Data Privacy & Security

Privacy Policy

Read all about the type of data we collect and how we use it. Click here to read our Privacy Policy. 

Your Privacy Rights

Exercise your rights when it comes to your personal data. Click here to learn more or contact us.

 

Cookie Notice

Learn how we use cookies to improve your website experience.  Click here to read our Cookie Notice. 


Privacy Policy

Last Updated: June 30, 2020

I. INTRODUCTION

DeWinter Holdings, LLC and its affiliates (collectively, “we,” “our,” “us,” or “DeWinter Group”) help company employers (“Clients”) fulfill their accounting, finance, information technology, engineering, human resources and other functional professional staffing needs on an executive search, consulting and contract basis (“Services”). Our Services include helping individuals looking for job opportunities (“Candidates”). We also directly contract and employ top talent (“External Consultants”) who work exclusively for our Clients as part of our Services.

Your privacy is important to us. This Privacy Policy explains what information we may collect, use, share and disclose, both online and offline, about you when you use our websites, including www.dewintergroup.com and www.mariscg.com, or any DeWinter Group software or mobile app(s) (each a “Site”), and/or as we endeavor to provide any of our Services described in the foregoing paragraph. This Privacy Policy also applies to our marketing and recruitment activities.  There may be additional notices of our offline privacy practices that we may provide to you at or before the time we collect additional personal information.  Please read any such notices so you can understand how they apply to you.

This Privacy Policy also describes your rights regarding your personal information and how you can exercise them. By visiting or otherwise using our Site or using or participating in our Services, you are consenting to our handling of your information as set forth in this Privacy Policy. If you do not agree or wish to consent, please discontinue use of our Site, and do not use or participate in our provision of Services. 

If you have any questions relating to DeWinter Group’s privacy practices, please contact us at Privacy@dewintergroup.com.

II.PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT

A. Categories of individuals of whom we collect personal information.

Visitors: Individuals who visit or use our Site(s).

Candidates: Individuals who are seeking job opportunities or for whom DeWinter Group is actively looking for job opportunities, or who are otherwise a part of or relate to DeWinter Group’s efforts to provide its Services.

External Consultants: Contractors or employees of DeWinter Group who we place with, and who work for, our Clients.

Clients and vendors, service providers or other suppliers: Employees, representatives or agents of our Clients, as well as of our vendors, consultants, service providers, or other suppliers of goods and/or services, with whom we have a business relationship and/or who help us provide the Site(s) and/or the Service(s).

Not Intended for Children: DeWinter Group’s Site(s) and Services are not intended for, and DeWinter Group does not knowingly collect personal information of, children less than 16 years of age.

B. How we collect your personal information

Information you provide to us:  DeWinter Group and/or our agents, vendors, consultants, service providers or other suppliers who help us provide the Site(s) and/or the Services may collect information that you provide to us directly. For example, if you create an account or use the “Contact Us” page of www.mariscg.com, or if you apply for a job posted at https://jobs.lever.co/dewintergroup, we collect all of the information in the resume or curriculum vitae (CV) you upload, your name, email address, phone number, current employer name, gender, race, veteran status, links to your social media profiles and any other website you identify, as well as any other information you choose to provide. If you use the “Contact Us” page of www.dewintergroup.com, we collect your name and email address, whether you are an employer currently hiring or a job seeker searching for employment, and any other information you choose to provide to us. We may also collect information you provide to us by completing any other online forms, in emails or during phone calls when discussing job opportunities, requirements and so forth. 

Information automatically collected:  DeWinter Group and its third-party service providers may also collect certain information from Visitors to our Site(s) through the use of a variety of technologies, including cookies, to help improve Visitors’ online experience, to conduct website traffic and other data analytics, and to modify, improve and enhance our Site(s) and Services. Such information includes Internet Protocol (“IP”) addresses, Internet or other electronic network activity information, such as browsing history, search history, and other information regarding your interaction with an Internet website, application, or advertisement. For more information about the cookies we use, please see our Cookie Notice section of this Privacy Policy.

Information we collect from other sources: We may acquire or receive information about you from vendors, consultants or service providers with whom we have a business relationship, and who we use to help us provide our Services, such as providers of background checks, professional databases, etc. We collect information you submit to your public social network profiles such as LinkedIn, and other job board-type websites such as Zoom Info, Monster, Dice, Indeed and Crunchbase. Third-party data collection, storage and sharing, or other activities, are subject to those third parties’ policies and practices. DeWinter Group makes no representations regarding, and is not responsible or liable for, the accuracy of the information provided by third parties or for those third parties’ policies or practices. We may combine such third-party data with other information we acquire or receive from or about you in order to provide our Services.

C. Personal information we collect and our business purposes for doing so

Categories of Personal Information Our Business Purposes
Identifiers, including name, alias, postal address, email address, telephone number and other contact information, information of professional and personal references and referral sources, emergency contact information, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number and other similar identifiers
  • To manage, administer and otherwise provide the DeWinter Group Services
  • To complete transactions, fulfill terms or obligations, and otherwise perform DeWinter Group Services
  • To identify and contact Candidates for job opportunities with Clients seeking talent
  • To help Candidates identify strengths and preferences for better job placement
  • To match job opportunities, including those of Clients seeking talent, to Candidates
  • To match Candidates to job opportunities
  • To meet legal obligations as an employer or potential employer, and
  • to assist our Clients in doing so
  • To contact identified person(s) in case of an emergency
  • To notify you of changes to our Site(s), our Services, or our policies and practices
  • To respond to your inquiries
  • To personalize our Site(s) to Visitors
  • To verify the identity of consumers or their Authorized Agents who submit requests relating to their personal information
  • To send you emails, mail, messages and other communications about DeWinter Group for marketing, advertising and other promotional purposes
  • To deidentify, aggregate and/or anonymize data for statistical analysis purposes
  • To investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to physical safety of any person, and/or violations of DeWinter Group policies, procedures and/or contracts
  • To comply with applicable laws and legal requirements, such as court orders, subpoenas, and search warrants, and cooperate with regulatory agencies and law enforcement
  • To establish or exercise legal rights and/or defend against legal claims of DeWinter Group, of its Clients, and of others for whom DeWinter Group has a legal duty to do so
Professional or employment-related information, and educational information, including information on your resume or CV, employment history, education history, certifications, languages, security clearance information, work authorization, past and expected compensation, and other work-related information
  • Same as above
Inferences drawn from any other personal information, including assessment of aptitudes, abilities and preferences
  • Same as above
Audio, electronic, visual or similar information, included voicemail messages, phone and/or video interviews, recorded phone calls, etc.
  • Same as above
Characteristics of protected classes, including race, nationality, ethnic origin, gender, gender identity, gender expression, age, disability status, military and veteran status, and other protected classifications under California and federal law
  • Same as above
  • For purposes of equal opportunity or affirmative action programs, as required or permitted by law
Commercial information, including records of personal property, and purchasing or consuming histories or tendencies
  • To evaluate our Site(s) and Services
  • To modify, improve and enhance our Site(s) and Services

Internet or other electronic network activity and geolocation data, including Internet Protocol (IP) address, browsing history, search history, interaction with websites, applications or advertisements 

  • To protect DeWinter Group’s Site(s) and Services
  • To modify, improve and enhance DeWinter Group’s Site(s) and Services
  • To analyze visits and activity on our Site(s)
  • To promote and market DeWinter Group and its Site(s) and Services.
  • For more information about our use of cookies and online tracking, please see our Cookie Notice
  • To detect security incidents, protect against malware, illegal activity, and/or pursue those responsible
  • Identify and repair errors that impair functionality

 

III. When, to whom and why we share this information 

DeWinter Group does not sell your personal information, and it has not sold any personal information in the preceding 12 months.

We share or disclose your personal information as follows:

  • To perform our Services:  If you are a Candidate or prospective Candidate, we may share your personal information with Clients and other employers looking for talent, for the purpose of providing our Services, e.g. looking for job opportunities, conducting executive searches, recruiting, hiring and/or filling job positions on a consulting or contract basis to meet our Clients’ accounting, finance and IT professional staffing needs.
  • Vendors, consultants and other service providers: We use vendors, consultants and other service providers to assist us in providing our Site(s) and Services, and it may be necessary for us to provide them with access to  your personal information, e.g., vendor, consultants and service providers who provide IT support, who provide background checks, and who provide online software solutions as part of our Services, such as the online platform for Candidates to apply for job opportunities.
  • In compliance with laws, at your consent or direction, and to protect rights, property and safety: We may preserve and disclose your information if we believe doing so is legally required or appropriate: (i) to comply with applicable laws and regulations, law enforcement or national security requests and legal process, such as a court orders or subpoenas; (ii) in response to your consent or at your direction to disclose the information; (iii) to protect your, our, or another’s rights, property, or safety; or (iv) to enforce our policies or contracts.
  • Merger, Sale, or Other Asset Transfers:  If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be shared as part of such a transaction as permitted by law and/or contract.
  • With your consent:  We may share or disclose your personal information for other purposes per your request or with your consent.
  • Note re our Clients’ own policies and procedures:  If you are or have been contracted or employed by a Client as a result of our Services, DeWinter Group’s Client will process your personal information in accordance with its own policies and procedures.

IV. California Privacy Rights 

If you are a resident of California, effective January 1, 2020, you have rights with respect to your personal information under the California Consumer Privacy Act (“CCPA”), as follows:

  • Right to be informed:  You have the right to be informed of the categories of personal information collected about you, the sources from which your personal information was collected, and the business or commercial purposes for which your information is used, disclose or sold, as well as the categories of third parties to whom your information is disclosed or sold.
  • Right of access and to obtain a copy:  You have the right to request access to and obtain a copy, no more than twice in a twelve-month period, of your personal information collected during the 12 months before your request.
  • Right of deletion:  You have the right to request that your personal information be deleted, subject to certain exceptions.  For example, your request to delete is subject to the need to complete transactions for which the personal information was collected and comply with legal obligations.
  • Right to opt-out of the sale of personal information:  DeWinter Group does not sell personal information to third parties.
  • Right not to be discriminated against:  In exercising any of the foregoing consumer privacy rights, you have the right not to be discriminated against.  DeWinter Group will not deny you Services or provide you a different level of services for exercising our rights, unless the difference is reasonably related to the value of your information.

If you would like to exercise your rights, please contact DeWinter Group:

  • By calling us at:   1-833-DWG-DATA or (1-833- 394-3282)
  • By emailing us at:  Privacy@DeWinterGroup.com
  • By writing to us at:

DeWinter Group

Attention:  PRIVACY REQUEST

1919 South Bascom Avenue, Suite 250

Campbell, California 95008

 

You may also designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with your written and signed permission to act on your behalf and by directly confirming with us that you have provided the authorized agent permission to submit the request. As permitted by law, we may require you to verify your identity in response to a request even if you choose to use an agent. The authorized agent will also need to verify its own identity directly with us.


After you or your authorized agent submit a request, we require a high degree of certainty that we have verified that the requester is, in fact, the consumer whose personal information is the subject of the request. We will endeavor to do so using the personal information that we, or one of our vendors, consultants or service providers, have about the consumer.  We may need to obtain additional personal information from the consumer or from other third-party sources to verify the requester’s or authorized agent’s identity, in which case, such additional personal information will be used solely for verification purposes.  If we are unable to verify your identity, we reserve the right to deny your requests.


Other California Privacy Rights:  California’s “Shine the Light” law (California Civil Code section 1798.83) gives customers who are California residents the right to ask, once a year, (1) what personal information was disclosed  to third parties for those third parties’ direct marketing purposes in the prior calendar year; and (2) the identities of the companies with whom the information was shared. The terms “customers” and “personal information” have the meaning given by the Shine the Light (California Civil Code Sec 1798.83). 

We do not share personal information, as defined in California Code Civil Section 1798.83, with third parties for their direct marketing purposes absent your consent.  If you are a California resident, you may request information about our compliance with California’s Shine the Light law by sending us a written request to privacy_inquiry@dewintergroup.com or by mailing us a letter to:  DeWinter Group, 1919 South Bascom Avenue, Suite 250, Campbell, California 95008, (Attention:  Privacy Inquiry).  Any such written request must include “California Shine the Light Law Request” in the first line of the description and include your name, street address, city, state, and zip code.  We are only required to respond to one Shine the Light law request per customer per year, and we are not required to respond to requests made by means other than through this email address and mailing address.  Further note that “Shine the Light” rights and CCPA rights are provided under different statutes and must be exercised separately.

V. Your Choices

Marketing and Promotional Communications:  In accord with your marketing preferences and applicable privacy and data protection laws, we may send you updates via email about opportunities or services we think may be of interest to you, such as active job postings that match your criteria, newsletters, articles, surveys, and event information.  If you would like to discontinue receiving such marketing or promotional communications from us, you can unsubscribe or opt-out from receiving such marketing communications from us.  Where you have consented to our processing of your information, you may withdraw that consent at any time and opt-out of further processing.

VI. Cookies and Online Tracking; “Do Not Track”

DeWinter Group uses “cookies” and similar technologies to help us tailor our Site(s) and your online experiences, and for analytical purposes.  For more information about cookies, the types of cookies we use, and how we use them, please see our Cookie Notice.  

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals. For information about “do-not-track”, please visit https://allaboutdnt.com/.

VII. Children’s privacy

Our Site(s) are not directed to children under the age of 13. We do not knowingly collect, use or disclose personal information from anyone under 13 years of age. The terms “personal information” and “child” have the same meaning given to them by the Children’s Online Privacy Protection Act (COPPA). If we learn that a user is under this age, we will not use or maintain his/her personal information. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.

VIII. Security of your information

We maintain reasonable safeguards to protect your information against unauthorized access, use, or disclosure or accidental loss or destruction, and we require third parties providing services on our behalf to do the same. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us.

IX. Links to other websites and third-party content

Our Site may contain links to other third-party websites that are not owned or operated by us. Our Privacy Policy only applies to our Site, and we are not responsible for the privacy practices or the content of other third-party websites. Any information you disclose to other websites are not subject to the provisions of this Privacy Policy. You should check the privacy policies of those sites before providing your information to them.

X. Data retention

We will retain your information for as long as needed to provide our Services or as otherwise required or permitted by law. We will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

XI. Changes and policy updates

We may change information on the Site and/or this Privacy Policy, at any time without prior notice to you, and any changes will be effective immediately upon the posting of the revised Privacy Policy on the Site. We may also notify you by other means, such as sending you an email.  We encourage you to periodically review this page for the latest information on our privacy practices.

XII. Contact us

If you are disabled and would like access to this Privacy Policy in an alternative format, or if you have any questions about this Privacy Policy, please call us at 1-833- 394-3282, email us at Privacy@dewintergroup.com, or send us a written letter to DeWinter Group, 1919 South Bascom Avenue, Suite 250, Campbell, California 95008, (Attention:  Privacy).

To download and/or print this Privacy Policy, click here.

Your Privacy Rights

At the DeWinter Group, we take your privacy very seriously, and we never sell your information; we use it to enhance your experience working with us. 

When it comes to your rights as a consumer, we want to make sure you have everything you need to make informed decisions. You have the right to:

  • Know how your personal information is used;
  • Access, request and receive the personal information we have collected in a portable manner;
  • Object to having your data sold or shared;
  • And request that we delete your personal data.

To submit a request via phone, contact 1-833-DWG-DATA or 1-833- 394-3282.  To submit a request by email, please email privacy@dewintergroup.com.  To submit a request via the web, please complete the form below and document your Request ID number

Cookie Policy

Last Updated: June 30, 2020

To make our Site functional, and to personalize your experience when using our Site, we use cookies. This Cookie Notice explains what cookies are, how we use them, and your ability to block or disable them.

WHAT ARE COOKIES?

A cookie is a small text file saved to your computer or mobile device when visiting our Site. On subsequent visits, cookies are then sent back to our Site, or to another website that recognizes them, creating a record of your online activity. Some cookies are essential for functionality of our Site and are of short duration, while others remain longer and help in understanding how you use the Site so that we can tailor or enhance your experience.

COOKIES WE USE

  1. Essential Cookies: These cookies are essential for the operation of our Site and to enable user navigation. These cookies do not gather information about you, and they do not follow you or remember where you have been on the internet. Essential cookies cannot be disabled. More information about our essential cookies are in the following chart:

    Essential Cookie Cookie

    Source

    Expiration

    Purpose

    __cfduid Cloudflare, Inc. 30 days to maximize network resources, manage traffic, and protect sites from malicious traffic.
    __hs_opt_out Hubspot 13 months to remember not to ask the visitor to accept cookies again.
    osano_consentmanager Osano, Inc. 1 year to enable the utilization of the Consent Dialog and associated features.
    osano_consentmanager_expdate Osano, Inc. 1 year to enable the utilization of the Consent Dialog and associated features.
    osano_consentmanager_uuid Osano, Inc. 1 year to enable the utilization of the Consent Dialog and associated features.

  2. Analytics Cookies: We use Google Analytics and Hubspot cookies to collect information about how you use our Site and browsing activity. These cookies let us understand the use of our Site, and the performance of our marketing and content. We anonymize the IP addresses, and that anonymized information is transmitted to and stored by the particular third-party cookie source. Those third parties may also transfer this information to third parties who process the information on their behalf, or where required to do so by law.

    Analytics Cookie

    Source

    Expiration

    Purpose

    __hssc

    Hubspot

    30 minutes

    keeps track of sessions

    __hssluid

    Hubspot

    2 weeks

    website analytics

    __hstc

    Hubspot

    13 months

    the main cookie for tracking visitors

    _conv_r

    Hubspot

    Session

    holds the referral data for the current visitor.

    _conv_v

    Hubspot

    6 months

    visitor-centric cookie

    _ga

    Google, LLC

    2 years

    Google Analytics cookie, used to identify visitor.

    _gid

    Google, LLC

    24 hours

    Google Analytics cookie, used to track user journey.

    _hjid

    Hubspot

    Session

    these cookies collect information about how visitors use a website

    DV

    Google, LLC

    6 hours

    to collect information about how visitors use our Site.

    HSID

    Google, LLC

    2 years

    to verify a Google user account and most recent login time.

    OTZ

    Google, LLC

    2 years

    provides an aggregate analysis of Website visitor


  3. Personalization Cookies

    Personalization Cookie

    Source

    Expiration

    Purpose

    __hssrc

    Hubspot

    Session

    to determine if the visitor has restarted their browser

    hubspotutk

    Hubspot

    13 months

    keeps track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts.

    NID

    Google, LLC

    6 months

    to store information about your preferences.


  4. Marketing Cookies: We use cookies that deploy when you interact with a marketing communication, such as on our Site, an email, or online advertising content. These types of cookies collect information about your unique identifying browser and internet device information, which pages you visit, your browsing history, and whether you viewed certain content, including advertisements before you arrive at our Site, and otherwise to help us with our marketing efforts. 

    Marketing Cookie

    Source

    Expiration

    Purpose

    __atssc

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    __atuvc

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    __atuvs

    AddThis

    Immediately

    to enable visitors to share content with a range of networking and sharing platforms.

    _fbp

    Hubspot

    Session

    to deliver a series of advertisement products such as real time bidding from third party advertisers

    _gat_gtag_UA

    Google, LLC

    2 years

    carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.

    _gcl_au

    Hubspot

    3 months

    Used by Google AdSense for experimenting with advertisement efficiency across websites using their services.

    _omappvp

    OptInMonster

    11 years

    to identify new vs. returning visitors for behavioural marketing purposes.

    _omappvs

    OptInMonster

    11 years

    to identify new vs. returning visitors for behavioural marketing purposes.

    1P_JAR

    Google, LLC

    1 Month

    carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.

    ANID

    Google, LLC

    2 years

    used for advertising

    APISID

    Google, LLC

    2 years

    allow the website to remember choices you make

    gpw_e24

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    loc

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    mus

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    na_id

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    na_tc

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    ouid

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    s_cc

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    s_fid

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    s_nr

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    s_sq

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    SAPISID

    Google, LLC

    2 years

    allow the website to remember choices you make

    SID

    Google, LLC

    2 years

    allow the website to remember choices you make

    SIDCC

    Google, LLC

    2 years

    carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.

    ssc

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    SSID

    Google, LLC

    2 years

    carries out information about how the end user uses the website and any advertising that the end user may have seen before visiting the said website.

    uid

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

    uvc

    AddThis

    1 year

    to enable visitors to share content with a range of networking and sharing platforms.

     

THIRD-PARTY WEBSITES' COOKIES

When using our Site, you may come across embedded content, such as videos from third-party sources, or you may be directed to other websites for such activities as surveys or job applications. Third-party websites and embedded content likely use their own cookies, and we do not have control over the placement of cookies by those other websites. Please review those third-party websites’ privacy policies and cookie practices.

HOW TO CONTROL, DISABLE OR REMOVE COOKIES

When you visit our Site, we will ask you to consent to our use of cookies as described in this Cookie Notice and provide you a link to this notice. We will record when you have consented to our use of cookies, and we will again ask for your consent at least once a year when we ensure that you and other users are up-to-date with our then-current Privacy Policy and Cookie Notice.

At all times, you can enable or disable many of the cookies we use on our Site by clicking on the cookie icon floating in the lower left side of any page of our Site, which will then open up a side panel, providing you on-off toggle switches next to each type of cookie we use. Simple click on a toggle switch to enable or disable the particular types of cookies (Analytics, Personalization or Marketing). Remember that essential cookies cannot be disabled.

You can also use your web browser’s method of blocking or removing cookies from all websites you visit, including our Site. For example, if you use Chrome, launch the browser, open Settings, select Privacy and security, and then select either Clear browsing data or Site Settings, which will allow you to clear cookies and other website data, your browsing history, your download history, or otherwise control what information websites can collect and use.

Remember that when you disable cookies, some features and functionalities of our Site may not work. Also remember that we cannot block or otherwise control cookies on third-party websites, even if those websites linked from our Site.