Privacy Policy

Last Updated and Effective: October 6th, 2023

Guidehouse Inc. and its global subsidiaries (collectively, “Guidehouse,” “Company,” “we,” or “us”) respects your privacy and is committed to protecting your Personal Data when using our website and related websites (“Sites”), as well as mobile websites and mobile Guidehouse applications (“Mobile Apps”), services, tools, other applications or your other interactions with us online or in person (collectively our “Services”).

This Privacy Policy (“Privacy Policy”) explains how Guidehouse uses and discloses the Personal Data that we collect when you use our Services. By using the Services, you confirm that you understand and agree to the use of your Personal Data in accordance with this Privacy Policy. If you do not agree to our Privacy Policy, you may not use our Services. If you have questions about this Privacy Policy or our privacy practices, please contact us.

The Global Chief Privacy Officer and Data Protection Officer for Europe, Middle East and Asia, can be contacted at privacy@guidehouse.com if you have any questions.

This Privacy Policy applies to Guidehouse’s current U.S. and international subsidiaries, including among others, Guidehouse Europe Limited; Guidehouse Europe Limited – France Branch; Guidehouse Germany GmbH: Guidehouse Netherlands B.V., Guidehouse WTTS B.V.: Navigant Consulting Inc- Korea Branch: Guidehouse Europe Limited-Swiss Branch; Guidehouse Lithuania UAB; Guidehouse International LCC-South Africa: Guidehouse Europe Ltd- Abu Dhabi Branch; Guidehouse Europe Ltd-Dubai Branch; Guidehouse India Private Ltd Kerala; Guidehouse Inc.-Puerto Rico Branch: Guidehouse International LLC; Guidehouse Tanzania LLC: Guidehouse Canada Ltd: Guidehouse Managed Services LLC; and Guidehouse Energy Services LLC.

This Privacy Policy explains Guidehouse’s privacy practices and the choices you can make about the collection and use of information we collect from you or you provide to us. Guidehouse is committed to protecting the information that our clients, prospects, suppliers, job applicants and vendors have entrusted to us.

Assistance for disabled - If you are disabled and would like to request our Privacy Policy in an alternate format, please email privacy@guidehouse.com or call +1.800.304.9649.

1. What Personal Data Do We Collect?

“Personal Data” is information that reasonably can be used to directly or indirectly identify you. The categories of Personal Data that we collect include:

• Identity Data including name, title, job title, company name, and username/password if you create an account.
• Contact Data including email address, telephone numbers, billing and delivery address.
• Transaction Data includes information about the products and services you have purchased from us.
• Professional or Employment-Related Information, when you apply for a job with us, including your job history, professional certifications, compensation information, references and information required for or generated during a background check.
• Education Information, when you apply for a job with us, including educational institutions attended, degrees and awards obtained and grade point average.
• Technical Data includes internet protocol (“IP”) address, cookies, java script, web beacons, clear gifs, HTTP headers, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Sites.
• Usage Data including the content and features you use or view on the Services, how you navigate through the Services, the online services you visit immediately before and after you access our Services, and the search terms you enter on our Services. Guidehouse may combine information collected through means such as cookies or third-party analytics tools with Personal Data maintained by Guidehouse. For more information, please see the section titled “Tracking Technologies (Cookies)/Online Identification Technologies.”
• Marketing and Communications Data including your communication preferences in receiving information from us.
• Social Media Application Data includes your public profile, social media relationships and “likes.”
• Sensitive Personal Data: Sensitive Personal Data includes a data relating to race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life or criminal record. Generally, Guidehouse does not collect other types of Sensitive Personal Data unless legally required to do so. If you choose to provide Sensitive Personal Data to us, you consent to the use of that information as described in this Privacy Policy or as described when you choose to disclose this data.

If you are an employee of Guidehouse, please refer to the Employee Data Protection Policy for information about how we collect and use your personal information during and after your working relationship with us.
We may collect the categories of Personal Data listed above directly or indirectly from different sources, including:

• You
• Our affiliated entities
• Our clients and prospects
• Suppliers and Vendors
• Third party technologies that help our Sites operate effectively

Third party social media applications such as LinkedIn, Twitter, or Facebook

The information that we collect from and about you may be combined with information from other sources or that is publicly available (e.g., demographic information, additional contact information) that we have acquired in compliance with relevant laws.

2. How Do We Use Personal Data?

We may use your Personal Data for the following business purposes:

• To provide our Services and operate our business
• To respond to your inquiries, including requests for newsletters, publications and market research reports
• To conduct surveys to understand your interests
• To perform a contract that we have entered into with you
• To evaluate your application for employment and conduct any related background checks
• To protect the security and integrity of our Services and business
• In connection with the sale, merger or reorganization of our business
• To comply with our legal and compliance obligations
• To provide requested marketing to you or others
• In connection with processing or evaluating an application for employment. Please visit our Career Submission Terms for more information regarding the types of career information we collect and how we treat it
  
  

We will not use your Personal Data for a purpose that is incompatible with the original purpose without first obtaining your consent.

3. What are our Legal Bases to Collect and Use Personal Data?

We only collect and use Personal Data if we have a legal basis to do so, these include:

• Necessary for performance of an agreement or to take steps at your request to enter into an agreement
• Your consent
• Necessary to comply with a legal obligation
• Our legitimate interests

4. Do We Disclose Personal Data?

We may disclose the categories of Personal Data described in this Policy for the business purposes listed above with the following types of entities:

The Guidehouse Corporate Family as Controllers. We may share the information we collect about you with the Guidehouse corporate family and their and our affiliates and subsidiaries.

• Vendors and Service Providers. We may disclose your information to service providers under contract who help with our business operations. These third parties are authorized to use your Personal Data only as necessary to provide these services to us.
• Other Entities with your Consent. Other third parties to whom you explicitly ask us to send your Personal Data (or about whom you are otherwise explicitly notified and consent to when using a specific service).
• Third Parties for legal reasons. We may share Personal Data when required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to comply with such legal process, or to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• Third Parties in the event of a sale, merger or reorganization of our business.

5. How long do we process and keep your Personal Data?

We will only retain your Personal Data in identifiable form for as long as needed for the purposes for which it is gathered and processed. In determining retention periods, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer need Personal Data, we either anonymize, securely delete, or destroy it.

6. Newsletters and Marketing: Your Choices

You can control how and when you want to receive notifications regarding electronic newsletters and marketing-related emails for services described on the Site by contacting us
at yourchoices@guidehouse.com or by following the “unsubscribe” instructions within the notices.

For Guidehouse Insights.com, go to https://www.guidehouseinsights.com/my-reports/profile to update or change your preferences regarding notifications or electronics newsletter, or follow the “unsubscribe” instructions within the notices.

7. Tracking Technologies (Cookies)

We may use online identification technologies, such as cookies, web beacons, or pixels in connection with the Sites. We may also use first party and third party cookies to improve our Site and your experience using our Site, and to deliver tailored content to visitors.
You may customize your cookie settings by selecting the “cookie settings” button on the cookie banner or clicking on the “cookie settings” link on the homepage. All cookies, except those that are strictly necessary for the Site to function may be enabled or disabled at your choice. If you disable the use of certain cookies, some features of the Site (such as saving your password) may not be available to you.

When you view videos on the Site, we use digital technologies that tracks analytics information about how visitors interact with these videos. You consent to our collection and use of this information through the Site or third-party social media for up to two years or as permitted by applicable law. If you do not consent, do not watch videos on the Site. You may revoke your consent by Contacting Us.

For more information about the use of cookies and similar technology on our Site please review this Privacy Policy and our Cookies and Tracking Technologies Policy.

8. European Residents

Notice to EEA Residents.

If you are located in the European Economic Area and use our Services or provide Guidehouse your Personal Data, it may be transferred to the United States. If you create an account/profile, you consent to the collection and/or processing in the United States of your personal information and tracking technologies/cookies as described in this Policy. Transfers of Personal Data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses approved by the European Commission to which governance the Guidehouse group companies have adhered. Guidehouse also complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Guidehouse has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Guidehouse has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Guidehouse remains liable under the DPF Principles for the processing of personal information by our third-party processors, unless we can demonstrate that we are not responsible for the event giving rise to the damage.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Guidehouse commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should contact us using the contact information in the “Contact Us” section of this policy. If your complaint cannot be resolved through Guidehouse, we will cooperate with JAMS pursuant to the JAMS DPF Program, which is described on the JAMS website at https://www.jamsadr.com/eu-us-data-privacy-framework. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has DPF investigatory and enforcement powers. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Guidehouse’s compliance with the DPF Principles.

You may be entitled to exercise certain consumer rights relating to your Personal Data. These rights include:

Transparency and the right to information: we provide notice to our customers, suppliers, vendors and others of how we use Personal Data in our day-to-day operations at the time of collecting Personal Data, or as soon thereafter as possible. We also publish this privacy notice for a greater transparency.

Right to access, rectification, restriction of processing, and erasure: we provide data subjects with access to their own personal data where required by applicable law. In addition, we will rectify their Personal Data when we are notified that it is inaccurate, and we will ensure the right to erasure and to restriction of processing when these rights are not compatible with local regulations.

Right to object and withdraw consent at any time: for all marketing materials, you can opt-out anytime, and free of charge. The right to object for other processing activities will be balanced in order to ensure that it is not incompatible with local regulations or the legitimate interests of Guidehouse.

Right to data portability: based on your specific situation, we provide data subjects with the right to obtain and reuse your data across different services and includes transferring of your data to you, another controller or a trusted third party.

Right to lodge a complaint with a supervisory authority: you have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of the alleged infringement.

These requests should be submitted as follows:

• Opt-out of marketing communications: you can opt-out anytime by following the opt-out instructions in our commercial e-mails
• To exercise the rest of your rights: you should send a communication in writing
  to privacy@guidehouse.com. Guidehouse will attend to your request in a timely manner within 30 days after receiving your request. If for any reason we need to extend this period of time, we will contact you.

9. Third Parties

Our Site may contain links to other third-party websites. Guidehouse does not review or endorse, and we are not responsible for the privacy practices or the content of these third-party sites and encourage you to review each site’s privacy policy before disclosing any Personal Data.

10. Security

Guidehouse is committed to the security, confidentiality and integrity principle. We take commercially reasonable precautions to keep all information obtained from our online visitors secure against unauthorized access and use and we periodically review our security measures. We are committed to processing your data in a secure manner and have put in place specific technical and organizational measures to prevent the personal data we hold from being accidentally or deliberately compromised. We store and process your information on our servers located in the United States and around the world. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal information is accurate. You should keep in mind however, that no data transmitted over the internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information that you transmit to or from our Services.

11. Children's Privacy

Our services are not designed for, intended to track, or directed towards children under the age of 18. We do not knowingly collect personal data from children. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us. If we become aware that a child has registered for a service and has provided us with personal data, we will delete such information from our files.

12. Notification Regarding Updates

From time to time, we may update this Privacy Policy. When we make a change to our Privacy Policy, we will update the date at the top of the Privacy Policy. Your continued use of our Services after we update the Privacy Policy is your consent to the updated Privacy Policy. If any updates are material, we will also post a notice that an updated Privacy Policy is available on the Site.

This section of the Privacy Policy only applies to residents of California. If you are not a resident of California, this section does not apply to you. Terms that are capitalized are defined in the California law.

This section of our Privacy Policy serves as a Notice at Collection and Privacy Notice for California Consumers (“California Privacy Notice”). It supplements the information contained in our general Privacy Policy. Our general Privacy Policy describes the Personal Information we may have collected directly from you or indirectly about you if you use our Services or otherwise interact with us and how we have used and/or disclosed your Personal Information as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collective, the “CCPA”). This California Privacy Notice describes the consumer rights the CCPA grants to California residents.

Your CCPA Consumer Rights
The CCPA provides Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

• The right to know what Personal Information the business has collected about you;
• The right to delete Personal Information that the business has collected from you, subject to certain exceptions;
• The right to correct inaccurate Personal Information that a business maintains about you;
• The right to opt-out of the sale or sharing of Personal Information by the business—for more information, please visit our “Do Not Sell or Share My Personal Information” page, which contains our Notice of the Right to Opt-Out and opt-out mechanism;
• If the business uses or discloses Sensitive Personal Information for certain reasons, the right to limit the use or disclosure of sensitive Personal Information by the business; however, Guidehouse does not use or disclose Sensitive Personal Information in a way that would trigger this right and
• The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

As described in our privacy policy and cookie policy, we use first party and third-party digital technologies including online identifiers to perform online analytics, provide customized advertising and interact with social media sites. We may disclose these online identifiers with our analytics and marketing partners. For California residents, the disclosure of your online identifiers to these partners may be considered a “sale” or “sharing” of your information as defined by the CCPA. You have the right to opt-out of this use.

To opt-out of this use, go to our cookie settings page where you can disable all categories of cookies except those strictly necessary for our Site to function.

To exercise your other California Consumer rights, please submit a verifiable consumer request to us by either:

• Emailing us at: privacy@guidehouse.com
• Calling us at: 1-800-304-9649

Please clearly identify which rights you wish to exercise in your email. Your request must provide sufficient information to allow us to reasonable verify you are the person about whom we collected Personal Information. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request relating to your Personal Information.

Other California Privacy Rights
California’s “Shine the Light” law permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To request relevant information, please send an email to us at privacy@guidehouse.com.

We do not currently respond to Do Not Track requests.

14. Notice to Canadian Residents

This policy considers the principles of accountability, identifying purposes, consent, limiting use and disclosures, openness and safeguards established by the Canadian Privacy regulation (PIPEDA).

However, there are other principles that we also guarantee for the Canadian residents such as the principle of limiting collection, retention, accuracy, and individual access and rectification.

• Limiting collection: we limit the amount and type of the information gathered to what is necessary for the identified purposes.
• Retention: we keep personal data only as long as necessary to satisfy the purposes for which it was collected. When information is no longer required for an identified purpose or a legal requirement we destroy, erase or render anonymous the information.
• Accuracy and right to correct: we keep your personal data as accurate, complete and up to date as necessary, taking into account its use and your interests. We also provide you to request correction to your personal data if its inaccurate or incomplete.
• Right of access: we will make available to you any personal information of yours that we have collected, used or disclosed upon request, to the extent permitted by law. To exercise your request please write us at privacy@guidehouse.com and provide sufficient data for your identification. The access request does not usually have any cost, in cases it has it we will provide you an estimate beforehand.

If you have questions or concerns about this policy, please contact us at privacy@guidehouse.com. We will respond to any request as soon as possible, or in any case not later than 30 days after receipt of the request. If you are not satisfied with our response, you have the right to make a complaint to the Federal Privacy Commissioner.