Privacy STATEMENT

We at Vendome Partners LLC respect your concerns about privacy and value the relationship that we have with you. We want you to know what happens to the personal information that we collect through the following website(s) www.vendomepartners.com and www.cavanaughmitchell.com and ("our Websites"); our social media activities on LinkedIn, Instagram, Twitter, and/or Facebook ("our Official Social Media Accounts"); and our other activities and sources.

For purposes of this Privacy Statement, "personal information" means information from or about you that identifies you directly and information that is associated with you and thus could potentially identify you, including when combined with other information from or about you.

Vendome Partners LLC is a U.S.-based consulting firm with international clients. As a result, personal information that we collect and personal information that we receive from clients may be transferred to our U.S. offices to permit us to comply with our legal and contractual obligations, to provide information and services to our prospective and current clients, and to perform related business services. In addition, we may transfer personal information to third-party service providers and business partners, in the U.S. and in other countries, to the extent necessary to support Vendome Partners LLC 's business activities. Thus, personal information that we collect may be transferred to and stored on servers located in the United States and in countries different from the country in which that information was initially collected. Similarly, personal information may be accessed by Vendome Partners LLC and its third-party service providers and business partners from countries other than the ones in which the personal information is stored.

This Privacy Statement does not apply to personal information arising from Vendome Partners LLC 's employment-related activities, which may be covered by a separate internal Employee Privacy Statement.

Our receipt, use, and disclosure of personal information that is protected health information under the Health Insurance Portability and Accountability Act ("HIPAA") are subject to the requirements imposed on us by HIPAA and any additional requirements imposed on us by our clients. For more information, please refer to HIPAA-Protected Personal Health Information, below.

California Residents – please see Information for California Residents, below.

EU Residents – please see Transfers of Personal Information from the EU to the U.S. and Other Non-EU Countries and Additional Rights for EEA Residents, below.

For information about how we collect, use, and share your information, please see below.

Vendome Partners LLC is committed to working with you to obtain a fair and rapid resolution of any queries, complaints, or disputes about privacy. If you have any questions or comments about our Privacy Statement or our information collection and data protection practices, please contact us at info@vendomepartners.com.

Information that We Collect From and About You

Information that We Collect Directly
Vendome Partners LLC may obtain information (primarily name, contact information, employer, title, and type of business) directly from and about you in a number of ways, such as:

  • Through interactive forms on our Websites, if you choose to provide it;

  • Through your registration for, or attendance at, one of our events;

  • Through your conversations with someone from the Firm;

  • Through your use of and access to our, newsletters, emails, and Official Social Media Accounts; and

  • Through other public sources.

Information that We Collect Through Cookies and Technology
When you visit our Websites or open an email or newsletter that we send you, we may collect information about your usage and device by automated means or by using technologies such as cookies, web server logs, and web beacons. As set forth in more detail below, we may also collect information about your usage and browsing habits using various web-based technologies, including but not limited to Cookies. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Some cookies may exist for only a single session and some are persistent for multiple sessions over time.

You have a right to a copy of the personal information which we hold about you, and you have a right to have that information amended if it is inaccurate. For further information about our privacy practices, please send an e-mail to info@vendomepartners.com. We will do our utmost to respond to your query within 14 days.

Cookies
A "cookie" is a very small data file comprised of text and/or numbers that downloads on your computer hard drive (via your web browser) when you visit a website. Cookies notify a web server that you are returning to a specific web page on it, and they contain information about your web browsing that can save you time, such as by remembering your preferences, or they can track certain web browsing data (such as which site pages are more important in terms of traffic or which web browsers are preferred by site visitors) that can aid websites in enhancing the user/visitor experience. Cookies cannot be executed as code or deliver viruses, and they can be controlled by end users through their browser settings (see below).

How We Use Information that We Collect From and About You
Your Control Over Information that We Collect From and About You
Who Do We Share Personal Information With, and Why?

Interaction with Your Social Media Accounts
Our Websites and Official Social Media Accounts, as well as the websites of some of our third-party service providers, may permit you to connect and share your online activities and interactions with us and our content with your online community through your accounts on social media platforms such as YouTube, LinkedIn, Instagram and Twitter, including through the use of social media plugins (such as the Twitter "Tweet" button). The operator of that social media plugin may set cookies or other tracking technology on your browser to recognize its users when they visit our Websites again. In addition, if you are logged into one of your social media accounts while you are browsing on our Websites, the social media plugins may allow the social media platform to receive information about your visit – including the pages that you viewed – and to connect information about your visit to our Websites with other personal information regarding your social media account.

When you use social media plugins to connect to your social media account, we may receive or review certain information that you post on that service in accordance with the Privacy Statement of that service and the privacy settings that are applicable to your account. This allows us to share information about your activities on our Websites with other users of their social media website. For example, Twitter social media plugins allow Twitter to show your Tweets and comments on our Websites to your Twitter followers. Your use of social media plugins is subject to each social media platform's Privacy Statement, and we encourage you to use care and thoughtfully read the Privacy Statement of each social media platform that you use. We have no control over the information that social media websites or social media plugins collect, store, or use. Before connecting to our Websites from a social media website or using a social media plugin on our Websites, please be certain that you understand the social media website's Privacy Statement and how it may gather information about your use of our Websites.

How Do We Protect Personal Information?
We maintain reasonable risk-based physical, technical, and administrative safeguards to protect against unauthorized and accidental disclosure, use, alteration, or destruction of personal information in our possession, and to maintain the confidentiality, integrity, availability, and resilience of our systems, data, and services. We restrict access to personal information to those individuals and third parties that need to know the information to accomplish the authorized business purposes described in this Privacy Statement. We are committed to taking appropriate measures to enforce compliance with this Privacy Statement. In addition, we comply with applicable law and with client-specific requirements for protecting personal information.

We provide reasonable security controls to protect electronic information that we receive from you against foreseeable hazards, but please note that no data transmission over the Internet and no data security measures can be guaranteed to be 100% secure. In addition, use of email to transmit personal information is insecure and violates Vendome Partners LLC policy. Please contact us if you need a more secure method for transmitting personal information.

Vendome Partners LLC uses the following cookies:
Controlling Cookies

Information that We Receive About You While Representing Our Clients
Our clients and others may provide personal information to us in connection with our representation of a client in a particular matter. The nature of the personal information provided will depend upon the specific matter, but may include medical, financial, family, and educational information, conduct and belief information, and other similarly sensitive categories of personal information.

Our clients and prospective clients are responsible for complying with all applicable federal, state, local, and international privacy laws and regulations regarding notice, disclosure, consent, and cross-border transfer requirements prior to providing personal information to Vendome Partners LLC. In addition, our clients and prospective clients are also responsible for identifying, in the representation agreement or in a related document, any additional requirements for protecting and handling personal information in a particular matter that exceed the risk-based administrative, technical, and physical safeguards that Vendome Partners LLC would otherwise routinely implement, that require a specific form of written privacy and data security agreement, or that otherwise require documentation because of inconsistency with this Privacy Statement.

Transfers of Personal Information from the EU to the U.S. and Other Non-EU Countries

Additional Rights for EEA Residents
Under the conditions provided for by the General Data Protection Regulation and in addition to the rights stated above, EEA residents have the right to request the restriction of the processing of their personal information, to object to the processing of their personal information for direct marketing purposes or, where the processing is based on legitimate interest, on grounds relating to their particular situation and to receive their personal information to transmit it to another data controller.

Transfers of Personal Information from Other Countries
We will comply with applicable law regarding collection and transfer of personal information from countries that have privacy or data security laws that are inconsistent with the practices described in this Privacy Statement.

Information for California Residents
If you are a California resident, you have the right to request information from us regarding the manner in which Vendome Partners LLC shares certain categories of your personal information with third parties, for the third-parties' direct marketing purposes.  California law provides that you have the right to submit a request, using the contact information shown below, and receive the following information:

  • The categories of information that we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and

  • The names and addresses of the third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.

Children's Privacy
We do not knowingly collect information from anyone under 16 years of age, and our Websites and Official Social Media Accounts are not directed at or intended for use by anyone under the age of 16. If you believe that we have collected information from anyone under the age of 16, please contact us as shown below and we will endeavor to return or delete any such information.

HIPAA-Protected Health Information
Vendome Partners LLC safeguards HIPAA-protected health information that we receive while representing clients by entering into Business Associate Agreements with clients and third-party service providers and by implementing HIPAA-compliant administrative, technical, and physical safeguards for each representation.

Links to Other Sites
Occasionally we provide links to other websites, social media platforms, or blogs for your convenience and information. Except to the extent that those websites, social media platforms, or blogs provide services with the authorization of and on behalf of Vendome Partners LLC, they operate independently from Vendome Partners LLC and are not under our control. These websites, social media platforms, and blogs have their own privacy notices in place, which we strongly suggest that you review if you visit any third-party links. Except to the limited extent that the third parties provide services to us or otherwise act our behalf, we are not responsible for their content, any products or services they may offer, or any other uses that are not related to Vendome Partners LLC services.

Data Retention
Pursuant to our retention policy, we retain personal information only as long as is necessary to accomplish the purpose for which it was collected, and as otherwise required for legal, compliance, or business requirements, and we securely delete it thereafter. The retention period will depend upon, among other factors, the status of your relationship with Vendome Partners LLC, Vendome Partners LLC 's legal ethical obligations, whether any applicable contract, law, statute, or regulation requires a specific retention period, and what the expectation for retention was at the time the data was provided to us.

How to Access, Change, or Delete Your Personal Information
You can update, correct, or delete your personal information, or you can ask us to remove it from our system by contacting us as shown below. If we cannot resolve your request promptly – within thirty (30) days or less - we will provide you with an estimated date by which the information will be provided. If we are unable to fulfill your request or if we deny your request, we will respond and provide an explanation.

Changes or Updates to this Privacy Statement
We may update or change this Privacy Statement from time to time and without prior notice to you. We will post a notice on this site to notify you of any significant changes to our Privacy Statement and indicate at the bottom of the Statement when it was most recently updated.

How We May Provide Notice to You

To the extent additional notice is required by law or otherwise, Vendome Partners LLC may deliver a general notice on our Websites and Official Social Media Accounts, or we may use email or other delivery methods if you have provided us with your contact information.

How You May Contact Us
If you have any questions about our information collection or our data protection practices, or if you wish to update or correct information provided to us or exercise any other rights you may have under applicable laws, please contact us at info@vendomepartners.com. We will respond promptly to your inquiries.
When making an inquiry, please always include a proof of identity to enable us to verify the lawfulness of the inquiry.

Effective Date:  March 1, 2022

Last Updated:  March 1, 2022