Last Updated: January 3, 2023
EBG Advisors, Inc. (“EBG Advisors,” “EBGA,” “ebgadvisors.com,” “We,” or “Us”) takes your privacy very seriously. This Privacy Policy describes our collection and protection of the information you provide to us during visits to our website www.ebgadvisors.com (the “Site”), our mobile apps, attendance at our events and similar activities and activities related to your use of our legal and professional services. (Collectively, our “Services”).
We also have a career page on the Site. If you connect with us on the career page or otherwise contact us about employment, our collection, use, and disclosure of your personal data will be governed by a separate privacy policy governing employment and recruiting data.
If you are a California resident, please review Section 16, the California Residents section, below for additional information on how we collect, use, and disclose your Personal Information and the rights you have under the California Privacy Rights Act.
2. Personal Data EBG Advisors Collects About You
When you use our Site or our Services EBG Advisors may collect the following information from you (collectively referred to as “Personal Data”):
- Name, company name, and/or title
- Contact information, such as email address, phone number, mailing address
- Preferences in receiving newsletters or other marketing materials from us
- Information you provide to us before or when attending an event, such as dietary restrictions or preferences, and other event-related information
- Information that responds to a request you make to us, or as part of a communication to us
- Information related to the Services we provide to you
- Information you may provide to us in email or voice mails
- Educational information such as your academic credentials or degrees
- Information about the device you use to access our Site such as hardware model, unique device identifiers, operating system version, browser type, and device settings and other information related to how your device is interacting with our Site
- Usage data such as errors, system activity, and dates and times of your activity and the features you access on our Site.
We also use cookies, web beacons, HTML local storage, and other similar technology to distinguish you from other visitors of our Site and remember your preferences. This helps EBG Advisors provide you with a good experience when you visit Our Site and allows Us to improve your experience while visiting our Site. For more information on cookies, please see Our Cookie Policy at Section 6.
3. How EBG Advisors Collects Information Your Personal Data
We collect Personal Data directly from you when you access our Site or Services. For example, when you subscribe to receive event invitations or to attend a webinar or if you otherwise contact us. When you visit our Site, we may automatically collect Device, IP, and Usage Data. Some Usage Data is collected by using cookies. Please see Our Cookie Policy for more information. We receive Device and Usage Data about you from analytics providers such as Google Analytics. We may also receive your Personal Data from other parties, such as clients, professional advisors, public resources, governmental authorities, and our service providers.
4. How EBG Advisors Uses Your Personal Data
We use the Personal Data that we collect in order to conduct our business. Generally we use Personal Data to:
- Provide you with Services and information that you request
- Administer the Site and our relationship with you
- Secure the quality and develop the Site
- Respond to inquiries or requests from you
- Provide you with newsletters and other direct marketing materials
- To exercise our legal and ethical rights and obligations
- For our business operations
5. How EBG Advisors Discloses Your Personal Data
We may disclose your Personal Data in the following ways:
- To our service providers that we use to support and provide our business
- To our successors, if to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, to the extent and in the way as prescribed by applicable law;
- Our professional advisors;
- Government and regulatory authorities;
- With others with whom you ask us to share your Personal Data; or
- If we believe, in good faith, disclosure is appropriate or necessary to:
- take precautions against liability;
- protect ourselves or others from fraudulent, abusive, or unlawful uses or activity;
- investigate and defend ourselves against any third-party claims or allegations;
- protect the security or integrity of the Site; or
- protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
Aggregate information is information that describes the habits, usage patterns, and/or demographics of users as a group but does not reveal the identity of particular users. We may use aggregate information to understand the needs of individuals using the Site.
6. Cookies
A "cookie" is a small data file sent from a website and stored on your device to identify your device in the future and allow for an enhanced personalized user experience. A "session cookie" disappears after you close your web browser or may expire after a fixed period of time. A "persistent cookie" remains after you close your web browser and may be accessed every time you use our Site. We may use both session and persistent cookies. You should consult your web browser to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may not be able to use certain features of our Site. There may be other tracking technologies now and later devised and used by us in connection with the Site. Further, third parties may use tracking technologies with our Site. We do not control those tracking technologies, and we are not responsible for them. However, you consent to potentially encountering third-party tracking technologies in connection with your use of the Site and accept that this Privacy Policy does not apply to the tracking technologies or practices of such third parties. In such cases, you must check the third-party websites to confirm how your information is collected and used. You can change your preferences for cookies on our Sites and opt out of most third-party cookies (other than those that are “strictly necessary”) through the Cookie Settings button.
Our Site does not support Do Not Track requests at this time. Do Not Track (DNT) is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit https://www.eff.org/issues/do-not-track.
7. Co-sponsored Events
We periodically post information or provide you with opportunities to attend programs and events that are sponsored by or co-sponsored by other firms or organizations. Should you choose to register electronically for any of these events or submit your information to these third parties, EBG Advisors will have no control over the third-party sponsors' use of this information, and this Privacy Policy will not apply.
8. Children’s Information
EBG Advisors does not knowingly collect identifiable information from anyone under the age of 18 through the Site. If you are under 18, please do not give Us any information that would allow Us to identify you. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide identifying information through any website without their permission. Please contact Us if you discover an individual under 18 has submitted their information contrary to this Privacy Policy and we will ensure that information is properly removed.
9. How We Protect Your Personal Data
We employ security measures to prevent authorized access or use of your Personal Data. However, we cannot guarantee that criminals or others acting unlawfully will not succeed in efforts to undermine our security measures.
10. Third-Party Links
We may provide links to websites of other organizations or companies that may offer materials and services as well as links to other sites. Please note that we do not accept any responsibility or liability for personal data that may be collected through these websites or services. We recommend that you read their privacy policies before you submit any personal data to them or use their services.
11. Your Rights
You have the right to:
- request access to and information about your Personal Data that is being processed by us,
- request correction of your personal data if it is inaccurate or incomplete, including to provide additional data if relevant information is missing,
- request erasure of your Personal Data,
- object to our processing of your Personal Data under certain circumstances,
- request that we restrict the processing of all or some of your Personal Data in certain situations and to ask us not to send you any direct marketing, and
- request a copy of your Personal Data in a structured, commonly used, and machine readable format and that we transfer your personal data to another controller.
EBG Advisors may deny your request, including but not limited to requests to delete your information, if such information is necessary for us or our service providers to:
- Comply with a legal or ethical obligation;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
12. Changes to the Privacy Policy
We reserve the right to change this Privacy Policy, and when updated, the effective date of the new version will be at the top of this policy.
13. Applicable Law and Jurisdiction
Our Site and Services are offered and operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the Site, or when using our Services, you consent to this transfer and our use of such information in accordance with this Privacy Policy.
14. Notice of Electronic Disclosure of Protected Health Information
In representing some clients, we may receive or create documents or other communications containing protected health information (PHI) related to individuals served by our clients. EBG Advisors will only use and disclose this PHI as necessary to perform our services for those clients, and only as permitted or required by law.
15. Contact
If you have any questions, comments, or requests regarding this Privacy Policy or our collection, use, or disclosure of your information or if you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data we collect, please contact:
Email: privacy@ebgadvisors.com
Mail: Privacy Officer, EBG Advisors, 1227 25th Street NW, Suite 700, Washington, D.C. 20037; or
16. California Residents
This Section 15 provides California residents with information and rights required by the California Privacy Rights Act (“CPRA”). This Section applies only to individuals residing in the State of California who are considered “consumers” under the CPRA and from whom we collect “personal information” as described in the CPRA.
We retain your Personal Data for as long as necessary to achieve the purposes set out in this Privacy Policy and in accordance with our document retention policy. In some cases, we may be required to continue to maintain your Personal Data to comply with our legal and ethical obligations or for the establishment, exercise, or defense of legal claims.
The chart below provides a more detailed description of the Personal Data we may collect from you.
Categories | Examples |
A. Identifiers | Identifiers such as name, mailing addresses, email addresses, telephone numbers, contact information, financial information, and other similar identifiers. |
B. Protected Characteristics Under Applicable Law | Demographic data and other similar characteristics, such as gender, race, ethnic origin, marital status, disability, medical condition, and veteran or military status. We only collect this information when required by law to do so, or when you voluntarily provide it to us. |
C. Commercial Information | Records of any services or products you obtain from us. |
D. Internet or Other Electronic Network Activity | Information systems information, such as your browsing history, search history, and IP addresses of the devices connecting to EBG Advisors’ information systems, devices, accounts, and networks. |
E. Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information | Such as voice mail messages. |
F. Professional or Employment Related Information | Such as your work history, positions held, resumes, references, background checks (to the extent covered under the CPRA), qualifications, licenses, certifications, professional memberships, and financial and banking information. |
G. Educational Information | Such as your academic credentials, degrees, licenses, training and institutions attended. |
H. Personal Profile | We may accumulate your personal information related to your preferences, for example what newsletters you sign up to receive. |
A. Purpose of Collecting and Using Personal Data
We collect, use, and disclose the categories of your Personal Data for the following purposes:
- Provide you with Services and information that you request
- Administer the Site and our relationship with you
- Secure the quality and develop the Site
- Respond to inquiries or requests from you
- Provide you with newsletters and other direct marketing materials
- To exercise our legal and ethical rights and obligations
- For our business operations
We do not collect, use, or disclose sensitive personal information for the purposes of inferring characteristics.
B. Sources of Collection of Personal Data
EBG Advisors collects personal information from the following categories of sources:
● Service providers and contractors providing services on our behalf, such as benefits administrators. We require our service providers and contractors who we provide your personal information to in order to provide services to maintain the privacy and security of your personal information;
● Government agencies;
● EBG Advisors’ Internet and intranet networks and internal communications systems (e.g., EBG Advisors’ telephonic systems, electronic mail, and messaging platforms); and
● From other parties, such as clients, professional advisors, public resources, governmental authorities.
C. Release of Personal Data to Third Parties for Business or Legal Reasons
We only disclose your personal information to other organizations who are not our service providers or contractors (i.e., third parties) when we have a legitimate business or legal reason to do so or with your prior permission.
We do not (i) “share” your personal information with third parties for cross-contextual behavioral advertising purposes; or (ii) sell your personal information to third parties. We have not shared with or sold any categories of your personal information (A-H) to third parties in the last twelve (12) months.
In the last twelve (12) months, we have, or may, disclose the information collected in Categories A-G above to outside organizations or entities who are not service provider or contractors providing services on our behalf including to: state or federal governmental agencies or entities, self-regulatory organizations, among other third-parties, including but not limited to where required by law.
D. Your Rights
You have the right to request that we provide you with the Personal Data we collect, use, and disclose about you. You may “request to know”:
- the categories of personal information that EBG Advisors has collected about you;
- the categories of sources from which the personal information is collected;
- the business or commercial purpose for collecting your personal information;
- business purpose to third parties and the categories of third parties with whom EBG Advisors discloses your personal information; and
- the specific pieces of personal information that EBG Advisors has collected about you.
Your request may pertain to the Personal Data collected about you on or after January 1, 2022. If your request covers a time period beyond 12 months from the date of your request, EBG Advisors may deny your request as to that time period where it would be impossible for EBG Advisors to provide you with the information or involve disproportionate effort. EBG Advisors may deny your request to search for certain information under certain circumstances (e.g., where EBG Advisors retains the information solely for legal and compliance purposes and satisfies other statutory exemptions).
- You have the right under certain circumstances to receive specific pieces of your Personal Data in a format that is understandable, and to the extent technically feasible, in a structured, commonly used, machine readable format that allows you to transmit the information to another entity.
- You have the right to correct inaccurate Personal Data.
- You have the right to request deletion of personal information under certain circumstances. For example, we may not be required to delete personal information if we need to retain the information to comply with a legal obligation or where the information is stored on an archived or backup system (in which case your request may be delayed until such time (if any) as the information is restored to an active system).
- You have the right to know what information is sold or shared to third parties, and to whom and to opt out of sale or sharing (as noted above we do not sell or share your Personal Data).
- You have the right not to receive discriminatory or retaliatory treatment for the exercise of any of these rights. We will not discriminate or retaliate against you because you have exercised your rights.
You may submit requests concerning any of your rights by contacting EBG Advisors by email at privacy@ebgadvisors.com or by telephone at 1-877-251-2156. EBG Advisors will use reasonable methods for verifying that the person making a request to know, data portability, request to correct, or a request to delete is the individual about whom EBG Advisors has collected personal information. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Please provide the method of delivery in addition to the address with such request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.