We self-certify compliance with the Privacy Shield Framework.
Keystone Partners is committed to protecting the privacy rights of all persons with whom it deals. To demonstrate its commitment to your privacy, Keystone Partners has made its information and privacy practices available in this statement.
Our Sites may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them. This Privacy Statement sets forth the online data collection and usage policies and practices that apply to the Keystone Partners Site including notification about:
- Any personally identifiable information of yours or third party personal identification that is collected from you through the website.
- How your personal information is used.
- With whom your personal information may be shared.
- What choices are available to you regarding collection, use and distribution of your personal information.
- The kind of security procedures that are in place to protect the loss, misuse or alteration of information under the control of Keystone Partners.
- How you can correct any inaccuracies in the information.
If you have questions or concerns regarding the privacy of your personal information, please write to Keystone Partners’ Privacy Officer at 125 Summer Street, Suite 1020, Boston, MA 02110.
By using the Keystone Partners’ Websites at https://www.keystonepartners.com, https://www.keystoneassociates.com, https://www.camdenconsulting.com and https://www.essexpartners.com, you consent to the policies and practices described in this Privacy Statement.
What is Personal Information?
Personal information is information that can be explicitly used to identify or contact you as an individual. (e.g. name, email address, mailing address, phone number, credit card number). Personal information is considered information that is (1) recorded in any form; (2) is about, or pertains to a specific individual; and (3) can be linked to that individual.
Personal information is collected by Keystone Partners only when you specifically and knowingly choose to receive information or services from Keystone Partners or its affiliated partners. You will be informed that your personal information is being collected, the purpose for which it is being collected and that you have a right of access to the information.
We may also receive personal information from our business associates and other third parties provided that such third parties confirm to us that they have obtained your consent to the disclosure of your personal information.
Information We Collect
We collect personally identifying information, such as your name, street address, email address, and phone number, and other information that would be related to the delivery of the services we are providing.
Keystone Partners uses the information we gather on the Keystone Partners Websites, whether personal, demographic, collective or technical, for the purpose of operating and improving the Keystone Partners Websites, fostering a positive user experience, and delivering the products and services available from Keystone Partners or its affiliated partners. Keystone Partners uses the information for:
- Monitoring information to ensure compliance with Keystone Partners policies;
- Editorial and feedback solicitation purposes;
- Establishing and maintaining communication, including marketing, advertising and other beneficial services; and,
- Compliance with federal, state, provincial or municipal laws
- Personal information that you provide to the Keystone Partners Websites will not be made available to third parties outside of Keystone Partners without explicit permission from you. We do not disclose to third parties your personal information, combined personal and demographic information or information about your use of the Keystone Partners Websites (such as the areas you visit or the services you access).
Keystone Partners Websites are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18.
Demographic and profile data is collected at our site. We use this data to tailor our visitor’s experience at our site, showing them content that we think they might be interested in, and displaying the content according to their preferences.
If we are going to use your personally identifiable information in a manner different from that stated at the time of collection we will notify you via email or by telephone. You will have a choice as to whether or not we use your information in this different manner.
Your personal information is required for:
When you register for services using any of the Keystone Partners Websites, Keystone Partners will request personal information from you, including your name and email address. Some of the information requested from you during registration is optional, and is clearly identified on the site.
Information collected by Keystone Partners as part of the log-in/registration is NOT made accessible to the public, other users of the site or anyone not employed by Keystone Partners directly. This information is held in strict confidence and can be removed at your request at any time.
Your personal information is used to communicate with you about your account and to provide you with information related to Keystone Partners services. We may use your contact information in order to send you email or other communications regarding updates to the Keystone Partners Websites, such as new career opportunities which may be of interest to you. The nature and frequency of these messages will vary depending upon the information we have about you.
You have the option to elect to receive additional communications, and information including without limitation free informational newsletters from Keystone Partners relating to topics that may be of special interest to you. You always have the option, however, to tell us not to share your personal information with other Keystone Partners Companies or to exclude you from offers for other products or services.
Personal contact Information is collected (e.g. First Name, Last Name, Address, Home Phone, Work Phone, Email Address, Fax number, and other information that would be related to the delivery of the services we are providing). You can choose to make this information visible to public in your resume or you may choose for this information to remain private.
Email Messages / Feedback
When you send us messages via email, we will use your name and email address only to respond to the concerns you write to us with. Your email may be shared with appropriate people within the Keystone Partners organization to help us respond to your concerns and improve the services we provide.
We have an area where you can submit feedback. Any feedback you submit in this area becomes our property, and we can use such feedback (such as success stories) for marketing purposes, without attribution, or contact you for further information and release.
Please remember that any personal information that is disclosed in public areas of the Keystone Partners Websites becomes public information. We recommend that you exercise caution when deciding to disclose any personally identifying information, as it could be collected and used by others over whom Keystone Partners has no control. We are not responsible for the use made by third parties of information you post or otherwise make available in public areas of the Keystone Partners Websites.
We collect cookies on our websites and use Google Analytics for aggregate data. A cookie is a text file that is placed on your hard drive to collect information about your activities on a website. “Cookies” give us an idea of which parts of our site users are visiting. For example, if you personalize Keystone Partners pages, or register for services, a cookie helps you to recall your specific information (e.g. your user name, password and preferences). When you return to the Keystone Partners Website, the information you previously provided can be retrieved, so you can easily use the features that you customized.
We use this information only as anonymous aggregate data to determine how many people visit our site, which features are used most frequently, and which browsers are primarily used. We do not use it to track or record information about individuals. This information assists us in diagnosing problems with our site and helps us deliver a better overall experience for you and other visitors.
Many consumers do not know that “cookies” are being placed on their computers when they visit websites. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer, and can usually only be read by the web server that issued the cookie to you.
Most browsers are initially set up to accept cookies. If you want to know when this happens, or to prevent it from happening, you can set your browser to warn you when a website attempts to place a “cookie” on your computer. You can also delete cookies on our websites. Accepting cookies is voluntary; however, if you decline cookies you may not be able to use some features of the Keystone Partners Websites.
How We Share Your Data
Keystone Partners may make aggregate information about our users available to third parties for the purposes of marketing, advertising and other beneficial services. The information gathered on the Keystone Partners Websites may be shared within Keystone Partners and its affiliated partners acting on our behalf, who are subject to confidentiality agreements.
YOUR PERSONAL CONTACT INFORMATION WILL NOT BE EXCHANGED OR SOLD TO ANY OTHER BUSINESS OR VENDOR.
Prior to disclosing Personal Information to a third party, Keystone Partners will notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure.
To enable us to more efficiently provide the services you have requested from us, Keystone Partners may share aggregated anonymous information about visitors to the Keystone Partners Websites (for example, the number of visitors to the Keystone Partners Websites) with its clients, agents and other third parties so that they may understand the kinds of visitors to the Keystone Partners Portal Site and how those visitors use the site.
We may disclose your personal information to other Keystone Partners companies, agents, contractors and individuals we employ to perform functions on our behalf. Only the information necessary to perform a specified business function will be disclosed (e.g. to provide career assistance, host our web servers, or provide customer service). These companies and individuals will have access to your personal information only as necessary to perform their functions, but they may not share that information with any other third party and are subject to strict terms of confidentiality.
In other circumstances we may be required or authorized by law to disclose the information you provide. Though we make every effort to preserve user privacy, we may need to disclose personal information if legally required to do so, if requested to do so by a governmental entity or if we believe in good faith that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect the rights or property of Keystone Partners or its affiliated partners; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public. Keystone Partners is held accountable for onward transfer of your information. Keystone Partners is potentially liable for any unlawful onward transfer of data to third parties.
Keystone Partners may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
How and Where We Store Your Data
We only keep your personal data for as long as we need in order to provide the services you have requested and/or as long as we have your permission to keep it.
Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR.
Keystone Partners will take reasonable steps to protect your information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information from loss, misuse, unauthorized access or disclosure, alteration or destruction.
Areas of this website that collect your information use industry standard secure socket layer encryption (SSL); however, to take advantage of this your browser must support encryption protection.
Your profile has a password so that only you can access it. We recommend that you do not provide your password to anyone, as you are ultimately responsible for maintaining the secrecy of your account information. If you share a computer with someone else or are using a computer in a public location, remember to sign out and close your browser window when you have finished to ensure that others cannot access your personal information.
Data Integrity and Purpose Limitation
Keystone Partners will only process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.
Individuals have the right to access data that Keystone Partners holds about them and may request access to such information through the inquiry process by contacting firstname.lastname@example.org or +1-617-720-7300. Keystone Partners will allow an individual access to their Personal Information to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
If you have any questions about the collection, use or disclosure of your personal information by Keystone Partners or our agents, you may contact our Privacy Officer. Except in limited circumstances, as specifically provided by applicable privacy legislation, we will tell you whether we hold personal information about you, the source of the information and allow you access to your personal information. We will provide an account of the use that has been made or is being made of the information and the third parties to which it has been disclosed upon request.
Keystone Partners will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation. If access is denied, Keystone Partners will provide you with the reasons for the refusal.
Change in Business Ownership
We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Statement, be permitted to use that data only for the same purposes for which it was originally collected by us.
Privacy Shield Frameworks for Data Transferred to the United States from the EU/Switzerland
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Keystone Partners is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Keystone Partners’ accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Keystone Partners remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Keystone Partners proves that it is not responsible for the event giving rise to the damage.
Mary Fay Kattman
125 Summer Street, Suite 1020, Boston, MA 02110
Keystone Partners has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
General Data Protection Regulation (GDPR)
The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach data privacy. The key articles of the GDPR, as well as information on its business impact, can be found throughout the GDPR website: https://eugdpr.org
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Links to Other Sites
This Privacy Statement applies solely to the information we collect on the Keystone Partners Websites, and does not apply to information we collect in any other fashion.
Users should be aware that when you are on Keystone Partners sites, you could be directed to other sites that are beyond our control. Keystone Partners is not responsible for the privacy practices or the content of other websites that may be linked to this site.
Changes to this Policy
Questions or Concerns
If you have any questions or concerns about the information contained in this privacy statement, please contact our Office at: email@example.com, 125 Summer Street, Suite 1020, Boston, MA 02110.
If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you may contact:
In the United States:
Federal Trade Commission at 1-877-FTC-HELP
In the European Union: