Privacy Policy

Last Updated: August 21, 2023

Introduction

This Privacy Statement explains how Aburto Kinney Consulting collects and uses Personal Data and describes the rights you have with respect to your Personal Data. In this Statement, “Aburto Kinney,” “we” or “us” refers to Aburto Kinney Consulting, Inc. and its affiliated entities. 

Aburto Kinney processes Personal Data for a variety of purposes. We collect Personal Data directly from you, such as when you submit a form or contact information on our website asking for information or when you register for a Aburto Kinney sponsored event. We also automatically collect Personal Data when you engage with our websites. Alternatively, we process your Personal Data in the context of providing professional services to our clients, such as conducting security assessments and data analytics on client entrusted data. Finally, we obtain your Personal Data through publicly available sources, such as government records and online resources, as well as through vendors.

Scope

"Personal Data" is any data that can be used to identify an individual, either alone or when combined with other information that is linked or linkable to a specific individual. Personal Data can directly identify an individual, such as a name, email address, or identification number. Personal Data can also indirectly identify an individual, such as when combined data elements specify a unique individual, such as race, gender, and job role within a work environment. Another example is when data elements specify the physical, behavioral, mental, genetic, economic, cultural, or social identity or activities of a unique individual.
“Sensitive Personal Data” includes the following special categories of personal data:

• Government identification card or number
• Financial account numbers and access codes
• Precise geolocation
• Biometric or genetic data when used to identify an individual
• Medical information
• Criminal records
• Racial or ethnic origin
• Religious or philosophical beliefs
• Union membership
• Sex life or sexual orientation
• Content of communications if obtained by someone who is not the intended recipient

Your Rights in Relation to the Personal Data We Collect and Process

You have the following rights related to your Personal Data that Aburto Kinney collects and processes:

• Right to request access to your Personal Data maintained by Aburto Kinney 
• Right to request amendment or correction of your Personal Data
• Right to request deletion of your Personal Data 
• Right to request data portability or the right to receive a copy of your Personal Data in a structured, commonly used and machine-readable format to transfer to another company
• Right to opt-out of marketing communications at any time
• Right to request restriction or to object to the processing of your Personal Data 
• Right to withdraw consent, if you have voluntarily provided, or have consented to provide your Personal Data
• Right to complain to a data protection authority 

If you want to assert any of the above rights, you may contact us at info@aburtokinney.com. We will respond to your request consistent with applicable law. See Related Privacy Policies for more details on your rights and how to exercise your rights.

In your request, please include the following:

• The nature of the request (the type of right you are asserting)
• What Personal Data you seek to access, amend, delete, restrict, transmit to another company, or withdraw consent to process

For your protection, we may only respond to requests with respect to the Personal Data associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and within the requirements of any applicable law.

Please note that we may need to retain certain information for recordkeeping purposes, to comply with legal obligations, and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records or in backups which will not be removed until the retention period ends.

Minors

Aburto Kinney does not intend this Site to be directed to individuals under the age of eighteen (18), and we do not knowingly collect, process, disclose, or share the Personal Data of minors from this Site. If you are a minor and believe that you have provided Personal Data, please ask your parent(s) or legal guardian(s) to notify us, and we will delete your Personal Data.

Purpose Specification and Use Limitation

Aburto Kinney limits the collection, use, retention, and disclosure of Personal Data to what is reasonably necessary and proportionate to achieve the purposes for which the Personal Data was collected or processed. Aburto Kinney also limits secondary use or disclosure to that which is compatible with the original purpose of the Personal Data collection, or we will get consent to process the Personal Data, unless the processing is permitted or required by law.

Individuals who engage on social media sites, plug-ins, and tools

Social Media Sites

Aburto Kinney uses various social media platforms, such as Facebook or LinkedIn, for recruitment or marketing purposes. We use social media to provide easy access to relevant information about job opportunities and events and to promote our services and brand. 

Aburto Kinney is responsible for the content it publishes using social media platforms, but does not have control over the social media platforms and the way they are administered. When using these social media platforms, you must adhere to the terms of use and privacy policies imposed by the platform providers.  If you would like to access this data or invoke your rights to the data, such as the right to correct or object to the processing of the data, you should contact the social media platform provider. 

Some social media platforms provide Aburto Kinney with data relevant to your pages that is aggregated or combined with similar data from other visitors to our social media sites, such as the number of “likes” triggered by our content or the amounts of posts, visitors to the sites, and information downloaded or links clicked.

Social Media Plug-Ins

We use some social media plug-ins on our site that allow you to share information with your social network, view content, and provide you with relevant information. When you interact with these features your internet browser will directly connect you to the relevant social network server to complete the action. The social media provider will know that the page with the plug-in on our site has been visited. 

Aburto Kinney or our service providers may also provide the social media provider with advertisements or marketing materials that they can deliver to individuals who viewed related content on our websites. The social media sites may also use the Personal Data collected in ways consistent with that provider’s notices and terms of use. 

We have no control over the data collected by the social media providers through the use of the buttons. Aburto Kinney does not know the type of data collected or how it is used. 

Individuals who engage Aburto Kinney through email correspondence

Email Correspondence

Aburto Kinney uses tools to protect the security of our information technology (IT) assets, including our email transmissions. Examples include:

• Systems that scan incoming emails for suspicious attachments and universal resource locators (URLs) to prevent malware attacks
• End-point threat detection tools to detect malicious attacks
• Tools that block certain content or websites.

If you send emails to Aburto Kinney, your emails will be scanned by these tools to maintain Aburto Kinney’s IT infrastructure security, which means that Aburto Kinney personnel other than the intended recipient may read your email content.

Individual contacts in Aburto Kinney’s Customer Relationship Management (CRM) systems

We process Personal Data about client contacts, industry partners, and Aburto Kinney alumni in our CRM system. This system supports Aburto Kinney business development and, to some extent, marketing efforts. In our CRM systems, we process the following categories of personal data:

• Name, email address, phone
• Name of employer or organization the individual is associated with
• Marketing opt-in or opt-out information if the individual has been identified in Aburto Kinney’s marketing list of contacts

Recruitment

We collect information from and about individuals in connection with employment opportunities at Aburto Kinney. In general, the data we collect includes resumes or CVs, identification documents, academic records, work history, and employment information. 

We use your information to determine qualifications based on education, experience, and skills for available positions at Aburto Kinney. The information is shared with recruiters, hiring managers, and other persons involved in the recruitment process. Aburto Kinney may collect further information if you are invited for an interview.

We also collect Sensitive Personal Data from candidates during recruitment and onboarding when employment law obligates us or when candidates consent and voluntarily provide the information, as permitted by applicable law.  This information assists Aburto Kinney in providing a diverse working environment and in providing benefits. For example, Aburto Kinney may request race or disability information for analyzing the diversity of our workforce or providing reasonable accommodations. In some cases, Aburto Kinney is required by law to provide diversity information and may need to make an assessment without the help of the candidate or employee.

In addition, we collect Sensitive Personal Data related to criminal background checks on prospective candidates after they receive an offer.

Depending on the country in which you apply, Aburto Kinney collects Personal Data about candidates from the following sources:

• From you directly – for example through the application you submit
• From third parties, such as placement firms, recruiters, or job-search websites – for example, when they contact us with your information as a potential candidate
• From referrals – for example friends at Aburto Kinney
• From publicly available sources online – for example, your professional profile posted on LinkedIn or on another website
• From education institutions – for example the universities listed on your resume
• From background screening either by Aburto Kinney or a Aburto Kinney service provider

Individuals who attend Aburto Kinney events

As described above, Aburto Kinney processes event registration through Aburto Kinney websites and social media applications. As part of the event management, we also process the following Personal Data:

• Name
• Email address
• Company 
• Title
• Country
• Any other information you choose to provide in a comment

We do not intend to collect Sensitive Personal Data, unless you provide it to us. We encourage you not to provide Sensitive Personal Data in free text boxes or communications, but if you do, you acknowledge that you consent to the collection and processing of the Sensitive Personal Data. 

If you submit any Personal Data relating to other people to us or to our service providers in connection with this Site, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy. 

In registering for an event, you may choose to receive marketing communications from Aburto Kinney. If you elect to opt-out of receiving Aburto Kinney publications or marketing communications, your basic contact details will remain on our opt-out list.

Photographs and video recordings at Aburto Kinney events

Aburto Kinney may take photographs or video recordings at Aburto Kinney sponsored or co-sponsored events. Participants will be asked to sign a consent for the use of their photographs during registration or at the event. Aburto Kinney will only use the photographs of participants who have signed consents permitting the use of their images for commercial purposes or marketing. 

For some events, Aburto Kinney may not be able to obtain explicit written consent for photographs and video recordings taken at the event. Instead, Aburto Kinney will post signage providing notice of the photographs and recordings. Aburto Kinney will only use these photographs and video recordings internally, unless you have provided a prior written consent to use the photographs and video recordings for marketing or commercial purposes. If you would like to withdraw your consent, you can contact Aburto Kinney at info@aburtokinney.com.

Clients

When a client engages Aburto Kinney for services or products, Aburto Kinney collects and processes Personal Data for legitimate business purposes in connection with those services. Aburto Kinney may process Personal Data voluntarily provided by our clients or third parties at the request of our clients. This Personal Data includes:

• Name
• Contact Information, including work address, email address, and telephone number
• Company where you work and your role at the company
• Financial information 
• Any other information provided to us for purposes of providing services

Individuals whose personal data we process in providing services to clients

In providing services to government and commercial clients, Aburto Kinney processes the Personal Data of individuals with whom we do not have a direct relationship (contractual or otherwise). For example, our government or commercial clients may contract with us to perform data analytics, cybersecurity assessments, or any other numerous services. In doing this work, we may have access to the Personal Data collected and maintained by our clients. In some client engagements, Aburto Kinney collects Personal Data of individuals on behalf of the clients. For example, Aburto Kinney may conduct a research project on behalf of the client where Aburto Kinney employees interact directly with individuals and collect their Personal Data. When Aburto Kinney collects Personal Data directly from the individuals, Aburto Kinney will ensure that the collection is done lawfully with either the required notice and consent of the individual or with the required legal authority acting on behalf of the client.

Individuals whose personal data we process in developing commercial products or conducting research

Aburto Kinney collects, receives, and processes Personal Data of individuals to develop and improve commercial products and services. 

Aburto Kinney also obtains data sets for the purposes of conducting research. In some cases, Aburto Kinney obtains and processes de-identified or anonymized Personal Data, which means that the data cannot be tied to an individual. In other cases, Aburto Kinney may obtain or process a limited data set, where the data set only has indirect identifiers, or a pseudonymized data set, where the data set is de-identified, but may be re-identified. 

The types of Personal Data that Aburto Kinney may obtain include, but are not limited to:

• Mobile device identifiers
• Photographs
• Audio recordings
• Health data 
• Videos

Individuals who pose a potential threat or risk to Aburto Kinney

Aburto Kinney collects and processes the Personal Data of individuals who present a potential security threat to Aburto Kinney people, facilities, assets, business, and reputation. Aburto Kinney only collects and processes the Personal Data as needed to assess and mitigate the threat. 

Suppliers

Aburto Kinney collects and processes Personal Data about suppliers, including vendors, subcontractors, and individuals associated with them. We process the Personal Data to manage our contractual relationships and to enable services from our suppliers. 

The Personal Data we collect and process generally includes:

• Name
• Employer name
• Contact information (phone and email address)
• Communications related to providing the services
• Financial information related to payment of services

Aburto Kinney also collects Personal Data to check for conflict of interest and to conduct background checks required by law or regulations, such as laws related to fraud and corruption and international trade compliance regulations. Aburto Kinney may also collect Personal Data in doing due diligence prior to engaging a supplier.

Retention

Aburto Kinney retains PII only as long as needed for the stated processing purpose. Aburto Kinney’s record retention schedule provides the required retention periods for Aburto Kinney records based on business and legal requirements, including the need to exercise and defend legal rights. Aburto Kinney also maintains records for archiving and historical purposes in compliance with retention periods. If Personal Data is not in a record subject to Aburto Kinney’s retention schedule, Aburto Kinney policy requires that the Personal Data be deleted when no longer necessary for the stated processing purpose.

Aburto Kinney Ethics

Aburto Kinney provides employees, clients, and external third-parties a means to report unethical or illegal behaviors that violate the law, regulations, or Aburto Kinney policy. Reports can be made to info@aburtokinney.com.

Security of Personal Data

Aburto Kinney uses reasonable organizational, technical, and administrative measures to protect the confidentiality, integrity, and availability of the Personal Data that Aburto Kinney collects, maintains, and processes. Aburto Kinney limits access to information to those with a need to know to process the Personal Data. Aburto Kinney also implements policies, procedures, and technical controls to safeguard the Personal Data from unauthorized access, loss, misuse, and improper disclosure.

If you have reason to believe that your Personal Data is no longer secure, please immediately notify us at info@aburtokinney.com. Because email communications are not always secure, please do not include sensitive information in your emails to us.

Security of Personal Data

Aburto Kinney maintains the accuracy, completeness, and timeliness of the Personal Data we store. We need your help in updating us on your contact details or other Personal Data to have the most up-to-date information. You can contact the staff you usually engage with at Aburto Kinney or info@aburtokinney.com.

Disclosures of Personal Data

Aburto Kinney discloses Personal Data for the following purposes:

• As directed by you or at your consent
• Where the disclosure is necessary and appropriate for the purposes described in this policy, including within the Aburto Kinney entities 
• If required by applicable law,      including laws outside the country where the Personal Data was collected
• In connection with a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business assets or stock      (including in connection with any bankruptcy or similar proceeding)
• To protect, exercise, and defend Aburto Kinney’s legal claims, safety, or property
• To comply with a regulatory or government inquiry, court order, or other legal obligation, including those outside the country where the Personal Data was collected
• To cooperate with law enforcement as necessary

Aburto Kinney is obligated to report certain activities or suspected criminal activity to relevant regulatory authorities and law enforcement. The law sometimes prohibits Aburto Kinney from informing the individual about the disclosure prior to the disclosure, or at all. Third-party recipients of the Personal Data may include:

• Law firms, tax advisors, or auditors
• Insurers
• Audit regulators
• Tax and customs, and excise authorities
• Regulatory bodies
• Credit reference agencies
• Courts, police, and law enforcement agencies
• Government departments and agencies
• Service providers

Complaints

If you want to report an alleged violation or breach of a privacy law or any other regulation, you should contact us at info@aburtokinney.com.

You also have the right to complain to the data protection authority in your country or refer the matter to a court of competent jurisdiction or as specified in any applicable engagement agreement with Aburto Kinney. 

If you are located in the EEA, you may lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs.

Revisions to the Privacy Statement

We may change this Privacy Statement to reflect changes in our practices and services. The “Last Updated” legend at the top of this page indicates when this Privacy Statement was last revised. Any changes will become effective when we post the revised notice on this website. We recommend checking this Statement from time to time to inform yourself of any changes based on the last updated date.