Lachman Consultant Services, Inc.  (“Lachman Consultants”, “we”, “our”, and “us”) is committed to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, Lachman Consultants is dedicated 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  (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 collection and processing of your information as set forth in this Privacy Statement, now and as amended by us from time to time.

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 register for a service, we may collect basic information about you such as your name, username, password, email address, physical address, phone number, and other personal and business demographic or contact information.

We use the information we collect to: provide you with the Online Services; communicate with you; operate, maintain, and enhance the Online Services; and fulfill your specific requests.  For example, if you send us a request to perform OnCall services, we will use your email address and other information you supply to respond to your request.  Your personal information is used only for the purposes described in this Privacy Statement, unless we otherwise obtain your permission, or unless otherwise required or permitted by law or professional standards.

In some cases where you have registered for certain services 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).  Lachman Consultants does not collect “sensitive” personal information. 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 do not provide sensitive information to Lachman Consultants.

1.1 Automatic collection of personal information

In some instances, Lachman Consultants and its service providers use cookies, web beacons, wayfinding technology, Wi-Fi, Bluetooth, Global Positioning System (“GPS”) technology, and other technologies (including other location-based 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 Lachman Consultants’ 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 Internet Protocol (“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 may be placed on your computer or internet-enabled device whenever you visit the Online Services.  This allows the Online Services to remember your computer or device and serves a number of purposes.

On some of our Online Services, a notification banner will appear requiring your consent to collect cookies.  If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities.  A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality.  Such cookies will not be blocked through the use of this notification banner.  Your selection will be saved in a cookie and is valid for a period of 90 days.  If you wish to revoke your selection, you may do so by clearing your browser’s cookies.

Although most browsers automatically accept cookies, you may be able to choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu).  You may also be able to delete cookies from your device. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of the features of the Online Services.

Other third-party tools and widgets may be used on our individual web pages or portions of the Online Services to provide additional functionality.  Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed properly.

BY ACCESSING OR USING OUR ONLINE SERVICES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE, OR A THIRD PARTY ACTING ON OUR BEHALF, CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

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

Lachman Consultants uses several third-party usage analytics tools including Google Analytics. More information about how Google Analytics is used by Lachman Consultants can be found here: https://www.google.com/analytics/terms/us.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.

1.2 Payment

Lachman Consultants uses a third-party service for processing payments for fees in connection with the Online Services.  We will not store or collect payment card details.  That information is provided directly to the third-party payment processor whose use of your personal information is governed by its privacy policy.  The payment processor adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.  The current third party service provider for payment processing is Stripe and its privacy policy can be viewed at https://stripe.com/us/privacy.

1.3 Children

Lachman Consultants 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.

 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,  as required or permitted by law or professional standards, or otherwise with your consent.

In some instances, Lachman Consultants may share PII about you with 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.  Each such third party is required to safeguard PII in accordance with its contractual obligations and data protection legislation applicable to its provision of services.

Lachman Consultants may 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.  In the event that the ownership of Lachman Consultants or an affiliate or their assets changes as the result of a merger, acquisition, or sale of assets, information owned or controlled by Lachman Consultants may be transferred to another company. Information may also be shared in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, assign or transfer all or a portion of our assets.  These disclosures may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.  Lachman Consultants does not sell PII to any third parties.  Also, Lachman Consultants will not transfer the PII you provide to any third parties for their own direct marketing use.

Lachman Consultants and our service providers may use personal information in an aggregated, anonymized form for research and development. This data does not identify you individually, but rather helps to identify trends in user preferences and behaviors.  In addition, we may share de-identified reports on user demographics and traffic patterns, as well as de-identified information, with third parties.

Cross Border Transfer.  Lachman Consultants is a US corporation and may transfer certain PII across geographical borders to other Lachman Consultants affiliates or to outside companies working with us or on our behalf.  Lachman Consultants 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 Lachman Consultants, you are consenting to this transfer and/or storage of your information across borders.  Each Lachman Consultants affiliate 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.  If you are located in the EU, you may have additional rights. You can find more information under Section 7 below.

3. Choices

We may require you to provide certain PII in order for you to receive additional information about our services and events.  Lachman Consultants 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 e-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 Lachman Consultants, 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 privacy@lachmanconsultants.com.

5. Data security and integrity

Lachman Consultants 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 Lachman Consultants’ 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. Residents of European Union and United Kingdom

For residents of the European Union (and United Kingdom), Lachman Consultants is the data controller responsible for your personal information collected pursuant to this Privacy Policy.  Our digital operations are conducted in the United States.  Regardless of where you live, you consent to have your personal data transferred to, processed and stored in the United States, and allow Lachman Consultants to use and collect your personal information in accordance with this Privacy Policy.

In addition, residents of certain countries, including European Union member states (and the United Kingdom), have some or all of the following rights with respect to personal information collected from and about them on the Online Services: the right to request access to, and the correction, erasure, and/or restriction of processing of, such personal information; in some instances, the right to object to the processing of such personal information; in some instances, the right to request that Lachman Consultants export, in a structured, commonly used, and machine readable format, and transmit to another controller, such personal information; and the right to withdraw, at any time, any consent to the processing of such personal information. To exercise these rights, please contact Lachman Consultants via email at privacy@lachmanconsultants.com.

7. Additional Disclosures for California Residents

This section applies to any California residents about whom we have collected personal information, including through use of our website, by purchasing or utilizing our products or services, or by communicating with us electronically.

For purposes of this section, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.  Personal information does not include publicly available information or information that has been de-identified.

7.1  Information We Collect

The types of personal information we collect about you will depend on your relationship with Lachman Consultants.  For example, in many cases, we may collect personal information from our business clients during the course of an engagement to provide services to our clients, and our collection and use of personal information is governed by our contract with that entity.  In other cases, we may collect personal information directly from consumers.

We may collect the following categories of personal information:

  • Identifiers, which may include real name and alias; postal address; unique personal identifier; online identifiers as detailed below; IP address; email address; telephone number; account number, name, and password; and/or other similar identifiers;
  • Commercial information, which may include products or services purchased, obtained, or considered; account balances, payment history, or account activity; bank account information and other information relating to your financial institution; and/or other purchasing or consumer histories or tendencies;
  • Information relating to Internet activity or other electronic network activity, which may include cookie identifiers, clear gifs, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp,  clickstream data, device platform, device version, and/or other device characteristics including your choice of settings;
  • Professional or employment-related information, which may include information regarding your current employers; job title and responsibilities; and
  • Other personal information not listed above and described in California Civil Code § 1798.80(e), which may include signature and/or bank account number, credit card number, debit card number, and other financial information.

7.2  Purposes and Sources of Collection

We may collect or use personal information for the following purposes:

  • Assessing third-party vendors and service providers;
  • Auditing and compliance with policy, procedures, laws, regulations, and professional standards;
  • Billing, payment, and fulfillment;
  • Protect against fraud and other malicious or illegal activity;
  • Customer and client communications;
  • Customer and client relationship management;
  • General business administration;
  • Provision and performance of the services;
  • Internal analytics and benchmarking;
  • Marketing our products and services;
  • Marketing the products and services of others;
  • Financial reporting and accounting;
  • Administer, maintain, and improve the website and services; and
  • Systems and data security.

We may collect personal information from the following sources:

  • Our clients and customers and prospective clients and customers or their authorized representatives, including via applications and forms, communications and interactions with us, and through our websites and mobile applications;
  • Our subsidiaries, affiliates, joint ventures, and other companies under our common control (collectively, “Affiliates”);
  • Government entities and databases, such as anti-fraud databases, sanctions lists, and court judgments; and
  • Publicly available sources.

7.3  Disclosures of Information

7.3.1 Categories of Third Parties With Whom We Share Information

We may share personal information as described in this Privacy Policy, including with the following categories of third parties:

  • We may share personal information with our Affiliates.
  • Technical and Operational Service Providers and Business Partners.  We may engage third parties to perform certain functions on our behalf.  To do so, we may disclose personal information to our third-party business partners and service providers in order to maintain and operate the websites and provide, improve, and personalize the services, including to fulfill requests for the services and for other technical and processing functions, such as sending e-mails on our behalf, fulfilling orders, and technical support.  We may also share personal information to service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal, or fraudulent activity or other threats.
  • Government Entities.  We may share personal information with government entities and agencies, regulators, law enforcement, and other third parties, including to provide the services, comply with applicable laws and regulations, to respond to a subpoena, search warrant, or pursuant to legal process, and to establish or exercise our legal rights or for fraud- or crime-prevention purposes.
  • Professional Service Firms.  We may share personal information with other professional service firms in connection with our legal, regulatory, and professional obligations and to establish or exercise our rights and defend against claims, including, for example, auditors, law firms, and consultants.
  • Corporate Transactions. Subject to applicable law, we reserve the right to transfer some or all personal information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets.  If any such transaction occurs, the purchaser will be entitled to use and disclose the personal information collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding personal information as described in this Privacy Policy.

7.3.2 Disclosures of Personal Information for Business or Commercial Purposes

We may have disclosed the following types of personal information to third parties for a business or commercial purpose in the previous twelve (12) months:

  • Identifiers
  • Commercial information
  • Information relating to Internet activity or other electronic network activity
  • Professional or employment-related information
  • Other personal information not listed above and described in California Civil Code
  • 1798.80(e)

7.3.3 Sales of Personal Information

We do not sell personal information and did not sell personal information in the previous twelve (12) months.

7.4 Your Privacy Rights

You may be entitled by applicable law to exercise the following rights with respect to your personal information:

  • Right to Know. You have the right to request what personal information we collect, use, disclose, and/or sell, as applicable.
  • Right to Delete.  You have the right to request that we delete the personal information that we have collected about you.
  • Right to Opt-out of the Sale of Personal Information. You have the right to request to be opted-out from the sale of your personal information.  However, as set forth above, we do not sell personal information.
  • Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

You may also authorize someone to exercise the above rights on your behalf.

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests.

To exercise your rights, submit your request to the following email address:  privacy@lachmanconsultants.com.

We will respond to authorized and verified requests as soon as practicable and as required by law.  Please note that, where we have received your information through our business clients, or where we are otherwise operating as a service provider, pursuant to applicable law.

In addition, the above rights are subject to various exclusions and exceptions under the law, and, under certain circumstances, we may be unable to implement your request. We will advise you of any reason for denying or restricting a request.

8. Links to other sites

Please be aware that the Online Services may contain links to other sites that are not governed by this Privacy Statement but by other privacy statements that may differ. Lachman Consultants 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.

9. Changes to this statement

Lachman Consultants 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 Lachman Consultants is protecting your information.

10. Questions and comments

Lachman Consultants 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 privacy@lachmanconsultants.com.  You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

Last updated May 10, 2020