Last Updated: 07/07/2022

Orion Group (“Orion”, “we”, or “us”) wants you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes our practices in connection with information that we collect through:

Websites operated by us from which you are accessing this Privacy Policy (the “Websites”);

HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and

Offline business interactions you have with us. 

Collectively, we refer to the Websites, emails, and offline business interactions as the “Services”.

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:

Name

Email address 

Telephone number

Postal address

IP address (we may also derive your approximate location from your IP address)

Other information you may disclose to us when you contact us, for example, your title or company

Collection of Personal Information 

We and our service providers collect Personal Information in a variety of ways, including:  

Through the Services.  

We collect Personal Information through the Services, for example, when you send us a request or message through the Services, attend one of our events, contact customer service, or participate in a survey.

From Other Sources. 

We receive Personal Information from our affiliates Alpine Investors, Alpine SG, and other affiliated Alpine portfolio companies.

We receive your Personal Information from other sources, for example, publicly available databases. 

We need to collect Personal Information in order to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy. 

Use of Personal Information 

We and our service providers use Personal Information for the following purposes: 

To respond to your inquiries and requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions or request information from us.

To assess, develop and follow up on business opportunities about which you contact us.

To send administrative information to you, such as changes to our terms, conditions, and policies. 

To send you commercial emails, with information about our services, events, and other news about our company. 

To better understand your interests and preferences, and other analysis, so we can improve our Services.

We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. 

For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements. 

For fraud prevention and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft. 

For enhancing, improving, repairing, maintaining, or modifying our services, as well as undertaking quality assurance measures. 

For identifying usage trends, for example, understanding which parts of our Services are of most interest to users. 

For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users. 

Disclosure of Personal Information  

We disclose Personal Information:

To our affiliates for the purposes described in this Privacy Policy.

You can find information about our affiliates here.

To our third party service providers, to facilitate services they provide to us.

These can include providers of services such as website hosting, data analysis, fraud prevention, information technology and related infrastructure provision, customer service, customer relationship management, marketing, email delivery, auditing, and other services. 

Other uses and disclosures.

We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others. We may use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets or stock (including in connection with any bankruptcy or similar proceedings). 

Other Information

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

Browser and device information

App usage data

Information collected through cookies, pixel tags, and other technologies

Demographic information and other information provided by you that does not reveal your specific identity 

Information that has been aggregated in a manner such that it no longer reveals your specific identity

Collection of Other Information 

We and our service providers may collect Other Information in a variety of ways, including:  

Your browser or device.

Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the version of the Services you are using.  We use this information to ensure that the Services function properly.  

Cookies.

Cookies are pieces of information stored directly on the computer that you are using.  Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, and other traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.  We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to allaboutcookies.org. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.  

Pixel tags.

Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.

Uses and Disclosures of Other Information 

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

Choices

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:  

Receiving commercial emails from us.

If you no longer want to receive commercial emails from us on a going-forward basis, you may opt out by emailing us at info@orionservicesgroup.com.

Our sharing of your Personal Information with affiliates for their commercial purposes.

If you would prefer that we discontinue sharing your Personal Information on a going-forward basis, please let us know by emailing us at info@orionservicesgroup.com.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

Retention Period

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.  

The criteria used to determine our retention periods include:  

The length of time we have an ongoing relationship with you and provide the Services to you;

Whether there is a legal obligation to which we are subject (for example, if certain laws require us to keep records for a certain period of time before we can delete them); or

Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. 

Use Of Services By Minors

The Services are not directed to, and we do not knowingly collect Personal Information from, individuals under the age of thirteen (13). 

Jurisdiction

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be collected and stored in countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the Services or otherwise to us.

Updates To This Privacy Policy

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.  

Contacting Us

If you have any questions about this Privacy Policy, please contact us at info@orionservicesgroup.com or at 920 Broadway, Floor 8, New York, NY 10010.

Because email communications are not always secure, please do not include any sensitive information in your emails to us. 

Additional Information Regarding California

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents. 

Collection and Disclosure of Personal Information

The following chart includes the categories of Personal Information, as listed in the CCPA, that we plan to collect and have collected and disclosed within the preceding 12 months, and the categories of third parties to which we disclosed Personal Information for our operational business purposes within the preceding 12 months. 

Categories of Personal Information

Disclosed to Which Categories of Third Parties for Operational Business Purposes

Identifiers, such as name and contact information.

affiliates; service providers; legal authorities

Personal information as defined in the California customer records law, such as name, contact information, and employment information

affiliates; service providers; legal authorities

Internet or network activity information, such as interactions with our online properties

affiliates; service providers

Employment Information. Professional or employment-related information, such as your title and employer

affiliates; service providers

Under the CCPA, if a business sells Personal Information, it must allow California residents to opt out of the sale of their Personal Information. However, we do not “sell” and have not “sold” Personal Information for purposes of the CCPA in the last 12 months.  For example, and without limiting the foregoing, we do not sell the Personal Information of minors under 16 years of age. 

Sources of Personal Information 

As described above, we collect this Personal Information from you and from affiliates and publicly available databases.  

Use of Personal Information

We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to: respond to your inquiries and requests; develop business opportunities; send administrative or commercial emails to  you; understand your interests and preferences; conduct audits; prevent and monitor for fraud and security issues; improve or maintain our services; undertake quality assurance; identify trends; determine the effectiveness of our promotional campaigns; and create aggregated and/or anonymized data. 

CCPA Rights and Requests

Requests to Know and Delete

If you are a California resident, you may make the following requests: 

“Request to Know”

You may request that we disclose to you the following information covering the 12 months preceding your request: 

The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;

The specific pieces of Personal Information we collected about you; 

The business or commercial purpose for collecting Personal Information about you; and 

The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable). 

“Request to Delete”

You may request that we delete Personal Information we collected from you.

To make a Request to Know or a Request to Delete, please contact us. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, in order to verify your identity and protect against fraudulent requests. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

If you want to make a Request to Know or a Request to Delete as an authorized agent on behalf of a California resident, you may use the submission methods noted above.  As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include: 

1. Proof of your registration with the California Secretary of State to conduct business in California;
2. Proof of a power of attorney from the resident pursuant to Probate Code sections 4121-4130. 

If you are an authorized agent and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:

1. Verify the resident’s own identity directly with us; or
2. Directly confirm with us that the resident provided you permission to make the request.

Right to Non-Discrimination

You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.

Applicant Privacy Policy

Orion Group (“Orion,” “we,” or “us”) values your trust and is committed to the responsible management, use and protection of personal information. This Applicant Privacy Policy describes our practices in connection with all the information that we collect when you apply for a job or internship with Orion or one of our affiliates through the Careers area of our website (“Careers Site”), through LinkedIn, or offline.  Personal information submitted elsewhere on Orion’s and its affiliates’ web sites will be used in accordance with our general online Privacy Policy.

Personal Information We Collect

Information You Provide

We collect personal information from you in connection with your application: 

Name, address, telephone number, e-mail address, and other contact information;

Username and password;

Work authorization status;

CV, resume, cover letter, previous work experience and education information;

Skills;

Professional and other work-related licenses, permits and certifications held;

Information relating to references; and 

Any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards or professional memberships).

As discussed in the “Diversity” section below, in certain cases we will ask questions about race/ethnic origin, gender, and disability of our applicants, for monitoring equal opportunity.  We can also inquire about criminal records. We will do so where permitted by applicable law.  Otherwise, we ask that you avoid submitting information that may be deemed sensitive information, except where such information is legally required. 

Any information you submit for your application must be true, complete and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action including immediate termination of employment.  In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

Information From Other Sources

To verify your qualifications, and as permitted by applicable law, we obtain information about you from other sources:

Your references;

Prior employers; 

Educational institutions you attended;

LinkedIn and other publicly available sources; and

Background check providers

Use Of Information

The information that you submit for your application will be used for our personnel recruitment, management and planning purposes, as permitted by applicable law:  

To process your application.

To assess your capabilities and qualifications for a job. 

To conduct reference checks.

To respond to your inquiries and communicate with you about your application, and to send you information regarding the Careers Site and changes to our terms and policies. 

To comply with or monitor compliance with any applicable law or regulation.  

To conduct background checks if we offer you a position, which may include a check of criminal history. 

To preserve our other legitimate interests, for example, for Orion’s administrative purposes, aggregate management reporting, internal training, and as generally required to conduct our business within Orion and its affiliates.

We may use automated processes to screen your application for eligibility for the position(s) for which you apply.  The information about you will be added to our candidate database and can be retained and used to consider you for opportunities at Orion and its affiliates other than the one(s) for which you apply.  If you do not wish us to do this, please contact us at the address in the “Contact Us” section below.

If we hire you, personal information we collect in connection with your application can be incorporated into our human resources system and used to manage the new-hire process; any such information can become part of your employee file and used for other employment-related purposes. 

Disclosure And Transfer Of Inforrmation

Where applicable, we share personal information with our affiliates that are involved in evaluating candidates for a given position. You can find information about our affiliates on Our Companies Page.

We will limit access to personal information to personnel with a business need to know the information for the purposes described in this Applicant Privacy Policy, including personnel in the recruiting, human resources and information technology departments, and in the department responsible for the position for which you are applying.  

We also share personal information with our third-party service providers to facilitate services they provide to us, including hosting and operating the Careers Site, recruiting assistance, and background check processing.  Disclosing your personal information can include transferring personal information to other countries, including any other country in which we or our service providers have operations.

Other Uses And Disclosures Of Information

We also use and disclose your personal information as necessary or appropriate: to comply with applicable law; to respond to requests from public and government authorities; to cooperate with law enforcement; to enforce our terms and conditions; to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and in connection with a sale or business transaction.

Data Retention

We will retain personal information for the period necessary to fulfill the purposes outlined in this Applicant Privacy Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods are: (i) the duration of the application process; (ii) as long as we have an ongoing relationship with you; (iii) as required by a legal obligation to which we are subject; (iv) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). 

We may remove personal information for inactive accounts from our database, subject to any applicable legal or regulatory obligations.  Furthermore, we can delete personal information about you (including your CV/resume) from our database at any time and without providing any reason.  Therefore, please retain your own copy of the personal information provided to us. 

Changes To Your Personal Information

If you would like to change personal information that you have already submitted for consideration for a specific position through the Careers Site, please update your profile and resubmit your application for that position.  We encourage you to promptly update your personal information if it changes or is inaccurate.

Security

We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

Orion hereby disclaims, as far as permitted by local laws, any liability for itself and its affiliates and contractors for any personal information we collect in connection with your application that is lost, misused, illegally accessed, disclosed, altered or destroyed or not timely delivered to our Careers Site.

Links To Third-Party Websites

This Applicant Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Careers Site links.  The inclusion of a link on the Careers Site does not imply endorsement of the linked site or service by Orion or our affiliates.  

Diversity

Orion is an equal opportunity employer, which means we offer equal treatment to all applicants.  Orion does not discriminate, either directly or indirectly, on protected grounds: race, color, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status or genetic information in any area of recruitment. 

Law Applicable To Job Application

This Careers Site is operated from the United States.  Accordingly, any personal information you submit to the Careers Site will be collected in the United States and will be subject to U.S. laws.  

About Children

The Careers Site is not intended for minors under the age of eighteen (18).

Current Personnel Of Orion

If you currently work for Orion or one of our affiliates, you must be eligible to apply for a different position within Orion to use the Careers Site. If you accept such a position, your benefits programs and Human Resources policies may change. Please consult with the HR manager for the new position concerning application eligibility, benefit programs, and HR policies applicable to that position.

Changes To The Applicant Privacy Policy

We reserve the right to amend this Applicant Privacy Policy at any time.  The “Last Updated” date at the top of this Applicant Privacy Policy indicates when this Applicant Privacy Policy was last revised.  Any changes will become effective when we post the revised Applicant Privacy Policy on the Careers Site. 

Contact Us

If you have questions or requests, please feel free to contact us at info@orionservicesgroup.com or at 920 Broadway, Floor 8, New York, NY 10010.

Because email communications are not always secure, please do not include sensitive information in your emails to us.

Additional Information Regarding California

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of personal information that we collect, use, and disclose about California residents.  

Collection and Disclosure of Personal Information

The following chart includes the categories of Personal Information, as listed in the CCPA, that we plan to collect and have collected and disclosed within the preceding 12 months, and the categories of third parties to which we disclosed personal Information for our operational business purposes within the preceding 12 months.  We do not “sell” and have not “sold” Personal Information for purposes of the CCPA in the last 12 months.  

Categories of Personal Information

Disclosed to Which Categories of Third Parties for Operational Business Purposes

Identifiers, such as name and contact information.

affiliates; service providers; legal authorities

Personal information as defined in the California customer records law, such as name, contact information, signature, and employment information

affiliates; service providers; legal authorities

Protected Class Information, such as characteristics of protected classifications under California or federal law, such as age and gender

affiliates; service providers

Internet or network activity information, such as interactions with our Careers Site

affiliates; service providers

Education Information subject to the federal Family Educational Rights and Privacy Act such as student transcripts, grade point average, grades, and disciplinary records

affiliates; service providers

Employment Information. Professional or employment-related information, such as your title and employer

affiliates; service providers

Inferences drawn from any of the Personal Information listed above to create a summary about, for example, your characteristics, abilities, and aptitudes

affiliates; service providers

Sources of Personal Information

As described above, we collect this Personal Information from you and from your references, prior employers, educational institutions you attended, LinkedIn and other publicly available sources, and background check providers.

Use of Personal Information

We may use this Personal Information for our personnel recruitment, management and planning purposes, as described above.

CCPA Rights and Requests

If you are a California resident, you may make the following requests: 

“Request to Know”

You may request that we disclose to you the following information covering the 12 months preceding your request: 

The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;

The specific pieces of Personal Information we collected about you; 

The business or commercial purpose for collecting Personal Information about you; and 

The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable). 

“Request to Delete”

You may request that we delete Personal Information we collected from you.

To make a Request to Know or a Request to Delete, please Contact Us.  We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.  We may need to request additional Personal Information from you, in order to verify your identity and protect against fraudulent requests.  If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information. 

If you want to make a Request to Know or a Request to Delete as an authorized agent on behalf of a California resident, you may use the submission methods noted above.  As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include: 

1. Proof of your registration with the California Secretary of State to conduct business in California;
2. Proof of a power of attorney from the resident pursuant to Probate Code sections 4121-4130. 

If you are an authorized agent and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:

1. Verify the resident’s own identity directly with us; or
2. Directly confirm with us that the resident provided you permission to make the request.

Right to Non-Descrimination

You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.

Do Not Track Signals

We do not currently respond to browser do-not-track signals.

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