Privacy Policy

Privacy Policy Updated August 23, 2021

Welcome to Bates Group LLC (Bates Group).   Bates Group is a consulting firm specializing in Anti-Money Laundering (AML) and Financial Crimes Prevention (FCP). The firm offers Consulting Services that include: BSA/AML/OFAC Program Development, Risk Management, Training, and Independent Reviews.

The purpose of this privacy policy statement is to provide transparency regarding the information we may collect about you through our https://CorComllc.com/ website (Bates Group Website).  Visitors to the Bates Group Website are urged to read the entire statement carefully as it contains important information regarding your rights.

This privacy policy statement discloses Bates Group’s privacy practices and contains detailed information about the following:

• What information do we collect?
• What are “cookies” and how does Bates Group use them?
• Do we share information with third parties?
• How do we use the information we collect?
• How can you review and modify your Personal Information?
• What is the opt-out policy for the Bates Group Website?
• Your California privacy rights
• Your European privacy rights
• What types of security procedures are in place to protect against the loss, misuse or alteration of your information?

Bates Group maintains compliance with applicable laws regarding privacy of your Personal Information (defined below) including:

• Disclosing the purpose of processing your Personal Information. This privacy policy statement is how we disclose this purpose.
• Limiting Personal Information collection to only the information required for our legitimate business purposes.
• When consent is required to process your Personal Information, we will request your consent before doing so and in such cases, if you do not consent, your Personal Information will not be processed.
• Ensuring that proper security measures are observed to protect your Personal Information by our employees and any parties that may process data on our behalf.
• Acknowledging and respecting your right to access, correct or delete your Personal Information should you so request.

“Personal Information”, is any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier or one or more factors specific to you. Personal Information includes sensitive Personal Information and pseudonymised Personal Information but excludes anonymous information or information that has had the identity of an individual permanently removed.

Your use of the Bates Group Website and/or provision of your Personal Information, including sensitive Personal Information, to Bates Group constitutes your consent to the use, storage, processing and transfer of that information in accordance with our privacy policy.

If you have any questions about this Privacy Policy Statement or the personal data we collect, please contact us by Email using the form provided below.  You can also reach us by telephone at 503-670-7772 or by mail at:

Bates Group LLC

1855 East Main Street, Suite 14

Spartanburg, South Carolina 29307

Attn: Privacy Policy

Please be sure to provide your full name when contacting us. When allowed by law, if we deem appropriate, we may require verification that you are the person making the request so that we can confirm we are modifying or deleting the correct person’s Personal Information.

We will update this Privacy Policy from time to time, so please check back periodically.

If we make a decision to use Personal Information in a way that is materially different from what our stated policy was at the time it was collected, we will do our best to notify you of such changes by updating this Privacy Policy with a new effective date, prior to implementing them.

In accordance with our Privacy Policy and applicable law, you have the right to know what personal information is being collected, why it is collected, what will happen to that information, and how long it may be retained.

You have the right to know:

• The category of personal information being collected.
• The category of sources from which the information was collected.
• The purpose for which the data was collected.
• The categories of third parties who may have access to the data.
• The specific personal information that has been collected.

You have the right to know if your personal information is being used by, disclosed to, or sold to third parties, and the identity of those third parties.

If your information is being sold or disclosed to third parties:

• You have the right to request the category of any personal information being collected, sold and/or disclosed.
• You have the right to request the category of third party to whom information is sold.
• The category of information sold must be disclosed for each third party to whom information is sold.

Exercising your privacy rights will not affect your right to equal service and prices.

You will not be discriminated against for exercising your privacy rights. Prohibited discrimination includes, but is not limited to:

• Denying goods or services
• Charging different prices or providing a different level of service or quality of goods than that received by other consumers, including through the use of discounts and benefits.
• Implying or suggesting that the consumer will receive a different price, quality of goods, or level of service.

Charging different prices or rates, or providing a different level of service or quality of goods, is permitted if it can be shown that the value provided to the consumer is reasonably related to the consumer’s data.

You have the right to access your personal data that we collect, and request that your Personal Information be modified or deleted.

When a valid request to delete data is received, the information will be deleted from our records and any service providers with access to that data will be directed to remove it from their records as well.

You have the right to correct, modify, supplement, or block your Personal Information. 

If consent was given to collect or use Personal Information, you may revoke that consent at any time. You also have the right to request a complete record of your Personal Information and transfer that record in whole to another controller.

Summary:

In Section 1 below we set forth what Personal Information we collect through the Bates Group Website and how it is collected.

In Section 2 below we set forth how we use “cookies”.

In Section 3 below we set forth how we may share your Personal Information.

In section 4 below we set forth how we may use your Personal Information

In Section 5 below we set forth how you may access and modify your Personal Information.

In Section 6 below we set forth how long we keep your Personal Information.

In Section 7 below we explain our opt-out policy.

In Section 8 below we explain your California privacy rights.

In Section 9 below we explain your European privacy rights.

In Section 10 below we explain the security measures we have in place to protect your Personal Information

1. What information do we collect?

Bates Group only collects information we are legally permitted to collect.  Specifically, we collect the following Personal Information about visitors to the Bates Group Website:

1. a)    Site Use Information

We collect technical information relating to each time a visitor comes to the Bates Group Website, including IP address, geolocation data, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform type (e.g. Internet Explorer browser on a Windows platform).

We may also collect information about your visit, including pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Gathering this technical information helps us to learn what browsers we need to support and helps us determine what sections of the Bates Group Website are most popular and how many visitors come to our site(s).  This information is available to Bates Group as a result of your visiting our site and, as noted above, by accessing the Bates Group Website, you agree to the collection of this technical information.  You do not have to register with the Bates Group Website for us to have access to this technical information.

1. b)    Information Provided to Bates Group

You may provide Personal Information to us in various ways including, via telephone, email, regular mail and web-based forms.  Personal Information you provide may include your name, home and/or work email address, postal address, phone number and/or fax number, your employer and job title, demographic information about you including birth year, certification designation, etc., and if you are making a purchase, your credit card information. Such information is only required to take advantage of optional products and services provided through the Bates Group Website.

We collect Personal Information in the following ways from different parts of the Bates Group Website:

• Registration: When registering for specific services we may ask for the same type of Personal Information. For example, if you register an account with us, we will ask you to provide your e-mail address, username, password and any other relevant account specific information.
• Online Purchases: When you make a purchase using the Bates Group Website we may also ask for the same type of Personal Information in order to process/collect payments authorized by you.
• Employment Applications: When you apply for employment with Bates Group using the Bates Group Website, we may ask for your Personal Information, including copies of your Resume or CV, and any other information required to verify your qualifications.

2. What are “cookies” and how does Bates Group use them?

A cookie is a small text file containing a unique identification number that is transferred from a website to the hard drive of your computer. This unique number identifies your web browser to Bates Group computers whenever you visit the Bates Group Website.

Most web browsers are initially set up to accept cookies. If you prefer, you can reset your browser to notify you when you have received a cookie. You can also set your browser to refuse to accept cookies altogether.

Bates Group does not require you to use cookies, however certain services may not function properly if you set your browser to refuse all cookies. To help serve you better, Bates Group generally uses cookies to collect information and improve our services.

The use of the Do Not Track (DNT) header field is supported by our website.  If you activate the DNT, your browsing history will not be tracked.

3.  Do we share Personal Information with third parties?

Personal Information collected through the Bates Group Website is generally collected and maintained solely by Bates Group or its contracted vendors.

Except as expressly provided for below, your personal data is not shared with any third parties.  We have not sold or disclosed your personal information to any third parties within the preceding 12 months.

We may share Personal Information in the following ways:

1. a)    Information You Give Us

1. Personal Information provided when you register for services or products. When you provide Personal Information about you on the Bates Group Website to register for a service, buy a product, or take advantage of a promotion Bates Group will share such Personal Information as necessary to the complete the transaction requested by you.

2. Information provided when you apply for employment with Bates Group.  If you apply for a position with Bates Group, you provide Personal Information required to verify your employment qualifications, including copies of your Resume or CV, in order to do required background checks and education and employment verification, including your employment status, as required by law or Bates Group policy.  Bates Group does not sell or share Personal Information related to employment applications except as necessary to process the application, to conduct the required background checks and education and employment verification, or as necessary to comply with legal obligations.

1. Sensitive Personal Information.  Bates Group does not share with third parties, sensitive Personal Information such as passcodes, social security numbers, credit card numbers, felony conviction information, or health information except as necessary to complete transactions requested by you, to process employment applications, or to comply with legal obligations, and under strict confidentiality and security protections; nor does Bates Group publish such sensitive Personal Information.

1. b)    Site Use Information

We may share aggregate website statistics with the media or other third parties. We do not disclose Personal Information to these sponsors/advertisers or other third parties as part of this process, only information in an aggregate form.

4. How do we use the information we collect?

We use your Personal Information according to the terms of the Privacy Policy in effect at the time of our use. We will only process your Personal Information, including sharing it with third parties, where (1) you have provided your consent which can be withdrawn at any time, (2) the processing is necessary for the performance of a contract to which you are a party (including any registration agreement with us), (3) we are required by law, or (4) processing is required to protect your vital interests or those of another person.

Please note that third party websites connected to our site by links are not covered by this Privacy Policy. It is not possible for us to guarantee or fully disclose how these third parties may use or collect your personal data. It is recommended that you read the privacy policies or statements of third party  websites before using them.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

We use Personal Information for the following purposes:

1. a)    Information You Give Us

We use the Personal Information you give us:

1. to carry out our obligations under any agreement entered into between you and us
2. to provide you with the information, products and services you request from us
3. to arrange and deliver newsletters, conferences, events and programming relevant to your job and subjects of interest where you have not opted out of receiving such information
4. to respond to your questions and provide related registration or customer services
5. to improve the Bates Group Website
6. to send you information about our services and products, and other information that Bates Group believes is relevant and useful to you, where you have not opted out of receiving such information; we may automatically process your information to determine which products and services may be of most use to you. You may object to such processing by contacting us as provided elsewhere in this Policy.
7. to send you third party information that Bates Group believes is relevant and useful to you, where you have given your consent
8. to ask you to provide feedback
9. to administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
10. for those who apply for employment with Bates Group, to process your employment application, including background checks and education and employment verification, as applicable
11. to comply with all applicable laws or legal processes, including providing information on individual users to the appropriate governmental authorities where required by law enforcement or judicial authorities

In matters involving a danger to personal or public safety, or to protect the rights, property or safety of Bates Group, our customers, or others, Bates Group may voluntarily provide Personal Information to appropriate governmental authorities

1. b)    Site Use Information

Bates Group may use this aggregate, anonymous data to perform statistical analyses of the collective characteristics and behavior of visitors to the Bates Group Website; to measure user interests regarding specific areas of the Bates Group Website; and to analyze how and where best to use our resources.

Without such data, we would not know which parts of Bates Group Websites are the most popular, and we would not be able to change and update the content and services appropriately.

5. How can you review and modify your Personal Information?

You should contact Bates Group if you wish to modify or delete any of your Personal Information or other information previously provided by you.

6. How Long Do We Keep Your Personal Information? 

Bates Group will retain your Personal Information for twelve (12) months after a requested service is completed or terminated.

7. What is the opt-out policy for the Bates Group Website?

Bates Group does not currently send unsolicited communications to site visitors or customers.  Should we do in the future, site visitors and customers will be provided with the opportunity to opt-out of receiving communications from us and our partners.

8. Your California Privacy Rights

For California Residents Only.  Bates Group does not currently disclose your Personal Information to third parties without your advance consent.  Should we do so in the future, as a California resident, you have the right to opt-out of having your Personal Information licensed to such third parties.  We will not share your information after we have received your notification that you are opting out.

9. Your European Privacy Rights

For European or United Kingdom Residents Only. If you are based in the EU or the UK, in certain circumstances, you have rights under the GDPR in relation to your Personal Information.

• Request access to your Personal Information.  You may have the right to request access to any Personal Information we hold about you as well as related information, including the purposes for processing the Personal Information, the recipients or categories of recipients with whom the Personal Information has been shared, where possible, the period for which the Personal Information will be stored, the source of the Personal Information, and the existence of any automated decision making.
• Request correction of your Personal Information. You may have the right to obtain without undue delay the rectification of any inaccurate Personal Information we hold about you.
• Request erasure of your Personal Information. You may have the right to request that Personal Information held about you is deleted.
• Request restriction of processing your Personal Information. You may have the right to prevent or restrict processing of your Personal Information.
• Request transfer of your Personal Information. You may have the right to request transfer of Personal Information directly to a third party where this is technically feasible.

Where you believe that we have not complied with our obligations under this Privacy Policy, or under European or UK data protection laws, you have the right to make a complaint to an EU or UK Data Protection Authority, such as the UK Information Commissioner’s Office.

If you wish to exercise your European or UK data subject rights, you have the following options:

10. What kinds of security procedures are in place to protect against the loss, misuse or alteration of your information?

The Bates Group Website has security measures equal to or better than those reasonably expected in the industry, such as firewalls, in place to protect against the loss, misuse and alteration of your Personal Information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we take reasonable precautions to prevent such unfortunate occurrences.

You are ultimately responsible for the security of your Bates Group login credentials. You may not share your Bates Group login credentials with colleagues or friends. You should log out of your browser at the end of each computer session to ensure that others cannot access your Personal Information and correspondence, especially if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe.

We reserve the right to amend this privacy statement at our discretion and as required by changes in law. Regularly reviewing this privacy statement is recommended in order to be aware of potential amendments. When appropriate or required, we will notify you of changes to this privacy policy statement.