Introduction
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
This Privacy Notice describes how Citrin Cooperman and its subsidiary entities collect, use, share, sell, disclose, retain, dispose of, and protect Personal Data when you interact with us as a subscriber, client, prospective client, office visitor, website user, job applicant, employee, contractor, supplier, event attendee, or any other relevant individual, and describes the choices you have relating to your Personal Data and how to exercise such rights.
Applicability
This Privacy Notice supplements the Citrin Cooperman Privacy Notice and addresses state-specific disclosures required under the Colorado Privacy Act (“CPA”). If you are a California resident, please see our California Privacy Notice.
This Privacy Notice applies to any Personal Data you provide to Citrin Cooperman and any Personal Data we collect during your employment, when you apply to a job posting, contact us, visit, or use our website, “www.citrincooperman.com” and all websites linked to this website, when you visit a Citrin Cooperman office, attend a Citrin Cooperman event or seminar, or request a service from us. The Personal Data we collect varies depending on the nature of the services we provide and how you interact with us. To use this site, you do not need to send us any Personal Data.
In this Privacy Notice, “Personal Data” means information that is linked or reasonably linked to an identified or identifiable individual and does not include de-identified data or publicly available information, defined as information that is lawfully made available from federal, state, or local government records and information that a controller has a reasonable basis to believe the consumer has lawfully made available to the general public.
Additionally, “Sensitive Personal Data” is a subset of Personal Data that requires heightened protection. Sensitive Personal Data means personal data revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, a person’s sex life or sexual orientation, citizenship, or citizenship status, as well as genetic or biometric data that may be processed for the purpose of uniquely identifying an individual. The definition also includes personal data from a known child.
At Citrin Cooperman, we value your privacy and are committed to safeguarding your information as part of our ongoing dedication to providing a secure and transparent experience for our users. As a result, we are committed to keeping our Privacy Notice up to date, reflecting any changes in our Personal Data practices or the adoption of new privacy policies. Should you have any questions or concerns about our Privacy Notice or how we process your Personal Data, please do not hesitate to reach out to us.
Your Personal Data
At Citrin Cooperman, we offer a wide range of Assurance, Tax, and Advisory services to meet the business and personal needs of our clients. Given the diversity of our Service offerings, we process broad categories of Personal Data, including Sensitive Personal Data. We use your Personal Data for lawful business purposes, including (i) using only Sensitive Personal Data provided by you with your consent, (ii) performance of a contract, and/or (iii) complying with legal and regulatory obligations.
We also collect and use your Personal Data when you apply for a job to assess your suitability for job opportunities and provide you with personalized experiences. Additionally, we collect and use your Personal Data as an employee to manage the employment relationship, communicate with you, improve the workplace and our services, protect the health and safety of our employees, and comply with legal and regulatory requirements.
We process your Personal Data for the following purposes:
- To provide products and services to you
- To comply with legal/regulatory requirements
- To operate and improve our business
- To manage our workforce and provide them with employment, training, compensation, or benefits
- For marketing and advertising purposes
- To improve the security and performance of our website, network, systems and services
- To protect against fraud and abuse
- To protect the safety and security of our employees and clients
- To communicate with you about our products and services
- To operate and understand your use of our website
You may have executed a contract, such as a Master Services Agreement (MSA), Statement of Work (SoW), Engagement Letter or other Agreement, that governs the relationship between you and Citrin Cooperman and the services we provide to you. If there is any conflict between the terms of your agreement with Citrin Cooperman and the terms of this Privacy Notice, the terms of your agreement will prevail.
Type of Personal Data We Collect
We may collect, process, and share the following information:
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Browsing and Device Information
Like many companies, your visit to our website triggers automatic collection of cookies and other tracking technologies. We and third parties, including our third-party service providers may automatically collect certain details about your device and browsing, like IP address, browser type, and page views through the use of cookies and other tracking tools like analytics and pixels. This information may be used to understand your interests and needs, improve the performance of our marketing campaigns, improve the performance of our website, personalize the content and advertising that we show to you, prevent fraud and abuse, comply with legal requirements, or improve the security of our website, systems, and services. If you no longer wish to receive promotional communications from us, you may at any time request that we discontinue sending you such materials by contacting us using this link.
Please visit our Cookies and Other Tracking Technologies Notice for more information.
Children’s Data
Our services are not directed at Children, and we do not knowingly collect any Personal Data from Children under the age of 16 without prior verifiable parental consent.
Certain Citrin Cooperman services, may process Personal Data related to Children, such as their date of birth, address, or other identifiable information to fulfill our service obligations to you. This Personal Data is not collected directly from Children, but from other parties such as your representative, or directly from you as the parent or guardian of the Child (e.g., so that the Child may be named a beneficiary to an insurance policy or pension plan).
If Citrin Cooperman learns that a Child under the age of 16 has submitted Personal Data without parental consent, we will take all reasonable measures to delete the data as soon as possible and to not use such data for any purpose, except where necessary to protect the safety of the Child or others as required or allowed by law. If you believe a Child under the age of 16 has provided us with Personal Data, please contact us at privacy@citrincooperman.com or use the mailing address below.
Categories of Third Parties with Whom Personal Data Is Potentially Disclosed
We may need to disclose your Personal Data in certain circumstances as outlined below to carry out our business. We take your privacy seriously and will only disclose your Personal Data when it is necessary to do so. Furthermore, we have put in place safeguards to protect your Personal Data and will only disclose it to third parties who have agreed to protect it as well.
- Third-party suppliers, service providers, affiliates, and business partners: Citrin Cooperman may disclose Personal Data to third-party suppliers, service providers, affiliates, and business partners to assist us in meeting business operation needs and to deliver our services and functions.
- Vendors: Citrin Cooperman may disclose Personal Data to vendors who provide services to the firm, such as information technology services, cloud computing services, and data storage services. This is done to allow these vendors to perform their services effectively and efficiently.
- Investors: Citrin Cooperman may disclose Personal Data to investors to provide them with information about the firm's financial performance and operations. This disclosure is necessary for investors to make informed investment decisions.
- Regulators: Citrin Cooperman may disclose Personal Data to regulators to comply with legal and regulatory requirements. For example, Citrin Cooperman may be required to disclose Personal Data to the Securities and Exchange Commission in connection with an audit of a public company.
- Law enforcement: Citrin Cooperman may disclose Personal Data to law enforcement agencies if required to do so by law. For example, Citrin Cooperman may be required to disclose Personal Data to the Federal Bureau of Investigation in connection with an investigation of a financial crime.
Sale and Share, Including Targeted Advertising, of Personal Data
Colorado’s expansive definition of "sale" means that even non-monetary exchanges, such as any instance where a consumer's personal data is transferred or disclosed to a third party, in exchange for any form of valuable consideration, constitutes a "sale," regardless of whether monetary compensation is involved.
We may sell or share Personal Data with third parties for various purposes including Targeted Advertising. We use third parties, such as Google Analytics, Sitecore, and Demandbase to automatically collect browsing, contact, device, personal detail, and social media Personal Data using cookies, web beacons and/or pixels on our behalf when you are using our site and other platforms. These services allow us to improve the performance of our website and to personalize the content and advertising that we show to you. In the process of setting cookies and tracking technologies, to provide Citrin Cooperman with certain analytics services on our site, some third-party providers may retain such analytics data for their proprietary purposes including for Targeted Advertising. Since the retention of analytics data may impact the price of the analytics services to Citrin Cooperman, it may be deemed a Sale of Personal Data.
- Google Analytics
We use the services of Google Analytics, a web analytics service provided by Google, Inc. (“Google”). This analytical tool uses cookies and other similar technologies to help analyze how visitors use the sites. Our site offers the ability to turn off tracking cookies. For more information about the collection and use of data through Google Analytics, please refer to https://www.google.com/policies/privacy/partners. Google offers the ability to opt-out of tracking through Google Analytics cookies. For more information, please visit https://tools.google.com/dlpage/gaoptout. Google has developed the Google Analytics Opt-out Browser Add-on to provide website visitors with more choices on how their data is collected by Google Analytics. The add-on communicates with Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services. You can also opt out of Google Analytics by declining cookies for advertising.
- Sitecore
We use the services of Sitecore, a digital experience platform (DXP) that helps us create and manage digital content and experiences. Sitecore uses cookies and other similar technologies to help analyze how visitors use the sites to create and deliver personalized digital experiences to you. Our site offers the ability to turn off tracking cookies. For more information about the collection and use of data through Sitecore, please refer to Sitecore Privacy Policy | Sitecore. Sitecore offers the ability to opt out of tracking through Sitecore cookies. For more information, please visit Your privacy choices (sitecore.com). Sitecore has a Privacy rights request form which you may use to facilitate Opt-out requests and provide you with more choices on how your data is collected by Sitecore. You can also opt out of Sitecore collection and processing by declining cookies for Analytics and Targeted Advertising (“Do Not Sell” Opt Out).
- Demandbase
We use the services of Demandbase, a go-to-market (GTM) platform that helps us identify and engage prospective clients. Demandbase and their analytics/service providers use tracking pixels, tags, web beacons and cookies to collect information. These technologies are used in analyzing trends, tracking users’ online movements, and gathering demographic information about our user base. Our site offers the ability to turn off tracking cookies. For more information about the collection and use of data through Demandbase, please refer to Demandbase Privacy Notice. Demandbase offers the ability to opt out of tracking through their Privacy Preference Center. Demandbase has a Privacy rights request form which you may use to facilitate Opt-out requests and provide you with more choices on how your data is collected by Demandbase. You can also opt out of collection and processing by declining cookies other than those that are strictly necessary.
- Vena Solutions
In the course of providing our services, we may share your personal details and contact information with Vena Solutions, as we are an authorized reseller of their solutions. This sharing is essential for ensuring that you receive optimal support and access to the features of the Vena platform. We are committed to safeguarding your information and will only share what is necessary to fulfill your requests and enhance your experience with our services. For more details on how Vena Solutions handles your data, we encourage you to review their privacy policy.
- Cookies and Other TrackingTechnologies
Please see our Cookie and Other Automated Technologies Notice to better understand our use of Cookies and Other Tracking Technologies, including your rights and how you can control your Personal Data collected from Cookies and Other Tracking Technologies. Turning off cookies also does not end collection of data through pixels. Pixels, also known as web beacons or clear GIFs, are small, transparent images that can be embedded in websites and emails. Turning off cookies will prevent websites from setting cookies on your browser. However, it will not prevent pixels from setting cookies on your browser, as pixels are not cookies, but are simply images. If you are concerned about your privacy, you can control which pixels are accepted by your browser by adjusting your privacy settings. Most browsers allow you to block all pixels or to only accept pixels from certain websites. To further understand your Personal Data rights, see the section, “Exercising Your Data Protection Rights,” below.
- Social Media
We may use third-party marketing Cookies and Other Tracking Technologies to help deliver advertisements relevant to your interests. These include:
- Facebook: You can learn more about Facebook cookies and how you can control them at Meta Cookies Policy | Privacy Center | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy.
- Google/YouTube: You can learn more about Google cookies and how you can control them at How Google uses cookies – Privacy & Terms – Google
- LinkedIn: You can learn more about LinkedIn cookies and how you can control them at Cookie Policy | LinkedIn
- Hubspot: You can learn more about Hubspot cookies and how you can control them at HubSpot Cookie Policy.
Third-Party Links and Services
This site and all websites linked to the website contain third-party links that can be used to access certain services provided by third parties. This Privacy Notice does not address data collection or processing by any of those parties.
Do Not Track/Global Privacy Control (GPC)
Do Not Track (“DNT”) or “Global Privacy Control” is a preference setting offered by various internet browsers, whereby a signal is automatically sent by the browser to each website visited requesting that the user’s activities are not tracked by that website and that the website does not enable onward tracking to other websites. You can usually access your browser’s DNT option in your browser’s preferences. If that occurs, the website visited will not recognize you upon return to that website or save your passwords or usernames, and some other features of a website may become unavailable or not function properly.
Retention
How long we retain your Personal Data depends on the purpose for which it was obtained and its nature. This includes providing you with a service you have requested from us or to comply with applicable legal requirements, including complying with the law, retaining records, resolving disputes, and enforcing our agreements. This storage period may extend beyond the term of your relationship with us. We will keep your Personal Data for the period necessary to fulfil the purposes described in this Notice unless a longer retention period is permitted or required by law and in accordance with the Citrin Cooperman Record Retention Policy.
Your Data Protection Rights
As a Colorado resident, you have specific rights under the Colorado Privacy Act (CPA) to control your Personal Data.
- Right of Access. You can ask us what Personal Data we have collected about you and request access to such data upon verifiable request.
- Right to Data Portability. You may have the right to receive a copy of the Personal Data we have collected about you. Colorado residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of Personal Data that we have collected about them and to have this delivered, free of charge, electronically in a portable and, to the extent technically feasible, readily usable format that allows the individual to transmit this information to another entity without hindrance.
- Right to Correction. Subject to certain exceptions, you can ask us to fix any inaccurate Personal Data we have about you upon verifiable request.
- Right to Deletion. Subject to certain exceptions, such as our ability to comply with a legal obligation, you have the right to request that we delete the Personal Data we have collected from you upon verifiable request.
- Right to Opt Out of Sale/Sharing of Personal Data (including for Targeted Advertising). You have the right to opt out of Sale/Share of Personal Data, including for Purposes of Targeted Advertising by clicking: Opt-out of Sale/Sharing of My Personal Information (including for Targeted Advertising. Please see our Cookies and Other Tracking Technologies Notice to better understand our use of cookies, as well as your rights involving cookies and other areas of automated Personal Data collection.
Automated Decision Making
While we don't rely solely on automated systems to make decisions about you, we may use profiling techniques like analyzing background checks to assist in tasks like assessing client eligibility. This helps us ensure responsible service provision and protect both you and us.
Exercising Your Data Protection Rights
You have the right to make a verifiable consumer request related to your Personal Data and may also make a verifiable consumer request on behalf of your minor child. If you are making a request on behalf of someone else, we may ask for additional information to protect their Personal Data, such as proof that you are authorized to make the request. We will only use Personal Data provided in a verifiable consumer request to verify the requestors’ identity or authority to make the request.
We cannot respond to your request, except for requests to Opt-out of Sale/Sharing of My Personal Information (including for Targeted Advertising), or provide you with your Personal Data if we cannot verify your identity or authority to make the request, or if we cannot confirm that the Personal Data relates to you or your minor child. We may also be unable to comply with your request if we have a legal or regulatory obligation to keep your Personal Data, such as when the Personal Data is necessary to complete a transaction.
To the extent any of the above rights are applicable and you would like to exercise your rights as a Colorado resident, please leverage our Data Subject Access Request Form or contact us by email at privacy@citrincooperman.com, or by phone at (888) 450-2221. You are not required to pay any charge for exercising your rights.
Once you have submitted a request, we will respond to you within forty-five (45) days. If, for some reason, you do not receive a response within forty-five (45) days of your submitted request, please send an email to privacy@citrincooperman.com, as an error may have occurred. If we cannot verify your identity within the forty-five-day (45) time period, we may deny the request. If necessary, we may take up to an additional forty-five (45) calendar days to respond to a request, for a maximum total of ninety (90) calendar days from the date the request is received, provided that we contact you with an explanation of the reason why we will take more than forty-five (45) days to respond to the request. If we are unable to assist you, we will notify you within forty-five (45) days of the date you submitted the request and provide you with notice and an explanation of the reason we are not able to fulfill your request, including how to appeal our determination.
Anti-discrimination
We cannot and will not discriminate against you for exercising your CPA rights. Specifically, we will not:
- Deny you services.
- Charge you different fees or rates for services, including using discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of services.
- Suggest that you receive different rates for services or services of a different level or quality.
Appeal Process
If your request is denied, please leverage our Data Subject Access Request Form and select option “Appeal Citrin Cooperman's Refusal to Take Action on a Request.” We will respond within sixty (60) days of receipt of your appeal. You may contact the Colorado Attorney General if you have concerns about the results of the appeal.
Changes to This Notice
We may update this Statement occasionally. When we do, we will post the current version on this site, and we will revise the version date located at the top of this page. We encourage you to periodically review this Notice so that you will be aware of our privacy practices.
View the full Citrin Cooperman Privacy Notice.
Accessible Format
This Addendum is available to individuals with disabilities. To access this Addendum in an alternative downloadable format, please click here.
get in touch
Our Contact Details
If you have any questions about our privacy practices, how we use your Personal Data, your choices, and rights, or would like to exercise your rights under Colorado law, please contact us.
citrin cooperman
Attn: Privacy Office
50 Rockefeller Plaza
New York, New York 10020, USA
Toll free telephone:
888-450-2221
Email:
privacy@citrincooperman.com