Your Consent

Please review this Policy periodically. You should read this entire Policy before submitting information, including Personal Information, to us in any form or using our Website. Whenever you submit Personal Information to us, you consent to the collection, use, disclosure, transfer, and storage of that information in accordance with this Policy.

All Personal Information may be used for the purposes stated in this Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form.

Collection of Personal Information

We collect Personal Information using the following methods: 1) from you when you voluntarily provide it, including online when you visit our website, or when you interact with us in any other manner; 2) using automated technology, including when you visit our website or interact with our electronic advertisements or communications; and 3) using third party sources including but not limited to service providers and entities providing data analysis and analytics. To see a complete list of what we collect, how we use this data, please see Annex 1 below.

Personal Information

G&A collects Personal Information, including contact information, such as your name and email address, and when you choose to provide it to us via our website.

Internet / Network Activity

When you visit our website, we collect information about you through your browser, computer hardware and software. This information can include your IP address, device ID, browser type, domain names, access times and dates, number of clicks, pages viewed, one or more cookies (as described below) that may uniquely identify your browser, and referring website addresses. We use this information for the improvement of our site.

How We Use Your Personal Information

We use Personal Information of customers for a wide range of purposes, including:

• to respond to your requests and feedback;
• to improve our business and Website;
• to follow up with you after you have communicated with us or submitted information to us;
• to send promotional communications or offers (unless you have requested that we not send such communications);
• for marketing, research legal purposes and other purposes;
• to address your interests and concerns; and
• as otherwise specified at the point of Personal Information collection.

How We Disclose Your Personal Information

Service Providers and Contractors

We disclose Personal Information you provide to consultants, service providers, and contractors that we use to support our business and operations who have agreed to keep the information confidential and use it only to provide the applicable service(s) such as vendors that help us communicate with you, vendors that host and support our website and data, security and fraud detection vendors.

Third Party Partners

We disclose Personal Information to third parties we work with who help us gather information from you and communicate with you including for email communications.

Legal Obligations

We may disclose Personal Information to outside parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations.

Sale or Corporate Restructuring

We may disclose Personal Information to third parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of our brand or company.

How We Use “Cookies” and Other Technology

As you enter the Website, our server records and monitors your IP address and uses it to develop statistical analysis. These analyses assist us in refining and adapting the content and design of our site. The use of IP addresses also enables us to prevent malicious Internet users from masquerading as other users. Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology. A cookie is a small piece of information sent by a website that is saved on your hard drive by your computer’s browser. A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags.

As you access or use our Site, we and/or third parties may collect information using cookies, web beacons, pixels, and navigational and location data collection (clickstream, log files, server logs) for the purposes described in this Policy. Such automated technologies further help us to keep track of your interactions with our website.

To find more information about cookies please visit www.allaboutcookies.org. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.

Third Party Analytics Disclaimer

We and/or third parties including service providers on our behalf, may use cookies, web beacons and other similar technology, to collect information from you such as your activities on the Website for the purposes described in this Policy including analytics, monitoring performance, and improvement of our Site (traffic, errors, page load time, popular pages, etc.)

Examples of our third-party service providers to help deliver our services or to connect to our services include:

• Google Analytics: We use Google Analytics to understand how our website, services, and products perform and how you use them. We have already entered into a service provider addendum with Google. To learn more about how Google processes your data, please visit Google’s Privacy Policy. If you would like to take additional precautions to opt out of Google Analytics and Ads, you can opt out of Google Analytics by installing Google’s Opt Out browser add on: Google’s Opt Out browser add-on and opt out of interest-based Google ads using Google Ad Center.

Retention of Personal Information

We will retain your Personal Information (collected through offline and online methods) for as long as it is necessary for the purposes described in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. For more information regarding retention of personal information, see Annex 1 below.

Intended Audience; COPPA Compliance

The Children’s Online Privacy Protection Act (“COPPA”) does not apply to us. Our Website is not directed to children under the age of 13. As a result, our Website does not request nor knowingly collect Personal Information from individuals under the age of 13. If you are not 13 or older, you should not visit or use our Website. If we learn that personally identifiable information of persons under 13 years of age has been collected on the Website without verified parental consent, we will take appropriate steps to delete the information.

External Links

We may make available third party applications through our Website, blog and social media applications for your use. Links to such applications, any other websites included in this Website or links on our social media accounts operate with privacy policies beyond our control. Unless otherwise indicated, once you have left our Website or our social media account, all use of information you provide is governed by the privacy policy of the other website’s or social media account’s operators. We are not responsible for any transactions that occur between you and a third-party website or social media account.

Contact Preferences & Email Marketing

We would like to keep in touch with you in ways that you find to be beneficial. If you do not want us to use your contact information to communicate with you, please tell us so when you provide your contact information. We may send promotion emails regarding our services and events. You may opt in to receive emails from us by providing your email address to us. If you no longer wish to receive email marketing communications from us, you may opt-out of receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the “unsubscribe” link in the email to unsubscribe) or by contacting us at [email protected].

Do Not Track Notice: Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to Do Not Track signals. In addition, we may allow third parties to collect Personal Information from your activity on our website, as described in the “Information Collection and Use” section above.

Security

We take appropriate steps to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration or destruction, whether in transmission or storage. Please keep in mind, however, that there is no such thing as perfect security, and no Internet transmission is ever completely secure or error-free.

Governing Law

This Policy and our privacy practices will be subject exclusively to the laws of the State of New York, United States of America. We make no representation that this Policy and its practices comply with the laws of any other jurisdiction.

Changes to This Privacy Policy

This Privacy Policy may be revised from time to time for any reason. If this Privacy Policy changes, the revised policy will include a new effective date and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Privacy Policy whenever you submit personal Information or use our website.

Contact Us

If you have questions or concerns related to this Privacy Policy or our information practices, would like to update or correct information you have provided or would like to opt-out of promotional communications from us, please contact us as follows:

CALIFORNIA CONSUMERS ONLY:

Your California Privacy Rights

This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). This Policy applies to our offline and online data collection practices, including when you visit our website at www.gallagherdesign.com (“Website”), inquire about our services, or when you engage or communicate with us via email or other methods both offline and online. If you are not a California resident, this Notice does not apply to you. Please review our Privacy Policy (“Policy”) above for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.

Information Collected

Within the past 12 months, we have collected the categories of personal information about California consumers as described in Annex 1.

Business-to-Business (“B2B”) Information

If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, we collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship. We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship. We do not disclose that information outside our business relationship without your consent. See Annex 1 below for more details.

Information Sold or Shared

We have not sold or shared any personal information in the preceding 12 months.

We have disclosed the following categories of personal information for a business purpose in the preceding 12 months:

• Personal Identifiers
• Internet Activity

We do not knowingly sell or share the personal information of individuals under 16 years of age without affirmative authorization.

For details regarding the categories of third parties with whom we have shared, sold, or disclosed personal information, please see Annex 1, below.

CPRA Rights and Requests

Under the CPRA, you are entitled to certain rights, and you can make certain requests with regard to those rights as follows:

• Right to Know and Access Categories of Personal Information Collected (“Right to Know”)
• Right to Request Deletion of Personal Information (“Right to Delete”)
• Right to Correct or Rectify Inaccurate Information about you (“Right to Correct”)

How to Make Your Requests to know, delete, or correct.

You have the right to make requests for the aforementioned rights (Request to Know; Request to Delete; or a Request to Correct (a “Request”).

To make a Request for any of the information set forth above, please submit a verifiable consumer request pursuant to the instructions below. The Request must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold, shared, or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request. We will acknowledge your Request within 10 business days and will attempt to respond substantively within 45–90 days.

You may make a Request the following ways:

Once we receive your Request, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identity.

We will review all information provided by you to us, to determine whether we can respond to your Request. We will inform you of our decision to deny or grant your Request.

For Requests to Know, you may make such Requests twice within a 12-month period.

For Requests to Correct, you will need to provide evidence supporting the inaccuracy of the current information, and we reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.

We will retain correspondence, documents and information related to any Request for 24 months as required by law.

Additional CPRA Rights

The following are additional rights afforded to you under the CPRA.

Right to Know Sensitive Personal Information Collected

We do not collect or process sensitive personal information as described in Annex 1.

Right to Know and Opt Out of Automated Decision Making

You have a right to know about and opt out of certain automated decision making processes. We do not engage in automated decision making with your personal information. For more information, please contact us at [email protected].

Right to Non-Discrimination for Exercising Consumer Privacy Rights

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein. Some of the functionality and features available to you may change or no longer be available to you in some instances.

Right to Opt Out of Sharing and Selling of Personal Information

You have the right to opt out of sharing or selling of your personal information, as those terms are defined under the CPRA. As discussed above, we do not sell or share your personal information.

Cookies

As explained in our “Cookies” section above, you can opt out of cookies using your browser. Please note:

• Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.
• Opt-outs may be stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
• We may still share your information with our service providers that help us perform functions that are necessary for our business such as vendors that host our Site, analytics processors, etc. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.

Authorized Agent Information

You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.

Authorized agents can make requests under the California Consumer Privacy Act by emailing us at email address: [email protected] or calling us at 212-951-0800. We will require authorized agents to provide proof of the consumer’s identity and proof of designation as the authorized agent. We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request.

We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

Other California Privacy Rights

California Shine The Light Law

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please email us at [email protected] with a reference to California Disclosure Information.

We will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are required to respond to each customer only once per calendar year.

California Do Not Track Notice

Because there are not yet common, industry-accepted “do not track” standards and systems, our website does not respond to Do Not Track signals. In addition, we may allow third parties to collect personal information from your activity on our website, as described in the “Information Collection and Use” section above and as described in Annex 1 below.

Contact for More Information

For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at [email protected] or call us at 212-951-0800.

This Policy may be revised from time to time for any reason. If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Policy whenever you submit personal information to us.

Annex 1

Notice of Collection, Use, and Disclosure