CDM Smith Online Privacy Statement

Your entry of information on our websites constitutes your acknowl­edge­ment of receipt of this Privacy Statement, and your consent for us to collect, use and disclose the information in accordance with this Privacy Statement.  

What’s covered by this Privacy Statement
Any CDM Smith website which links to this Privacy Statement is covered by this Privacy Statement. This Privacy Statement does not cover, and we are not responsible for third-party websites or appli­ca­tions that may be linked from our websites as described in the Links to Other Websites and Third Parties section of this Privacy Statement. These websites are hosted and maintained within the United States. 

Information We Collect
We and our Service Providers may collect information that you provide us voluntarily or that you have consented to for its collection. When you interact with us online, register or inquire for a service, such as when you provide us with certain personal information in connection with an application for employment, complete the “Contact Us” form on the website, send us an e-mail address in a request for information, or when you otherwise share your information with us. 

In some cases where you have registered or submitted your information for certain services with CDM Smith or our Service Providers, your privacy rights will be determined by the notice provided at or during the time of collection and is associated with the service being offered. In the event of a conflict between our privacy notice and the notice of our Service Provider, the specific notice provided with the service applies. As an example, you may voluntarily provide personal information in connection with a job application. The collection or delivery of your personal information is subject to the privacy policy of the Service Provider’s platform when you use it to submit your application. You will have the opportunity to review their privacy policy before providing your personal information.

We may also collect your information if you contact us through our web forms, which may include your name, email address and telephone number; if you create an account on our website, which may include your username and password; or if you apply for a job through our website, which may include details from your job application. 

Many of the pages on our website (insights, projects, news releases) can be e-mailed, either to yourself or others you choose. Information we collect directly may include your name, title, address and phone number. Other information is collected auto­mat­i­cally, such as usage, viewing, and technical data, through the use of cookies and similar tech­nolo­gies. This may include your IP address and the type of browser and operating system you are using.

By submitting a telephone number to us you agree that a repre­sen­ta­tive of CDM Smith, or a third party on CDM Smith's behalf, can contact you at the number you provide, potentially using automated technology (including texts/SMS messaging) or a pre-recorded message. Your consent is not an obligation to receive any of our products and/or services.

Purposes and Legal Basis of Processing
CDM Smith processes personal information in the following ways:

As applicable, when we receive explicit consent to do so, we will process information voluntarily submitted to us to send you requested materials or provide information about our services. If you have requested to sign up for our newsletter, we may also use your personal information to provide information about services we think may be of interest to you. 

If you are an EU resident, the legal basis for the processing of your personal data in these cases is Art. 6 (1) (a) GDPR. 

Users who wish to stop receiving these materials may unsubscribe by clicking on the link in those materials.

As applicable, when we receive your explicit consent to collect information via cookies, we also may use viewing data to analyze how visitors use the website in order to provide statistics and improve the experience of interacting with the website. 

Disclosure, Sharing and Transfer of Your Information
We may disclose, share and transfer your information to the extent consistent with applicable law and in the following circum­stances:

• With our Company affiliates and subsidiaries worldwide;
• With business partners and third-party business providers who use your personal information to provide services to us, such as companies that provide us career recruitment, technical support, data hosting, and services;
• As required by law or court order;
• In connection to a merger, acquisition, reor­ga­ni­za­tion, or liquidation of CDM Smith;
• To auditors, contractors or other advisors auditing any of our business processes;
• Where we are legally required to disclose your information; and
• When we are contrac­tu­ally obligated to disclose it.

Third Party Service Providers may also act on our behalf to collect and use data that assists in the hosting, maintenance, and improvement of this website. Service Providers are third-party entities that provide specific services (e.g., online job application intake) on behalf of CDM Smith and are contrac­tu­ally prohibited from using your personal information for any purposes other than to deliver the requested services to us.

CDM Smith requires Third Party Service Providers who process information on CDM Smith’s behalf to provide adequate safeguards for your personal information (e.g., restriction of their access, use and disclosure of personal information, solely to meet their contractual obligations in the performance of the specific functions described above). A copy of these safeguards may be made available by writing to us at the address provided in the Contact Us section below.

We do not sell your personal information to third parties. 

Retention
Information collected through this website will be retained for the period necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law.

Links to Other Websites and Third Parties
To allow you to interact with other websites on which you may have accounts (such as Facebook and other social media platforms), to apply for a job at CDM Smith, or to interact with some of our Service Providers, we may provide links or embed Third-Party appli­ca­tions that provide these connections. CDM Smith is not responsible for the collection of personal information or the security or privacy of information on any Third-Party websites or appli­ca­tions. Your use of these links is subject to the Third Party’s privacy policy, and you should become familiar with their practices before using the links or appli­ca­tions. CDM Smith cannot guarantee the privacy and safety of these websites and is therefore not responsible for any content you post. Use these features at your own risk.

Cookies and Similar Tech­nolo­gies
The first time that you visit our website, we notify you about our use of cookies through a noti­fi­ca­tion banner and we request your explicit permission. You may withdraw your permission for using these cookies at any time by following the opt-out link provided.

A cookie is a small piece of data that a website can send to your browser, which may then be stored on your hard drive as a “tag” that identifies your computer. Cookies can allow us to properly format the web page on subsequent visits for your specific computer and browser, letting us personalize your experience and tailor our inter­ac­tions with you. Cookies also help us to gather anonymous statistics about usage and effec­tive­ness of our website. An example of this is CDM Smith’s use of Google Analytics. The tool uses cookies to collect standard Internet log information and visitor behavior information. The information generated by the cookie about your use of this website, including your IP address, is transmitted to Google. This information is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity for us. We do not use the statistical analytics tool to track or to collect any Personal Information of visitors to our website. We do not seek to link an IP address with the identity of a computer user. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser. Google’s ability to use and share information collected by Google Analytics about your visits to this website is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. 

We occa­sion­ally embed video content from websites such as YouTube or Storify, which may embed their own cookies from these websites. These Third-Party websites may set a cookie when you are also logged in to their service. CDM Smith does not control the dissem­i­na­tion of these cookies. You should check the relevant third-party website for more information about these.   

Most web browsers auto­mat­i­cally accept cookies, but you can change your browser’s settings to disable cookies if you wish. However, disabling them could diminish the func­tion­al­ity of the website and negatively impact your experience with our website.

Most web browsers also allow you to set a ‘do not track’ signal visible to websites. Our Site will respond to these signals. To learn more about how to enable these signals, you can visit the Digital Advertising Alliance’s (DAA) website. You can access the DAA’s universal, easy-to-use choice mechanisms available at both optout.​aboutads.​info and your adchoices.​com/​control.

For Google Analytics, as noted above, you can install an opt-out in your web browser. There are also browser-specific do not track settings. For example:

• Safari 13.1 or higher:

1. In the Safari app on your Mac, choose Safari > Preferences, then click Privacy.
2. Select “Prevent cross-site tracking.”

• Chrome:

1. On your computer, open Chrome.
2. At the top right, click More : > Settings.
3. Under “Privacy and security,” click Cookies and other site data.
4. Turn Send a “Do not track” request with your browsing traffic on or off.

• Firefox:

1. Click the menu button and select Options.
2. Select the Privacy & Security panel.
3. Under Enhanced Tracking Protection, select the Custom radio button to choose what to block.
4. Select the Cookies checkbox. Cross-site and social media trackers is the default setting.
5. Close the about:preferences page. Any changes you’ve made will auto­mat­i­cally be saved.

We do not track users across time or across websites, and we do not use flash cookies.

Advertising and Marketing
When you visit or use our Service Providers’ sites, you may engage with cookies, plugins or similar tech­nolo­gies that are controlled by your privacy settings on those sites. Depending on your settings, our Service Providers may collect and share information with us, including when you view, like or share content/posts we have published on their platforms. We may also receive information about you when you use Service Provider features on partner sites (such as “Apply with LinkedIn,” which lets you pre-populate job appli­ca­tions with your profile data on job forums outside LinkedIn).

As a result of your settings, activity, and the personal and profes­sional demographic data you include on the Service Providers’ sites, we may target adver­tise­ments about our services to you within their platforms and partner sites. We may also display interest-based ads, sometimes referred to as person­al­ized or targeted ads, using information you make available to us when you interact with our site, content, or services and/or products.

Ad companies working on our behalf sometimes use technology to serve ads about our products and services via their partner sites. This type of advertising is often referred to as retargeting; for example, you may visit our site, read about a product or service, leave our site and then see a display ad on another site about the same product or service. Those third parties auto­mat­i­cally receive your IP address when this happens. They may also use cookies to measure the effec­tive­ness of the ads and to personalize ad content. We do not have access to or control over cookies or other features the third party websites may use, and the information practices of these third parties are not covered by our Privacy Policy. If you wish to opt-out of this type of online tracking, please visit the Digital Advertising Alliance’s website (or https://​www.​youron­line­choices.com/) or the Network Advertising Initiative’s website for more information.

To summarize the types of data we use when targeting ads, the following may be used separately or combined:

• Data about you that the Service Providers collect through their own pixels, ad tags, cookies and device identifiers;
• Data you give the Service Providers about yourself in your profile pages (e.g., name, company name, job title, industry);
• Data you give to CDM Smith through our opt-in marketing processes, such as when you fill out a form on our website to send us a contact message, subscribe to receive marketing email content, download white papers, or register for events that interest you; and,
• Similar data you give to CDM Smith via other marketing tech­nolo­gies (e.g., chat bots) we may use to help you find information on our website about industry hot topics or our services.

We do not sell or share your personal information for a commercial purpose with any third-party advertisers or ad networks. We promote our services to you and others who seek more information and have consented or opted in to receive it.

We will not use personal information we collect for materially different, unrelated, or incom­pat­i­ble purposes without providing you with notice and/or updating this Privacy Policy. In addition to marketing and advertising our services, we use information that you provide to share commu­ni­ca­tions related to news and events happening in the industry or sector for which you’ve requested information or that may be of relevance to you (e.g., legislative alerts).

We use data, including your feedback, to conduct research and development for our services to provide you and others with a better, more intuitive, and person­al­ized service experience.

Security
CDM Smith takes reasonable admin­is­tra­tive, technical, and physical measures to protect the security of Personal Information from unau­tho­rized access, use, and disclosure. This includes policies that limit access, technical controls including firewalls, and other security measures. We also require our partners and Service Providers protect such information that we provide to them. Nonetheless, the trans­mis­sion of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us elec­tron­i­cally on our website, and trans­mis­sion of such data is therefore entirely at your own risk.

Children’s Privacy
This website is intended to be used by adults and corporate entities interested in our solutions and services, and, as such we do not knowingly collect or store personal information from anyone under the age of 16. If at any time we are informed that a visitor under the age of 16 has submitted information to us through this website, we will endeavor to promptly delete the information.

By using our website, you affirm that you are at least 16 years of age or older. We are not liable for any damages that may result from a user’s misrep­re­sen­ta­tion of age.

No one under age 13 is authorized to submit or post any information, including personally identifying information, on our website. Under no circum­stances may anyone under age 13 use our website. Parents or legal guardians of children under 13 cannot agree to these terms on their behalf.

Notice to Individuals located in the European Union of European Economic Area and Your rights in connection with your Personal Information
Under certain circum­stances, and as required by law, you have the right to:

• Request access to your personal information. This enables you to receive a copy of the personal information we hold about you.
• Request correction of any incomplete or inaccurate personal information that we hold about you.
• Request erasure of your personal information when there is no need for us continuing to process it or you have exercised your right to object to processing (see below).
• Object to processing of your personal information for direct marketing purposes, including profiling to the extent that it is related to such direct marketing, at any time.
• Request the restriction of processing of your personal information to suspend the processing, for example if you want us to verify its accuracy or the reason for processing it.
• Request to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format, including to transmit those data to another controller without hindrance.
• Withdraw consent you have previously given to us for the processing of your personal data at any time, but without affecting the lawfulness of such processing of your personal data before the withdrawal.
• If you are located in the EU, you have the right to lodge a complaint with an EU Supervisory Authority. However, if you have a complaint regarding the processing of your personal information, we encourage you to first contact us and we will reply on timely basis.

If you want to exercise any of these rights, please submit your request to the contacts named in the Contact Information section of this Privacy Statement. Valid requests will be honored within 30 calendar days of request. This 30-day period may be extended for another two (2) months for complex requests with noti­fi­ca­tion of the reasons for the extension to you.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alter­na­tively, we may refuse to comply with the request in such circum­stances. In addition, there may be requests that we are unable to process because of other EU legal require­ments. If a request is denied, we will notify you of the reason.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Changes to this Privacy Policy
Due to changes in technology or legal require­ments, we may revise this Privacy Statement from time to time. We will notify you of changes by posting those changes on this page, or by other appropriate means. 

Acces­si­bil­ity Statement 
We are committed to making sure that our website is accessible to everyone. To access this Privacy Statement in an alternative form, please email us at privacy@​cdmsmith.​com . For more information, please see our Acces­si­bil­ity Statement.

NOTICE OF CALIFORNIA PRIVACY RIGHTS
“Shine the Light Law.” While CDM Smith does not provide your personal information to third parties for their use in marketing, under California law, California residents have the right to opt-out of such use of your personal information if it occurred.

If you are a resident of California, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collec­tively "CCPA”): 

a) to know what categories of personal information about you we have collected and used, including how the personal information was collected;
b) to know what categories of personal information is being sold or disclosed, and if it is being sold or disclosed to third parties and a list of categories of information that are sold (note that we do not sell any of your personal information); 
c) to opt out of the sale of your personal information (note that we do not sell any of your personal information);
d) to access your personal information, including the right to download or transfer personal information collected during the previous 12 months;
e) to request that your personal information be corrected;
f) to request that we limit our use of your sensitive personal information, as applicable;
g) to request that your personal information be deleted; and
f) to equal service and equal price for goods or services even if you exercise your rights under the CCPA. 

While California residents have the right to opt-out of the sale of their personal information under CCPA, we do not sell personal information to any third parties, and therefore, we have not included a “Do Not Sell My Personal Information” link on our Site. If our practices change, we will update this Privacy Policy and take any other necessary action to comply with applicable law.

However, we do share certain information collected through cookies and other analytics tech­nolo­gies which may be considered a sale under the CCPA and may be used for purposes of targeted advertising. As such, if you wish to opt-out of this non-essential tracking, you can learn how to enable these signals by visiting the Digital Advertising Alliance’s (DAA) website. You can access the DAA’s universal, easy-to-use choice mechanisms available at both optout.​aboutads.​info and yourad­choices.com/control. 

A consumer or their repre­sen­ta­tive may instead submit a request to opt out of sharing or selling by sending an email to privacy@​cdmsmith.​com. 

Please note that online opt-outs are device and browser-specific. You may still see person­al­ized ads from us while using a different device or browser, unless you also opt-out using that device or browser. 

If you are a California resident and you want to exercise any of your rights as set forth above, please contact us at us at (888) 312-9266 or email us at privacy@​cdmsmith.​com  or submit your request online. For all requests, it is helpful to put the statement “California Privacy Rights” in the body of your request, describe the nature of your request, and provide your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response. For more information, read the full Privacy Notice for California Residents.

We will not discrim­i­nate or retaliate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 

Contact Information
If you have any questions, inquiries, individual rights requests or complaints, please contact us at:

CDM Smith
75 State Street, Suite 701
Boston, MA 02109 USA
Attn: Privacy Office
Email: privacy@​cdmsmith.​com

For individuals in the following countries, inquiries or complaints may also be addressed to the following:

Germany 
CDM Smith SE
CDM Smith Consult GmbH
Am Umweltpark 3-5
44793 Bochum, Germany
Attn: Data Privacy Office
Email: priva­cyeu­rope@​cdmsmith.​com

Data Protection Officer in Germany:
Scheja und Partner Rechtsanwälte mbB
Adenauer­allee 136
53113 Bonn
Germany
Email: info@​scheja-​partner.​de

Poland
CDM Smith Sp. z o.o.
Al. Jero­zolim­skie 123a
02-017 Warsaw, Poland
Attn:  Data Privacy Office
Email: priva­cy­poland@​cdmsmith.​com

If you are located in the EU, you have the right to lodge a complaint with an EU Supervisory Authority. However, if you have a complaint regarding the processing of your personal information, we request that you first contact us and we will reply on timely basis.

Data Controller
As it pertains to users of our websites located in the EU, the controller of your personal information is CDM Smith, Inc., 75 State Street, Suite 701, Boston, MA 02109 USA.