Privacy Policy

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Last Updated: April 2025

Spurlock Consulting respects your concerns about privacy. This Website Privacy Policy applies to personal information we collect on the Spurlock Consulting website and mobile applications (collectively, the “Sites”), how we use the information, with whom we share it, and the choices available to users of our Sites regarding our use of the information. We also describe the measures we take to protect the security of the information and how users can contact us about our privacy practices.

Information We Collect

The types of personal information users of our Sites may submit include:

• Contact information (such as name, postal address, telephone number, and email address)
• Login credentials for the Sites
• Information (such as dietary restrictions) relating to events for which website users      may register
• For Spurlock Consulting alumni, current employment information (such as title,      division, and employer) and information regarding previous employment with      Spurlock Consulting
• For Spurlock Consulting job applicants, personal information contained in a résumé, C.V., application and/or our recruitment template, employment history,      education history, references, transcripts, and, where legally      permissible, ethnicity, race, gender, disability status, and veteran      status
• Other personal information found in content that users, including Spurlock      Consulting alumni, provide (including through surveys)

Spurlock Consulting will not consider information regarding an applicant’s ethnicity, race, or gender, or an applicant’s choice to decline to provide it, in evaluating the applicant’s qualifications for employment with us. This information will be used only for Equal Employment Opportunity reporting and other legal compliance purposes.

Information We Collect by Automated Means

When you visit our Sites, we may collect certain information by automated means, using technologies such as cookies, web server logs, web beacons, and JavaScript. Our Sites are designed to respond to the Global Privacy Control settings on browsers but may not be designed to respond to all “do not track” signals from browsers.

Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Sites may use cookies (such as HTTP and HTML5 cookies) and Flash cookies, as well as other types of local storage (such as browser-based or plugin-based local storage). Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. You also may be able to delete your Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies you may not be able to use all of the features of our Sites.

In conjunction with gathering information through cookies, we may collect the the following category of information: Identifiers and Internet and other Similar Network Activity, as described in this section. As part of this collection, our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses, and the country and time zone where your device is located. The web server logs also may record information such as the address of the web page that referred you to our Sites and the IP address of the device you use to connect to the Internet. They also may log information about your interaction with the Sites, such as which pages you visit. To control which web servers collect information by automated means, we may place tracking codes or other small files on our web pages such as web beacons, pixels, or other tags that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the Sites.

When you use our Sites or mobile apps, we may collect data such as unique device identifiers or their equivalents.

We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers help us analyze how users use the Sites. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn more about opting out of these activities, click here.

The providers of other third-party plug-ins on our Sites, such as social sharing tools, may use automated means to collect information regarding your use of the Sites and your interactions with the plug-ins. This information is subject to the privacy policies or notices of the plug-in providers and is not subject to this Website Privacy Policy. We are not responsible for these providers’ information practices.

How We Use the Information We Collect

We may use the information described above to:

• Provide our products and services
• Send you promotional materials or other communications
• Communicate with you about, and administer your participation in, special events,      programs, offers, surveys, and market research
• Respond to your inquiries
• Process employment applications, including by assessing qualifications, verifying      information, conducting reference or other employment-related checks, and      notifying you of future opportunities that might be of interest to you
• Perform data analyses (including anonymization and aggregation of personal information)
• Operate, evaluate, and improve our business (including developing new products and      services; enhancing and improving our products, services, websites and mobile apps; managing our communications; analyzing our products and services; and performing accounting, auditing and other internal functions)
• Protect against, identify, and prevent fraud and other unlawful activity, claims and other liabilities
• Comply with and enforce applicable legal requirements, relevant industry      standards, and our policies

We also may use the information in other ways for which we provide specific notice at the time of collection.

In addition, we use information collected through automated means for purposes such as (i) customizing our users’ visits to our Sites, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our Sites, and (iii) managing our Sites and other aspects of our business.

Information We Disclose

We do not sell or otherwise disclose personal information we collect about you, except as described in this Website Privacy Policy. We may disclose categories of personal information listed under “Information We Collect” and “Information We Collect by Automated Means” to service providers who perform services on our behalf based on our instructions. Examples may include IT service providers who manage our IT and back office systems and telecommunications networks and marketing technology providers.

In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government entities, and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Your Rights and Choices

We offer you certain choices in connection with the personal information we collect from you. You may opt out of receiving future promotional email communications from us by following the instructions in the footer of promotional email communications and updating your preferences. For other inquiries about updating your preferences, please contact us as indicated in the “How to Contact Us” section of this Website Privacy Policy. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.

Children's Privacy

We do not knowingly collect any personal information from children under the age of 13 without parental consent, unless permitted by law. If we learn that a child under the age of 13 has provided us with personal information, we will delete it in accordance with applicable law.

Data Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.

How We Protect Personal Information

We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide on the Sites against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. However, please note that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot and do not guarantee the security of any information you disclose or transmit to our Services and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information, or any other disclosures out of our control.

Links to Other Websites and Apps

Our Sites may provide links to other websites or apps for your convenience and information. These websites may operate independently from us. Linked sites and apps may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for the website’s or apps’ content, any use of the websites or apps, or the privacy practices of the websites or apps.

Updates to Our Website Privacy Policy

This Website Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our Sites to notify you of any significant changes to our Website Privacy Policy and indicate at the top of the notice when it was most recently updated.

How to Contact Us

If you would like us to update information we have about you or your preferences, please contact us by email at max@spurlock-consulting.com.   

Supplemental Information for California Residents:

Effective January 1, 2023, California residents have certain rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) regarding their personal information.

Information Collected by Spurlock Consulting and How it is Used

The CCPA and CPRA require that we provide certain disclosures to you about how your personal information is collected and used. The Privacy Policy sections above provide the relevant information, with additional information provided below.

Sources of Personal Information

We may collect personal information from you or from third-party vendors supporting our website or supporting our services, business operations, and administrative activities, public databases, or social media platforms where permitted under applicable local laws, and internet and network activity as described above under “Information We Collect by Automated Means.”

Sensitive Personal Information

We may use or disclose your log-in credentials as applicable, which are considered sensitive personal information under CPRA, for the purposes of providing our services to you and for purposes of operating, evaluating, and improving our business (including developing new products and services; enhancing and improving our products, services, websites and mobile apps; managing our communications; analyzing our products and services; and performing accounting, auditing, security and other internal functions).

Under CPRA, Sensitive Personal Information is defined to include personal information that is not publicly available and reveals: an individual’s social security, driver’s license, state identification card, or passport number; an individual’s consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, an individual’s precise geolocation, an individual’s racial or ethnic origin, religious, or philosophical beliefs, or union membership; the contents of a consumer’s mail, e-mail and text messages, unless Spurlock Consulting is the intended recipient of the communication; an individual’s genetic data; and the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; or personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

Sales or Sharing of Personal Information

In the preceding 12 months, Spurlock Consulting has sold or shared the following categories of personal information: Identifiers and Internet and other Similar Network Activity, as described above in “Information We Collect by Automated Means.”

Spurlock Consulting may sell or share your personal information to the following categories of third parties: Third-party cookies used to track activity and deliver targeted ads. 

Your Rights and Choices

The CCPA and CPRA provide California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Your Rights and Choices

The CCPA and CPRA provide California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two      separate lists disclosing:
  • sales, identifying the personal information categories that each category of       recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories       that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free      speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code      § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research      in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Correction Request Rights

You have the right to request that we correct any information about you that may be inaccurate. Once we receive a verifiable request to correct inaccurate information, we will use reasonable efforts to correct the information as you direct.

Right to Opt-Out of the Sale or Sharing of your Personal Information

You have the right to direct us to not sell your personal information at any time (the "right to opt-out" of sales). The CCPA defines a “sale” as disclosing or making available to a third party personal information in exchange for monetary or other valuable consideration. While we do not disclose personal information to third parties in exchange for monetary compensation, we do disclose or make available personal information to third parties in order to receive certain services or benefits from them. We do not sell personal information about California residents who we know are younger than 16 years old without opt-in consent. The personal information disclosed may fall into the following category: Identifiers and Internet and other Similar Network Activity as described above in “Information we Collect by Automated Means.”

You also have the right to opt-out of information Spurlock Consulting shares for cross-context behavioral advertising purposes. To exercise the right to opt-out of “Selling” or “Sharing”, you may configure your browser to send the Global Privacy Control (“GPC”) signal, which will transmit your opt-out request to Spurlock Consulting automatically.

Limitation of Use and Disclosure of Sensitive Information

You have the right to request that Spurlock Consulting limit Spurlock Consulting’s use of your sensitive personal information to that which is necessary to provide services or goods requested by you as described in the privacy notice above. Note that this right is limited to sensitive personal information that Spurlock Consulting collects to infer characteristics about you.

Exercising Access, Data Portability, Deletion, Correction, and Limitation Rights

To exercise the access, data portability, deletion, correction, and limitation rights described above, please submit a verifiable consumer request to us by emailing max@spurlock-consulting.com.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand,      evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Retention

We will keep your personal information, including any sensitive personal information as described above, for as long as we have an ongoing legitimate business need to do so. This includes providing you with a service you have requested from us or to comply with applicable legal requirements. It also includes keeping your personal information for so long as there is any possibility that you or we may wish to bring a legal claim, or where we are required to keep your personal information for legal or regulatory reasons.

Non-Discrimination

If you elect to exercise any of your rights under the CCPA, Spurlock Consulting will not deny services, provide a different price or rate for our services, provide a different level of service to you, or suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services because you exercised such rights.