Last Updated: 12/16/2019
Last Reviewed: 12/16/2019

Your privacy is important to us. Hughes Marino, Inc. and its subsidiaries and affiliates (collectively “Hughes Marino”, “we”, “us”, and “our”) respect your privacy concerns and recognize the importance you place on protecting your privacy. This privacy policy (“Privacy Policy” or “Policy”) applies to your use of our website, as well as your interactions with Hughes Marino employees, agents, and contractors (collectively our “Services”). This Policy describes how we collect, use, share, and protect your personal information (“Personal Information” or “Personally Identifiable Information”). This Privacy Policy also explains your rights and choices provided by law and lists multiple ways to contact us for more information or to make a request concerning this Policy or your Personal Information. By providing information to us or by using any of our Services, you indicate that you have read, understood, and agree to the terms and conditions of this Privacy Policy.

Types of Information We Collect
How We Collect Information
How We Use Your Information
How We Store and Protect Your Information
Linking to Other Sites
How We May Share Information We Collect
Your Choices and Control Over Your Personal Information
Rights of California Consumers
Changes to Our Privacy Policy
Hughes Marino Contact Information


Types of Information We Collect

As an integral part of our business and in order to provide our Services, we routinely collect our clients’ Personal Information. We regularly collect Personal Information from the following categories, and therefore have collected Personal Information from each of these categories in the preceding 12 months.

  1. Identifiers
    • your name, postal address, e-mail address, or phone number
  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code Section 1798.80(e))
    • your name, signature, physical description, education, or employment
  3. Protected classification information
    • your age, religion, marital status, gender, or military status
  4. Commercial information
    • records of your personal property, products or services purchased, or other consuming histories or tendencies
  5. Biometric information
    • your sleep, health, or exercise habits
  6. Internet or other similar network activity
    • your interactions with our website (including cookies) and marketing materials
  7. Geolocation data
    • information collected automatically via our website or shared with us directly by you
  8. Your professional or employment-related information
    • your current or past job history
  9. Inferences drawn from other Personal Information
    • your attitudes and abilities

Please note Personal Information does not include certain types of publicly available information, de-identified data, or aggregated information.

How We Collect Information

Hughes Marino obtains the categories of Personal Information listed above from the following categories of sources:

  • Directly from you:
    • for example: from forms you fill out on our website or in person, or from emails and other communication with Hughes Marino employees, agents, and contractors; and
  • Indirectly from you:
    • for example: from observing your interaction with our website or marketing emails, or from interactions you have with Hughes Marino employees, agents, and contractors; and
  • From third-party business partners:
    • for example: social media sites or ad networks.

Please note, when you visit our website, we and our trusted partners may use cookies (small text files, each containing a string of characters, that are sent to your computer when you visit a website) or similar technologies to identify your browser or device. Most browsers recognize when a cookie is offered and allow you to refuse or accept it. Your browser’s help menu should show you how to modify how it treats cookies. Cookies are used to enhance your online experience and are not used to track your navigational habits, unless we otherwise obtain your permission to do so. Depending on how you visit our website, some of the information we collect will be used to identify you and some of the information we collect is anonymous. We use the information we collect to make our website more useful and engaging for all our clients, and to help provide you Services.

We may receive personal information about you from third parties, including, for example, information about your relationships with various product and service providers and your use of certain applications. For example, if you access our web pages through a third-party account, such as Disqus, Facebook, Twitter, Instagram, or Google, that third party may pass certain information about your use of its service to us. This information could include the user ID associated with your account, any information you have allowed the third party to share with us, and any information you have made public in connection with that service. You should always review your privacy settings on third-party websites and services before using them to log-into/access our website.

Our website may track some Personally Identifiable Information of individuals over time or across third-party websites to potentially provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. In addition, some third-party websites do track your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, most browsers allow you to set the DNT signal through your browser settings so that third parties (particularly advertisers) know you do not want to be tracked.

Third parties that have content embedded on our website, such as a social feature, may set cookies on a user’s browser or obtain information about the fact that a web browser visited our website from a certain IP address. Third parties cannot collect any other Personally Identifiable Information from our website unless you provide it to them directly.

How We Use Your Information

We use the Personally Identifiable Information listed from A through I above in a variety of ways, including:

  • To contact our clients when they express interest in our Services;
  • To send emails and other marketing communications to keep our past, current, and future clients informed about our latest services, products, and news (you may always choose to opt out of receiving this information by contacting Hughes Marino via the instructions contained in the email or by any of the methods listed below in the “Hughes Marino Contact Information” section);
  • To provide our clients with our Services and otherwise manage our relationship with them;
  • To respond to law enforcement requests and as otherwise required by applicable law, court order, or government regulations.

We may also use de-identified and aggregate data about our clients for our own analytical purposes as they relate to our legitimate business needs. We use this and other Personal Information to provide better Services to our current clients and to reach out to potential clients who may benefit from working with us. We continually strive to operate, evaluate, and improve our business practices (including developing new service lines, managing our communications, and evaluating our marketing strategies) so that we may provide optimal Services to our clients.

We will notify you before we collect additional categories of Personal Information or use your Personal Information for a purpose that is different from or in addition to the purposes already stated in this Privacy Policy. Unless you ask us not to, we may contact you in the future to tell you about our Services or to notify you about changes to this Privacy Policy.

How We Store and Protect Your Information

At Hughes Marino, we recognize our responsibility for protecting your privacy and Personal Information. We seek to use reasonable organizational, technical, and administrative measures that are designed to safeguard your Personal Information. We store your Personal Information on a secure server and use procedures designed to protect the Personal Information we collect from unauthorized access, destruction, use, modification, or disclosure. In the event that information under our control is compromised as a result of a breach of data security, we will take reasonable steps to investigate the situation, and, where appropriate, notify those individuals whose information may have been compromised and take any additional steps in accordance with applicable laws and regulations.

Linking to Other Sites

Our website may contain links to other websites that are not operated or controlled by Hughes Marino. These linked websites likely contain their own, different policies regarding the collection, use, and safeguard of your Personal Information. We are not responsible for the privacy practices or content of such linked websites. The links on our website do not imply that we endorse or have reviewed such companies’ privacy policies, if any, nor does a link imply an affiliation with the third party. We strongly encourage you to review the privacy policies of any third party when linking to such websites.

Please note that we are not responsible for the collection, use, or disclosure policies and practices (including the data security practices) of other organizations, such as any other app developer, social media platform provider, or operating system provider, including any information you disclose to other organizations through or in connection with our social media pages.

How We May Share Information We Collect

We share the Personal Information listed from A through I above with our service providers, business partners, and corporate affiliates, with third parties you may authorize, with other third parties as and when required by law, or in other circumstances. Therefore, we have disclosed our clients’ Personal Information listed from A through I above in the past 12 months. However, we do not sell our clients’ Personal Information. Hughes Marino has not sold Personal Information in the preceding 12 months.

Your Choices and Control Over Your Personal Information

You have several choices available when it comes to your Personal Information, and we will honor the choices you make to protect your privacy.

If you would like to review or request changes to any of your Personally Identifiable Information that we maintain, please contact us using any method of contact information listed below.

You may also contact us at any time to change your subscription preferences to any of our marketing material. Subscription preferences can also be updated by clicking on an “unsubscribe” hyperlink contained in promotional emails sent by us or on our behalf. Please be aware that even if you opt-out of receiving future promotional communications from Hughes Marino, you may still receive specific transactional communications that relate to past, present, or future business partnerships with Hughes Marino.

California consumers may be offered additional control over their Personal Information as described in the Rights of California Consumers section below.

Rights of California Consumers

Residents of California are offered additional and specific rights as indicated by the California Consumer Privacy Act of 2018 (the “CCPA”). These rights include:

The Right to Access Your Personal Information

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 that Personal Information;
  • The categories of third parties with whom we share that Personal Information;
  • The specific pieces of Personal Information we have about you; and
  • 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.

The Right to Request Deletion of Your Personal Information

You have the right to request that we delete your Personally Identifiable Information that we have 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 request if retaining your Personal Information is necessary to perform any of the following actions, among others:

  • Complete the transaction for which we collected your Personal Information, 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;
  • Comply with the California Electronic Communications Privacy Act; or
  • Comply with a legal obligation.

The Right to Opt-Out of the Sale of Your Personal Information

You have the right to direct a business that sells personal information about you to third parties not to sell your information. This is often referred to as the right to “opt-out.” We do not sell our clients’ Personal Information to third parties.

The Right to Non-Discrimination

You have the right to non-discrimination. Hughes Marino will not discriminate against you for exercising any of your CCPA rights. We will not:

  • Deny you services;
  • Charge you different prices or rates for services;
  • Provide you a different level or quality of services; or
  • Suggest that you may receive a different price or rate for services.

How to Make a Request

Residents of California may contact us to exercise any of their rights under the CCPA by either:

Only you or an agent authorized to act on your behalf may make a request under the CCPA regarding your Personal Information. You may only make a request to Hughes Marino under the CCPA twice within any 12-month period, and we must be able to verify your identity in order to respond to your request. Your request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information; and
  • Provide sufficient detail that allows us to understand, evaluate, and respond to it.

Verifying a California Consumer Request

In order to further protect our clients’ privacy and as required under the CCPA, we must verify each request that comes to us under the CCPA before we supply the information or take the action as requested. In order to verify your request, we may ask you to provide several pieces of Personal Information that we may use to match with your Personal Information that we already maintain. Please note that requests made through an authorized agent are subject to separate verification of the consumer’s identity. We will only use Personal Information provided in a CCPA request to verify the requester’s identity or authority to make such request. If we are unable to verify your identity, we will explain to you why your identity cannot be reasonably verified in light of the nature of your request, and we therefore may not be able to process your original request.

Changes to Our Privacy Policy

We may revise this Privacy Policy at any time. We will continue to evaluate this Policy against new technologies and business practices, as well as our clients’ needs and preferences, and we reserve the right to update, change, amend, or modify this Privacy Policy at any time and from time to time without prior notice unless otherwise required by law. Please review this policy periodically.

If we make any material changes to this Privacy Policy (as determined by us), we will post a notice on our website and update the date of the Policy.

This Privacy Policy was last updated on the date indicated above. Your continued use of our Services, including your decision to supply Hughes Marino with Personal Information, indicates your agreement with the terms of such revised and then-current Privacy Policy.

Hughes Marino Contact Information

Hughes Marino operates this website from its headquarters in San Diego, California. If you have any questions or comments about this Privacy Policy, the ways in which Hughes Marino collects and uses the Personal Information described in this Policy, your choices and rights regarding our use of your Personal Information, or if you wish to exercise your rights under any applicable laws, please reach out to a member of our team using any of the following contact methods.

Phone: 1-833-389-0117
Email: Privacy@HughesMarino.com
Address: Hughes Marino
Attn: Legal Department
1450 Front Street
San Diego, CA 92101