Corgan Policies

Collection of Policies and Statements

Overview

As part of our core values, Corgan holds ourselves to high standards of integrity and ethical conduct. This page is to inform you of our policies, terms, and transparency statements.

This Privacy Policy (this “Policy”) sets forth the information that Corgan (“Corgan”, “we,” or “us”) collects on you when you request or otherwise obtain services (as defined in the Proposal or Contract for Professional Services), how the information may be used or disclosed, the measures we take to protect such information, and your rights with respect to Corgan’s collection and use of such information. By visiting, using, or otherwise accessing www.corgan.com or any other current website of Corgan (the “site”), or by requesting or obtaining services, you accept the privacy, use, and disclosure practices described in this Policy. This policy is not applicable to information retrieved from publicly available sources or through Freedom of Information Act requests.

1. Definitions

“Client” means a customer of Corgan.

“Personal Data” means any information about an individual maintained by Corgan that may reasonably be used to identify or trace an individual’s identity, such as name, mailing address, social security number, driver’s license number, taxpayer identification number, date and place of birth, biometric data, or any other information that may be linked to an individual such as medical or financial information.

“Visitor” means an individual who visits the site.

2. The Information We Collect

2.1. Information Provided by Clients or Visitors

We collect and use information to provide the services and to provide various features of the site. When you obtain the services or access the site as a visitor, you may provide, and we may collect, personal data. You may provide us with personal data in various ways, for example, when you contact us via telephone, mail, or email; use the contact forms on the site; request any service; or submit customer service-related requests.

2.2. Information Collected Automatically

We may automatically collect certain information including IP addresses, browser type, device type, page visit history, and duration of visit, from the visitor’s device by using various types of technology, including cookies, “clear gifs" or “web beacons” when a visitor accesses the site. We may also use these technologies to collect information to determine a visitor’s interaction with email messages, for purposes of analyzing such as whether the visitor opens, clicks on, or forwards a message. We collect this information from all visitors.

2.3. Information from Other Sources

We may collect information, which may include personal data, from third parties such as our partners, advertisers, or credit rating agencies. If we combine information from third party sources with personal data collected through the service or the site, we will treat the combined information as personal data in accordance with this Policy.

3. How We Use the Information We Collect

3.1. Operations

We may use the information to operate, maintain, enhance, and provide all features of the site, to provide the services and information which you request, to respond to comments and questions, and to provide support to users of the service.

3.2. Improvements

We may use the information to analyze the usage, trends, and preferences of visitors; to improve the site; or to develop new products, services, or features of the site. If Corgan is required to process personal data for these purposes, then Corgan will anonymize or aggregate the data prior to such use.

3.3. Communications

We may use a visitor’s or client’s email address or other information collected to contact that person (i) for administrative purposes such as customer service; (ii) for purposes arising from or related to services provided to client; (iii) for promotions, and events, relating to products and services offered by us and by third parties we work with, or (iv) general marketing purposes. You may opt-out of receiving any promotional communications as described below under Section 5 below.

3.4. Cookies and Tracking Technologies

We may use information collected on the site through cookies and similar technologies to: (i) tailor the user experience; (ii) analyze the effectiveness of marketing activities; and (iii) monitor site usage metrics.

3.5. Analytics

We use Google Analytics to evaluate website traffic and evaluate visitor activity. We do not use any of this information to identify visitors. For more information, visit the Google Analytics Help Center.

4. To Whom We Disclose Information

Except as described in this Policy, we will not intentionally transfer, exchange, license, sell, lease, or otherwise disclose your personal information without your approval. We may also disclose information in the following circumstances:

4.1. Service Providers

We may work with third-party service providers who may have access to or process personal data as part of providing those services for us. When third-party service providers are used, we take reasonable measures to limit the information provided to that which is reasonably necessary for the third-party service providers to perform their functions.

4.2. Non-Personally-Identifiable Information

We may disclose non-personally-identifiable information to third parties for various purposes, including, (i) compliance with certain reporting obligations; or (ii) business or marketing purposes.

4.3. Law Enforcement, Legal Process, and Compliance

We may disclose personal data or other information if required to do so by applicable law or if a good-faith belief exists that such disclosure is necessary (i) to comply with applicable laws; (ii) to comply with a valid court order, subpoena, or warrant; or (iii) to otherwise comply with requests from law enforcement or other governmental agencies. Prior to disclosing personal data in such circumstances, Corgan will make reasonable attempts to inform the client or visitor of the nature of the request or proposed disclosure.

We may also disclose personal data or other information that we believe is appropriate or necessary to (i) prevent liability; (ii) protect Corgan’s interests; (iii) investigate and defend any third-party claims, causes of action, or allegations; (iv) ensure the security or integrity of the services; or (v) protect Corgan’s property or other legal rights, enforce contracts, or protect the property, rights, or safety of others.

4.4. Change of Ownership

We may disclose to a third-party visitor or client information, including personal data, to an acquirer, successor, or assignee of Corgan as part of any merger, acquisition, asset sale, debt financing, or other transactions; as well as in insolvency, bankruptcy, or receivership proceedings. In the event of such disclosure, Corgan will undertake reasonable measures to ensure the recipient of the information is bound by an agreement or privacy policy with terms substantially similar to this Policy.

5. Your Choices

5.1. Access, Correction, Deletion

We acknowledge and respect your rights to privacy and will provide you with reasonable access to the personal data that you may have provided through your request for, or retention of, services and your use of the site. If you would like to obtain or change personal data we hold about you, or request that we delete any information about you, please contact us using the procedures set forth in Section 11. At your request, provided that applicable law permits, we will remove or block references to your information in our database.

You may request an update, correction, or deletion of your information and preferences at any time by contacting us using the procedures as set forth in Section 11. Please note that while changes you request will be reﬂected our databases within a reasonable period of time, we may keep all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe a legitimate reason to do so exists.

You may refuse to share certain personal data with us. If you refuse to share Personal Data, we may not be able to provide you with some of the features and functionality of the site or otherwise provide services.

5.2. Opting out of Commercial Communications

You may occasionally receive marketing emails from us. You may unsubscribe to our marketing emails at any time by following the procedures contained within the email or by submitting a request to stop receiving such communications via the link provided in Section 11.

It may take up to 5 business days for Corgan to process your request to stop receiving marketing emails. If, after you submit a request to stop receiving marketing emails, you subsequently opt-in to receive emails from Corgan, we may resume sending you marketing emails. Please be aware that even if you opt-out of receiving Corgan’s marketing communications, (i) you may still from time to time receive messages from us regarding services, and (ii) we will continuously maintain your email address in our databases to enable us to track your election to remove your email address from Corgan’s mailing list.

6. Cookies

6.1. The site uses the following cookies:

Cookies that enable users to navigate the site and utilize certain features of the site. These cookies are essential to experience all the features of the site and do not collect identifying information of visitors.

Cookies that collect information about how visitors use the site. These cookies may track error messages and which pages a visitor accesses. These cookies also do not collect identifying information of visitors. These cookies are used to provide data to improve the functionality of the site.

7. Data Security

Corgan utilizes generally accepted administrative, technical, and physical safeguards to reasonably protect personal data provided and collected from visitors and clients from accidental or unlawful disclosure or misuse.

If we learn of a breach of the security of our systems affecting your personal data, we will notify you of the breach in accordance with applicable law.

8. Data Retention

Unless otherwise required by law, we will retain personal data only for as long as needed to carry out the purposes for which we have collected the personal data or to comply with our legal obligations, resolve disputes, and enforce any agreements between Corgan and you.

9. Data Transfer

Corgan may transfer, process, and store personal data we’ve collected in databases or with service providers located within or outside of the United States.

10. Changes and Updates to this Policy

Corgan reserves the right to amend or update this Policy from time to time. Please review this page periodically to remain informed of any changes to this Policy. Your continued use of the site or the services after an amended or updated Policy becomes available indicates that you have read and agree to the current Policy as amended or updated.

11. How to Contact Us

You may contact us with any questions or comments regarding this Policy, your personal data, or our use and disclosure policies by email at privacy [at] corgan.com (privacy[at]corgan[dot]com). You may modify your email consent through the Communication Preferences in any marketing communication email received, unsubscribe here, or unsubscribe on the Insights page of corgan.com.

Last Updated: December 2022

What is this Privacy Notice about?

Corgan Associates Inc. and its subsidiary and associated entities (us or we, known as “Corgan”) are data controllers or joint data controllers for the purposes of data protection law and are responsible for processing personal data about you. Personal data means any data about an individual from which that person can be identified.

This notice describes how and why we collect and use personal data about you during the application and recruitment process and you should read this carefully to understand how we handle your personal data.

If you have any questions about this Privacy Notice, please contact our Privacy Officer by emailing privacy [at] corgan.com (privacy[at]corgan[dot]com)

This Privacy Notice applies to all applicants for all roles with Corgan who are based in the United Kingdom or the European Economic Area. It does not form part of any contract we may have with you and may be amended by us from time to time. This Privacy Notice does not in any way change the status of your relationship with us and is not an indication of employment or any contractual obligations between us.

What data do we hold about you and why?

We collect personal data about you through the application and recruitment process, both directly from you and from recruitment agencies and background check providers.

If we offer you employment, we may also collect additional data from third parties which may include former employers, criminal record agencies, education and training providers, other employees or contractors and your employment referees.

Automated Decision-making

We do not currently carry out any automated decision-making.

Data Sharing

Why might you share my personal data with third parties?

We do share your data with third parties, (including third-party service providers and our other entities) where required by law or where we have another legitimate interest in doing so including in the administration of our recruitment process.

If we do share data, we require third parties to take appropriate security measures and only process your data for specified purposes.

Which third-party service providers process my personal data?

“Third parties” includes third-party service providers (including contractors and designated agents) and, in particular, our other entities.

We have appropriate arrangements in place to require those other entities to protect your personal data in the same way as we do.

We do use third party software to manage our recruitment processes and your personal data will be uploaded by you, your recruitment consultant or us onto that software during the application process.

The services provided by third-parties include: IT, professional advice, recruitment, and identification, criminal and background checks.

Transferring data outside the UK and the EU

As we are an international organization and use external third party providers, we may sometimes transfer your personal data outside of the UK/EU.

Whenever we transfer your personal data out of the UK/EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Secretary of State or European Commission.

Where we use certain service providers, we may use specific contracts approved for use in the UK and the EU which give personal data the equivalent protection that it has in the UK.

Please contact us if you want further data on the specific mechanism used by us when transferring your personal data out of the UK and EU.

Data Retention

Our intention is to retain your personal data for only as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you are not successful in being offered employment, ordinarily, for the exercise or defence of possible legal claims, your data will be held securely for six months from the date your application was determined and after that date it will be erased.

However, where your application is not successful for the position you applied for, but we think you may be suitable for a position at Corgan in the future, we may keep hold of your details and/or share them with our group companies.

We will only contact you about similar positions if you have provided your consent for us to do so. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact corganhr [at] corgan.com (corganhr[at]corgan[dot]com).

Rights of access, correction, erasure, and restriction

Under certain circumstances, by law you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you, in certain circumstances, to receive a copy of the personal data we hold about you and to be told about how that data has been collected and used.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

Request erasure of your personal data. This enables you, in certain circumstances, to ask us to delete or remove personal data,

Object to processing of your personal data where we are relying on our own legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.

Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal data to another party.

Withdraw consent for the processing of your personal data. In the limited circumstances where you have provided your consent to the collection and processing of personal data you may wish to withdraw your consent. rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

How you exercise these rights

Any request in relation to any of the above rights should be directed to the Privacy Officer.

What we may need from you

We may need to request specific data from you to help us confirm your identity and ensure your right to access the data (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Further questions or complaints

If you have any questions about this privacy notice or how we handle your personal data, please contact the Privacy Officer.

You have the right to make a complaint to the Information Commissioner’s Office, the UK supervisory authority.

Organization

This statement applies to Corgan Associates, Inc. and all companies within and associated to Corgan (referred to in this statement as ‘The Group’). The information included in the statement refers to the financial year 2025.

Organizational Structure

Corgan is a leading architecture and design firm with a user-centered approach and deep technical experience. We are consistently ranked as one of the top 10 architecture firms in the United States and our core disciplines are supported by a wide range of supplemental services, all of which have a singular goal: to build environments where our clients thrive.

Corgan operates from 19 offices in the United States with 3 international offices, in the United Kingdom, Ireland, and Singapore.

Definitions

Corgan considers that modern slavery encompasses:

- Human trafficking

- Forced work, through mental or physical threat

- Being owned or controlled by an employer through mental or physical abuse of the threat of abuse

- Being dehumanized, treated as a commodity or being bought or sold as property

- Being physically constrained or having restrictions placed on freedom of movement.

Commitment

Corgan acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Corgan understands that this requires an ongoing review of both its internal practices in relation to its labor force and, additionally, its supply chains.

Corgan does not enter into business with any other organization, in the United States or abroad, which knowingly supports or is found to involve itself in slavery, servitude, and forced or compulsory labor.

No labor provided to Corgan in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United States, United Kingdom, Ireland, and Singapore.

Supply Chains & Potential Exposure

The company’s supply chain in relation to its services may consist of other regulated professional services such as engineers or landscape architects. The Group considers these to be low risk in relation to human trafficking and slavery so does not take action in this area.

The main goods supplied to The Group include those related to office supplies, office furniture, computer hardware and software. The supply of these goods is not regular, and the company will assess whether additional measures should be put in place in relation to the acquisition of such goods alongside its robust procurement processes.

Steps

The Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organization or supply chains, including conducting a review of the controls of its suppliers.

The Group has not, to its knowledge, conducted any business with another organization which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, The Group has taken the following steps to ensure that modern slavery is not taking place:

- measures in place to identify and assess the potential risks in its supply chains

- undertaking impact assessments of its services upon potential instances of slavery

- creating action plans to address identified risk to modern slavery

Policies

A modern slavery policy is contained within the employee handbook.

Training

All employees undergo a thorough induction into The Group’s policies and procedures during their first days of employment, which covers the Modern Slavery Policy.

Compliance

All concerns regarding modern slavery should be addressed by contacting Human Resources, who will then undertake relevant action with regard to The Group’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval: January 2025

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