Effective date: May 2018
Introduction DiSanto Priest & Co. (“DiSanto, Priest” or “we”) is a New England regional professional services firm which provides assurance, tax, advisory, and consulting services to private and publicly-traded businesses, as well as to individuals (the “Services”). This Privacy Statement outlines our general policy and practices for protecting personal information that we collect through our Web site at www.disantopriest.com (“Site”) that we operate and in connection with the provision of the Services. This Privacy Statement explains the types of information we gather through our Site and in connection with our Services, how we use that information, and the choices individuals may exercise regarding our use of, and their ability to correct that information. By submitting personal information to us, you are consenting to use of your personal information (including any disclosures, processing, and transfers of your information to third parties by DiSanto Priest) in accordance with this Privacy Statement. Any consent you provide is entirely voluntary. If you do not accept this Privacy Statement, then you should not submit any personal information to DiSanto Priest through our Site or Services.
Notice, Choice and Use In order to use our Site, you do not need to send us any personal information. You may voluntarily provide us with personal information, such as your name and contact information, by subscribing to publications, registering for events (e.g., webcasts, or seminars) or by submitting requests through our “Get-In-Touch” fill forms. We may use the personal information you submit through the Site to respond to your requests (e.g. send you information about DiSanto Priest’s services or events), send you administrative information, our periodic News Letters, send you information about our services, and for our internal business purposes. If you no longer wish to receive promotional communications from us, you may at any time request that we discontinue sending you such materials by contacting us using the contact information listed below.
We do not seek sensitive personal information on our Site except where we are required to do so as part of the recruitment process. If you choose to apply for a job through our Site, we may collect information such as name, address and other contact information, work and educational experience, licenses and certifications, and other personal information. Your decision to submit such information is entirely voluntary. We may use this information to process and evaluate your application for employment and to communicate with you about employment opportunities. We may also retain and use this information to identify and communicate with you about future potential employment opportunities with us. If we elect to make an offer of employment, this information may become part of the employee file and may be used for other employment and work-related purposes.
In connection with providing Services, DiSanto Priest enters into contracts with its clients that describe the purpose for which information (including personal information) is collected and used. Companies that engage DiSanto Priest are responsible for obtaining, as required pursuant to law or regulation, consents from parties that provided the company with their personal information, which will be transferred to and used by DiSanto Priest to perform the Services requested. Individuals that engage DiSanto Priest will be asked to consent to provide their personal information to us to perform the Services requested.
Our legal basis for processing any personal information provided to us is either that: (i) you have expressly consented to the practices described in this Privacy Statement by voluntarily providing your personal information to DiSanto Priest, or (ii) such processing is necessary for the performance of a contract where DiSanto Priest has been engaged to provide Services.
We retain personal information for only so long as necessary for the intended purpose for which it was collected, unless a longer retention period is required or permitted by law or by our document retention policies based on professional standards and best practices. We may also store your name and email address in a customer relationship management tool and use it to manage our relationship with you and/or your company.
Cookies and Similar Technologies As is the case with many commercial Web sites, DiSanto Priest automatically logs certain information about user access to the Site, which may include a user’s internet protocol address, browser type, internet service provider, referring/exit pages, operating system, as well as date and time stamps. We also use “cookies” which are small data files stored on a user’s computer to enhance your on-line experience when visiting our Sites. The use of “cookies” is common practice for most Web sites; however, most Web browsers include settings that allow users to decline cookies.
Do Not Track Signals Some Web browsers incorporate a “do-not-track” or similar feature that signals to Web sites with which the browser communicates that a visitor does not want to have his or her online activity tracked. As of the effective date of this Privacy Statement, not all browsers offer a “do-not-track” option and “do-not-track” signals are not yet uniform. For this reason, DiSanto Priest does not currently respond to “do-not-track” signals.
Disclosures and Transfers DiSanto Priest will not disclose an individual’s personal information to third parties, except as set forth in this Privacy Statement, when we have permission to make the disclosure, or as necessary to fulfill the purpose for which the information was submitted. We also may use or disclose personal information as we believe to be necessary or appropriate (a) under applicable law (including to meet a national security or law enforcement requirement), (b) to comply with legal process or professional standards, (c) to protect our rights, privacy, safety or property and/or those of our affiliates or clients; or (d) in a merger, acquisition or asset sale.
DiSanto Priest may use third-party service providers to provide administrative or operational support to DiSanto Priest. Such entities may be located within or outside the United States and, depending upon the services, they may have access to personal information in connection with their services. We require all such service providers to protect the information we entrust to them and to use such information only as necessary to provide services to us.
Additionally, DiSanto Priest may disclose and transfer personal information to resource service providers. The transfers described above may result in data passing from one jurisdiction to another, including to and from the United States, and possibly other countries outside of the European Economic Area, some of which may not have been deemed by the European Commission to ensure an adequate level of protection for personal information.
Accordingly, the level of safeguards and legal protections provided in such other non-European countries may not be as stringent as those under European data protection standards or the privacy laws of some other countries, possibly including your home jurisdiction.
Third-Party Sites This Privacy Statement does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any Web site or service to which the Site links. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us or by our affiliates.
Data Security The security of your personal information is important to us. We seek to use reasonable physical (e.g. key card office entry, locking doors), technical (e.g. password protection, network firewalls, laptop encryption, authentication mechanisms), and administrative safeguards (e.g. confidentiality agreements, training, procedures that limit access to and use of data) to protect the information we process. However, no method of transferring data over the Internet or storing electronic data is completely secure. Therefore, while we strive to use reasonable and appropriate means to protect your personal information, we cannot guarantee absolute security. Users should take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission’s website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.
Data Integrity We process personal information only in ways compatible with the purpose for which it was collected, as subsequently authorized by the individual, or as otherwise permitted by applicable law. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.
Access and Correction If an individual becomes aware that information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may contact us using the contact information below. We will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate. We may limit or deny access to personal information where providing such access would be unreasonably burdensome or inappropriate under the circumstances. All requests to access or change personal information will be handled in accordance with applicable legal requirements.
If you are a resident of the European Union, you may have certain rights under European data protection law with respect to your personal information, including the right to request access to, correct, amend, delete, limit the use of, or withdraw your consent for the processing of your personal information.
To request deletion of, access to or to make changes to information, or to otherwise exercise any of your rights, please send us an email at firstname.lastname@example.org. DiSanto Priest will take steps to address your request to the extent consistent with and permitted by laws, regulations and professional standards applicable to DiSanto Priest and our own internal policies. If you are a client and request that we delete or limit the use of your personal information required to perform our Services, we may not be able to complete our engagement.
Enforcement and Dispute Resolution We will investigate and attempt to resolve complaints and disputes regarding our use and disclosure of personal information in accordance with this Privacy Statement. We encourage interested persons to raise any concerns with us using the contact information below. Any employee who we determine is in violation of our privacy policies will be subject to disciplinary process.
Privacy Statement Changes DiSanto Priest reserves the right to amend or modify this Privacy Statement from time to time. We will post any revised Privacy Statement on this Site, or a similar Web site that replaces this Site. By continuing to use any of our Sites, you agree that the terms of this Privacy Statement as of the effective date will apply to information previously collected or collected in the future as permitted by law.
Minors This Site is not designed for or directed at persons 18 years of age or younger, and we do not intentionally collect information from anyone under the age of 18 through this Site.
How to Contact Us Questions, comments or concerns about DiSanto, Priest & Co.’s Privacy Statement, or data collection and processing practices can be e-mailed to email@example.com, or by writing to us using the contact details below:
Corporate Mailing Address:
DiSanto, Priest & Co.
Attention: Office Managing Partner
117 Metro Center Boulevard, Suite 3000
Warwick, RI 02886