Effective date: June 1, 2018
Thank you for engaging with Transition Management Advisors at jimcanterucci.com. We are committed to safeguarding the privacy of our website visitors.
The use of the web pages of jimcanterucci.com is possible without providing any Personal Data. Some services provided do require the processing of Personal Data. When Personal Data is needed we generally obtain consent.
The processing of Personal Data such as name, email address, address, or telephone number shall be in accordance with the accepted data protection regulations of the United States and the General Data Protection Regulation (GDPR).
Personal Data – Personal data is any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Data Subject – Data Subject is any identified or identifiable natural person, whose Personal Data is processed by the controller responsible for the processing.
Processing – Processing is any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of Processing – Restriction of processing is the marking of stored Personal Data with the aim of limiting their processing in the future.
Profiling – Profiling means any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Pseudonymisation – Pseudonymisation is the processing of Personal Data in such a manner that the Personal Data can no longer be attributed to a specific Data Subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the Personal Data are not attributed to an identified or identifiable natural person.
Controller – Controller or Data Controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor – Processor is a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller.
Recipient – Recipient is a natural or legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a third party or not. However, public authorities which may receive Personal Data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third Party – Third party is a natural or legal person, public authority, agency or body other than the Data Subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process Personal Data.
Consent – Consent of the Data Subject is any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to him or her.
Name and Address of the Controller
Transition Management Advisors
992 Martingrove Court
Westerville, Ohio 43081-3596
Name and Address of the Data Protection Officer
The Data Protection Officer of the Controller is:
Transition Management Advisors
992 Martingrove Court
Westerville, Ohio 43081-3596
Any Data Subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.
The jimcanterucci.com web site stores cookies on your computer. These cookies are used to collect information about how you interact with the website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics on this web site.
We log “Personal Data” to Clicky as follows, for the stated legitimate purposes. A “Unique ID” tracking cookie to identify unique visitors, your IP address for security and fraud prevention, and your username to help us to analyze visitor behavior and assist with customer service needs.
The Data Subject may, at any time, prevent the setting of cookies by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Cookies may be deleted at any time via an Internet browser or other software program. If the Data Subject deactivates the setting of cookies in the Internet browser used, all functions of our website may not be entirely useable.
Collection of general data and information
The website jimcanterucci.com collects a series of general data and information when a Data Subject or automated system accesses the website. This general data and information is stored in server log files. Data collected may include the browser types and versions used, the operating system used by the accessing system, the website from which an accessing system reaches jimcanterucci.com (referrers), the sub-websites, the data and time of access to the website, an Internet Protocol address (IP address), the Internet service provider of the accessing system, and any other similar data and information that may be used in the event of attacks on our information technology systems.
When using this general data, Transition Management Advisors does not draw any conclusions about the Data Subject. Rather this information is needed to deliver the content of our website correctly, optimize the content of our website, ensure the long-term viability of our information technology systems and website technology, and provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Transition Management Advisors analyzes anonymously collected data and information statistically, with the aim of increasing the data security of our company, and to ensure an optimal level of protection for the Personal Data we process. The anonymous data of the server log files are stored separately from all Personal Data provided by a Data Subject.
Subscription to email communication
During the registration for email communication, the IP address of the computer system assigned by the Internet service provider (ISP) and used by the Data Subject at the time of registration and the data and time of registration is stored. The collection of this data is to protect against the possible misuse of a Data Subject email address at a future date.
The Personal Data collected as part of registration for email communication will only be used for the specified email communication. There will be no transfer of Personal Data collected by the email service to third parties. The subscription to our email communication may be terminated by the Data Subject at any time. The consent to the storage of Personal Data, which the Data Subject has given for email communication, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each email communication. It is also possible to unsubscribe from the email at any time on the website of the Data Controller, or to communicate this to the controller in any other way.
Email communications contain tracking pixels. This tracking enable log file recording and analysis. This allows statistical analysis. Based on this tracking, Transition Management Advisors may see if and when an email is opened and if links within the email are clicked. Such data is collected to optimize the quality and performance of email communication. Revocation of consent to receive email communication also serves as revocation of email tracking.
The website jimcanterucci.com contains contact information for Transition Management Advisors allowing direct communication with us. There is no transfer of Personal Data that is part of this communication to any third party.
Blog comments are not accepted or maintained on the jimcanterucci.com website. No Personal Data is stored as a result.
Routine erasure and blocking of Personal Data
The Data Controller shall process and store the Personal Data of the Data Subject only for the period necessary to achieve the intended purpose or required by law.
Rights of the Data Subject
Right of Confirmation – Each Data Subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not Personal Data concerning him or her are being processed. If a Data Subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.
Right of Access – Each Data Subject shall have the right granted by the European legislator to obtain from the controller free information about his or her Personal Data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the Data Subject access to the following information: the purposes of the processing; the categories of Personal Data concerned; the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the Personal Data will be stored or if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of Personal Data, or restriction of processing of Personal Data concerning the Data Subject, or to object to such processing, the existence of the right to lodge a complaint with a supervisory authority; where the Personal Data are not collected from the Data Subject, any available information as to their source; the existence of automated decision-making, including Profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the Data Subject. Furthermore, the Data Subject shall have a right to obtain information as to whether Personal Data are transferred to a third country or to an international organization. Where this is the case, the Data Subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a Data Subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.
Right to Rectification
Each Data Subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate Personal Data concerning him or her. Taking into account the purposes of the processing, the Data Subject shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement. If a Data Subject wishes to exercise this right to rectification, he or she may at any time, contact our Data Protection Officer or another employee of the controller.
Right to Erasure (Right to be forgotten)
Each Data Subject shall have the right granted by the European legislator to obtain from the controller the erasure of Personal Data concerning him or her without undue delay, and the controller shall have the obligation to erase Personal Data without undue delay where one of the following grounds applies, as long as the processing is not necessary: the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; the Data Subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing; the Data Subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the Data Subject objects to the processing pursuant to Article 21(2) of the GDPR; the Personal Data have been unlawfully processed; the Personal Data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; the Personal Data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR. If one of the aforementioned reasons applies, and a Data Subject wishes to request the erasure of Personal Data stored by Transition Management Advisors, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer or another employee shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made Personal Data public and is obliged pursuant to Article 17(1) to erase the Personal Data, the controller considering available technology and the cost of implementation, shall take reasonable steps, including technical measures to inform other controllers processing the Personal Data that the Data Subject has requested erasure by such controllers of any links to, or copy or replication of, those Personal Data, as far as processing is not required. The Data Protection Officer of Transition Management Advisors or another employee will arrange the necessary measures in individual cases.
Right of Restriction of Processing
Each Data Subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies: the accuracy of the Personal Data is contested by the Data Subject, for a period enabling the controller to verify the accuracy of the Personal Data; the processing is unlawful and the Data Subject opposes the erasure of the Personal Data and requests instead the restriction of their use instead; the controller no longer needs the Personal Data for the purposes of the processing, but they are required by the Data Subject for the establishment, exercise of defense of legal claims; the Data Subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the Data Subject. If one of the aforementioned conditions is met, and a Data Subject wishes to request the restriction of the processing of Personal Data stored by Transition Management Advisors, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of Transition Management Advisors or another employee will arrange the restriction of the processing.
Right to Data Portability
Each Data Subject shall have the right granted by the European legislator, to receive the Personal Data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the Personal Data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the Data Subject shall have the right to have Personal Data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the Data Subject may at any time contact the Data Protection Officer or another employee of the controller.
Right to Object
Each Data Subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of Personal Data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to Profiling based on these provisions. Transition Management Advisors shall no longer process the Personal Data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject, or for the establishment, exercise or defense of legal claims. If Transition Management Advisors processes Personal Data for direct marketing purposes, the Data Subject shall have the right to object at any time to processing of Personal Data concerning him or her for such marketing. This applies to Profiling to the extent that it is related to such direct marketing. If the Data Subject objects to Transition Management Advisors to the processing for direct marketing purposes the Personal Data will no longer be processed for these purposes. In addition, the Data Subject has the right, on grounds relating to his or her particular situation, to object to processing of Personal Data concerning him or her by Transition Management Advisors for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for the reasons of public interest. In order to exercise the right to object the Data Subject may directly contact the Data Protection Officer of Transition Management Advisor or another employee. In addition, the Data Subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
Automated Individual Decision Making Including Profiling
Each Data Subject shall have the right granted by the European legislator bot to be subject to a decision based solely on automated processing, including Profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the Data Subject and a Data Controller, or (2) is both authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests, or (3) is not based on the Data Subject’s explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the Data Subject and Data Controller, or (2) it is based on the Data Subject’s explicit consent, Transition Management Advisors shall implement suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller to express his or her point of view and contest the decision. If the Data Subject wishes to exercise the rights concerning automated individual decision making, he or she may, at any time, directly contact our Data Protection Officer or another employee of the controller.
Right to Withdraw Data Protection Consent
Each Data Subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her Personal Data at any time. If the Data Subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our Data Protection Officer or another employee of the controller.
Data protection provision about the application and use of LinkedIn
The controller has integrated components of the LinkedIn Corporation on jimcanterucci.com. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.
With each access to one of the individual pages of this website, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the Data Subject is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins. During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the Data Subject.
If the Data Subject is logged in at the same time on LinkedIn, LinkedIn detects with every access to our website by the Data Subject—and for the entire duration of their stay on our website—which specific sub-page of our website was visited by the Data Subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the Data Subject. If the Data Subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the Data Subject and stores the Personal Data.
LinkedIn receives information via the LinkedIn component that the Data Subject has visited our website, provided that the Data Subject is logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the Data Subject, then he or she may prevent this by logging off from their LinkedIn account before access to our website is made.
Data protection provision about the application and use of YouTube
On this website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish various kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
With each access to one of the individual pages of this website, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the Data Subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the Data Subject.
If the Data Subject is logged in on YouTube, YouTube recognizes with each access of a sub-page that contains a YouTube video, which specific sub-page of our website was visited by the Data Subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the Data Subject.
YouTube and Google will receive information through the YouTube component that the Data Subject has visited our website, if the Data Subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the Data Subject, the delivery may be prevented if the Data Subject logs off from their own YouTube account before a call-up to our website is made.
YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of Personal Data by YouTube and Google.