Privacy Policy

This Privacy Policy describes how The Heller Group, LLC and its affiliates (collectively, “Heller Group,” “we,” “us,” or “our”) collects, uses, shares, and safeguards personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions. You can jump to particular topics by going to the headings below

Sharing of Information.

Your Choices.

Authorized Agent

Annual Data Requests

Please address written requests and questions about your rights to [insert email address]. Note that, as required by law, we will require you to prove your identity. If you choose to designate an authorized agent to submit requests on your behalf, we will also require verification that you provided the authorized agent permission to make a request on your behalf. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the contact information we have on file for you, or the date you entered into services with us. We may also ask you to provide a signed and notarized declaration confirming your identity. If you are not satisfied with our response to your request, you may appeal our decision by emailing us.

Contact Information

Types Of Information We Collect.

The following provides examples of the type of information that we collect from you and how we use that information.

Context	Types of Data	Primary Purpose for Collection and Use of Data
Account Registration	We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account.	We have a legitimate interest in providing account related functionalities to our users. Accounts can be used to save your preferences.
Client Information	We collect the name, and contact information, of our clients and their employees with whom we may interact.	We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing. In some circumstances, we collect client information to perform our contract for services.
Cookies and first party tracking	We use first-party tracking technology such as cookies and clear GIFs. “Cookies	We have a legitimate interest in making our website and mobile application
Demographic Information	We collect personal information, such as your age or location.	We have a legitimate interest in understanding our users and providing tailored services.
Distance Information	When you use our mobile application we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location. This location information is limited to broad, imprecise location.	In some contexts our use is based upon your consent to provide us with geolocation information. We also have a legitimate interest in understanding our users and providing tailored services.
Employment	If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.	We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations.
Feedback/Support	If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.	Our collection of feedback and support information is based upon your consent to provide us with such information. We also have a legitimate interest in receiving, and acting upon, your feedback or issues.
Mobile Devices	We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website.	We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.
Service Requests	We collect your name, billing address, shipping address, e-mail address, and phone number when you request services.	We use your information to perform our contract to provide you with services.
Website interactions	We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.	We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to better tailor our services. We also have a legitimate interest in detecting and preventing fraud.
Web logs	We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.	We have a legitimate interest in monitoring our networks and the visitors to our websites

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.

Use And Processing Of Information

In addition to the purposes and uses described above, we use information in the following ways:

To identify you when you visit our websites or mobile application.
To provide services.
To understand the types of services that may interest you.
To understand the types of artwork that may interest you.
To conduct analytics.
To respond to inquiries related to support, employment opportunities, or other requests.
For internal administrative purposes, as well as to manage our relationships.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you request services from us, we may collect your personal information in order to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after our contract for services is complete so that we can quickly and easily respond to any questions you may have about your experience of the services rendered. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Sharing Of Information.

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
Other Disclosures With Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
Other Disclosures Without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the provision of services by a third party intermediary.
Service Providers. We may share your information with service providers. Among other things, service providers may help us to administer our website and provide technical support.

Your Choices.

You have a number of choices with respect to your personal information. Depending on the information we have about you, you may have a right to access, delete, update, object to the processing of, or revoke your consent to the processing of your personal information. In some cases, you may request access to your personal information in a portable format. If required by law we will grant your request, but you should not that in many situations we may be unable to honor your request in order comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

You may be permitted to create an account. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

Other Important Information

The following additional information relates to our privacy practices:

Transmission Of Information To Other Countries. Your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
Retention of Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law.
Changes To This Privacy Policy. We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.
Information for California Residents. California law indicates that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose”(as those terms are defined under California law). You can find a list of the categories of information that we collect and share here . If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the "Contact Information" section below. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.

Contact Information. If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy- related information.

requests@hellergroupllc.com

+1 (303) 572-6500

Greenberg Traurig LLP

Attn: Data Privacy Team

1144 15th Street

Suite 3300

Denver, CO 80202

If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

Effective Date:

Last Update: July 20, 2021

California Information Sharing Disclosure

California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). We do not “sell” your personal information. The [table/lists] below indicate[s] the categories of personal information we collect and transfer in a variety of contexts. Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself. For example, while we transfer credit card or debit card numbers for our business purpose in order to process payments for orders placed with us, we do not collect or transfer credit card or debit card numbers of individuals that submit questions through our website’s “contact us” page.

Categories of Personal Information We Collect	To Whom We Disclose Such Personal Information for a Business Purpose
Identifiers; Commercial Information; Internet or Other Electronic Network Activity Information; Inferences drawn from any of the information listed in this chart	Affiliates or subsidiaries Business partners Data analytics providers Internet service providers Joint marketing partners Operating systems and platforms Other Service Providers Payment processors and financial institutions Professional services organizations, this may include auditors and law firms
California Customer Records; Characteristics of Protected Classifications; Geolocation Data; Audio, Electronic, Visual, or Similar Information; Professional or Employment-Related Information; Non-Public Education Information	Affiliates or subsidiaries Business partners Other Service Providers Payment processors and financial institutions Professional services organizations, this may include auditors and law firms

We may collect and disclose the following categories of personal information to affiliates and subsidiaries, business partners, data analytics providers, data brokers, internet service providers, joint marketing partners, operating systems and platforms, payment processors and financial institutions, professional services organizations, social networks, and other service providers:

Identifiers;
Commercial Information;
Internet or Other Electronic Network Activity Information; and
Inferences drawn from any of the information listed.

We may collect and disclose the following categories of personal information to affiliates or subsidiaries, business partners, payment processors and financial institutions, professional services organizations, and other service providers:

California Customer Records;
Characteristics of Protected Classifications;
Geolocation Data;
Audio, Electronic, Visual, or Similar Information;
Professional or Employment-Related Information;
Non-Public Education Information