PRIVACY NOTICE

Introduction

Your privacy is very important to Cadien Mayers Consulting LLC (“CMC” or “we”, “our” or “us”). This privacy notice (“Privacy Notice”) describes the policies we follow for the collection, use, storage, sharing, disclosure (“processing”) and protection of your personal information.

Your “personal information” may mean different things under the various privacy and data protection laws that apply to our processing of your personal information in different jurisdictions, but it generally means any information that relates to, describes, identifies or can be used, directly or indirectly, to identify you as an individual.

Please note that while this Privacy Notice is posted on our website (the “Site”), it applies to personal information we collect through a variety of channels, including personal information collected when you:

• Visit the Site, sign up for our mailing list, subscribe to any of our publications, download content from the Site, or contact us through the Site.
• Visit our offices.
• Investigate or apply for employment with CMC or accept an offer of employment.
• Engage CMC to perform services (or when an entity with which you are associated does so) and share personal information with us to help us perform those services.
• Provide goods or services to CMC (or when an entity with which you are associated does so).
• Respond to one of our online advertisements or social media profiles.
• Use other applications, websites and collection points that reference this Privacy Notice.

Please note that the Site may contain links to other sites and certain content on the Site may be hosted by third parties. We are not responsible for the privacy practices of these third-party sites.

The types of personal information we may collect and how we collect it

Depending on the channel through which we collect your personal information and our reason for doing so, personal information we collect about you may include:

• Identification and Contact Information: including your name, title, occupation, employer, physical address, email address, telephone number, date of birth, place of birth, citizenship, residence and work status.
• Financial Information: including your net worth, assets and liabilities, bank account information, brokerage account information, and credit history.
• Government Identifiers: including your social security numbers, taxpayer identification numbers, driver’s license information, passport information and other government issued identifiers.
• Images: including your likeness, images of your driver’s license or other identification cards, and CCTV footage of your movements. Note that this type of personal information, which may be collected when you visit our offices, is often collected in the first instance by the building owner or operator and may or may not be shared with CMC. This Privacy Notice does not apply to our building owners and operators; any personal information they collect from you will be subject to their privacy policies.
• Background Information: including your educational, employment and professional history, such as what might appear on your resume or an employment application.
• Social Media: including personal information you make available through social media channels.
• Demographic and Diversity Information: including your age, race, ethnicity, gender, sexual orientation, veteran status, citizenship, marital status and disability status.
• Marketing Information: including your communications preferences, interactions with our Site, interactions with our advertisements, usage of our services, and interest in our content.
• Technical Information: including your browsing history, devices, browser type and plug-ins, browser version, IP address, interactions with the Site, and interactions with our advertisements.
• File Sharing: including documents, spreadsheets, records, correspondence and other files you elect to share with us by hand delivery, courier, mail, emails, electronic file sharing services and similar delivery methods.
• Voluntary Disclosures: including other sensitive personal information that you choose to share with us.

CMC generally collects only personal information that you elect to share with us. However, we may also obtain personal information through background checks, credit checks and other due diligence methods if you apply for employment with us, when you or an entity with which you are associated seek to engage CMC’s services, or when you or such an entity seek to provide goods or services to CMC. Certain personal information may also be collected using automated methods when you visit the Site or one of our offices, or interact with us through email or other electronic methods (see our Cookie Notice for more information).

If you provide personal information to us about another person, you should ensure that you provide that person with this Privacy Notice and comply with any legal obligations that may apply to your provision of the information to us.

How we may use your personal information

Where we have a lawful basis for doing so, we may process your personal information for various purposes, including:

• Services. Providing our services to you or an entity with which you are associated (including communications and reporting). This would include all of types of personal information described above.
• Operational and Compliance Support. Supporting our everyday operations, including meeting our legal and compliance obligations. Again, this would include all of types of personal information described above.
• Employment. Supporting our infrastructure and human resources needs, including hiring, employee payroll, employee benefits, labor law compliance and tax reporting and remittance. This would typically include the types of personal information described above under the headings Identification and Contact Information, Financial Information, Government Identifiers, Images, Background Information, Social Media, Demographic and Diversity Information, and Voluntary Disclosures.
• Business and Service Improvements. Managing and improving our services and business operations. This would typically include the types of personal information described above under the headings Social Media, Marketing Information, Technical Information, and Voluntary Disclosures.
• Marketing. Marketing of our services, such as by providing you with newsletters and other content. This would typically include the types of personal information described above under the headings Identification and Contact Information, Social Media, Marketing Information, Technical Information, and Voluntary Disclosures.
• Compliance. Complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities with jurisdiction over our business). This would typically include the types of personal information described above under the headings Identification and Contact Information, Financial Information, Government Identifiers, Images, Background Information, Technical Information and Voluntary Disclosures.

Your personal information will be processed in accordance with applicable privacy and data protection laws, rules and regulations. This may be with your consent, upon your instruction, or where we believe there is a lawful purpose for doing so.

Please note that where we require your personal information to satisfy a statutory or regulatory obligation or a contractual requirement, your failure to provide us with such information may result in us being unable to provide our services to you or to an entity with which you are associated. In addition, please be aware that if we have any suspicion of unlawful activity, we may submit personal information to relevant law enforcement agencies or supervisory authorities when required or permitted to do so.

How we may share your personal data

Our primary service is advising banks, broker-dealers, hedge funds, investment advisors and wealth managers on designing and implementing compliance programs designed to satisfy their various regulatory obligations. During this process, we may collect your personal information to the extent it is relevant to the compliance program we are engaged to address. While performing our services, we may work with third-party vendors and service providers that may provide software, hardware, data, infrastructure, security and consulting needed to implement and operate a particular compliance program and we may communicate your personal information to these third parties.

If you seek or obtain employment with CMC, we may disclose your personal information to various vendors and service providers with whom we work, including those providing background checks, payroll processing, tax reporting, employee benefits, accounting and legal services, cloud storage and backup, human resources services, and security and fraud prevention services.  We may also provide your personal information to governmental, regulatory and self-regulatory agencies when necessary or appropriate.

If you provide goods or services to CMC (or when an entity with which you are associated does so), we may also disclose your personal information to various vendors and service providers with whom we work, including those providing background checks, payment processing, tax reporting, accounting and legal services, cloud storage and backup, and security and fraud prevention services.

Although CMC may use your personal information to provide you with our own newsletters, updates and other marketing materials, and may disclose your personal information to third parties that assist us in these efforts, CMC will never sell or disclose your personal information to third-party advertisers.

In the event CMC enters into a sale, merger or other transaction that results in the transfer of all or part of our business or assets to a third party, CMC may disclose, sell, assign or transfer your personal information to such third party.

We may also disclose your personal information in response to court orders and inquiries from law enforcement and regulatory and self-regulatory agencies.

Finally, we will also disclose your personal information if you direct us to do so.

Our use of Cookies

This Site uses cookie technology. Please see our Cookie Notice for more information regarding how we use cookies and how you can disable or manage their use.

Retention periods and security measures

We will not retain personal information for longer than is necessary in relation to the purpose for which it is collected, subject to applicable data protection laws. How long we will hold your personal information will be determined based on: (a) the purpose of which we are using it; and (b) the legal and regulatory obligations that apply to us (these may set a minimum period during which we must retain your personal information). This will typically be no longer than seven years, unless we have a legitimate need to keep your information for a longer period, such as a need to meet regulatory or legal requirements, help detect or prevent fraud and financial crimes, deal with disputes, or comply with applicable laws and regulations. From time to time, we will review the purpose for which personal information has been collected and decide whether to retain it. As noted below under the heading “Your rights”, under certain circumstances you may have the right to require us to erase your personal information.

To protect your personal information from unauthorized access and use, we apply organizational and technical security measures that comply with applicable data protection laws and regulations. These measures include computer safeguards and secured files and buildings. Please be aware, however, that any email or other electronic transmission that is sent through the internet cannot be completely protected against unauthorized interception. We will notify you of any material data breaches that may affect your personal information as soon as we determine it is reasonable prudent to do so after learning of any such breach.

International transfers

Because our clients often operate internationally, we may transfer your personal information outside your home country, when doing so is necessary for the performance of our services. This may include places that may not have the same level of data protection as that afforded in the United States. In such cases, we will take appropriate measures to ensure your personal information is handled as described in this Privacy Notice.

Your rights

As a resident of certain states, you may have the following rights in relation to our processing of your personal information:

• Portability: The right to request a copy of your personal information in a commonly used electronic format and the right to be informed about how we use it and share it. You can also request that we transmit the personal information to someone else where it is technically possible.
• Knowledge and Access: The right to know more about the personal information that we have collected about you and disclosed in the preceding 12 months. You may be able to access your personal information, receive details on its collection, and the purpose for such collection.
• Deletion: The right to request that we delete personal information where we do not have a legal or regulatory obligation or other valid reason to continue to retain it.
• Opt-out: CMC does not sell your personal information for marketing or other similar purposes. However, you may opt-out of having your personal information shared with certain vendors that we use for providing insights about user interactions with our Site (such as Google Analytics) and for delivering our newsletters, emails and other content and to you. You also have the right to unsubscribe from our newsletters, emails or other similar content.
• Correction: The right to request that we update or correct any personal information that you believe is incorrect or incomplete.
• Restriction: The right to request that we restrict the way in which we process your personal information.
• Automated decision making: We do not make any decisions about you based solely on automated processing.

We will review and verify any requests you make to exercise your rights (to protect your personal information), and will act on these requests fairly and in accordance with applicable privacy and data protection laws and regulations. Certain states provide the right to appeal a denial of a request.

You will not be disadvantaged in any way by exercising your rights regarding your personal information.

Who to contact about this Privacy Notice

If you have any questions about our Privacy Notice or wish to exercise any of your rights described above, please contact us in writing at:

By E-mail to: privacy@cadienmayersconsulting.com 

By Mail to:

Cadien Mayers Consulting LLC

814 Undercliff Ave

Edgewater, NJ 07020

Attn.: Privacy

Changes to this Privacy Notice

We may revise this Privacy Notice from time to time. If we decide to change our Privacy Notice, we will post the revised Policy Notice on the Site. As we may make changes at any time without notifying you, we suggest that you periodically consult this Privacy Notice. Please note that our rights to use personal information will be based on the Privacy Notice in effect at the time the information is used.