or law enforcement.
• Enforce this Privacy Policy.
• Protect the rights, property or safety of Wolf-Gordon, our customers or the public.

If Wolf-Gordon merges with another entity, if Wolf-Gordon sells its assets, business or equity to another entity, or if Wolf-Gordon undergoes an insolvency proceeding (each referred to as a “Transaction”), we may disclose your personal information to an acquiring entity (or potential acquiring entity) and its advisors.  While Wolf-Gordon will use commercially reasonable efforts to ensure that such acquiring entity (or potential acquiring entity) treats such personal information in accordance with this Privacy Policy at the time of the Transaction, Wolf-Gordon makes no guarantees as to whether such entity will treat your information in accordance with the Terms & Conditions (including the Privacy Policy), and Wolf-Gordon therefore disclaims any liability arising out of such entity’s failure to do so. 

This Website may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) that uses cookies to track how users navigate the Website. Please see our Cookies Notice for more information on our use of cookies. This service may also collect information regarding your use of other websites and applications. You may refuse the use of these cookies via the settings in your browser. You also can opt out of being tracked by Google Analytics by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: https://tools.google.com/dlpage/gaoptout.

Your browser may offer you a “Do Not Track” option, which allows you to signal that you do not want them to track your online activities. The Website does not currently support Do Not Track requests.

We retain personal information for as long as necessary for the purposes that such information was obtained.  We use the following criteria to determine the length of the retention period: the duration of our relationship with you (including if you are a customer), whether there are legal requirements to retain the information, and whether we deem retention necessary in connection with potential legal claims or positions.

Wolf-Gordon takes commercially reasonable steps designed to protect personal information that you provide us by employing appropriate physical, technical and administrative security measures. Despite the security procedures we employ, you should be aware that it is impossible to guarantee the security of information that you transmit to us via the Internet.  Your transmission of your personal information to us via the Website is done entirely at your own risk. 

This Website and other Services may contain links to other websites that are not maintained or controlled by Wolf-Gordon.  Wolf-Gordon is not responsible for the privacy practices (if any) of such other websites, and you are encouraged to review their privacy policies (if any). The fact that a link to a third-party website exists on the Website or other Services does not mean that the third-party site operates under the same or similar privacy practices as set forth in this Privacy Policy.  The policies and procedures that Wolf-Gordon describes here do not apply to third-party websites.  If you access a third-party website using a link, then you do so at your own risk. You acknowledge that your access of any links to social media features on the Website and other Services (e.g., links to LinkedIn, etc.) is governed by the terms of use and privacy policies of the companies providing such social media features.

Please note that Wolf-Gordon is headquartered and located solely within the United States.  As of the effective date of this Privacy Policy, Wolf-Gordon does not operate any offices outside of the United States, including any offices in the European Economic Area (EEA) or the United Kingdom (UK).  If you are a visitor to this Website, and you reside outside of the United States (including in the EEA or the UK), please note that in providing any personal information to us via the Website or other Services, you may be providing information to a jurisdiction (the United States) whose laws may not provide the same level of protection for personal information as that provided in your home country.  If you do not wish to have your personal information made available to Wolf-Gordon personnel outside your home jurisdiction, please do not provide it to us via the Website or any other means.

We do not promote, market or direct Services to minors. As a result, Wolf-Gordon does not knowingly collect or solicit personal information from anyone under the age of 18. By using our Website or by providing us your personal information, you represent that you are not under 18 years of age.

If you are a resident of California, you may have certain rights under various California privacy laws.  Please see the California Addendum in this Privacy Policy for more information.  If you are a California job applicant, please see the Notice to California Job Applicants and Employees in Section A of the California Privacy Addendum. 

Wolf-Gordon reserves the right to revise this Privacy Policy at any time.  If we make substantial changes to this Privacy Policy, we will endeavor to notify you of such changes (e.g., by email or an alert on the Website for a period of time).  However, regularly reviewing this page is the best method to ensure you are always aware of the information Wolf-Gordon collects, how it is used and under what circumstances.

You may stop or opt out of email messages and other promotional mailing us via e-mail at [email protected] or via regular mail at 333 Seventh Avenue, New York, NY 10001.  You may also contact us via email or regular mail to change information you previously provided, or to request information or ask questions concerning this Privacy Policy, the online Terms & Conditions or any other notice posted on our Website. 

Wolf-Gordon provides the following additional details to California residents and households in connection with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”) (collectively, the CCPA and CPRA, the “California Privacy Laws”).  

A.        Categories of Personal Information Collected

Below are the categories of personal information of California residents that Wolf-Gordon plans to collect and that we have collected, used and disclosed for our business purposes in the twelve (12) months preceding the effective date of this Privacy Policy:

1. Identifiers, such as your name, preferred name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, date of birth and other similar identifiers.
2. Personal information classifications contained in the California Customer Records statute, such as your name, signature, Social Security number, address, telephone number, education, employment or employment history.
3. Characteristics of protected classifications, such as minority, veteran and disability status, through voluntary self-disclosure. Such information will only be collected as permitted by applicable law and will not be used to make hiring decisions.
4. Commercial information, such as records or history of Services and financial or payment information.
5. Internet or other similar electronic network activity information, such as your IP address, log-in information, browsing history or information regarding your interaction with a website, application or advertisement.
6. Geolocation data, such as IP addresses and device location from which we can determine your general location.
7. Audio, electronic, visual and similar information, such as call recordings and CCTV footage (such as if you visit one of our offices) created for safety and security purposes, and audio and video recordings of events, conferences and meetings.
8. Professional or employment-related information, such as your role/title, employer name, work history, references, information about skills and abilities, accomplishments and awards, training and development information, performance evaluation information and employment termination information.
9. Education information subject to the Federal Educational Rights and Privacy Act, such as your education history, education records (such as grades, transcripts and class lists) and other information included in a resume or cover letter. 
10. Inferences drawn from other personal information, such as a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
11. Sensitive Personal Information, defined under the CPRA to include: 
    • Social Security or other state identification number;
    • account log-in, financial account, debit card or credit card number in combination with any required security or access code, password or credentials allowing access to an account; 
    • geolocation;
    • racial or ethnic origin, religious or philosophical beliefs or union membership; 
    • the contents of your mail, email or text messages (unless Wolf-Gordon is the intended recipient of such communications); 
    • genetic data;
    • biometric data;
    • health information; and
    • information concerning sex life or sexual orientation (collectively, “Sensitive Personal Information”).
12. Legal or contractual information, such as information necessary to respond to law enforcement and governmental agency requests, comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to, or establish, exercise and defend, legal and contractual rights claims.
13. Other information collected in the case of California job applicants, such as job interview notes, responses to screening questions, assessment results and any other information you provide in connection with the recruitment process.

Please see the following sections of our general Privacy Policy for more information on:

• Section 1: the sources from which we obtain the above categories of personal information; 
• Section 2: the business purposes for which we use such categories of personal information; and
• Section 3: the purposes for which we disclose such personal information and the parties to whom such information is disclosed.

B.         California Privacy Law Rights

Subject to certain exceptions and limitations, rights under California Privacy Laws include, and you may make, the following requests:

• Right to Know. You have the right to request what personal information we have collected about you in the preceding twelve (12) months (or, if required under the CPRA and to the extent possible, taking into account applicable data retention periods, in the time period starting January 1, 2023), including the categories of personal information collected, the categories of sources from which such information is collected and the business or commercial purpose of collecting such information.  In addition, your right to know extends to a right of data portability, which requires us to provide you the pieces of specific personal information that we have collected about you in a portable and, to the extent technically feasible, in a structured, commonly used, machine-readable format so that you may transmit the information to another entity. 
• Right to Correct: You have the right to request that we correct inaccuracies in your personal information.
• Right to Delete. Subject to certain exceptions detailed below, you have the right to request that we delete or de-identify the personal information we have collected from you.  However, such right does not apply when the information is necessary for us or an applicable third party to do any of the following:
  • Provide Services to you.
  • Perform a contract between you and Wolf-Gordon.
  • Protect your security and enforce your rights regarding the same.
  • Protect your or others’ free speech rights.
  • Comply with the California Electronic Communications Privacy Act.
  • Engage in public or peer-reviewed scientific, historical or statistical research in the public interests that adheres to all other applicable ethics and privacy laws.
  • Comply with a legal obligation.
  • Make other lawful uses of the personal information, to the extent such uses are compatible with the purposes or context to which such information was provided.
• Right to Opt-Out. You have the right to opt-out of the disclosure of your personal information when that disclosure is made by us in exchange for valuable consideration, or when that disclosure is made to a third party for cross-contextual behavior advertising (in each case, whether for money or otherwise). However, please note that we do not sell or rent your personal information to third parties for monetary or other valuable consideration, nor do we share your personal information for the purposes of cross-contextual behavioral advertising. We have also not done so in the prior twelve (12) months since the effective date of this Privacy Policy.
• Right to Request a Record of Third-Party Direct Marketing Disclosures. Also known as the “Shine the Light” law, this permits California residents to request and obtain from us a list of what personal information we disclosed to third parties for direct marketing purposes in the preceding twelve (12) months and the names and addresses of those third parties.  This request may be made no more than one (1) time per calendar year.

If you exercise your applicable California rights, Wolf-Gordon will not discriminate against you.  To exercise any such rights, please submit a verifiable consumer request to [email protected] or by calling the following toll-free number: 800-347-0550. We will verify your identity and respond to your request, taking into account the type and sensitivity of the personal information subject to your request.  To protect you (and to protect against fraudulent requests), we may request additional information to verify your identity, including your name, mailing address and email.  You may use an authorized agent to submit a request.  However, we may need to request that such agent provide evidence that such agent is indeed authorized by you.  Moreover, even if an agent submits a request on your behalf, you may still be required to provide us with information that verifies your identity, as described above.

We strive to respond to each verifiable consumer request within 45 days of receiving such request. If we are unable to meet this timeline, we will inform you in writing.

C.         Limitations on the Use and Disclosure of Sensitive Personal Information

Under the CPRA, you have the right to limit the use and disclosure of Sensitive Personal Information where such Sensitive Personal Information is used for the purpose of inferring characteristics about a consumer.

However, please note that we do not use Sensitive Personal Information for the purpose of inferring characteristics about a consumer.   We use Sensitive Personal Information only for the purposes of providing Services to you, ensuring security and integrity of our Services, short-term transient use, servicing accounts, providing customer service, verifying customer information, for human resources purposes (if you are an employee or job applicant) and quality control and safety control matters.

D.         Minors

We do not “sell” or “share”, as each such term is defined under California Privacy Laws, any personal information of minors under 16 years of age.    

E.         Automated Decision-Making

We do not use personal information for automated decision-making.

F.         Conflicts

This California Privacy Addendum is supplemental to, and is incorporated into, our Privacy Policy.  In the event of a conflict between this California Privacy Addendum and the Privacy Policy, the California Privacy Addendum shall control, but solely to the extent the conflict relates to personal information subject to California Privacy Laws.

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NOTICE TO CALIFORNIA JOB APPLICANTS AND EMPLOYEES

Under California Privacy Laws, we are required to provide the following notice, which applies to California residents who apply for employment with Wolf-Gordon, as well as California residents who are current employees.  For purposes of this notice, “employees” also includes “interns” and “contractors.”  This notice applies to HR Data (as defined below) provided via the Website, in person, or any other means that we receive HR Data, directly or indirectly, from you.

Note: This notice is supplemental to our California Privacy Addendum.  If you provide us with HR Data (as defined below), the rights outlined in Section B below, as well as the disclaimers regarding Sensitive Personal Information, minors and automated decision-making outlined in Sections C, D and E, respectively, also apply to such HR Data.

What personal information do we collect from job applicants and employees?

From job applicants and employees that are California residents, Wolf-Gordon plans to collect, and has collected, used and disclosed in the twelve (12) months preceding the effective date of this Privacy Policy, the following categories of personal information listed above: categories (i), (ii), (iii), (v), (vi), (vii), (viii), (ix), (x), (xi), (xii) and (xiii).  All such personal information is collectively referred to in this notice as “HR Data.”

From what sources do we collect HR Data?

• Voluntarily Provided. We collect HR Data directly from you when you voluntarily provide us information requested during the job application or other recruitment process and interview process. If you become or are currently an employee of Wolf-Gordon, you may also voluntarily provide us with HR Data that is needed to administer your payroll, benefits, insurance and taxes. 
• Automatically Collected.  We automatically collect HR Data in the form of Internet or other similar electronic network activity information (such as IP address or other device identifiers) when you visit the Website, including any careers page or any online job postings.
• Public Sources.  We collect HR Data from publicly available sources such as your social media profiles and prior employer websites.
• Private Sources.  For job applicants, we collect HR Data from recruiters, prior employers, professional references, universities and other educational institutions and pre-employment screening providers (e.g., background check providers).   For both job applicants and current employees, we collect HR Data from credentialing and licensing organizations, as well as governmental entities.
• Other Sources.  You may direct us to other sources of HR Data as part of your job applicant process or as part of managing your employment.

How do we use HR Data?

We use HR Data for the following business purposes:

• To process and manage your job application.  We use HR Data to evaluate you and your qualifications.  We may collect photographs of you for identification purposes during the application process, and, with your consent, we may record video of your interview. 
• To conduct screening and background checks.  To the extent permitted under applicable law, we may conduct a background check and/or other employee screening check on you.  These checks require HR Data, including some Sensitive Personal Information such as social security numbers.
• To apply for a visa or work permit.  In some cases, where you need to obtain a visa or work permit, we use HR Data to assist you in doing so.
• To manage your employment.  If you become an employee, we use HR Data (including HR Data provided in the pre-employment stage) to manage your employment, including managing any of your associated compensation, benefits, insurance and taxes and any termination of employment.  We also may use HR Data to evaluate your ongoing performance at Wolf-Gordon.
• To comply with legal or regulatory requirements.  We keep records of HR Data as required by applicable law.  In other cases, we may be required by law or legal order to retain or use HR Data, such as to detect, prevent or investigate security incidents, fraud or other illegal activities, or to protect the rights, property and safety of Wolf-Gordon or others. 
• Improve our recruiting process and employment practices.  We use HR Data to understand and improve our recruiting process, as well as the practices we have with respect to current employees.

How do we disclose HR Data?

We disclose HR Data for the business purposes described above in this notice, both internally within Wolf-Gordon, as well as externally as follows:

• To service providers.  We disclose HR Data to service providers that operate and assist in our recruiting process, including recruiting firms, technology providers, security and fraud consultants, analytics providers, screening and background check providers and other providers of hiring management tools used by Wolf-Gordon.  For current employees, we disclose HR Data to service providers that assist us in the management and administration of standard human resources functions such as payroll, benefits, insurance and taxes.  We also disclose HR Data to IT service providers as part of administering and maintaining our IT infrastructure, networks and security (including servicing IT support requests generated by Wolf-Gordon or by you).
• To governmental authorities and law enforcement.  We disclose HR Data as required under applicable law, including to any required state or federal tax authorities.  We also may disclose HR Data if we receive a request to do so by governmental authorities or law enforcement.  We also may disclose HR Data if required to do so to detect, prevent or investigate security incidents, fraud or other illegal activities, or to protect the rights, property and safety of Wolf-Gordon or others.   This may include enforcing a contract or resolving a dispute.
• Transaction.  If Wolf-Gordon undergoes a Transaction, we may disclose HR Data pursuant to Section 4 of our Privacy Policy.
• Professional Advisors.  We disclose HR Data to our professional advisors, including our accountants, legal counsel, consultants and insurance providers.