Ducera Partners LLC (“Company,” “Ducera,” “we,” or “us”) respects individual privacy and wants you to be familiar with how we collect, use, disclose, and retain information. This Privacy Policy describes our practices in connection with the Personal Information we collect about you via our Friends of the Firm and Ducera Partners Alumni Network (the “Network”). “Personal Information” is information that identifies you as an individual or relates to an identifiable individual.
This Privacy Policy does not apply to the Personal Information we collect about our business contacts, employees, or job applicants.
Notice at Collection
The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business purposes, including within the 12 months preceding the date this Privacy Policy was last updated.
| Categories of Personal Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes | Processing Purposes (See the chart below for a detailed description of each Processing Purpose) |
Identifiers, such as: - Contact information: name, alias, title, date of birth, postal address, email address, telephone number
- Unique personal identifiers: account name, online identifiers
| Affiliates, for the purposes outlined in this Privacy Policy; service providers who provide services such as such as website hosting, data analysis, payment processing, fraud prevention, information technology, and customer service; legal authorities, such as in response to a request from law enforcement; other parties in litigation
| - Provide our Network
Operations and general business purposes - Marketing
- Improve and develop new products and services
- Fraud prevention and security
- Legal and compliance
|
Personal information as defined in the California customer records law, such as: - Contact Information: name, address, telephone number
- Education and Employment Information
|
| Protected Class Information, such as gender, gender identity or expression, primary language, marital status |
| Internet or network activity information, such as access and usage of the Network website, browsing history, search history, interactions with our online properties or ads, information from cookies |
| Geolocation Data, such as device location and approximate location derived from IP address |
| Audio/Video Data. Audio, electronic, visual, and similar information, such as photographs |
| Education Information such as undergraduate school and year, graduate school and year |
| Employment Information. Professional or employment-related information, such as employer name, title, address, phone, other employers, Ducera employment date range, professional expertise, industries, secondary languages spoken, areas of interest |
Sensitive Personal Information - Account login information: Account log-in, credentials allowing access to an account
|
We may also process your Personal Information or disclose it to a third party in the event of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Purposes for the Collection, Processing, or Other Disclosure of Personal Information
We collect, process, or otherwise disclose Personal Information to operate, manage, and maintain our business, and to provide our products and services, including to:
| Purpose | Examples of Processing Activities |
| Provide our Network | Provide the Network, such as arranging access to the Network and verifying your information.
Disclose Personal Information to our service providers and processors so that they can use it on our behalf to provide services to us, and to manage and oversee our service providers and processors.
Administer customer support services to facilitate and address inquiries, requests, comments and complaints about any of our Network services (such as in person, via phone, or email), and to send you documents or product information you request or assist you in using the Network.
Send you important information regarding our relationship with you, our Network, any changes to our terms, conditions, policies and procedures, and/or other administrative information.
|
| Operations and general business purposes | Administer the Network websites (including troubleshooting and diagnostic testing, conducting performance analyses of our systems and services, testing new system features to evaluate their impact, performing system/log maintenance, technical support, and system debugging, and hosting data); facilitate mergers, acquisitions, and other reorganizations and restructurings of our business (including prospective transactions); aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. |
| Marketing | Subject to your communications preferences, send you promotional information about our Services and other news about our Company.
|
| Improve and develop new products and Services | Conduct data analysis, for example, monitoring and analyzing usage of services and using data analytics to improve the efficiency of our services; develop new products and services; consider ways for enhancing, improving, repairing, maintaining, or modifying our products and Services; identify usage trends, for example, understanding which parts of our services are of most interest to users; undertake quality and safety assurance measures. |
| Fraud prevention and security | Conduct audits; verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements; monitor for and prevent fraud; promote security, including system security and on-site security of our premises. |
| Legal and compliance | Fulfil our legal and compliance-related obligations, including complying with applicable laws; comply with legal processes; respond to requests from public and government authorities; meet national security or law enforcement requirements.
Enforce our terms and conditions; protect our operations; protect the rights, privacy, or property of the Company; pursue available legal remedies, defend claims, and limit damages that the Company may sustain.
|
Collection, Processing, and Disclosure of Sensitive Personal Information
Subject to your consent where required by applicable law, we collect, process, and disclose Sensitive Personal Information for purposes of: providing services as requested; ensuring safety, security, and integrity; countering wrongful or unlawful actions; performing services for our business, including maintaining and servicing accounts, providing user service, verifying user information; and other collection and processing that is not for the purpose of inferring characteristics about an individual.
We do not use Sensitive Personal Information beyond these purposes.
Retention Period
We retain each category of Personal Information, including Sensitive Personal Information, for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide services to you, for example, for as long as you have a Network account, and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
- Whether there is a legal obligation to which we are subject; and
- Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations.
Sources of Personal Information
We collect Personal Information from you and from affiliates, trusted third-party service providers, publicly available databases, and joint marketing partners.
Other Information
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
- Browser and device information
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you
- Aggregated information
We and our third party service providers may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version. We use this information to ensure that the Network websites function properly.
- Using cookies: Please see our Cookies and Similar Technologies Policy for details about the cookies and similar tracking technologies we use. Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Network websites, pages visited, language preferences and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience while using the Network websites. We also gather statistical information about use of the Network websites in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions about them. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept these cookies, you may experience some inconvenience in your use of the Network websites.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Network services to, among other things, track the actions of users, measure the success of our marketing campaigns and compile statistics about usage of the Network websites.
We do not currently respond to browser do-not-track signals.
- IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Network websites, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels of the Network websites, helping diagnose server problems, and administering the Network websites.
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.
We may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
Third Party Services
This Privacy Policy 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 site or service to which the Network websites link. The inclusion of a link on the Network websites does not imply endorsement of the linked site or service by us or by our affiliates.
Security
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.
Rights and Requests
You may, subject to applicable law, make the following requests:
- To know whether we process your Personal Information, and to access such Personal Information, for example:
- The categories of Personal Information we have collected and processed about you and the categories of sources from which we collected such Personal Information;
- The business or commercial purpose for collecting Personal Information about you; and
- The categories of Personal Information about you that we have disclosed, and the third parties to whom we disclosed such Personal Information.
- To correct inaccuracies in your Personal Information.
- To have your Personal Information deleted.
- To receive the specific pieces of your Personal Information, including a copy of your Personal Information in a portable format.
You have the right not to be unlawfully discriminated against for exercising your privacy rights.
To make a request under #1-4, above, please contact us at info@ducerapartners.com or (212) 671-9700. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may decline to honor your request where a law is inapplicable or an exception applies. We may need to request some Personal Information about you in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.
We do not sell Personal Information (including Sensitive Personal Information), and we do not “share” or otherwise process Personal Information (including Sensitive Personal Information) for purposes of cross-context behavioral or targeted advertising, as defined under applicable law. We have not engaged in such activities in the 12 months preceding the date this Privacy Policy was last updated.
Without limiting the foregoing, we do not sell or “share” Personal Information (including Sensitive Personal Information) of minors under 16 years of age.
Appeal Process
If we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us via info@ducerapartners.com or (212) 671-9700.
Authorized Agents
If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Rights and Requests.” We will process the agent’s request consistent with applicable law. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Rights and Requests” or confirm that you provided the agent permission to submit the request.
Use of Services by Minors
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.
Cross-Border Transfer
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
Changes to this Privacy Policy
We may change or update this Privacy Policy from time to time. When we do, we will post the revised Privacy Policy on this page with a new “Last Updated” date.
Contact Us
Ducera Partners LLC, located at 11 Times Square, 36th Floor, New York, New York 10036, is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at info@ducerapartners.com, or:
Ducera Partners
11 Times Square
36th Floor
New York, New York 10036
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
Additional Information Regarding the EEAYou may lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at
here.
