Your privacy is important to 1901 Group (“1901 Group,” “we,” “us”). You may choose to provide personal information when you communicate with us using this website. The information we collect, and the ways in which that information is submitted, collected, stored, processed, and transferred are set out herein, along with the ways we may use and protect that information.
Before accessing or using our website, please read and make sure you understand our collection, storage and use of your personal information. By accessing or using our website, you are accepting and consenting to the practices described in this policy.
This policy generally applies to information we collect through our website. It does not apply to information we collect offline or through any other means. The CCPA Notice includes information about California residents that we collect online and offline.
We collect personal information online when you voluntarily submit information to us, either using a form on our website or by submitting your resume and job application. Personal information being collected is generally limited to name and email address and any other information contained in your application, such as work history, education, skills and experience. We use the collected information for our general commercial purposes such as to improve our website, grow our business and to offer our own, our affiliates’ or third-party products or services that we think you may find of interest. We use your contact information to respond to your inquiries or to provide information on products or services to you.
You can submit your resume and other information online using www.1901Group.com to apply for jobs with 1901 Group. We use a third-party service provider called Jobvite to help us conduct recruitment-related activities. The information you submit goes directly to Jobvite’s platform and is used to evaluate your job application and to contact you regarding possible careers with 1901 Group.
You may choose to contact us through our website. If you email us or submit comments or questions using the Contact Us form on this website, we will use the information you provide to respond to your inquiries.
1901 Group does not use any 1901 Group-specific cookies to collect data or user information. Some of the features of services we use, such as Google Analytics, media players, and WordPress, are used by default. 1901 Group does not store any of the information received by these third parties and has no control over the third parties or the information they may collect and store. We allow selected third parties to place cookies through our website to provide us with better insights into the use of the website or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website.
Do Not Track Disclosure
We currently do not use technology that recognizes a ‘Do-Not-Track” signal from your web browser.
Links to Other Websites
We may provide links to other websites for your convenience and information. These sites operate independently from www.1901group.com and may not be under our control. These sites may have their own privacy notices in place, which we strongly suggest you review if you visit any linked websites. The entities that operate these sites are responsible for the content of their sites, any products or services they may offer through their sites, or any other use of their sites.
We do not sell, rent, trade, or otherwise disclose personal information about our website visitors, except as described here.
We may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (iv) to our agents, outside vendors or others who provide functions on our behalf (e.g., analyzing data, providing marketing or hiring assistance, providing customer service, processing orders, etc.).
We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the transferee uses personal information you have provided through this website in a manner that is consistent with this privacy notice.
Information Storage and Transfer
Personal information you submit to us is stored in a controlled environment with limited access. Because no transmission of information using the internet is completely secure, we cannot guarantee the security of your personal information during transmittal, and any transmission is at your own risk. We maintain up-to-date administrative, technical, and physical safeguards to protect against unauthorized disclosure, use, alteration, or destruction of the personal information in our possession.
We do not transfer or store personal information outside of the United States.
Information We Retain
We keep your information only as long as we need it for the purpose it was collected, including our legitimate business interests and any legal or reporting requirements. In determining the length of time we will keep your information, we consider the nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes we may retain it, and relevant legal requirements.
Notice to California Residents
Your California Privacy Rights. California law permits customers who transact with 1901 Group for personal, family or household purposes and who reside in California to request disclosure or an opt out if we share their information with third parties who are permitted to use the information to directly market their own products or services. 1901 Group does not share such information with third parties for their direct marketing purposes.
California Consumer Privacy Act (“CCPA”) Notice.
CCPA Rights. Verified California residents have the right to:
• Request and receive disclosure of our personal information collection practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information.
• Request and receive a copy of the personal information we have collected about them during the prior 12 months.
• Request and receive disclosure of our information sharing practices during the prior 12 months, including a list of the categories of personal information sold with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose.
• Request that we not sell personal information about them.
• Request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.
The foregoing rights do not apply to our current, former, or prospective employees and the employees of our business partners. In order to make a request for disclosure California residents may contact us by either calling toll free 855-891-4928 or emailing us at Privacy@1901group.com. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. Please understand that we cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time.
For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well.
We will not discriminate against you as a result of your exercise of any of these rights.
Using an Authorized Agent. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorize the person to make the request on your behalf, (4) you verify your own identity directly with us, and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.
Information Collected and Sources. We collect personal information from California residents when they interact with us online through our website or offline. This includes information that provided to us directly, information we collect automatically, information that we may collect from third parties such as service providers, affiliated companies, marketing or data partners, or other third parties with whom you interact. It also includes information that we collect about employees and business partners and vendors from those individuals directly or from references, referrals or consumer reporting agencies. Not all information is collected from everyone who interacts with us.
During the past 12 months we may have collected the following categories of personal information:
• Identifiers such as contact information (your name, address, phone number, email or postal address), Unique Personal Identifiers (that may include but are not limited to your legal name or preferred alias and online identifiers like user account names), an encrypted version of your password, communications. We may collect additional information from suppliers, vendors, or employees including business contact information, phone number, email and postal addresses and titles.
• Sensitive information such as financial and payment information like credit or debit card information.
• Commercial information such as transaction histories, billing and shipping information, and product preferences.
• Inferences we make about you or your interests based on analysis of other information we have collected.
• Geolocation information that may be identifiable using your IP Address.
• Audio or video information such as call center recordings or monitoring records from our customer support centers and security video recordings at our facilities.
• Employment, education and professional related information, protected classification information, biometrics (collected from current and prospective employees, contractors, service providers, vendors and suppliers).
• Other types of personal information that we may disclose to you prior to the point of first collection.
Business Purposes for Collecting Personal Information. We collect personal information in order to operate and grow our business, improve our website, and to offer our or third-party products or services that we think you may find of interest. More specifically, we collect personal information for the following business purposes:
• Provide the services and information you have requested from us and notices relating thereto including providing customer and technical support for our services and collecting fees or other amounts owed in connection with those services.
• Verify that you qualify as a registered user of our services.
• Provide information to you about our products or services and third-party products and services that we think may be of interest to you.
• Provide you with marketing communication and information.
• Analyze, improve, and customize our services including measuring the effectiveness of advertising and internal research on users’ interests and behaviors to better serve our users.
• Administer the website, web platform and services and for internal operations, including troubleshooting, data analysis, testing, research, security, statistical and survey purposes.
• Respond to your inquiries about posted job positions and evaluate employment applications.
• For legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud.
• Internal and external audit requirements, information-security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions or other agreements; and (d) to protect our rights, privacy, safety, or property, or those of other persons.
Information Shared for a Business Purpose. During the past 12 months we have disclosed the following categories of personal information to the following types of third parties for a business purpose.
• Service providers: We may have shared your information such as identifiers, commercial information and financial information with our service providers who provide us support services such as hosting our website, processing payments, legal and accounting professional services, postal delivery and electronic mail, mobile messages, conducting analysis to improve our products and Site, fulfilling requests you make, managing payments and answering your questions. Service providers only use the information they receive from us for the purposes we hired them for; we don’t allow them to retain, use or otherwise handle the data for their own purposes.
• Marketing Partners: We may have shared your information such as electronic network activity, identifiers, commercial information and inferences with marketing partners to display online, mobile or other advertising based on your activity on websites and mobile apps, and preferences you share with us so we can provide you with promotions and special offers that may interest you. We may also share information with marketing partners to help us analyze data, sometimes combined with other sources, so that we can send more relevant communications to you.
• Third Parties, including governmental authorities and law enforcement, for legal or compliance purposes: We may share any or all categories of your information where we believe the disclosure is required by law or otherwise necessary to comply with the law, regulatory requirements, requests from public authorities, or to enforce our agreements or policies or protect or defend the rights and property of our customers, the company, our partners or the public (including for fraud prevention purposes).
Selling Personal Information. We do not sell your information for monetary or any other valuable consideration.
Notice to Nevada Residents
We do not transfer personal information for monetary consideration. If you would like to tell us not to sell your information in the future please email us at Privacy@1901group.com with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.
Notice to European Union and United Kingdom Residents
In accordance with applicable privacy law, residents of the European Union and the United Kingdom may have the following rights with regard to your personal information that we hold:
Right of access and transferability. The right to obtain access to your personal information along with certain information, and to receive that personal information in a commonly used format and to have it transported to another data controller.
Right to delete. The right to have your personal information deleted without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
Right to non-discrimination. The right to not be discriminated against if you exercise any of the rights described in this policy.
If you reside in the European Union (EU), 1901 Group is the controller of your personal information for purposes of European data protection legislation. You also have the right to lodge a complaint to your local data protection authority. Information about how to contact your local data protection authority is available at ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Our Policy Regarding Children
Our website is not directed at persons under 16 years of age and we do not intend to or knowingly collect personal information from children. If you believe that a child has provided us with personal information, please contact us using the contact information below so that we can take appropriate action in accordance with our policy and the law.
Updates to this Privacy Notice
We may change or update portions of this privacy notice at any time and without prior notice to you. You should review this policy periodically. When this policy is updated, we will post the updated policy here with an updated version and effective date at the bottom.
© 2020 1901 Group
Digital Millennium Copyright Act Notice
If you believe that any content on this site infringes on your copyrights, you may submit a written notification of claimed infringement to 1901 Group’s designated agent (see below). Your notification must include the following, pursuant to 17 USC 512(c)(3):
- A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
- Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site.
- Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit 1901 Group to locate the material.
- Information reasonably sufficient to permit 1901 Group to contact you, such as an address, telephone number, and, if available, an electronic mail address at which you may be contacted.
- A statement that you have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.
- A statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
You may submit the notification to 1901 Group’s designated agent:
Executive Counsel Plc
2883 Macao Drive
Herndon, VA 20171
Section 508 Compliance
Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794 (d)) in 1998 requires Federal agencies to make their electronic and information technology accessible to people with disabilities. Inaccessible technology interferes with an individual’s ability to obtain and use information quickly and easily. 1901 Group recognizes and acknowledges the requirement for compliance with Section 508 of the Rehabilitation Act and the Accessibility standards within 36 CFR part 1194.