Privacy Notice

Introduction

Lathrop operates www.lathropinc.com and may operate other websites. It is Lathrop’s policy to respect your privacy regarding any information we may collect. This Privacy Policy sets out the principles governing Lathrop’s use and protection of personal data.

This policy is effective as of September 10, 2026.

This privacy policy will be reviewed and updated, if required at a minimum of every 12 months.

Lathrop encourages visitors to frequently check this page for any changes to its Privacy Notice. If we make changes, we will revise the “Effective” date at the top of this statement, and we may provide additional notice such as on the Lathrop website homepage, or via the email address we have on file for you.

Lathrop may collect Personal Data in the course of our normal business activities, as detailed below.

Lathrop collects, uses, stores, and processes Personal Data, which is data that identifies, relates to, describes, or can reasonably be associated with a particular person. For all data subjects, this can include:

• Identifiers: Identifying information including name, postal or e-mail address, and phone or fax number, social security numbers, driver’s license numbers, biometric information.
• Personal Information: Names, signatures, Social Security Numbers, addresses, government identification documents, financial information such as bank account, credit or debit card information, health insurance information, education information.
• Business contact information including as job title, department and name of organization, business address, e-mail address, mobile telephone number.
• Usernames and passwords used to access internal Turner network resources such as our Partner Logon on web page or Turner University.
• Website visitor activity including IP address, the identity of the Internet service provider, the name and version of the operating system, the name and version of the browser, the date and time of the visit, the pages visited. This data may be aggregated such that the individual identities have been removed.
• Biometric information: Genetic, physiological, behavioral, biological characteristics, activity patterns, fingerprints, eye scans, health or exercise data.
• Geolocation information: Physical location, movements, and mobile device unique identifier.
• Images via video surveillance.
• Financial information including as financial account information used for payment purposes and/or information that may be contained in a consumer report, bank account information.
• Contact information for referrals.
• Employment information: employment history, employee number, performance appraisals, salary and benefits, healthcare information, emergency contact information.
• Protected class information: Age, race, color, national origin, citizenship, religion or creed, marital status, disability information, sex, genetic information, military or veteran status.

Lathrop’s services are not directed to persons under 13 years of age. We do not knowingly collect personal information from children under 13. If a parent or guardian becomes aware that their child has provided us with personal information without the parent’s consent, they should contact us at info@lathropinc.com. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete the information from our records.

When you visit our website, we may collect information about your visit.

Directly from clients, contractors, sub-contractors, vendors, employees, and job applicants.

From third parties including contractors, sub-contractors, government agencies.

We collect personal information to conduct our business activities. Lathrop collects only the minimum amount of personal data required to fulfill these activities. These activities include:

• Executing business activities, including completing our services.
• Conducting marketing and promotional activities, including responding to inquiries about Lathrop products or services, providing offers and information (as permitted by law) about products, services, or events offered by Lathrop.
• Improving the functionality, security, and usability of Lathrop’s website.
• Security, including monitoring log-in portals for access, validating identity, and preventing fraud.
• Fulfilling a legal or contractual obligation.
• Managing employee relationships, including the administration of benefits.
• Processing job applications, including background investigations.
• Validating identity for security to allow access to Lathrop premises and job sites.
• For health and safety reasons.
• Complying with applicable laws or regulations.

Lathrop will not use the personal data it collects for purposes other than those described above without notifying data subjects identified by the data.

We use the information you have given us in order to conduct business activities.

Information Sharing

Lathrop may share this information with:

• Other entities controlled by or under common control with Lathrop, including all affiliated entities using the TURNER® mark
• Vendors
• Service providers
• Contractors or sub-contractors
• Federal, state, and local governments

For the purposes of:

• Fulfilling Lathrop’s commercial, contractual, legal, and regulatory obligations.
• Responding to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements.
• Investigating illegal activities, suspected fraud, or as otherwise required by law or regulation. Centralizing Lathrop’s administrative, IT maintenance, and IT security practices.
• Providing information about Lathrop products, services, or events.

Any third-party that receives personal information from Lathrop may only process the information in accordance with applicable data processing agreements or contracts terms which require the third-party to protect the data and process it in a manner consistent with applicable privacy laws, regulations and Lathrop’s policies and practices.

Lathrop’s website may provide links to other third-party websites that are outside of Lathrop’s control and not covered by this Privacy Policy. Lathrop is not responsible for the availability, content, or accuracy of third-party policies, nor is it responsible for the privacy practices of other websites, products, services, or goods that may be linked to Lathrop’s websites. Lathrop encourages all users of its websites to review the privacy policies posted on these (and all) sites.

Lathrop takes the responsibility of keeping your information secure.

Storage

The security measures Lathrop uses vary based on the sensitivity of the personal information we collect, process, and store, and the current state of technology. We also take measures to ensure service providers that process personal data on our behalf also have appropriate security measures.

Retention

Lathrop retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law.

If you have consented to the processing of your Personal Data, Lathrop will retain and process your Personal Data until you withdraw your consent (“opt-out”), unless the Personal Data must be kept for administrative, legal, or regulatory purposes.

If Lathrop has not received your opt-in, Lathrop will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed.

Disposal

Data is securely destroyed or disposed once it is no longer necessary to retain the data.

Security

Lathrop has in place security policies that are intended to ensure the security and integrity of all Personal Data. Lathrop has appropriate technical and organizational measures in place to protect against unauthorized or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Lathrop. If Lathrop forwards Personal Data to any third party, Lathrop requires that those third parties have appropriate technical and organizational measures in place to comply with this Privacy Policy and applicable laws.

You have certain rights for the collection, use, or dissemination of your Personal Data to the extent required by law as applicable to Lathrop and your data.

Your Individual Data Subject Rights

Right to request access to data: You have the right to ask for copies of your Personal Data.

Right to correction: You have the right to request correction of your Personal Data.

Right to deletion: You have the right to request that we delete your Personal Data.

Right to opt-out of communications: You have the right to opt-out from marketing communications. We provide an unsubscribe link in certain marketing communications. You may also request to opt-out of marketing communications via the data subject rights request process.

The California Consumer Privacy Act of 2018 provides California consumers (California residents) with specific rights regarding their personal information.

You may exercise your data subject rights using any of the following methods:

• Emailing info@lathropinc.com.
• Mailing the request to the Privacy Officer at Lathrop, 810 7th Ave #601 New York, NY 10019.

When a data deletion request is received from an individual claiming to be a data subject, the identity must be verified, and the jurisdiction governing the request must be determined. This is done by sending you an acknowledgment of the request and asking for the following information:

1. Where you reside
2. In what context and time frame would we have collected your personal information

If you reply with the requested information, the Privacy Office will initiate a search for the information and take appropriate action, including providing a resolution. In the absence of either of these pieces of information, no further action is required and the request will be considered fully addressed.

Lathrop will respond as described below:

Lathrop will deliver the required information within 30 days of a verifiable request, and you will receive notification if Lathrop will need an additional 30 days to respond.

Lathrop will provide response to requests for access to data in a written, readily usable format for data portability and free of charge to the consumer after Lathrop receives a valid request.

You will receive your requested information either by your account, electronically, or via mail.

Lathrop will not provide you with specific pieces of personal information if the disclosure would create a substantial, articulable, and reasonable risk to the security of the personal information, your account with the business, or the security of Lathrop’s systems or networks.

Lathrop will notify you when data has been deleted.

There may be circumstances where Lathrop must deny your verified request because of a conflict with state law, federal law, or an exception to applicable privacy laws. If Lathrop must deny a request accordingly, you will be informed and given the basis for the denial. If the request is denied only in part, Lathrop will disclose the other information sought by you.

If you have any concerns or questions about anything in this Privacy Notice, please get in touch with us.

This website is owned and operated by Lathrop.

Our principal place of business

Lathrop
810 7th Ave #601
New York, NY 10019