California Consumer Privacy Act (CCPA) Policy

This privacy policy and notice for California residents applies solely to visitors, users, and individuals, who reside in the State of California (“consumers” or “you”). We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA). The terms “business,” “business purpose”, “personal information”, “processing”, and “service provider” have the meanings giving to them in the CCPA and CPRA.

Our Role

Kroll LLC (and all affiliates and subsidiaries, collectively “Kroll” “we” or “us”) may collect and use consumer personal information for its commercial and business purposes and related operational purposes. With respect to these activities, Kroll may have direct responsibilities as a business subject to the CCPA. For example, for certain activities related to direct interaction with consumers who have a direct relationship with Kroll, interacting with prospective/current clients, marketing, website and web application use, engaging vendors, and interacting with visitors/users of our Website. In these cases, this privacy policy is applicable.

Kroll also collects information in its capacity as a service provider to our clients, providing valuation, corporate finance advisory, governance, risk, investigations, disputes consulting and related services. In that case, Kroll receives personal information from or on behalf of our clients where we have no direct relationship with the individuals whose personal information we process, and information is provided to us solely for the business purpose of providing those services. If you are a customer or other user associated with one of our clients on whose behalf we have collected or processed your information, this privacy policy does not apply to you, and if you have questions or wish to exercise your rights relating to your personal information (such as information, access, correction or deletion), please contact that client directly. 

Categories of Personal Information We Collect

The specific personal information that we collect, use, and disclose relating to a California resident covered by the CCPA and CPRA will vary based on our relationship or interaction with that individual.

In the past 12 months, we have collected, used and disclosed for business purposes, the following categories of personal information relating to California residents covered by this policy:

Sources of Personal Information We Collect

• Information directly from you, the consumer, that you choose to provide, when you interact with us, for example, when you communicate with us by phone, email or otherwise, register for an event, subscribe to marketing or other communications, or inquire about or purchase a product or service.
• Information we automatically collect when you interact with our website, content or emails such as your IP address and the pages you visited, and when you use our services, we may collect information on how you use those services. Please see our Website Use and Cookies Policy for additional information.
• Information provided by our clients in order for us to provide specific services as a service provider, or information from third parties, acquired at the direction of our clients in order to provide the services.
• Information from other sources, including service providers or publicly available sources.

Business Purposes

We collect personal information to offer and administer our services and products. These include valuation, corporate finance advisory, governance, risk, investigations, disputes consulting and related services. We use personal information for the following business purposes:

• To provide the products or perform services for clients pursuant to a written agreement, including contacting you in the course of our ordinary commercial relationship, maintaining and servicing client accounts, verifying client information, processing payments, or similar activities as needed to provide services for or on behalf of our clients.
• To comply with our legal, risk, or compliance obligations in operating our business, for example conducting anti-money laundering/ due diligence checks on clients, vendors, third parties, or business partners.
• For marketing purposes. For example, we may use your information to further discuss your interest in the services and to send you information regarding Kroll such as information about promotions, events, products or services. You may opt-out of receiving marketing communications and updates at any time. 
• To improve Kroll's communications with you. Emails sent to you by Kroll may include standard tracking, including open and click activities. Kroll may collect information about your activity as you interact with our email messages and related content in order to verify or maintain the quality of our communications, or improve, upgrade, or enhance the services we provide.
• For operating and improving Kroll website and web applications and your customer experience, including debugging to identify and repair errors that impair existing intended functionality or to verify or maintain the quality of our website, auditing related to counting ad impressions to unique visitors and verifying positioning and quality of ad impressions, and to improve, upgrade or enhance the website services. For example, we may collect and analyze data on your use of our website and process it for the purpose of improving our online experience. Please see our Website Use and Cookies Policy for additional information.
• For security and integrity purposes, including securing Kroll’s network, detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
• For other business purposes, which will be disclosed at the time we collect personal information.

Selling/Sharing of Personal Data

In the preceding 12 months, we have not sold personal information and we have not shared personal information with a third party for cross-context behavioral advertising.

Disclosure of Personal Data for our Business Purposes

We have disclosed personal information for business purposes in the preceding 12 months to the following categories of parties:

• Our affiliates, as needed to operate our business and provide services.
• Service providers or contractors, such as vendors, consultants and other service providers who perform certain services on behalf of Kroll, in which case we enter a contract that describes the purpose of processing and requires the recipient to not use it for any purpose except performing the contract.
• Third parties to whom you or your agents request or authorize us to disclose your personal information in connection with products or services we provide to you.

Data Retention

Kroll will retain personal information for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with state, local, and federal regulations, and in accordance with Kroll’s Document Retention Schedule.

Your Rights

Subject to the CCPA, CPRA and other applicable laws, you have the following rights concerning your data processed by Kroll:

• Deletion: You have the right to request that Kroll erase your personal information, and Kroll will erase such information unless it is reasonably necessary for Kroll to maintain your personal data in accordance with CCPA 1798.105 (d) or 1798.145
• Correction: You have the right to request that Kroll correct inaccurate personal information, taking into account the nature and purpose of processing the information.
• Access: You have the right to request to access the personal information that Kroll holds about you, including specific pieces of personal information Kroll has collected about you.
• Non-discrimination: Kroll will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA or CPRA.

Contact Us

Please contact us if you wish to exercise your rights under CCPA/CPRA:

Email: [email protected]

In Writing: Kroll Compliance and Privacy Office, 167 N. Green St., Floor 12, Chicago, IL 60607