Privacy Policy

Last Updated: January 10, 2025

Welcome to Brobston Group (“we”, “us”, or “our”). We value your privacy and are committed to protecting your personal data. This Privacy Policy describes how Brobston Group LLC collects, uses, and discloses information when you visit our website, create an account, or otherwise engage with our services.

By using our website or services, you agree to the practices described in this Privacy Policy. If you do not agree with any part of this policy, please refrain from using our website or services.

Who We Are

• Legal Entity: Brobston Group LLC
• Founded: 2017 by William Brobston
• Location: Based in New York City, operating primarily in the United States and Canada.
• Services: We are a leading recruitment and consulting agency specializing in luxury fashion, jewelry, beauty, and home décor. We offer both hands-on recruiting and job posting services for luxury brands and retailers, as well as resume and coaching services for candidates.

Scope and Regulatory Compliance

• We comply with U.S. federal privacy laws, the California Consumer Privacy Act (CCPA) where applicable, and the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada.
• We are not currently subject to the General Data Protection Regulation (GDPR) in the European Union.
• Payments are processed by Stripe, which is PCI DSS compliant.

Information We Collect

Information You Provide Directly

• Account Registration: When you create an account, we collect your name, email, phone number, city/state/country, resume, professional/educational background, skills, languages spoken, compensation expectations, and job search preferences.
• Contact Forms: If you fill out a contact form (e.g., job inquiries, employer inquiries), we collect your name, email, phone number, company/title (if applicable), and the details of your inquiry.
• Resume and Coaching Services: When you request resume or coaching services, we may collect additional information about your employment history, references, or other relevant background data.
• Employer Inquiries: For employers contacting us, we collect name, company, title, email, and the nature of their request.

Information Collected from Third Parties

• LinkedIn and Coresignal: We may access publicly available profile or professional information to enrich candidate profiles.
• Stripe: If you pay for services, we receive confirmation of payment and certain billing-related details. Payment card details are processed and stored by Stripe, not by us.

Information Collected Automatically

• Cookies and Similar Technologies: We use cookies to remember your preferences, customize your experience, and perform analytics.
• Analytics: We use Google Analytics and Microsoft Clarity to understand how users interact with our site.

We do not collect sensitive personal data (such as date of birth or government ID), nor do we knowingly allow account creation by minors under 13 (or 16).

How We Use Your Information

1. Recruitment and Placement: We review resumes and match candidates with relevant job openings. With a candidate’s consent, we may share candidate information (e.g., resume, professional details) with prospective employers.
2. Coaching and Resume Services: We use your provided information to deliver personalized coaching or resume editing services.
3. Account Management: We maintain your profile in our CRM (Zoho Recruit) to store application details and job preferences.
4. Marketing and Communications: We send newsletters or promotional emails to candidates and employers who opt in. You can unsubscribe at any time.
5. Analytics and Improvements: We analyze aggregated data (e.g., job categories, market statistics) to improve our services and share industry insights in a non-identifiable, aggregate form.
6. Legal Compliance: We may use your data to comply with applicable laws, regulations, or legal obligations.

Legal Bases for Processing (Where Applicable)

• User Consent: By registering, contacting us, or otherwise using our services, you consent to the collection and use of your personal data.
• Contractual Necessity: Some data processing is necessary for us to provide the requested services, such as recruitment or coaching.
• Legitimate Interest: We have a legitimate interest in conducting our recruitment business, improving our services, and communicating with you, provided these activities do not override your rights and interests.

Sharing and Disclosure of Information

1. Service Providers: We share limited personal data with our third-party service providers (e.g., Zoho Recruit for candidate management, Stripe for payments) to facilitate and improve our services.
2. Employers: We share candidate data with prospective employers only after obtaining the candidate’s consent.
3. Aggregated or Anonymized Data: We may share aggregated, non-identifiable data (e.g., industry trends) with third parties.
4. Legal Requirements: We may disclose personal data if required by law, court order, or a valid legal process.
5. Business Transactions: In the event of a merger, acquisition, or other business transaction, user information may be transferred as part of that deal, subject to confidentiality agreements and applicable law.

We do not transfer your data to servers or entities outside the United States and Canada, nor do we rely on Standard Contractual Clauses (SCCs).

Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Recognize Returning Visitors: Store user preferences and login status.
• Analytics: Track how users interact with our site (via Google Analytics and Microsoft Clarity).

You can control cookie preferences through your browser settings. By using our site, you consent to our use of cookies in accordance with this Privacy Policy.

Data Retention

We generally retain your data indefinitely, unless you request deletion or unless we decide it is no longer needed for the purposes for which it was collected. This includes:

• Candidate Profiles
• Contact Form Submissions
• Coaching/Resume Services Information

We do not maintain distinct retention periods for different data types; all data is handled under a uniform retention policy unless you request otherwise or applicable law requires a shorter or longer retention period.

Your Rights and Choices

Depending on where you reside, you may have certain rights regarding your personal data, including:

• Access: The right to request a copy of your data.
• Correction: The right to update or correct inaccurate data.
• Deletion: The right to request deletion of your personal data.
• Opt-Out: The right to unsubscribe from marketing or withdraw consent for certain data uses.

To exercise these rights, please contact support@brobstongroup.com. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

Data Security

We implement technical and organizational measures to protect your personal data, including:

• Encryption: Data is encrypted at rest and in transit where feasible.
• Access Controls: Only authorized personnel can access sensitive data, subject to password protection and authentication measures.
• Monitoring: We use intrusion detection systems, firewalls, and vulnerability scanning to identify unusual activity.
• Logging and Audit Trails: We maintain logs of system activities to quickly identify unauthorized access or anomalies.

Incident Response

• Containment & Investigation: Upon discovering a security incident, we work to isolate the affected systems and determine the scope of the breach.
• Notification: If personal data is compromised, we will notify affected individuals and regulatory authorities as required by law.
• Post-Event Analysis: We review each incident to enhance our security measures and policies.

External Links

We provide links to third-party websites or services (e.g., LinkedIn, Instagram). Once you leave our site, we are not responsible for the content or privacy practices of those external sites. We encourage you to review their respective privacy policies and terms.

Third-Party Integrations

We may use embedded widgets or scheduling tools (e.g., calendar scheduling) to streamline operations. Such tools may collect your name, email, phone number, and call subject for appointment scheduling. Any data you submit via these integrations is also subject to the third party’s privacy practices.

Marketing Communications

We may send newsletters or promotional emails to candidates and employers. Each email will include an “unsubscribe” link, allowing you to opt out of future communications at any time.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any material changes will be posted on our website. By continuing to use our website or services after updates take effect, you consent to the revised policy.

Contact Us

If you have any questions or concerns about this Privacy Policy, or wish to exercise any of your rights, please contact us at: