Privacy Policy

This Privacy Policy applies to all users of the austinshirepartners.com website. We adopt this Privacy Policy to comply with multiple United States federal and state privacy laws. By using the website, you agree to the terms of this Privacy Policy. You may revoke your consent at any time. If you do not agree to this Privacy Policy, do not use this website.

Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer ("personal information"). We collect information that you actively choose to provide to us, such as your name, address, phone number and email address when establishing an account (Active Information). By providing Active Information, you agree and consent to being contacted in response to any inquiries and regarding our or third party products and services. We also collect information about your use of the website via cookies and web beacons such as the information you click on, your browser type, IP address, referring URL and timestamp information. Some content or applications, including advertisements, on the website are served by third parties including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, web beacons, or other tracking technology to collect information about you when you use our website. We do not control these third parties' collection activities. Our website may contain links to third party websites to which our Privacy Policy does not apply, so consumers are advised to read the privacy policies for any such third party sites that they visit. In particular, our website has collected the following categories of personal information from its users within the last twelve (12) months:

Category	Collected
A. Identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	YES
C. Protected classification characteristics under California or federal law.	NO
D. Commercial information.	NO
E. Biometric information.	NO
F. Internet or other similar network activity.	YES
G. Geolocation data.	NO
H. Sensory data.	NO
I. Professional or employment-related information.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	NO
K. Inferences drawn from other personal information.	NO

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete when you register on our website.
• Indirectly from you. For example, from observing your actions on our website and the links that you click on emails that we send you.
• From third-party business partners including partners with websites on which we have placed web beacons, which allow us to determine that you have visited a particular website or have clicked on a particular link, and from other partners such as social media sites, ad networks, and analytics providers.

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you provide your personal information to utilize our services, we will use that information to deliver the service and refine our processes to more effectively provide services to you in the future.
• To recognize you when you return to our website.
• To process your requests, and to speed up your searches.
• To store information about your preferences, allowing us to customize our website according to your individual interests.
• To provide, develop, and support our website and our services.
• To create, maintain, customize, and secure your account with us.
• To personalize your experience on our website and to deliver content and product and service offerings relevant to your interests.
• To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our website and our services.
• To estimate our audience size and usage patterns.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the applicable privacy law.
• In the event that we need to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held about our website users is among the assets transferred.
• We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. We retain your personal information for three (3) years, for so long as you request services from us, or as permitted or required by law.

We may disclose or share your personal information with a third party, service provider or contractor for a business purpose. When we disclose or share personal information for a business purpose, we enter a contract that describes the limited purpose of the disclosure, requires the recipient to comply with provisions of applicable privacy laws including, without limitation, the required privacy protections, and not use the personal information for any purpose except performing the contract or as permitted by law. Additionally, the contract grants us rights to help ensure that the recipient uses the personal information in a manner consistent with our privacy obligations and permits us to take reasonable steps to stop and remediate unauthorized use of personal information. The recipient is required to notify us if it determines that it can no longer meet its obligations.

We share your personal information with the following categories of third parties:

• Service providers (advertisers, ad networks and servers, content providers and application providers).
• Data aggregators (collecting data from both online and offline sources).

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category F: Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers
• Data aggregators
• Sales of Personal Information

In the preceding twelve (12) months, we have not sold any personal information.

Residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia have specific rights regarding their personal information.

Consumers in the above mentioned states have the right to request that we disclose certain information to them about our collection and use of their personal information. You may also request that we disclose such information concerning personal information collected for an indefinite period beginning January 1, 2022 provided such disclosure would not involve a disproportionate effort or be impossible as defined under the applicable privacy law. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting, sharing or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

If we sold, shared or disclosed your personal information for a business purpose, two separate lists disclosing:

• Sales or sharing, identifying the personal information categories that each category of recipient purchased or that was shared with them; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete your personal information from our records (and notify our service providers, contractors, and third parties to whom we sold or shared your personal information to delete, and to notify their service providers, contractors, and third parties to delete, your personal information from their records), unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s), contractors, or third parties to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.

You have the right to request that we correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will use commercially reasonable efforts to correct the inaccurate personal information.

To exercise the access, data portability, correction, and deletion rights described above, please submit a verifiable consumer request to us by: Emailing us at abuse@austinshirepartners.com, or here or send us correspondence at the following address:

Austinshire Partners

Unit 10031, PO Box 6945, London, W1A 6US, United Kingdom

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. Although we never intentionally collect information regarding minors, you, as parent or guardian, may also make a verifiable consumer request on behalf of your minor child.

You may make a verifiable consumer request for access, correction, deletion or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
• Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising opt-out rights for cookies, sale, profiling or targeted advertising see Personal Information Opt-Out and Opt-In Rights.

Residents of Minnesota may request that we disclose results of any profiling that we performed on their personal information, the reasons that the profiling resulted in any decision, and actions that the consumer could take to secure a different decision.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing, typically an additional 45 days. You may appeal our response to your consumer request, and we will respond within sixty (60) days or, for Oregon and New Jersey residents, within forty-five (45) days. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. In the event that the appeal results are not satisfactory to you, you may elect to contact your state's Attorney General, or in New Jersey, the Division of Consumer Affairs in the Department of Law and Public Safety, or in Delaware, the Department of Justice. The following online methods are available for residents of applicable states to submit a complaint:

California: Complaint Form - California Privacy Protection Agency (CPPA)

Colorado: https://coag.gov/file-complaint/

Connecticut: CT Attorney General: e-Complaint Form

Delaware: Privacy Complaint Form - Delaware Department of Justice - State of Delaware

Indiana: Attorney General: Consumer Protection Division: File a Complaint

Iowa: Online Consumer Complaint Form | Iowa Attorney General

Kentucky: Consumer Complaint Form

Maryland: Welcome to the Maryland Consumer Protection Complaints Portal | Maryland Consumer Protection Portal

Minnesota: Minnesota Consumer Data Privacy Act

Montana: Complaint - Business Inquiry | MT Office of Consumer Protection

Nebraska: AGO Data Privacy Complaint Form : AGO - Attorney General's Office

Nevada: Nevada Complaint Form

New Hampshire: NH Online Forms System - Consumer Complaint Form. Version 1.16

New Jersey: OCP Complaint Form.indd

Oregon: Oregon Consumer Privacy Act Complaint

Rhode Island: File a Consumer Complaint | Rhode Island Attorney General's Office

Tennessee: Consumer Complaint Form

Texas: Texas Complaint Form

Utah: Submit Complaint | Privacy Utah

Virginia: OCA - Official consumer complaint form

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If you are 16 years of age or older, you have the right to direct us to not sell or share your personal information at any time (the "Right to Opt-Out"). We never intentionally collect information from users that we actually know are less than 16 years of age, and will never sell or share the personal information of users we actually know are less than 16 years of age. Users who opt-in to personal information sales or sharing may opt-out of future sales and sharing at any time. To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request via the consumer rights methods in this Privacy Policy. We also support the following mechanisms for signaling your preferences regarding cookies, personal information sales, targeted advertising, and profiling: http://www.aboutads.info/choices

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales, targeted advertising, or profiling. However, you may change your mind and opt back in at any time by contacting us via the methods provided in this Privacy Policy.

You do not need to create an account with us to exercise your Right to Opt-Out. We will only use personal information provided in an opt-out request to review and comply with the request.

We will not discriminate against you for exercising any of your rights. Unless permitted by the applicable privacy law, 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.
• Retaliate against an employee, applicant for employment, or independent contractor for exercising their rights.

However, we may offer you certain financial incentives such as a membership or loyalty program that can result in different prices, rates, or quality levels. Any financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. In the event that exercising a consumer right interferes with participation in a membership or loyalty program, we will implement your consumer rights request and may notify you that your participation in the financial incentive has ended. You may choose to re-enroll.

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to abuse@austinshirepartners.com.

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated Policy on the website and update the Policy's effective date.

If you have any questions or comments about this Policy, the ways in which we collect and use your information described above, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at: abuse@austinshirepartners.com, or here or send us correspondence at the following address:

Austinshire Partners

Unit 10031, PO Box 6945, London, W1A 6US, United Kingdom