The Bar Raisers, LLC (the “Company”, “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Notice (this “Privacy Notice”) applies to our website and describes how we collect, use, share and otherwise process Personal Data (as defined below) about visitors to our website, contact persons for our clients and/or prospective clients, contact persons for our suppliers of goods or services to our Company, or any other individuals about whom the Company obtains Personal Data.

In this Privacy Notice, “Personal Data" means information that (either in isolation or in combination with other information held by the Company) enables you to be identified as an individual or recognized directly or indirectly.   

For the purposes of data protection laws in the European Economic Area (“EEA“), including the General Data Protection Regulation (the “Data Protection Law“), the Company is a data controller of your Personal Data, and as such, is responsible, and controls the processing of, your Personal Data. 

By accessing or using the Company’s website and service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your Personal Data as described in this Privacy Notice.

What personal data do we collect about you?

We collect Personal Data you provide to us in a variety of ways in connection with the day-to-day management of our business and our commercial relationships. For example, you may provide us your Personal Data when you visit our website, place an order, request information, order a service, send us messages, subscribe to our mailing list, newsletters or other forms of marketing communications.

The categories of information we collect may include:

Basic contact and profile information. We may collect personal information, such as your name, phone number, address, business information, title, job responsibilities, gender, age, zip code, address, e-mail address, contact details and information about family life, (excluding special categories of data) including family, children, hobbies and interests.

• Special categories of data. In limited circumstances, we may collect information you provide to us as necessary for a specific service we are providing to you, such as religious or other beliefs, racial or ethnic origin, sexual orientation, health data and details of trade union membership.

• Registration data. Newsletter requests, event/seminar registrations, subscriptions, listserv, downloads, and username/passwords.

• Client service data. Personal Data received from clients in respect of employees, customers or other individuals known to clients, invoicing details and payment history, and client feedback.

• Payment and transaction information. We may collect information such as payment information including your credit/debit card number. We use this information to complete your transaction, detect and prevent fraud, and to inform our advertising and marketing.

• Marketing data. Data about individual participation in conferences and in-person seminars, credentials, associations, interests, and preferences.

• Transaction data. Personal Data contained in documents, correspondence or other materials provided by or relating to transactions conducted by our clients.

• Compliance data. Government identifiers, passports or other identification documents, dates of birth, beneficial ownership data, and due diligence data.

• Comments, chat and opinions. When you contact us directly (e.g., by email, phone, mail or by completing an online form), we may record your comments and opinions. We use this information to respond to your question or comment, to evaluate and improve our services and to inform our marketing and advertising.

• Job applicant or contractor data. Data provided by job applicants or independent contractors in connection with employment or project opportunities.

Device data. Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our website (Usage Data).

We collect Personal Data from a number of sources, either directly from the data subjects, or from clients, colleagues and publicly available sources. Where the Company receives data from its clients about employees of clients or other individuals, the client is responsible for ensuring that any such data is transferred to us in compliance with applicable data protection laws.

How do we use personal data?

We use Personal Data to provide our services and respond to inquiries, to manage accounts and maintain business operations, to provide relevant marketing, and to fulfill other business and compliance purposes as follows:

• To provide advice and respond to inquiries we use basic data, registration data, client service data, and device data. We need to process your information in this way in order to perform our obligations under our contracts with our clients.

• To manage our business operations and administer our client relationships we use basic data, special categories of data, registration data, marketing data and client service data. This processing is necessary in order to perform our obligations under our contracts with our clients (e.g. issuing and processing invoices) and suppliers (e.g. managing the supply of goods and services to the Company).

• To make our website more intuitive and easy to use we use device data.  It is necessary for our legitimate interests to monitor how our website is used to help us improve the layout and information available on our website and provide a better service to our users.

• To protect the security and effective functioning of our website and information technology systems we use basic data, registration data, transaction data, and device data. It is necessary for our legitimate interests to monitor how our website are used to detect and prevent fraud, other crimes and the misuse of our website. This helps us to ensure that you can safely use our website.

• To provide relevant marketing such as providing you with information about events or services that may be of interest to you including business consulting services, updates, and conferences, we use marketing data, basic data, special categories of data, registration data, client service data, and device data. It is necessary for our legitimate interests to process this information in order to provide you with tailored and relevant marketing, updates and invitations.

• To address compliance and legal obligations, such as complying with the Company's tax reporting obligations, checking the identity of new clients and to prevent money laundering and/or fraud we use compliance data, basic data, registration data, transaction data, and device data. This processing is necessary for the purposes of complying with legal requirements to which we are subject.

• To consider individuals for employment and contractor opportunities and manage on-boarding procedures we use job applicant data and compliance data. The processing is necessary for the purposes of recruitment and on-boarding and for complying with legal obligations to which we are subject.

How do we share your personal data?

We share Personal Data as necessary to provide our services, respond to requests, and to fulfill other business and compliance purposes with the following categories of recipients:

• Suppliers and service providers: Personal Data may be shared with third party vendors and other service providers who perform services for us or on our behalf. These include IT services providers, our finance systems and our customer relationship management databases; third party consultants who provide us with support in respect of business consulting services and marketing campaigns. We require such parties by contract to provide reasonable security for Personal Data and to use and process such Personal Data on our behalf only.

• Financial institutions: We share Personal Data with financial institutions in connection with invoicing and payments.

• Mandatory disclosures and legal claims: We share Personal Data in order to comply with the Company's tax reporting obligations, comply with any subpoena, court order or other legal process, to comply with governmental request or any other legally enforceable demand. We also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.

Marketing Choices

You have control regarding our use of Personal Data for direct marketing. You can choose to not receive such communications at any time. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication, please follow the unsubscribe link in the relevant communication or contact us as per below.

Cookies

When you visit our Company’s website, we may send one or more cookies – a small text file containing a string of alphanumeric identifiers – to your computer that uniquely identify your browser. This will tell us how and when pages in our website are visited. You can review your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise choices you have for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of our website, and you may be required to re-enter your log-in details.

Cross-border Data Transfers

We transfer Personal Data to jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. In particular, our website is hosted on servers in the United States. If you are located in a non-US jurisdiction, the transfer of Personal Data is necessary to provide you with the requested information and/or to perform any requested services. When you submit Personal Data to us you are transferring your data across borders.

With respect to transfers originating from the EEA to the United States and other non-EEA jurisdictions, we implement standard contractual clauses approved by the European Commission, and other appropriate solutions to address cross-border transfers as required or permitted by Articles 46 and 49 of the Data Protection Law.

Data Retention

Personal Data that we collect and process for business purposes will be retained for as long as it is necessary to fulfill the purposes outlined in this Privacy Notice and as otherwise specified in applicable record retention policies and procedures.

Jurisdictional Disclosures

We may choose or be required by law to provide different or additional disclosures about our data privacy practices depending on your state or country of residence. Please review this section to understand how our practices or policy may differ in your jurisdiction:

Europe

If you are located in the EEA, you have the following rights in respect of your personal information that we hold:

• Right of access. The right to obtain access to your Personal Data.

• Right to rectification. The right to obtain rectification of your Personal Data without undue delay where inaccurate or incomplete.

• Right to deletion. The right to obtain the deletion of your Personal Data unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

• Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Data in certain circumstances, such as where the accuracy of the personal data is contested by you, our processing is unlawful, or we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.

• Right to portability. The right to portability allows you to move, copy or transfer your Personal Data easily from one organization to another.

• Right to object. YOU HAVE A RIGHT TO OBJECT TO ANY PROCESSING BASED ON OUR LEGITIMATE INTERESTS WHERE THERE ARE GROUNDS RELATING TO YOUR PARTICULAR SITUATION.

• Withdrawing Consent. If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us.

If you are in the EEA, you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable Data Protection Law.

United States

California. For information about our data processing practices as required by the California Consumer Privacy Act 2018, please view our CCPA Disclosure Notice.

Changes to Our Privacy Notice

We may modify or update this Privacy Notice from time to time to reflect the changes in our business and practices, so you should review this Privacy Notice periodically. When we change this Privacy Notice in a material manner, we will do so by indicating and updating the “last modified” date in the heading of this Privacy Notice.

Contact Us

If you have questions or comments regarding this Privacy Notice or our privacy practices or if you wish to exercise one of these rights, please contact us at hello@thebarraisers.com.

If we are unable to deal with any issues you raise with us, you also have the right to lodge a complaint with your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html.