- How We Collect Information About You
ESB may collect Personal Information from you in a variety of ways. These may include, but are not limited to:
- Directly from you: ESB may collect Personal Information directly from you in connection with the provision of our Services. We may also collect Personal Information from you when you visit our Site.
- Third parties: ESB may collect Personal Information about you from other sources, such as our vendors and marketing partners, or references when you inquire about a partnership or position with us.
- Information that you provide to us
When you visit our Site or use our Services, we collect Personal Information directly from you, including:
- Identifiers (e.g., real name, postal address, email address, telephone number, account log-in credentials);
- Internet or other electronic network activity (e.g., IP address, browser type, browser language, operating system, referral sources, information regarding interactions with the Site, links clicked or opened in ESB emails);
- Professional or employment-related information (e.g., job history, performance evaluations);
- Characteristics of protected classifications under California or federal law (e.g., gender, race/ethnicity, veteran status, and disability status, where legally permissible); and
- Inferences drawn from other Personal Information (e.g., profiles reflecting preferences and trends).
When you join our talent network or apply for a position with us via our careers website (https://careers.myrgroup.com/), you may provide us with certain information, including your name, email address, country, location, desired job title, information included in your resume, and other information about your background and qualifications. In addition, where legally permissible, you may provide information regarding your gender, race/ethnicity, and your veteran and disability status. ESB will not consider either this information or your choice to decline to provide it in evaluating your qualifications for employment with us. This information will be used only for Equal Employment Opportunity reporting and other legal and compliance purposes.
- Information we obtain from other sources.
ESB may also collect some information from other sources, including:
- If we have a business relationship with the organization that you represent, your colleagues or other business contacts may give us information about you, such as your contact details or details of your role in the relationship; and
- Information from third-party data providers or publicly available sources for anti-money laundering, background checking, and similar purposes, and to protect our business and comply with our legal and regulatory obligations.
If you provide information to us about another person, you should ensure that you comply with any legal obligations that may apply to your provision of the information to us.
- Information we obtain by automated means.
Depending on how you use our Site, we may collect certain information by automated means (such as by cookies). The information we collect in this manner includes your IP address, network location, browser characteristics, browser language, device characteristics, operating system, referring URLs, information on actions taken on our Site, and dates and times of your visit to our Site.
Cookies. Our Site stores cookies on your computer to collect certain aggregate data about our users and to customize certain aspects of your specific user experience. A cookie is a small data text file that is stored on your computer or Internet-connected device that uniquely identifies your browser. Cookies may also include more personalized information, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and your first name to welcome you back to our Site.
We use different types of first and third-party cookies on our Site for several reasons. First-party cookies are those that we place on your device through our Site; third-party cookies are cookies that another party places on your device through our Site.
- Track user trends and patterns. This helps us better understand and improve areas of our Services that our users find valuable.
- Offer social media features and analyze our traffic. We also share information about your use of our Site with our social media and analytics partners. We use the information from cookies to provide services better tailored to your needs.
We use four types of cookies: strictly necessary cookies, performance cookies, functional cookies, and website analytics cookies.
- Strictly necessary cookies. Strictly necessary cookies are essential in order to enable you to move around our Site and use their features. These are temporary cookies that last only as long as your web browser is open, and are used for purposes such as enabling better navigation on our Site. Without these cookies, the services you have asked for cannot be provided. Once you close your browser, the cookie disappears.
- Performance cookies. Performance cookies are stored on your device for longer periods and are used for purposes including tracking the number of unique visitors to our website services and information such as the number of views a page gets, how much time a user spends on a page, and other pertinent web statistics. The collected information is aggregated and therefore made anonymous. These cookies are used to improve the performance of our Site, and with it, the user experience.
- Functional cookies. Functional cookies enable our Site to save information that has already been entered (such as usernames, language choices, and your location) so that it can offer you improved and more personalized functions. Functional cookies are also used to enable features you request, such as playing videos. These cookies collect anonymous information and cannot track your movements on other websites.
For more information on the cookies we use and how you can manage them, please contact google analytics or adjust the settings on your browser. Please note that if you disable functional cookies on your browser, some parts of our Site may not work fully.
Cross-device tracking. ESB uses data analytics companies, advertising networks, or social media companies, and the features they offer, to engage in “cross-device tracking,” which occurs when platforms, publishers, and advertising technology companies try to connect a consumer’s activity across smartphones, tablets, desktop computers, and other connected devices. The goal of cross-device tracking is to enable companies to link a consumer’s behavior across devices.
- How We Use the Collected Information
- Provide you with access to our Site;
- Improve our Site, including statistical analysis of our Site;
- Customize your experience on our Site;
- Manage our Site;
- Operate, evaluate, and improve our Services;
- Respond to your inquiries;
- For our information technology or security purposes;
- Debug to identify and repair errors that impair existing intended functionality on our Site;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
- Comply with applicable laws and regulatory requirements, or as requested by the government or regulatory authorities;
- Facilitate a merger, divestiture, acquisition, 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 by us is among the assets transferred.
ESB may also use the information in other ways for which we provide specific notice at the time of collection.
- Information that We Disclose to Others
- Affiliates, service providers, partners, and other third parties (“Service Partners”).
- Financial and transaction counterparties;
- Professional advisors; and
- Your agents and representatives.
ESB may disclose information about you in the following contexts:
- If we are required to do so by law or legal process;
- To law enforcement authorities, regulators, and/or other government entities and/or other competent authorities based on a lawful disclosure request; or
- When we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
We reserve the right to transfer Personal Information we have about you or otherwise process in the event that we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution, or liquidation). In addition, ESB may share anonymous/aggregated information with third parties, such as service providers, in order to facilitate our business operations.
- How We Protect Personal Information
On our Site, ESB maintains administrative, technical, and physical safeguards designed to protect the Personal Information we obtain through our Site against accidental, unlawful, or unauthorized access to or alteration, disclosure, or destruction of your Personal Information. However, neither individuals nor security systems are foolproof, and the transmission of information over the Internet or any wireless network is completely secure. As a result, while we use reasonable security measures to protect your Personal Information, we cannot guarantee its absolute security.
- International Transfers
- Retention and Deletion of Your Information
We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected.
Note that we may retain some limited information about you so that we can maintain a continuous relationship with you if and when we are in contact with you again. You can opt-out of receiving marketing information or contact us to delete your contact details at any time.
- Your Rights and Choices
ESB offers you certain choices in connection with the Personal Information we collect from you.
Email Communications. If you receive direct marketing communications from us, you may opt-out by clicking the link in the relevant communication, completing the forms provided to you (where relevant), or by contacting us at https://esboulos.com/contact.
Do Not Track. Our Site is not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising, please visit www.aboutads.info/choices, or http://www.networkadvertising.org/choices/.
- Rights and choices for residents of California
If you are a resident of California, this section describes the Personal Information we collect about you, how we use and disclose it, and how you can exercise certain rights you may have available to you under the California Consumer Privacy Act (“CCPA”) in connection with your business relationship with ESB.
- Categories of Personal Information
|Categories of Personal Information||Categories of Third Parties|
|Identifiers (e.g., real name, postal address, email address, telephone number, account log-in credentials)||Service Partners Professional advisors; Agents and representatives; Law enforcement (based on a lawful disclosure request)|
|Internet or other electronic network activity (e.g., IP address, browser type, browser language, operating system, referral sources, information regarding interactions with the Site, links clicked or opened in ESB emails)||Service Partners Professional advisors; Agents and representatives; Law enforcement (based on a lawful disclosure request)|
|Professional or employment-related information (e.g., job history, performance evaluations)||Service Partners Professional advisors; Agents and representatives; Law enforcement (based on a lawful disclosure request)|
|Characteristics of protected classifications under California or federal law (e.g., gender, race/ethnicity, veteran status, and disability status, where legally permissible)|
|Geolocation data (e.g. physical location)|
|Inferences drawn from other Personal Information (e.g. profiles reflecting preferences and trends)|
- California Privacy Rights
If you are a resident of California, the California Consumer Privacy Act (“CCPA”) provides you with the following rights regarding your personal data:
- Right to Know: You have the right to request information about our collection, use, and disclosure of your Personal Information over the past twelve (12) months concerning (i) the categories of Personal Information we collected about you, (ii) the categories of sources from which your Personal Information is collected, and (iii) categories of third parties with whom we share your Personal Information.
- Right to Deletion: You have the right to request that we delete certain Personal Information that we have about you. We may not be able to fulfill your request if we (or our service providers) need to retain your Personal Information for certain authorized purposes, such as to provide a good or service you requested, to secure our Services, to protect against fraud, to improve our Services, or to comply with or exercise rights under applicable law.
- Right to Non-Discrimination: You have the right not to receive discriminatory treatment against you for exercising any of your privacy rights under the CCPA.
If you would like to exercise any of these rights provided under local law, you can contact us at: https://esboulos.com/contact.
Only you or an authorized agent acting on your behalf may make a request related to your Personal Information. We may need to verify your identity (and if applicable, your agent’s authority to make the request on your behalf) before we are able to process your request. We will ask you to provide certain information to verify your identity: name, e-mail address, and telephone number.
If you have an authorized agent who makes the request, then (i) we need proof that you have provided the agent with power of attorney; or (ii) you must provide the agent with signed permission to submit a request to know or delete; you must verify your identity directly with us, or you must confirm with us that you provided the authorized agent permission to submit the request.
During the verification process, we will try to match the information you provided against known information in our databases. If we still need additional information, we also may contact you or your authorized agent by e-mail or telephone number to ask you additional questions about the products or services you purchased or your last order with us, so that we can match your identity with the Personal Information we have about you. In some instances, we may ask you to declare under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.
If we cannot verify your identity or sufficiently differentiate you from another consumer, or cannot confirm an agent’s authority to act on your behalf, we are not required to fulfill your request.
- Use and disclosure of Personal Information
ESB does not “sell” your Personal Information in the traditional sense. Like many organizations, however, we engage third parties to help deliver interest-based advertisements to you and may make use of third-party tracking technologies or other online marketing services. In doing so, we may make available or transfer your Personal Information (e.g., Identifiers such as your IP address, Geolocation data, and Internet or other similar network activity) to third parties, such as analytics providers, social media platforms, and other similar technology companies. In certain cases, sharing data with these providers could be considered a “sale” under the CCPA even though it is not a sale in the traditional sense.
- To opt-out of receiving interest-based advertising, you can exercise your choice by using your account privacy settings described in the “Information we obtain by automated means” Section I(C) above
- You have the right not to receive discriminatory treatment from us based on your exercising of any privacy rights conferred by the CCPA.
- Links to Other Websites
Our Site may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked websites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.
- Public Areas of the Website
The Personal Information which you voluntarily disclosed (i.e., your name, email address, etc.) in the public areas on our Site, along with any information disclosed in your communication, is beyond ESB’s control. As a result, such Personal Information can be collected, and used by third parties and may result in unsolicited messages (including unwanted spam messages) from third parties.
- Children’s Privacy
Our Site and our Services are designed and intended for adults. By accessing our Site or utilizing our Services, you represent that you are at least eighteen (18) years of age.
Our Site and our Services are not intended for children under the age of thirteen (13). We, therefore, do not knowingly collect information from or otherwise market our Site or our Services to children under thirteen (13) years old. If you are a parent or guardian of a child under the age of thirteen (13) and believe that he or she has disclosed Personal Information to us, please contact us as described in the “Contact Us” section below. You may review and request the deletion of your child’s Personal Information or prohibit the further use of such information.
- Contact Us