Connecticut Privacy Policy

This policy supplements the information contained in our Privacy Policy and Client Data Privacy Notice (“Privacy Notice) (together, “Privacy Statements”) and is adopted to comply with the Connecticut Data Privacy Act (“CTDPA”), and related regulations, as may be further amended from time to time (“CTDPA Policy”). This CTDPA Policy applies solely to individuals who reside in the State of Connecticut (“Consumers”). Any terms defined in the CTDPA have the same meaning when used in this CTDPA Policy. All other capitalized terms shall have the same meaning as those designated in the Privacy Statements. For purposes of this CTDPA Policy, “Personal Information,” shall include the CTDPA’s definition of “Personal Data.” This CTDPA Policy explains how CohnReznick, and certain affiliates as applicable, (“CohnReznick,” “we,” “us,” or “our”) collect, use, disclose and retain Personal Information and how consumers may exercise their rights under CTDPA. Note CohnReznick LLP and its affiliates are separate legal entities, and each entity is solely responsible for its own acts and/or omissions.

WHAT INFORMATION IS COLLECTED

CohnReznick’s data collection practices include the collection and use of Personal Information as described in the Privacy Statements and as set forth below. This CTDPA Policy applies to our data practices both online and offline. 

Generally, CohnReznick collects the following categories of Personal Information: 

• Identifiers, including contact information and biographic information;
• Commercial information;
• Financial information; 
• Internet or other similar network, browsing, or search activity;
• Non-precise Geolocation data;
• Professional or employment-related information; and
• Sensitive personal information 
  
  

OUR PURPOSES FOR THE COLLECTION AND USE OF PERSONAL INFORMATION

We may collect Personal Information directly from Clients, users of our website, certain affiliates, business partners, agents, etc. Our collection and use of Personal Information is limited to the purposes of performing and improving services, supporting business operations and maintaining Client relationships, which may include the following: 

1. For execution of a Contract, to execute and protect our rights or the rights of our service providers under a Contract, or enforce the terms and conditions arising under a Contract (e.g., performing services, maintaining the client relationship, keeping the client informed, invoicing and bill collection) or other agreement between the parties;
2. To perform client acceptance procedures, including verifying identities and addresses and performing other due diligence to protect our business interests and to determine eligibility for services; 
3. To comply with legal, tax, accounting, or regulatory obligations to which CohnReznick or a third party is subject, including complying with auditing standards;
4. To manage risk and operations, legal obligations, including ensuring internal compliance with our policies and procedures, to respond to regulatory and government oversight applicable to CohnReznick, and to investigation complaints or pursue and defend claims, proceedings, or disputes;
5. To protect the security and integrity of CohnReznick’s information technology systems;
6. To provide information about relevant services offered by CohnReznick, opportunities and experiences offered by CohnReznick;
7. To evaluate, develop and improve the quality of CohnReznick’s professionals and services or our website and for other related internal business purposes;
8. To seek professional advice, such as from professional advisors (including, but not limited to, legal counsel);
9. For recruitment and evaluation of qualifications for employment or internships;
10. For website related services, like analytics, insights, or customer support, quality and safety maintenance, or to develop new technological improvements; 
11. To evaluate or facilitate the sale or potential sale of all or part of CohnReznick or CohnReznick’s potential acquisition of other entities; 
12. For other purposes that are compatible with this Privacy Policy or where permitted by applicable law; and
13. As otherwise disclosed upon collection, or to the extent Client or a data subject provides other consent or authorization to the collection, use, disclosure and storage of personal information.

CATEGORIES OF PERSONAL INFORMATION SHARED WITH THIRD PARTIES

CohnReznick may disclose the categories outlined in the “What Information is Collected” section to third parties. 

CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE PERSONAL DATA

We may use, disclose, or transmit Personal Information we collect to other service providers or other third parties for business purposes, to provide our Services, to support business operations, store and protect information, or for other purposes as provided by the CTDPA. CohnReznick may also disclose your personal information to third parties, including: 

1. our employees, certain affiliates, contractors, agents and third-party vendors to perform services related to your account, to offer our products and services, and for business operations;
2. professional service providers for business operations; 
3. information technology, software, and cloud providers, security providers, and similar services in connection with providing services and in the support of daily operations;
4. service providers to support business operations, develop, operate, and maintain our website, and for marketing purposes;
5. government agencies and regulators to fulfill legal obligations;
6. a buyer or successor in the event of a merger, divestiture, 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 or third parties in connection with CohnReznick’s acquisition of other entities; 
7. to third parties for the purposes of fraud prevention and credit risk reduction (e.g., if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CohnReznick, our clients, or others);
8. law enforcement or government officials; or 
9. any other entity disclosed by CohnReznick when you provide the information, or for which you provide consent.

CONSUMER RIGHTS UNDER CTDPA

The CTDPA provides Consumers with specific rights regarding their Personal Data, one per consumer during any twelve-month period. This Section details how your rights may be exercised. 

1. Consumers have the right to confirm whether or not CohnReznick is processing Personal Data and access such Personal Data (the “Right to Access/Confirm”). 
2. Consumers have the right to obtain a copy of the Consumer's Personal Data maintained by CohnReznick (the “Right to Data Portability”). 
3. Consumers have the right to correct inaccuracies in the Consumer's Personal Data (the “Right to Correct”) maintained by CohnReznick. 
4. Consumers have the right to request deletion of Personal Data, subject to certain exceptions (the “Right to Delete”). Once we receive a request and confirm the Consumer’s identity, we will review the request to determine if an exception allowing us to retain the information applies.
5. Consumers have the right to opt out of the processing of the Personal Data for purposes of Target Advertising (the “Right to Opt-Out”).  

HOW TO EXERCISE RIGHTS UNDER CTDPA

Connecticut Consumers or their authorized agents may submit a request using the contact information below.  

If you’re making a request as an Authorized Agent, please submit the request on behalf of the Consumer and provide proof that the Consumer provided you signed permission to submit the request. We may also require that you confirm your identity by providing a driver’s license, passport or other form of identification.  

When submitting a request under CTDPA, we are required to reasonably Authenticate your request to appropriately secure Personal Data. If we cannot authenticate the request, we will notify the requestor that we are unable to fulfill the request. We will only use Personal Data provided in the request to verify the requestor’s identity or authority to make it. We endeavor to respond to an authenticated consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period. We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will detail why we made that decision and provide a cost estimate before completing the request. If you have any other questions regarding this process, please contact us. 

If you disagree with the CohnReznick’s refusal concerning a consumer request, you have the right to appeal the decision by contacting us using the information provided below. Within sixty (60) days after receipt of an appeal, CohnReznick shall inform you, in writing, of any action taken or not taken in response to the appeal, including an explanation of CohnReznick’s decision. 

UPDATES TO THIS CTDPA POLICY

You are advised to review this policy periodically for any changes. We may update this CTDPA Policy from time to time as it may be revised due to legislative changes, changes in technology or our privacy practices or new uses of Personal Data not previously disclosed in this CTDPA Policy. We will notify you of any material changesand update the “Last Updated” date at the top of the policy .  Changes to this CTDPA Policy are effective when they are posted on our website.  If you have any comments, concerns or questions about this CTDPA Policy, please contact us. 

CONTACT US

You acknowledge and consent to your Personal Information being collected, processed, stored, analyzed and disclosed as set forth in this privacy policy. If Connecticut consumers or Authorized Agents have any requests, questions or complaints regarding the privacy of their Personal Information or have a request to exercise their rights under the applicable laws governing their Personal Information, they may submit a request or contact CohnReznick in one of the following ways:

1. By emailing us at [email protected]   
2. By telephone at: 1-862-245-5031
3. By submission of a Privacy Request Web Form: Privacy Request Web Form
4. By written notice mailed to:  

   CohnReznick LLP
   Attn: Legal Department
   14 Sylvan Way
   Parsippany, New Jersey 07054