Privacy Policy

This Privacy Policy (the “Policy”) describes how Feinberg & Co. (“Feinberg”, “we”, “us”, or “our”) collects, uses, discloses, and safeguards personal information in connection with the feinberg.io website (the “Site”) and the services we provide to our clients (the “Services”).

This Policy applies to visitors of the Site, to persons who contact us, and to our clients. Where Feinberg processes personal information on behalf of a client in the course of providing the Services, the client is the controller of that information and Feinberg acts as a processor; the client’s own privacy notices govern that processing, and this Policy describes only Feinberg’s role.

By accessing the Site or providing personal information to us, you acknowledge that you have read and understood this Policy.

Information you provide. We collect information you submit to us directly, including your name, business affiliation, email address, telephone number, the contents of your inquiries, and any other information you choose to share. From clients, we also collect billing information, authorised contacts, and the credentials required to perform the Services.

Information collected automatically. When you visit the Site, our servers and infrastructure providers may automatically collect technical information such as your IP address, browser type, device characteristics, referring URLs, and the pages you view. This information is used to operate, secure, and improve the Site.

Client Data processed on a client’s behalf. In the course of providing the Services we receive, transmit, and store information at the direction of our clients, which may include the personal information of the client’s counterparties (such as buyers, sellers, consignors, and authenticators). We process such information only to provide the Services and as otherwise instructed in writing by the client.

We use personal information to:

(a) provide, operate, maintain, and improve the Site and Services; (b) respond to inquiries and provide customer support; (c) administer engagements, including billing and account management; (d) communicate with clients and prospects about Services, including service announcements and material updates to this Policy; (e) secure the Site and Services, prevent fraud, and enforce our Terms; and (f) comply with legal obligations and respond to lawful requests from public authorities.

Where required by law, we rely on a recognised legal basis to process personal information, including the performance of a contract, our legitimate interests in operating and securing our business, compliance with legal obligations, and your consent where applicable.

We do not sell personal information. We share personal information only as follows:

Service providers. We share information with vetted third parties that provide infrastructure, hosting, communications, security, and professional services on our behalf, subject to written obligations of confidentiality and data protection at least as protective as this Policy.

Legal compliance. We may disclose information where we believe in good faith that disclosure is required by law, by valid legal process, or to protect the rights, property, or safety of Feinberg, our clients, or others.

Business transfers. In the event of a merger, acquisition, reorganisation, or sale of assets, personal information may be transferred as part of the transaction, subject to confidentiality obligations and consistent with this Policy.

With your consent. We may share information for any other purpose disclosed to you at the time of collection or with your consent.

The Site uses a limited set of cookies and similar technologies to enable core functionality, remember preferences, and maintain security. We do not use third-party advertising cookies, cross-site tracking, or session-replay tools on the Site.

Most browsers allow you to refuse or accept cookies. If you disable cookies, parts of the Site may not function as intended. We do not respond to “Do Not Track” browser signals at this time, as no industry standard governing their interpretation has been adopted.

We retain personal information only for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, regulatory, or reporting requirements, and to enforce our agreements.

Personal information processed on behalf of a client in the course of providing the Services is retained for the duration of the engagement and, on termination, is returned or destroyed in accordance with the client’s written instructions, subject to any retention obligations imposed by law. Reconciliation records may be retained in archival form for the period required to substantiate our books and tax filings.

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorised access, alteration, disclosure, or destruction. These safeguards include access controls, encryption of data in transit and at rest, network monitoring, vetting of personnel, and written confidentiality undertakings from all operators.

No method of transmission over the Internet or method of electronic storage is fully secure. While we take the security of information seriously, we cannot guarantee its absolute security. In the event of a personal-data breach affecting our clients, we will notify the affected clients without undue delay and assist them in meeting their own notification obligations.

Depending on your jurisdiction, you may have the right to (a) access the personal information we hold about you; (b) correct inaccurate or incomplete information; (c) request deletion of your information; (d) restrict or object to certain processing; (e) request portability of your information in a structured, commonly-used format; and (f) withdraw consent, where processing is based on consent.

To exercise any of these rights, please contact us at contact@feinberg.io. We will respond within the timeframe required by applicable law. We may need to verify your identity before fulfilling a request and may decline a request where permitted by law.

If your personal information is processed by Feinberg on behalf of one of our clients, please direct your request to that client; we will assist them in responding as required by applicable law.

Feinberg is based in the United States and our infrastructure providers are primarily located in the United States. If you access the Site or provide information from outside the United States, your information will be transferred to, processed in, and stored in the United States, which may have data-protection laws different from those in your country of residence.

Where required, we rely on appropriate safeguards for international transfers, including the Standard Contractual Clauses approved by the European Commission and analogous mechanisms recognised by other jurisdictions.

The Site and the Services are intended for business clients and their authorised representatives, and are not directed to children under the age of sixteen (16). We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, please contact us and we will take steps to delete it.

The Site may contain links to third-party websites or services that are not operated or controlled by Feinberg. This Policy does not apply to those websites or services, and we are not responsible for their content or privacy practices. We encourage you to review the privacy notices of any third-party site you visit.

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), affords you additional rights with respect to your personal information, including the rights to know, delete, correct, and limit the use of sensitive personal information, and the right not to be discriminated against for exercising those rights.

Feinberg does not sell or share personal information for cross-context behavioural advertising as those terms are defined under the CCPA. To exercise your rights, please contact us at contact@feinberg.io. You may designate an authorised agent to make a request on your behalf; we may require verification of the agent’s authority.

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the rights described in Article VIII above under the EU General Data Protection Regulation, the UK GDPR, or the Swiss Federal Act on Data Protection, as applicable.

You have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or place of the alleged infringement. Where Feinberg is the controller of your personal information, our basis for processing is described in Article III above.

We may update this Policy from time to time. The effective date at the top of this page indicates when the Policy was last revised. If we make material changes, we will provide notice by posting an updated Policy on the Site and, where appropriate, by additional means such as email. Your continued use of the Site or Services after the effective date of the updated Policy constitutes acceptance of the revised Policy.

If you have questions about this Policy or our privacy practices, or if you wish to exercise any of your rights, please contact us:

Feinberg & Co.
Attn: Privacy
contact@feinberg.io