Cumming Privacy Policy

Cumming Privacy Notice (last updated January 13, 2023)

Cumming Group respects your right to privacy. This Privacy Notice has been compiled to explain how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies only in respect of personal information that we collect through our website https://emea.cumming-group.com (“Website”).

Please read our Privacy Notice carefully and in full to ensure you are fully informed.

What personal information do we collect from people who visit our website and why?

• Information that you provide voluntarily

Certain parts of our Website may ask you to provide personal information voluntarily. For example, if you are a customer or prospective customer, we may ask you to provide your contact details and company information to:

• communicate with you effectively;
• provide more relevant and helpful responses to your service requests;
• understand whether you are affiliated with a current client, partner or affiliate and tailor our responses within this context;

• provide further details about our service offerings;
• enable you to subscribe to marketing communications from us, and/or
• create an account.

If you are applying for a job through our online career opportunity portal here Careers – Cumming Group, EMEA (cumming-group.com), we may ask you to provide your contact details, and information regarding your work history and education so that we can contact you and also assess your qualification for a particular role.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to supply your personal information.

• Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your device. In some counties, including the UK and countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include information such as your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city level location), number of users and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our Website, where they come from and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further in our “Cookie Policy” which can be viewed here [https://emea.cumming-group.com/cookie-policy/].

When do we collect information?

We collect information from you when you fill out a form or enter information on our Website, and as otherwise described in our Cookie Policy.

What is our legal basis for processing your personal information?

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party) we will make clear to you at the relevant time what those legitimate interests are.

If we collect and use your personal information in reliance on your consent, you have the right to unconditionally revoke your consent to such processing at any time by contacting us as described below. Any withdrawal of your consent will not affect the lawfulness of processing based on your consent before your withdrawal.

If you have questions about or require further information concerning the legal basis on which we collect and use your personal information, or to revoke your consent for such processing, please contact us using the contact details provided under the “How To Contact Us”.

How do we protect your personal information?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. For example, we run regular malware scanning of our Website and also use an Secure Sockets Layer (SSL) certificate to help protect the data that you submit to our Website while in transit.

Do we use ‘cookies’ and similar technology?

Yes, we use cookies and similar tracking technology (collectively “Cookies”) to collect and use personal information about you, including to better serve interest-based advertising. Please see our Cookie Notice here [https://emea.cumming-group.com/cookie-policy/] for further information about the types of Cookies we use, why we use them, and how you can control Cookies.

Who do we share your personal information with?

We may disclosure your personal information to the following categories of recipients:

• To our group companies, third party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or to help to enhance the security of our Website), or to otherwise process personal information for the purposes that are described in this Privacy Notice or notified to you when we collect your personal information.

• To any competent law enforcement body, regulatory, government agency, court of other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation; (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

• To any actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer they must use your personal information only for the purpose disclosed in this Privacy Notice; and

• To any other person with your consent to the disclosure.

Save for as described above, we shall not sell, trade, or otherwise transfer your personal information to any other parties, unless otherwise notified to you in advance, and we have obtained your consent if and where this is required by applicable data protection laws.

International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). Specifically, your personal information may be transferred to the US and other countries in which our group companies and third party service providers and partners operate. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses (or UK equivalent) for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union (or UK) data protection law.

Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

How long do we retain your personal information?

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service or information you have requested, to consider you for future job vacancies where you have indicated your wish for us to do so or to comply with applicable legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete it or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives) then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Do we operate third party advertising on our Website?

No, we do not include or offer third-party products or services on our website.

What are your data protection rights?

You have the following data protection rights:

• If you wish to access, correct, update or request deletion (‘right to be forgotten’) of your personal information, you can do so at any time by contacting us using the contact details provided under the “How To Contact Us”.

• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How To Contact Us”.

• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How To Contact Us”.

• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

• You have the right to complain to a data protection authority about our collection and use of your personal information.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

How To Contact Us

If you have any questions or concerns about our use of your personal information, please contact us using the following details:  

Cumming Management Group, Inc. 
1325 4th Ave Ste 1010
Seattle, WA 98101-2505
United States
800-717-1278
info@cumming-group.com

The data controller of your personal information is (for the UK) Cumming Europe Limited which is registered with the UK’s Supervisory Authority, the Information Commissioner’s Office, with registration number ZA159731 and (for the EU) Cumming Management Ireland Limited.