Privacy Policy and Information Notice
NKSFB LLC (“NKSFB,” “us,” “we” or “our”) is committed to maintaining the confidentiality of the personal information or our clients, employees, and website visitors. This Privacy Policy (together with our Terms of Use and any other policies referenced) identifies how we will collect and handle any personal information that we collect from you, or that you provide to us.
If you are a California resident, our privacy practices comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”). Explanation of your rights under the CCPA can be found here.
If you are a resident of the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, this Privacy Policy also outlines additional policies applicable to our collection and processing of your personal information, which can be found here. Non-EEA countries do not have the same data protection laws as the United Kingdom, Switzerland and EEA. We will, however, take steps to ensure that any transfer of personal information will be secure and complies with applicable data protection laws.
SMS Consent: By providing your consent to receive SMS/text messages from NKSFB, you are agreeing to receive messages exclusively from us. Your SMS consent is not shared with or sold to third parties. Any third parties with whom NKSFB may do business are required to obtain their own consent to send SMS/text messages to you.
As our services evolve and we perceive the need or desirability of using your personal data collected in other ways, we may from time to time amend this Privacy Policy. The effective date appears at the end of this Privacy Policy. We encourage you to check our Site frequently to review the current Privacy Policy in effect and any changes that may have been made to it.
- Introduction
- What Personal Information does NKSFB collect?
- How does NKSFB use Personal Information?
- Do we share your Personal Information with any third parties?
- Our storage of your Personal Information
- Access to other websites
- Protecting children’s privacy
- Additional Policies for California Residents
- Additional Policies Residents of the EEA, UK and Switzerland
- Conditions of use and changes to our Privacy Policy
- Contacting us
1. Introduction
This Privacy Policy describes how NKSFB collects, uses, and shares personal information of our clients, prospective employees, visitors to our website at www.nksfb.com (“Site”), NKSFBInsider (“App”) and individuals who contact us to request information. The Website and our other programs and services are referred to in this Privacy Policy as the “Services.” This Policy describes how we collect and use personal information (information which can be used to identify a specific individual) and anonymous data (which cannot be used to identify a specific individual).
Region specific provisions. Certain provisions of this Policy, which are clearly labelled, apply only to users who are citizens or residents of particular regions (e.g., the EU or California). Otherwise, this Policy applies to all users of our Services, regardless of location.
Children. Our Services are not directed to children. See Protecting children’s privacy below.
2. What Personal Information does NKSFB collect?
For purposes of this Policy, “Personal Information” means information (whether stored electronically or in paper based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession). The table below describes the categories of Personal Information we may collect.
| Category | Description |
| Identifiers | Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number or state identification card number, passport number, or other similar identifiers. |
| Protected Classes | Race, age, gender, religion, citizenship, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information |
| Commercial Information | Records of personal property, purchasing or consuming histories or tendencies |
| Biometric Information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
| Internet Activity | Browsing history, search history, IP address, website interactions |
| Geolocation Data | GPS coordinates, location history or movements |
| Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information |
| Professional Data | Current or past job history or performance evaluations |
| Education Data | Educational background, grades, scores |
| Other Data | Financial information, medical information, health insurance information |
| Inferences | Profiles drawn from other Personal Information reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
The examples given in this table are not meant to provide an exhaustive list, but are examples of the kinds of data included in each category. Sections 2.1 through 2.4 below specify the categories of information we do collect.
2.1 Personal Information and Sensitive Personal Information
NKSFB collects only that Personal Information that is relevant for the purposes for which the data is requested. NKSFB does not use your Personal Information in any way that is incompatible with the purposes for which it was collected or for which you have consented.
Some of the categories of Personal Information include “Sensitive Personal Information,” and NKSFB may collect and maintain your Sensitive Personal Information, which includes the following (if the information is not publicly available):
- Identifiers: social security number, driver’s license, state identification card, or passport number.
- Other Data : Most data in this category includes sensitive personal information, such as health information and data, account log-ins, financial account information, debit or credit card numbers in combination with any required security or access code, password, or credentials allowing access to an account.
- Protected Classes: a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, or information concerning a consumer’s sex life or sexual orientation.
- Biometric Information: a consumer’s genetic data, or any biometric information processed for the purpose of uniquely identifying a consumer.
- Internet Activity: the contents of a consumer’s mail, email, and text messages, unless NKSFB is the intended recipient of the communication.
- Geolocation Data: a consumer’s precise location.
2.2 Personal Information Collected about Clients
In order to provide our clients with individualized services, we collect certain non-public, personal information about you from documents you provide to us, such as tax returns, contracts, and bank and investment account statements. In addition to receiving personal information directly from you, we may also receive information from your attorneys, banks, financial institutions, securities brokers, investment advisers, and other sources. We will only obtain such information from third parties with your express consent and as permitted by law.
2.3 Personal Information Collected about Prospective Employees
We may collect Personal Information from individuals seeking employment with NKSFB and entering information within the NKSFB employment portal on our website. We do not collect Commercial Information, Biometric Information, Internet Activity or Sensory Data from prospective employees.
2.4 Personal Information Collected about Website Visitors or Callers
We may collect Personal Information from Visitors to our website and others who contact us to request information. In addition, our web server automatically collects and stores the following information from visitors to our Site:
- We collect information from web browsers, mobile devices, and servers, including browser type, IP address, unique device identifiers, language preference, referring website, date and time of access, operating system and mobile network information.
- We may also determine the approximate location of your device from your IP address. We collect and use this information to determine statistics about our website, including how many people visit our website from certain geographic regions.
- Our Site uses cookies and pixel tags to collect this information, including Google Analytics cookies.
- You can block our use of cookies through settings in your browser. Because these settings are different in different browsers, we recommend that you visit All About Cookies at www.allaboutcookies.org, where you can find comprehensive information on cookie management and blocking for a wide variety of browsers.
We do not collect any other categories of information from our website visitors or individuals who contact us to request information.
3. How does NKSFB use Personal Information?
3.1 Personal Information Collected about Clients
We will use this information:
- to provide you with the Services that you request from us;
- to carry out our obligations arising from any contracts entered into between you and us or any affiliated companies or third party vendors;
- to contact you in the future to provide you with information about other products and services we offer, or that are offered by our affiliates or third party vendors;
- to notify you about changes to our Services;
- to comply with applicable laws and regulations.
3.2 Personal Information Collected about Prospective Employees
We will use this information:
- to respond to and process your job application;
- to make inquiries about you for credit and reference purposes.
3.3 Personal Information Collected about Website Visitors or Callers
We will use this information:
- to provide information you requested about our Services;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- as part of our efforts to keep our site safe and secure.
4. Do we disclose your Personal Information to any third parties?
4.1 Personal Information Collected about Clients
NKSFB does not sell your Personal Information to any third parties, or share your Personal Information to facilitate advertising goods or services by others.
NKSFB may share your information with service providers and contractors to provide the Services. When we do, we enter into a written agreement requiring that party to comply with all applicable laws, such as the CCPA, and restricting that party from: selling or sharing Personal Information; using the Personal Information for any purpose other than the purpose specified the agreement; using, retaining or disclosing the Personal Information other than as specified in the Agreement; or combining the Personal Information with Personal Information the service provider or contractor receives or collects in other contexts. There are times when a service provider or contractor may engage another party to assists in providing the Services; in those cases, the service provider or contractor must notify us in advance, and must have an agreement restricting the use, sale and sharing of the Personal Information that is similar to our agreement with our Service Provider or Contractor.
By using our Services and providing your Personal Information, you agree that we have the right to disclose the categories of Personal Information we collect, as identified in Section 2 with our service providers for the following business purposes identified in Section 3.
There are other circumstances when we may share your Personal Information:
- Merger or Sale – We may share information in conjunction with a prospective purchase, sale, or merger of all or part of our practice, provided that we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser does not disclose information obtained in the course of the review. If we sell all or a part of our business or assets, or merge with another company, we will disclose Personal Information to the purchaser as part of the transaction.
- Legal Proceedings – We may share Personal Information in connection with actual or threatened legal proceedings or alternative dispute resolution proceedings, either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit, and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.
- Legal Obligations – If we are under a duty to disclose your Personal Information in order to comply with any legal obligation, or any lawful request by public authorities (including to meet national security or law enforcement requirements), or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of us, our customers, or others.
4.2 Personal Information Collected about Prospective Employees
We do not disclose any Personal Information about prospective employees and job applicants except as permitted or required by law. Personal Information about prospective employees and job applicants may be disclosed to service providers for the following business purposes:
- To verify information provided on the job application.
- To perform a credit check on the job applicant, but only after obtaining consent to do so.
In some instances we received Personal Information about prospective employees and job applicants from third party services providing employment referrals. In such situations, one we receive the Personal Information we do not disclose it except as set forth in this section.
4.3 Personal Information Collected about Website Visitors or Callers
We do not disclose to any third parties Personal Information collected from website visitors or callers seeking additional information about our Services.
5. Our storage of your Personal Information
NKSFB uses reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Information we collect.
We will keep your Personal Information for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you (for example if you have made a complaint about our Services) for as long as is necessary to protect us from a legal claim.
6. Access to other websites
Our Site may include links to and from other websites of affiliates or other unaffiliated third parties. If you follow a link to any of these websites, please note that these websites are not covered by this Privacy Policy. We are not responsible for the privacy practices of any third parties or the content of linked sites although we do encourage you to read the applicable privacy policies and terms and conditions of such parties or websites. This Privacy Policy only applies to how NKSFB deals with your Personal Information, and it does not apply to any other company or any other company’s websites even if you access them via our Site. Please check those websites’ policies before you submit any Personal Information to them.
7. Protecting children’s privacy
We are strongly committed to protecting the safety and privacy of children who visit our Site. Our Site is not designed nor is it intended to be used by children under 13, and we do not knowingly collect personal information online from children under 13 and have adopted techniques to ensure compliance with this Privacy Policy and the Children’s Online Privacy Protection Act of 1998 (“COPPA”). Our Site includes content that we believe to be unsuitable for children under 13, and we encourage all parents to talk to their children about online safety and to monitor their children’s use of the Internet.
8. Additional Policies for California Residents
The CCPA affords California consumers the rights with respect to their Personal Information set forth in this section.
8.1 Your Rights With Respect to Your Personal Information
Subject to certain exceptions, you have the following rights with respect to your Personal Information:
- To request that NKSFB disclose what personal information it has collected, used, or disclosed, over the 12-month period preceding NKSFB’s receipt of such a request;
- To request that NKSFB disclose whether any of your information was sold or shared with third parties, to whom such information was sold or shared, and the business purpose for selling or sharing the information;
- To request that any inaccurate or incomplete Personal Information maintained by NKSFB be corrected or supplemented; and
- To request deletion of your Personal Information maintained by NKSFB.
All of these rights are subject to certain conditions and exemptions. For example, NKSFB will not be obligated to delete your Personal Information if we need to retain it to protect ourselves in the event of a legal claim.
To exercise any of these rights, please submit a written request to us using the contact information set forth below. NKSFB reserves the right to charge a fee in dealing with such a request as permitted by applicable law and regulations. You may also opt out of receiving additional marketing information by using the unsubscribe feature in any marketing email we send you.
8.2 Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
California consumers have the right to not be discriminated against because the consumer exercised any of the consumer’s rights under the CCPA. That means that a company may not deny goods or services to the consumer, charge different rates for goods or services, or provide a different level or quality of goods or services if the consumer chooses to exercise their rights under the CCPA (unless the different rate or different level or quality is reasonably related to the value to the business of the consumer’s data). We will not deny you any Services or charge you a different price, level or quality of Services because you exercise any of your rights under the CCPA; however, we may not be able to provide the Services if you refuse to provide us the Personal Information that is necessary for us to provide the Services, or if you ask us to delete your Personal Information.
8.3 Submitting a CCPA Data Request
To submit a request to NKSFB regarding your Personal Information as described in this section, please contact us by calling this toll free number (877)-277-4657, emailing us at ConsumerRequest@nksfb.com, or completing our online form.
NKSFB is required to verify the identity of the individual requesting access to a consumer’s data or requesting deletion of a consumer’s data. To verify your identity, we will rely upon information we have previously collected about you, such as phone calls received from a known phone number or emails received from an known email. We will also rely upon our personal relationship with our clients to verify the identity of a requester.
If the California consumer submitting a request is not a NKSFB client, such as an individual who requested information through our website or a phone call to our “contact us” number, then we will verify identify by confirmation using the information we collected, such as phone number of email address.
8.4 Authorized Agent
California consumers may designate an authorized agent to exercise a CCPA right on the consumer’s behalf. If a consumer utilizes an authorized agent to exercise a CCPA right, the following proof that the agent has been authorized to act on the consumer’s behalf will need to be provided:
- Proof of written permission by the consumer for the authorized agent to act on his or her behalf and separate verification of the consumer; or
- Proof that the authorized agent holds a power of attorney to act on the consumer’s behalf pursuant to Cal. Probate Code §§ 4000-4465.
8.5 Exclusion for Business to Business Information
The rights set forth in this section do not apply to personal information reflecting a written or verbal communication or a transaction between NKSFB and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency and whose communications or transaction with NKSFB occur solely within the context of the NKSFB conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, nonprofit or government agency.
8.6 Exclusion for Financial Sector Data
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) are not subject to the CCPA. With respect to such information consumers do not have the enumerated rights under the CCPA set forth in this section.
9. Additional Policies for Residents of EEA, UK and Switzerland
In addition to the other policies described in this Privacy Policy, residents of the EEA, the UK and Switzerland are afforded the following additional rights and protections as required by the European Union General Data Privacy Regulation (“GDPR”), and UK and Swiss data protection laws. The additional rights and protections set forth in this section of this Policy apply only to residents of the EEA, the UK and Switzerland. For ease of reference, when we refer to GDPR in this section, we are referring to the UK and Swiss data protection laws, as well as the GDPR. For the purposes of this the GDPR, NKSFB is a “Controller” which means NKSFB determines the purposes for which, and the manner in which, any Personal Information is Processed and used in its business.
9.1 Definitions
The following additional definitions apply to this Section of the Privacy Policy:
“Processor” means any Person Processing Personal Information.
“Person” means a natural person, corporation, association, organization, partnership, or other legal entity.
“Process” or “Processing” is any activity that involves use of the Personal Information. It includes, without limitation, obtaining, recording or holding the Personal Information, or carrying out any operation or set of operations on the Personal Information including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Information to third parties.
9.2 The legal basis for Processing your Personal Information
In order to comply with the GDPR, we are required to set out the legal basis for the processing of your PeIn order to comply with the GDPR, we are required to set out the legal basis for the Processing of your Personal Information. In accordance with the purposes for which we collect and use your Personal Information, as set out above, the legal basis for Processing your Personal Information will be one of the following:
- our own legitimate business interests, or the legitimate business interests of our third party partners, promoters, affiliates, distributors, suppliers, vendors, and subcontractors, such as, for example, providing direct marketing to our customers of our products and services that we think would be of interest, permitting prospective employees to search and apply for job opportunities, handling inquiries from our promoters, affiliates, distributors, vendors, and customers, or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest;
- the performance of a contract that we have in place with you;
- your consent where appropriate; or
- compliance with our legal obligations, including to meet national security or law enforcement requirements.
9.3 Where we store your Personal Information
The data that we collect from you is stored on our servers or on servers provided by cloud service providers. By submitting your Personal Information, you agree to this transfer, storing, and Processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
The transmission of information via the Internet is not completely secure. Although we take reasonable steps to protect your Personal Information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
9.4 Addendum to how long we store your Personal Information
In some cases, there is a legal requirement to keep Personal Information for a minimum period of time. Except in those circumstances, we do not keep your Personal Information for any longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further Processed.
9.5 Your rights with respect to your Personal Information
Subject to certain exceptions, you have the following rights with respect to your Personal Information:
- To receive or access a copy of the Personal Information that we hold about you;
- To request that any inaccurate or incomplete Personal Information be corrected or supplemented;
- To have your Personal Information erased, unless we have a legitimate reason to retain the Personal Information (such as if we are required to do so for legal reasons); and
- To ask us not to Process your Personal Information for a particular purpose, including for marketing.
All of these rights are subject to certain conditions and exemptions. For example, NKSFB will not be obligated to erase your Personal Information if we need to retain it to protect ourselves in the event of a legal claim.
To exercise any of these rights, please submit a written request to us using the contact information set forth below. NKSFB reserves the right to charge a fee in dealing with such a request as permitted by applicable law and regulations. You may also opt out of receiving additional marketing information by using the unsubscribe feature in any marketing email we send you.
10. Conditions of use and changes to our privacy policy
If you choose to receive our Services or visit our Site, any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the law of the State of California. If you have any concern about our privacy practices, please contact us with a thorough description, and we will try to resolve it. As our business changes, our Privacy Policy and Terms of Use may change also. We may e-mail periodic reminders of our notices and conditions, but you should check our Site frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.
11. Contacting us
This Site is owned and operated by NKSFB. If you have any questions or suggestions with respect to this Privacy Policy or our privacy practices, please e-mail us at ConsumerRequest@nksfb.com or you can contact us by mail or telephone at:
10960 Wilshire Blvd., 5th Floor
Los Angeles, CA 90024
(877) 277-4657
CCPA-Specific Requests
Please submit CCPA-specific data requests through the procedures set forth in Section 8.
GDPR/UK/Swiss-Specific Requests
For residents of the EEA, the UK or Switzerland, please contact Matt Kirk, at dataprotection@rossbennetsmith.com or telephone at 020 7930 6000.
Updated December 2022