Hockema Whalen Myers Associates
Effective Date: February 8, 2019
Last Updated: February 8, 2019
Hockema Whalen Myers Associates, Inc. (“HWMA,” “we,” “our,” or “us”), respects your privacy and is committed to maintaining and using your information responsibly. Accordingly, HWMA has developed this Privacy Statement in order for you to understand how HWMA collects, uses, discloses, and otherwise processes your personal information. This Privacy Statement describes how we manage the personal information that we collect at http://www.hockema.com (the ”Site”) as well as through other electronic means. This Privacy Statement covers your use of the Site, whether you simply access and browse the Site, enter information into the Site, and/or use any services or other features that we may offer through the Site. The foregoing activities are collectively referred to as your “use of the Site” (or a similar phrase) or the “Activities”.
PLEASE READ this Privacy Statement before you use the Site. Your use of the Site signifies to us that you have read and understand all of the terms of this Privacy Statement.
This Privacy Statement explains:
- What personal information we collect about you in the course of your engagement with the Activities, why we collect it, who it goes to and how long we keep it;
- How we use your personal information;
- How we protect your personal information; and
- Your legal rights in respect to your personal information, including how to access and update the information we hold about you.
Please note that some of the provisions herein will only apply if you are based in the EU.
The relevant sections of the Privacy Statement are listed below:
- About us
- What information do we collect about you?
- Why do we collect your personal information and on what grounds?
- Marketing communications
- Who do we share your information with?
- Will my information be sent abroad?
- How long do you keep my personal information?
- Your rights in respect to your personal information
- Cookies and other technologies
- Third party links on the Site
- Children’s Privacy
- Changes to this Privacy Statement
- Contact us
For the purposes of applicable data protection laws, Hockema Whalen Myers Associates, Inc., with its principal address at 5306 Ballard Avenue NW, Suite 204, Seattle, WA 98107 USA, is the controller of your information. This means that we are the primary entity who decides the purposes and means for dealing with your personal information.
What information do we collect about you?
We collect several types of information from and about our Site users and clients, including:
Personal information we collect directly from you, such as:
- Information provided to us if you contact us or make an inquiry, such as records and copies of your correspondence (including e-mail address(es)) if you contact us electronically, including through the Contact page of the Site.
- Information you provide to us directly, or indirectly when you connect or engage with us via social media platforms, including but not limited to LinkedIn.
Information received from other sources:
- Technical information in aggregate and anonymized form compiled from user visits to the Site including, but not limited to, information about user internet connections, the equipment used to access our Site, usage details, traffic data, location data, weblogs and other communication data.
- Publicly available information, such as information that may be provided by social media platforms when you connect or engage with us via social media.
You may also provide information to be published or displayed (hereinafter, “Posted“) on social media platforms that are visible to other Site users. Your Posted information which you publish may be displayed or transmitted to others at your own risk.
Why do we collect your personal information and on what grounds?
We will only use your personal information if we have a permitted lawful basis to do so. Generally we collect your personal information because it is necessary for:
- Performing our contract with you, or responding to your requests or inquiries, related to the Activities;
- The pursuit of our legitimate interests (as set out below); or
- Complying with our legal obligations.
We may also rely on your consent to use your personal information for:
- Keeping you informed of HWMA events, or other notification activities (see “Marketing Communications” below).
You have the right to withdraw your consent to these activities at any time, which will mean (unless another lawful basis applies to your personal information) that we will cease to process the affected information after consent is withdrawn. However, please note this may result in us being unable to provide you with certain features of the Site and/or Activities.
The primary purpose for which we collect information about you is to support the Activities you engage in. We also may collect information about you for the following purposes:
To perform our contract with you, or provide requested services to you
- To process your communications and to enable your use of the Site and the Activities
- For making the Activities available to you
- For continuity of service. This will be in accordance with our data retention practices (see “How long do you keep my personal information?” below)
- To provide you with information or services that you request from us
- For handling contacts, queries, complaints, or disputes
For our legitimate interests
- For market research and analytical purposes, e.g. to improve our understanding of contacts, inquiries, and event attendance, as applicable
- For improving existing Activities and developing new events and services
- For promoting, marketing, and advertising our Activities
- For protecting HWMA by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to HWMA
- To effectively handle any legal claims or regulatory enforcement actions taken against HWMA
- To generally run the Site and for internal operations, in order to provide you with an up to date, efficient, and reliable service
To comply with our legal obligations
- To help prevent fraudulent activity
- To comply with our legal and regulatory obligations (including under applicable data protection laws)
- For preventing, investigating and detecting crime, fraud or anti-social behavior and prosecuting offenders, including working with law enforcement agencies
- To fulfill our duties to our clients
HWMA does not use your personal information to send marketing communications. If at any time in the future HWMA intends to use your personal information to send marketing communications, it will do so only if HWMA already has an established business relationship with you, or otherwise with your consent. If you consent to receive marketing messages about our publications, events, and services, we will use your information to send you such messages by e-mail or by mail. You may revoke your consent at any time by contacting us or clicking on the “unsubscribe” link at the bottom of any marketing e-mail. Please note that you may not opt out of receiving messages that are transactional in nature rather than marketing messages (e.g., messages responding to inquiries you send us, or messages that are otherwise required to fulfill any services you ask us to perform for you).
Who do we share your information with?
We may disclose aggregated and anonymized non-personal information about our Site users. This is information that does not identify you or any individual.
We may disclose personal information that we collect or you provide as described in this Privacy Statement with the following third parties:
- Contractors / sub-contractor, service providers, or other third parties we use to support the Activities and our organization, or fulfill our obligations to you, and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- Third parties we may be required to disclose such personal information to in order to comply with our legal obligations or enforce our legal rights, e.g. any relevant authority or enforcement body and fraud protection and credit risk reduction agencies.
- Any potential or actual third party buyer of our operations and/or assets in the event that we sell, trade, or license ownership of any part of HWMA or its assets (including management of the Site).
Will my information be sent abroad?
As our Site and contacts database are based and hosted in the US, any personal information you submit to us will be held in the US. If you are based in the EU, this means that if you use our Site and if we collect your personal information through the means described in this Statement, your personal information will be processed by us in the United States, which (in the absence of an adequacy decision from the EU Commission or similar body from another country or territory) may not have the same level of data protection as in your country. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Statement.
How long do you keep my personal information?
We keep your information for as long as necessary to meet the relevant purposes for which we’ve collected your information, including for the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate length of time for holding your information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purpose for which we process your information and whether we can achieve those purposes through other means, along with the applicable legal requirements.
In some circumstances you can ask us to delete your information: see “Your rights in respect to your personal information” below for further information.
Your rights in respect to your personal information
The following section applies only if you are based in the EU.
In certain circumstances you have rights under data protection laws in relation to the personal information we hold about you. You can request to:
- Access information held about you.
- Rectify any incorrect or incomplete information we hold about you. It is both in our interest and yours that any personal information we hold about you is accurate, complete and current. If the information we hold about you is inaccurate in any way, please contact us to have your personal information corrected. You can update any incorrect contact information yourself by contacting us.
- Delete, restrict or remove the information we hold about you.
- Transfer the information we hold about you to another party.
- Object to any further processing of your information.
You can make all such requests via e-mail to email@example.com.
We will attempt to respond to your requests within one month and at no cost to you. Please note that in respect of all these rights, we reserve the right to:
- Refuse your request based on the exemptions set out in the applicable data protection laws,
- Require proof of your identity to process the request or request further information, and
- Charge you a reasonable administrative fee for any repetitive, manifestly unfounded, or excessive requests.
If we refuse your request to exercise these rights, we will provide reasons for our refusal and allow you to challenge our decision.
If you have any concerns about how we handle your information, please contact us. If you are not satisfied after we’ve tried to resolve your issue, you’ll be entitled to lodge a complaint with the data protection regulator for your country of residence.
Security of your information
We have put in place commercially reasonable security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we use reasonable means to limit access to your personal information to those employees, agents, contractors and other third parties who have a legitimate need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
Cookies and other Technologies
Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. You can obtain information about how to manage cookies in most commonly used browsers by following the linked browser names below or visiting www.aboutcookies.org. Please note that if you choose to erase or block your cookies, you will need to re-enter your original account credentials to gain access to certain parts of the Site.
Our use of Google Analytics
When you visit our Site, Google Analytics may automatically collect information from you through the use of Google’s analytics IDs, and Google provides some of this information to us in aggregate and anonymized form. An analytics ID is a specific string of numbers and letters (often called a “character string”) that is assigned to your computer or device but does not name you. The analytics ID allows Google to track usage data of a website, such as date and time of visit, duration of visit, website traffic patterns, “clickstreams,” other similar information about how visitors use a website, the type of web browser used, the operating system/platform a visitor use, IP address, the websites that referred or linked a user to a Website, and your CPU speed. Google Analytics provides information about the use of our Site to us in aggregate form (i.e., data about many Website users combined and not just about you). Some of this data might include the regional location or city of Site users, but again, this data will be in aggregate (and not individual) form. Google Analytics also provides data anonymization features which HWMA enables for its use of Google Analytics on the Site. We might use information we receive from Google Analytics to learn how users are using the Site in general, and to improve the Site. We will not receive the analytics ID assigned to your computer or device that you use to access and use the Site.
“Do Not Track”
The Site does not track your online activities over time and across third-party web sites or online services, and so does not respond to browser “Do Not Track” signals. As described below, the Site may contain links to other websites not owned or operated by HWMA. These websites may set cookies that obtain information about the fact that a web browser visited the Site from a certain IP address. These websites are not authorized to collect any other personal information from the Site unless you provide it to them directly.
Third Party Links on the Site
The Site may contain links to, or embedded code from, other websites not owned and operated by HWMA, for example, social media platforms such as LinkedIn and YouTube. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, or click on embedded content from another site, we encourage you to read the privacy notice of the third party site or content provider.
We do not knowingly collect personal information from children under the age of 16. If we learn that we are in possession of personal information collected from a child under the age of 16, we will immediately delete that information from our systems.
Changes to this Privacy Statement
We may from time to time review and amend this Privacy Statement to take into account changes in law, technology, and our operations. We will post any changes to this Privacy Statement on the Site from time to time and, where appropriate, notify you by e-mail. Please periodically review this Privacy Statement before using the Site as continued use of the Site shall indicate your acknowledgment and understanding of any changes. All personal information held by us will be governed by the most recent Privacy Statement posted on the Site.
If you have any queries relating to this privacy notice (including any requests to exercise your legal rights in respect to your information), you can contact us through the Contact page of our Site.