Privacy Policy

Last Modified: August 11, 2023

Introduction

Charles Taylor Ltd and its subsidiaries (collectively “Charles Taylor”) respect your privacy and are committed to safeguarding it in accordance with this policy.

This policy outlines the types of information that the Charles Taylor subsidiary Guardian Managed Care Solutions LLC (“Guardian” or “We“) may collect from you or that you may provide when you visit the website guardianmcs.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

It’s important to understand that Charles Taylor comprises several separate individual entities and some have their own Privacy Policies which should be read when dealing with a specific entity. This policy applies to Guardian’s website and practices.

This policy applies to information we collect:

On this Website.
In email, text, and other electronic messages between you and this Website.
Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

It does not apply to information collected by:

Us offline or through any other means, including on any other website operated by Guardian or any third party.
Any third party, including through any application or content (including advertising) that may link to or be accessed from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website, register on the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at dpo@charlestaylor.com.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including:

Personal information, like name, contact details, postal address, email address, telephone number, social security number or any other identifier by which you may be contacted online or offline (“Personal Information“);
Information about you that is not personally identifiable; and/or
Information about your internet connection, equipment used to access our Website, and usage details.

We collect this information:

Directly from you when you provide it to us.
Automatically as you navigate through the Website via tracking technologies like cookies.
From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

Information provided when registering, subscribing, posting material, requesting services, or reporting problems
Records and copies of correspondence (including email addresses), if you contact us.
Your responses to surveys and research.
Details of transactions and orders you carry out through our Website and of the fulfillment of your orders.
Your search queries on our Website.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, we may issue cookies when you direct your browser to our Website.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons that permit the Company, for example, to count users who have visited those pages and for other related website statistics.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide though it.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Data Retention

We will keep your personal data only for so long as is necessary and for the purpose for which it was originally collected. We may need to retain it for as long as there is any possibility that either you or we may wish to bring a legal claim, or where we are required to keep your personal data due to legal or regulatory reasons.

We have implemented a Group Document Retention Policy which sets out details of the periods for which certain categories of personal data shall be retained and the lawful basis for that retention.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Charles Taylor’s or Guardian’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Guardian about our Website users is among the assets transferred.
To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our terms of use or terms of sale and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Guardian, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by logging into the Website and adjusting your user preferences in your account profile, checking or unchecking the relevant boxes, or emailing us.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by emailing DPO@charlestaylor.com.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Security

We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline. Our website uses SSL encryption to protect data transmissions. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information:

Right to request deletion of personal information (California)
Right to opt-out of sale of personal information (California, Nevada)
Right to access and request disclosure of personal information collected (California, Colorado, Connecticut, Utah, Virginia)
Right to correction of inaccurate personal information (Colorado, Connecticut, Virginia)
Right to opt-out of profiling (Colorado, Connecticut, Virginia)

California Privacy Rights (Effective January 1, 2020)

Data Subject Rights – California Residents

This portion of our Privacy Policy advises California residents of rights provided in the California Consumer Privacy Act (“CCPA”) and how to effectuate those rights by communicating with us. Please note, we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal data.

Please customize your data preferences or direct any rights requests or additional questions you may have regarding this Privacy Policy to dpo@charlestaylor.com.

If you do, we will need to collect personal data and other information such as your name, email or transaction history in order to verify your identity. You may also authorize an agent to make a request on your behalf, who will need to provide similar information for verification.

Right to Deletion of Personal Data

California residents have the right to request the deletion of personal data as prescribed in Section 1798.105(a) of the CCPA. Charles Taylor may not delete some or all requested personal data as allowed or required by applicable law.

Right of Access: Right to Request Disclosure of Data Collection and Sharing Practices

You may request to receive details about how we collect, use, and share your personal data. Specifically, you may request to receive the specific pieces of personal data that we have collected about you.

You may also request to receive:

the categories of personal data that we have collected about you,
the categories of personal data that we have disclosed for a business purpose,
the categories of sources from which we collected the personal data,
our purposes for collecting that personal data, and
the categories of parties with whom we share your personal data.

Right to Opt-Out of Sale

We do not, and do not intend to, sell your personal data.

Right to Non-Discriminated for Exercising CCPA Rights

We do not discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above.

Right to California Residents Under 16 Years of Age

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please contact us at dpo@charlestaylor.com for more information.

Colorado, Connecticut, Virginia, and Utah Residents Privacy Rights

Colorado, Connecticut, Virginia, and Utah residents have the right to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Data portability.
Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia Residents Additional Privacy Rights

Colorado, Connecticut, and Virginia residents also have the rights to:

Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please email dpo@charlestaylor.com.

Nevada Residents Privacy Rights

We do not, and do not intend to, sell your personal data which would trigger Nevada’s opt-out requirements.

Changes to Our Privacy Policy

We may update this Privacy Policy from time to time and will post changes by updating it together with the effective date on this page. The date the privacy policy was last revised is identified at the top of the page. We encourage you to review this website and our Privacy Policy periodically.

Do Not Track

We treat the data of everyone who comes to our Website in accordance with this Privacy Notice, regardless of their “Do Not Track” setting.

Contact Information

We are committed to processing all personal data fairly, lawfully, and transparently. To make things simpler, Guardian and Charles Taylor have nominated one data controller, Charles Taylor Ltd, to handle all requests or queries you might have about our processing of your personal data. We have appointed a Data Protection Officer (DPO) to oversee compliance with data protection law. The contact details are:

Emma Hancock, The Minster Building, 21 Mincing Lane, London, EC3R 7AG;

dpo@charlestaylor.com.