Effective: July 30, 2021

Introduction

Cornerstone Search Group, LLC (“Company”) is a New Jersey Limited Liability Company with its principal place of business located at 1200 Morris Tpke, Suite 3005, Short Hills, NJ 07078 (United States).  This statement (“Privacy Policy”) sets forth the privacy standards that the Company utilizes to collect, retain, and use personal data obtained from or about individuals located within the United Kingdom (“UK”), the European Union (“EU”) and the European Economic Area (“EEA”), as well as from individuals located in Switzerland, the United States and elsewhere in the world. It is the Company’s policy to respect, and protect, personally identifiable information obtained from individuals as set forth in this Privacy Policy.

There are certain provisions of this Privacy Policy that only apply to individuals from the UK, EU or EEA.  Those sections are denoted as “UK/EU/EEA Data Subjects Only.”

There are certain provisions of this Privacy Policy that do NOT apply to individuals from the UK, EU or EEA.  Those sections are denoted as “Not Applicable to UK/EU/EEA Data Subjects.”

You should also review our Terms and Conditions of use of the website, which can be found at https://cornerstonesg.com/terms-conditions/ and is applicable and binding upon you with respect to your use of the website and is incorporated herein.

1. What Is the Scope of this Statement?

This Privacy Policy sets forth the principles under which the Company collects, uses, processes, retains, and discloses personal data and/or sensitive data in the United States, the UK, or the EEA or elsewhere from individuals, including by and through our website located at https://cornerstonesg.com/ and services provided by the Company as referenced therein (together, the “website”) and information you provide to us based upon information from our website (i.e., if you send us an e-mail at an e-mail address identified on the website) or through our website (i.e., using contact us).  This Policy covers information received in electronic and all other formats.

2. Terms

The terms “we“, “us” and “our” refer to the Company, and its officers, directors, owners, employees and agents.

The term “personal data” means any data which relates to a natural person (as opposed to a business or corporate entity) that makes you identifiable.  As used herein and in connection with our business, the term personal data may include:

  • Names and contact information, including phone number, physical address, fax and e-mail, all only to the extent provided by you (or on your behalf) to us, or which you manifestly make public;
  • Potentially gender and nationality;
  • Title, position, business/company/institution name for whom you work or provide services, including as indicated in public information or as provided by you to us;
  • Referral source data (i.e., how you ended up at the website);
  • Any other similar information provided to us by you in connection with our services or through the website.

The term “data controller” means the person or entity which decides the purposes for which, and the way in which, any personal data is processed.

The term “data processor” means the person or entity which processes personal data on behalf of the data controller.

The term “processing” means any operation or set of operations performed on personal data.  Processing includes, but is not limited to, the collection of data, the organizing of data, the recording or saving/storage of data, the altering of data, the using of data, the disclosing or transfer of data, the deleting or destruction of data, or the making available of data.

3. What Information We Collect About You

We may collect all types of personal data about you as described in Section 2 above under the definition of “personal data.”

You agree that we may collect and process all such personal data that you provide to us, or that you or your employer (or other entity for whom you provide(d) services) manifestly make public through publication or otherwise, and/or any entity which retains us and provides to us to enable us to provide the services (the “Services”) for which we were retained by said customer and as otherwise set forth in the agreement related to such Services.  In addition to the Services identified on the website, these Services may also include Services in connection with the use and management of the website and all content and services therein.

You also hereby consent that we may use your personal data for the following additional purposes which may be included in, or part of, the Services:

  • Updating our records;
  • In connection with any application for employment with the Company;
  • Internal analysis for our business management purposes;
  • Any statutory or regulatory purpose which requires the processing of your personal data;
  • Legal and regulatory compliance;
  • Fraud and crime prevention;
  • Internal or external audits; and
  • Any other purpose for which valid consent is obtained.

In addition to the above, we may also collect other data from you which is not personal data, such as information about your employer, the content of articles or other information you publish or otherwise make public, etc.

Please do not supply the following to us:

  • Any other person’s personal data, unless the Company explicitly asks you to do so;
  • Any categories of your personal data that have not been explicitly requested by the Company;
  • Any confidential, proprietary, secret or legally protected information which you are not explicitly requested by the Company to provide; and
  • Any confidential, proprietary, secret or legally protected information which are under any legal obligation to not provide to or share with the Company.

4. How We Collect Information About You

We collect information about you (including personal data) when:

  • You Give Us Information – You may provide us information when:
  • you set up an account with us; you provide it to us by filling out forms;
  • you send us e-mail; you provide information via phone or in person;
  • you provide us with information in writing and send it to us other than via e-mail, phone or in person (i.e., mail, FedEx, etc.);
  • you provide us with documentation;
  • you provide us with information which may contain personal data;
  • you provide it to use through our “Contact Us” page on the website;
  • you provide it to us through social media;
  • you provide us with information in connection with seeking employment with the Company.
  • We Collect Information Automatically – We automatically collect certain types of information when you visit our website (as explained below).
  • We Collect Information From Other Sources – We may also obtain information about you from outside sources. For example, we may obtain commercially available information about you from third-parties or purchase e-mail lists from third parties for advertising, marketing or informational purposes.  We may also receive information from third-parties who provide services for us through web-beacons and other technologies described in this Privacy Policy.
  • Use of Cookies

5. About Cookies

  • A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  • Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
  • Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
  • Shared local objects (commonly referred to as “FLASH cookies”) are cookies that are placed on your computer that are not removed through normal browser management tools. If we use FLASH cookies, we will only do so in a manner consistent with the purposes for which they were designed unless you are specifically notified that we intend to use them for a specific service.

Cookies That We Use

We use cookies for the following purposes related to the services we provide for and to you and our users:

  • authentication – we use cookies to identify users of the website and/or the location of individuals accessing the website;
  • status – we use cookies to help us to determine if you are logged into our website;
  • personalization – we use cookies to store information about your preferences and to personalize the website for you;
  • security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

UK/EU/EEA Data Subjects Only – You have the right to disable advertising cookies.  However, the website does not use advertising cookies;

  • analysis – we use cookies to help us to analyze the use and performance of our website and services; and
  • cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies Used By Our Service Providers And Vendors

Our service providers and vendors may use cookies and those cookies may be stored on your computer when you visit our website.  These service providers and vendors may include, but may not necessarily be limited to:

Google Analytics (see https://support.google.com/analytics/answer/6004245?hl=en and information therein).

  • You should review the privacy and cookie policies of the above website(s) to learn more about the cookies that are used in connection with the above.
  • The above website(s) and cookies may change from time to time as we use different vendors or service providers to provide some or all of the services offered or provided by the above services and websites, or additional services we decide to include. While we will periodically update our list of such vendors and service providers, the above list may not be complete at any given time.

Microsoft Clarity (See https://privacy.microsoft.com/privacystatement and information therein)

  • We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

VWO (See https://vwo.com/privacy-policy and information therein)

  • Additionally, we partner with VWO to provide A/B testing in order to optimize and improve user experience. Website usage data is captured using technologies like cookies, web logging, and/or other direct and indirect methods. For more information visit the VWO Privacy Policy

Managing Cookies

6. Use of Web Beacons, Clear-GIFs, Pixel Tags and JavaScript

  • Except as set forth herein, our use of web beacons, clear-gifs, pixel tags and JavaScript is critical to proper functionality our website, and disabling them may impact the functionality of the website and the services we provide.
  • We also may use “pixel tags” (also called “action pixels,” “web beacons” or “clear gifs”) and/or JavaScript plug-ins, placed on the website and in our emails to you.
  • These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or in an email message which are used for such things as recording webpages or advertisements clicked-on by a user, or for tracking the performance of email marketing campaigns. These devices help us analyze our users’ online behavior and measure the effectiveness of our website and our marketing.
  • We may also work with third-party service providers that help us track, collect, and analyze this information.  Third-party entities with whom we have agreements may place these devices on the website and/or in emails to use information obtained from them such as pages viewed, emails opened and items upon which you may click in emails.  These third-party providers may also place cookies onto your computer. Those third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and your preferences from these third-party sources as well as our information we have about you. See above for more information on our cookies.
  • UK/EU/EEA Data Subjects Only – You may be able to disable use of web beacons, clear-gifs, pixel tags and JavaScript if you provide us with notice as set forth in Sections 15 and 16 hereof. However, doing so may impact your ability to use our website and/or our services and/or impact the cost of our services to you.

7. Server Logs

  • A web “server log” is a record of activity created by a computer that delivers certain webpages to your browser.  Certain activities that you perform on our website may record information in server logs. For example, if you enter a search term on the website or enter your login information, the server log may record the search term, the link you clicked on to bring you to our website and/or information about your browser, such as your IP address and the cookies set on your browser.

8. Search Queries on Our Website

We may provide you with options to search for information on our website.  If you enter information in a search query box, we may store that information and we may aggregate that information with other information we may have about the browser and/or IP address from which the search query originated.

9. Social Media Platforms

We may link to certain Company social media platforms on Facebook®, LinkedIn®, or Instagram® or other platforms.  When you engage with our content at or through these social media platforms, you may be asked to share certain information about these interactions with us.  Please review the privacy policies/notices and privacy settings with each such social media platform you use so you understand how this data and information may be used, and to choose your options for the sharing of such data and information.

10. How We Use Your Personal Data

  • We process your personal data identified in this Privacy Policy to perform the Services as defined above. The legal basis for this processing is your consent set forth herein, your consent based upon certain information you manifestly make public, as well as our contractual obligations.
  • We may process your personal data identified in this Privacy Policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
  • We may process your personal data identified in this Privacy Policy where necessary for the purposes of managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
  • We may process your personal data identified in this Privacy Policy where such processing is necessary or advisable for compliance with a legal obligation to which we are subject (in the United States, the United Kingdom, the EEA, the EU or elsewhere), or in order to protect your vital interests or the vital interests of another natural person.

11. Providing Your Personal Data To Others

  • We may disclose your personal data to our officers, directors, employees, and agents insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy Policy, including to provide or potentially provide Services to you or for your benefit.
  • We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings, ADR or in an administrative or out-of-court procedure.
  • We may disclose certain of your personal data to our suppliers and subcontractors pursuant to separate consent provided by you to us.
  • We may disclose certain of your personal data to our vendors and subcontractors in connection with providing our Services or our other permitted uses as set forth herein.
  • The foregoing disclosures are made insofar as reasonably necessary, and only to the extent required, for assisting us in providing our Services to you, storing data and in connection with the administration of our business.
  • In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution, or in an administrative or out-of-court procedure.

12. International Transfers of Your Personal Data – For UK/EU/EEA and Swiss Data Subjects Only

  • In this Section, we provide information about the circumstances in which your personal data may be transferred to countries outside the EEA (Austria, Belgium, Bulgaria, Czech Republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden) or the United Kingdom.
  • Cornerstone Search Group, LLC is a New Jersey Limited Liability Company with its principal place of business located at 1200 Morris Tpke, Suite 3005, Short Hills, NJ 07078 (United States). The European Commission has made an “adequacy decision” with respect to the data protection laws of the United States.  In the event the Company transfers any of your personal data to a third party in the United States or elsewhere outside of the EEA, or the United Kingdom, such transfers will be protected by appropriate safeguards through the use of standard data protection clauses adopted or approved by the European Commission (as same may be updated), or other similarly applicable law concerning the United Kingdom; or through other legal means.
  • By providing your personal data to the Company, you are agreeing to the transfer and processing of your personal data to and in the United States and any other countries as identified herein in accordance with this Privacy Policy.

13. Retaining And Deleting Personal Data

  • This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
  • Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  • We will retain your personal data:
  • to the extent your personal data that we hold was obtained from data you knowingly, intentionally and manifestly made public or which is in the public domain independent of any act or action of us, it will be retained in that form for as long as it is needed or required for the purposes for which we obtained the information from the public record, or as otherwise required by applicable law;
  • to the extent your personal data that we hold was pulled by us and separated from data you knowingly, intentionally and manifestly made public or which is in the public domain independent of any act or action of us, it will be retained by us for as long as required by us for the purpose for which it was obtained and as required by our contractual requirements with third-party clients or as otherwise required by applicable law.
  • In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based upon the performance of our Services, and any applicable industry and governmental standards.
  • We may also retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

14. Amendments

  • We may update this Privacy Policy from time to time by publishing a new version on our website.
  • You should check this page occasionally to ensure you are happy with any changes to this Privacy Policy.
  • We may notify you of significant changes to this Privacy Policy by email or through the private messaging system on our website.

15. Your Rights – UK/EU/EEA Data Subjects Only

  • In this Section, we have summarized the rights that UK/EU/EEA data subjects have under applicable data protection law, including the GDPR and the UK GDPR. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
  • Your principal rights under data protection law are:
  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent under certain circumstances.
  • You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.  Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.  The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
  • You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
  • In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing where no other legitimate basis for retention exists; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed.  However, there are exclusions of the right to erasure.  The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation (including contractual obligations); or for the establishment, exercise or defense of legal claims.
  • In some circumstances you may have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data.  However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
  • You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
  • You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
  • You have certain rights to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
  • If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the UK, as applicable, or the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
  • To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
  • If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Policy, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be.  Please include the words “GDPR OPT-OUT” in the subject line. Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request, or your request to exercise any of your rights in relation to your personal data by written notice to us at:

Cornerstone Search Group, LLC
1200 Morris Tpke, Suite 3005
Short Hills, NJ 07078
Attention: Privacy Officer (privacy@cornerstonesg.com)

With a copy (including the words “CORNERSTONE – GDPR” in the subject line) to:

OlenderFeldman LLP
422 Morris Avenue
Summit, NJ 07901 (United States)
Attention: Michael J. Feldman, Esq. (mfeldman@olenderfeldman.com)

16. Your Choices About Information We Collect – Not Applicable to UK/EU/EEA Data Subjects

  • If you do not consent to the way in which we may use your personal information, please do not submit any personal information to us. Please note that if you do not provide us with certain personal information the Company may be unable to provide you with its Services, or those Services may not be as good as they otherwise could be.
  • If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Policy, please provide us with your exact name and address and advise us that you wish to opt-out for any information sharing or receiving information from us or both as the case may be.  Please include the words “OPT-OUT” in the subject line. Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request to the following contacts:

Cornerstone Search Group, LLC
1200 Morris Tpke, Suite 3005
Short Hills, NJ 07078
Attention: Privacy Officer (privacy@cornerstonesg.com)

With a copy (including the words “Cornerstone – Privacy” in the subject line) to:

OlenderFeldman LLP
422 Morris Avenue
Summit, NJ 07901 (United States)
Attention: Michael J. Feldman, Esq. (mfeldman@olenderfeldman.com)

  • If you do not wish to receive other marketing materials from us via e-mail, you can also click the unsubscribe link on such e-mails, or call us at 973-656-0220 and clearly set forth your request.

Please note that even once we comply with any of your requests as set forth above, de-identified and aggregate data including your personal data may still be shared, but it will not be identified or identifiable to you.

17. Privacy of Children Who Visit the Website

We recognize the importance of children’s safety and privacy. The website is not designed to attract children, and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18.  If you are under age 18, you do not have permission to use this website or our Services.

18. Your California Privacy Rights

  • We collect various types of personal information about you during the course of your relationship with us. Under California law, if you are a resident of California, you may make a written request to us about how we have shared your information with third parties for their direct marketing purposes. In response to your written request, we are allowed to provide you with a notice describing the cost-free means to opt-out of our sharing your information with third parties with whom we do not share the same brand name, if the third party will use such information for its direct marketing purposes.
  • If you would like to exercise your rights under California law, please send your written request to the e-mail address or postal address below. Please include your postal address in your request and the words “CALIFORNIA OPT-OUT” in the subject line of your request. Within thirty (30) days of receiving your written request, we will provide you with a Third-Party Direct Marketing Opt-Out Form so you may request that your personal information not be disclosed to third parties for their direct marketing purposes.

E-mail Address:

privacy@cornerstonesg.com

Postal Address:

Cornerstone Search Group, LLC
1200 Morris Tpke, Suite 3005
Short Hills, NJ 07078
Attention: Privacy Officer

19. Security

We believe in providing a safe and secure experience for all of our online visitors. To that end, we have implemented security measures to protect the information collected from you. We maintain reasonable physical and electronic safeguards designed to limit unauthorized access to your personally identifiable information, and to protect you against the criminal misuse of that information.

While we use the foregoing security measures to protect your information, please note that no data transmitted over the Internet or stored and utilized for business purposes can be guaranteed to be completely secure.  No security measures are perfect or impenetrable. We cannot guarantee that only authorized persons will view your information. We cannot ensure that information you share on the website will not become publicly available. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up to date antivirus software.

20. Questions / Changes in Notice

If you have questions or concerns with respect to our Privacy Policy, you may contact us at privacy@cornerstonesg.com. We may elect to change or amend our Privacy Policy; in such event, we will post the notice changes in our Privacy Policy on the website.