Privacy Policy

Last Updated: December 15, 2025

Benedict Miller, LLC ("Company") is committed to protecting the privacy of certain data we collect when you access and use benedict-miller.com ("Site"). This Site is intended for use in the business to business context and is not a consumer website.

This Privacy Policy ("Policy") describes our policies and practices regarding the collection, use and disclosure of information you submit or we obtain in connection with your use of our Site unless otherwise noted. This Policy is incorporated into the Terms of Use [link].

Please read this Policy carefully before using the Site or otherwise submitting personal information to us. By accessing or visiting the Site or otherwise submitting personal information to us, you indicate your understanding that the collection, use, disclosure, and retention of your personal information is subject to the terms of this Policy and our Terms of Use. If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this Policy, please do not provide us with such information. This Policy does not apply to third-party websites accessible through our Site or other applications.

Changes to this Policy

We reserve the right to change this Policy at any time. In the event we make material changes to the Policy, we will provide notice through the Site. Changes will be effective immediately upon posting to the Site and will apply to your use of the Site after the "Last Updated" date listed above. You understand and agree that your continued use of the Site after the effective date means that the collection, use, and sharing of your information is subject to the updated Policy. Except to the extent we receive your authorization or as permitted or required by applicable law, we will handle your information in accordance with the terms of the Policy in effect at the time of the collection.

What Personal Information Do We Collect?

We may collect, or have collected in the preceding 12 months, the following categories of personal information ("PI" or "personal information"). We may add to the categories of PI we collect and the purpose(s) we collect and use it. In those cases, we will inform and update this section of the Policy.

Identifiers (including personal information described in Cal Civ Code sec. 1798.80 (e)) such as real name, postal address, unique personal identifier, online identifier, Internet Protocol address, phone number, email address, account name, Social Security number, driver’s license number, signature, or other similar identifiers.
Characteristics of protected classifications under federal or California law such as veteran status, race, religion, gender.
Commercial information such as products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric information such as an individual’s physiological, biological, or behavioral characteristics used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity.
Internet or other electronic network activity such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
Geolocation data such as location information while visiting our website.
Audio, electronic, visual, thermal, olfactory, or similar information such as identifiable information obtained about you from voicemail messages, while speaking with our service representatives, including on the telephone, and captured by video cameras.
Professional or employment-related information such as your contact information, employer and similar information.
Sensitive Information. Sensitive information means a consumer’s social security, driver’s license, state identification card, or passport number; 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; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; personal information collected and analyzed concerning a consumer’s sex life or sexual orientation; data related to citizenship or immigrations status, neural data, and data related to a known minor under the age of 16 years old. data.

10. Consumer profile such as inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.

Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.

How Do We Collect Your Personal Information?

The Company may collect your personal information from a variety of sources, including:

You. We collect information you provide us, for instance, when you communicate with us, create an account on our website, sign up for our newsletter, participate in our surveys, request information, or visit one of our facilities (e.g., CCTV).
Related parties and entities. We may collect information about you from our related entities, affiliates and business partners including joint ventures.
Service Providers and Vendors. We may collect your personal information from service providers or vendors who collect information needed to provide you with products or services, in connection with your use of our website, or as related to our marketing activities.

· Third Parties. We may collect information about you from third parties such as your employer, referrals, sales representatives or other third-party sources that are lawfully entitled to share your data with us.

Social media and related services. We may collect information about you through your social media services consistent with your settings on such services or from publicly available websites consistent with their terms and conditions.
Information Collected Automatically. As you navigate through and interact with our Site, we may collect information automatically from you through web technologies such as cookies and tracking pixels. For additional information, please see the section on Cookies, below. We may also collect information when you use our guest Wi-Fi service.

Cookies, Tracking, and Certain Communications

Our Site may use web technologies such as cookies, browser analysis tools, server logs and web beacons for purposes which may include recognizing you when you return to the Site, estimating our audience size, tracking visits to the Site, helping us improve the quality of the Site, processing your requests, and providing you with relevant advertising based on your interests. Some of these technologies may be set by us or a third party.

Cookies are small files consisting of letters and numbers that automatically collect certain information. These files uniquely identify and recognize your browser or device and transmit information back to the server. Depending on the type of cookie, it can perform different functions. We may use the following cookies on the Site:

Strictly Necessary/ or Essential Cookies: These are essential to the basic operation of our Site and without them, we may be unable to provide the Site or certain services or features. For example, these cookies help remember information you input, enable you to navigate around the Site and use its features, or provide you with requested services.
Performance/Analytics Cookies: These gather information about how you use the Site. Some of these may be analytics cookies set by third parties to analyze how you use the Site so we can improve it and the products and services we offer. To do so, they may collect information about your equipment, browsing actions and patterns, details of your visits to our Site (e.g., traffic data, location data, logs and other communication data and the resources that you access and use on the Site), information about your computer and internet connection (e.g., IP address, operating system, browser type, type of device you are using, mobile ad identifiers), information about your preferences to make your use of the Site more productive.
Functionality/Personalization Cookies: These save information that you have entered so the Site can recognize you, remember your username or choices such as language, or personalize the Site’s content for you.
Advertising and Targeting/Tracking Cookies: These may record your visit to the Site. They may also collect details about the device you use to access the Site (e.g., your computer or mobile phone), your IP address, browser type ,and operating system. This information may be used for purposes such as tailoring the Site; ad targeting or performance measurement; and, remembering whether you have previously visited the Site. Some of these cookies may follow you when you leave the Site and travel to other websites so that we can serve personalized ads tailored to your preferences. We may place these cookies on your device or third parties, such as advertising partners, service providers, or social media platforms may place them when you visit the Site.
Social media widgets. The Site includes social media features, such as Meta, LinkedIn, X and You Tube, widgets. These features may collect information such as your IP address and the pages you visit on the Site through cookies or other tracking technologies. Social media features and widgets may be hosted by a third party. Your interactions with those features are governed by the privacy policies of the social media companies that provide them and we recommend reviewing their policies for further information.

Controlling cookies. You can control cookies through your browser settings and other tools. Most browsers will allow you to block or refuse cookies. However, you may need to manually adjust your preferences each time you visit a website. Unless you have adjusted your browser setting to refuse cookies, our system will issue cookies when you direct your browser to our Site. Please note that if you block certain cookies, some of the services and functionalities of our Site may not work. For more information, see the Help section of your browser. You can also find information about managing cookies at the following links:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/16.0/mac/11.0
Edge: https://support.microsoft.com/en-us/windows/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use-168dab11-0753-043d-7c16-ede5947fc64d
Mozilla Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectslug=enable-and-disable-cookies-website-preferences&redirectlocale=en-US

The Site may also use web technologies such as:

Web beacons/pixels/tracking or targeting cookies. We or third parties may set these small electronic files to help with functions such as tracking, analytics, counting Site visitors, or for marketing and media services including serving you targeted ads. They may collect your Site interactions (e.g., page view, view content, search, sign up, download, submit form), user information (e.g., IP address, browser information), or information about your online activities over time and across third-party websites or other online services. These may include, without limitation, Facebook/Meta, LinkedIn, and YouTube pixels.
URL trackers. These third party trackers are strings of code that track user behavior after clicking on a URL for marketing purposes.
Browser/device/online fingerprinting. These third party tools use scripts to track the attributes of the visitor’s device or browser to build a profile of the user.
Chatbot. The Site may use a chatbot to process and respond to user questions. The chatbot is an automated bot. The user’s interaction with the chatbot may be monitored, recorded and shared with the vendor supporting us.
Session replay. We may record your interaction with the Site to help us analyze and understand how the Site is utilized by visitors and to help improve it. This tool may record information such as your clicks, scrolls and mouse movements, feedback polls, country, duration, device, name, email, ID, browser, OS, and IP address

Email pixels. We may embed email pixels in emails we send you. When you open the email, is sends back information to us including how many people open our emails, click on links, the percentage of recipients who read email on their phones, etc. We use this information for marketing purposes and to learn more about our audience.

IMPORTANT: By using the Site, you consent to the processing of any information for the analytics purposes and functions described above.

How Long Do We Keep Your Personal Information?

We retain your personal information for as long as necessary to achieve the purpose for which we collect it. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, collect fees, etc. or as permitted or required by applicable law. We may also retain your Personal Information in a deidentified or aggregated form so that it can no longer be associated with you.

To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; applicable legal requirements.

What Are Your Choices?

You can always limit the information you provide to us, but if you choose not to provide certain requested information, you may be unable to access or receive some of the services, products, and information we offer or use features on the Site.

You can unsubscribe from our marketing communications by following the unsubscribe instructions in the communication.

How Do We Use Your Personal Information?

In general, we use the personal information we collect about you only for the purpose it was collected, for compatible purposes, or as permitted or required by law. We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent when required by law.

For example, we may use your personal information for one or more of the following purposes:

To provide you with information, products, or services you request from us.
To improve our performance and offers to customers; provide customer service; and engage in quality control activities concerning our products and services.
To process payments.
To engage in marketing activities including email alerts and other notices concerning our products, services, events, or news that may be of interest to you.
To ensure your information is accurate and to personalize our communications to you. For example, we may aggregate your personal information with data from various sources for purposes of keeping information up to date. If you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal or share and use it as described elsewhere in this Policy.
To carry out our obligations and enforce our rights including those arising from any contracts entered into with you including for billing, payment, collections or enforcing our Terms of Use.
To review, improve, and monitor our website, applications, online services, and overall consumer experience, including customization to meet specific needs.
For testing, research, analysis and product and service development.
As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.

We reserve the right to use, or disclose to third parties as necessary, current or past personal information collected about you: (a) if such information is subpoenaed; (b) to comply with federal, state, or local laws; (c) to comply with a civil, criminal, or regulatory inquiry, investigation, or summons by federal, state, or local authorities; (d) to cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; (e) to conduct an investigation, exercise or defend a legal claim, (f) if we are sold, merge with a third-party or are acquired by a third-party (collectively, "M&A Transactions") (including where we share your personal information in connection with the due diligence process associated with a potential M&A Transaction); (g) if we are the subject of bankruptcy proceedings; and/or (h) when we deem it necessary or appropriate. You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third parties without permission. We may also use and disclose your personal information at your direction.

How Do We Disclose or Share Your Personal Information?

In general, we will not disclose your personal information except as described in this Privacy Policy, as permitted or required by law, or with your consent. This includes disclosing your personal information for the same reasons that we may use it. In doing so, we may disclose your personal information to the following categories of third parties:

Our employees and personnel with a need to know based on job responsibilities.
Service providers and vendors. We may share information with third parties who collect or process information on our behalf or provide us with certain services. For example, website operation or hosting, business support, IT services, cloud storage, shipping and fulfillment services, payment processing, analytics, security and fraud protection, and marketing and advertising.
Related entities, affiliates, agents, distributors, and business partners. We share information with our related entities or with their employees, agents, contractors, representatives, legal counsel and/or accountants for operational, management and administrative purposes, internal audit, legal, regulatory, security, insurance, financial, processing and other similar purposes.
Professional advisors, including lawyers, accountants, auditors, bankers, and insurers where necessary in the course of the professional service that they render to us.
Social networks in connection with marketing.
Third parties as directed by you. We disclose personal information at your direction.

The following chart lists the categories of personal information we may disclose or have disclosed in the preceding 12 months to service providers or contractors.

Personal Information	Disclosed to Service Provider or Contractor
Identifiers (including personal information described in Cal Civ Code sec. 1798.80 (e)) Commercial information Biometric information Internet or other electronic network Geolocation data Audio, electronic, visual, thermal, olfactory, or similar information Professional or employment-related information Sensitive Information Consumer profile	Yes

Embedded Content

The Site may contain embedded third-party content from other sources (e.g., videos, images, articles). Embedded content may place third party cookies on your device that monitor your interaction with the embedded content, for marketing purposes or to enhance your user experience. We have no direct control over the information these cookies collect and we recommend that you should visit the website privacy policy for the third parties that provide this content.

Do Not Track

"Do Not Track" is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Site is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.

Third Party Website Links

We may provide links to websites or resources outside of our Site for informational purposes only. We may also provide links to third party integrations. Third party integrations are websites or platforms that synchronize with our Site to provide you with additional functionality, tools, or services such as maps, sending requested information, etc.

You acknowledge and agree we are not responsible for the availability of third party sites, resources, or integrations and do not endorse and are not responsible or liable for any content, advertising, goods, services or other materials on, available through, or provided by such sites, resources, or integrations. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of personal information that you provide, or is collected by, such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites.

Email

We may collect your email address via cookies and pixels on the Site through the use of trusted third-party partners. These partners may combine your email information with other information they have access to such as mailing address so that we may send relevant marketing offers to you via direct mail.

Children

Our Site is not directed at children under the age of 13 years old and we do not knowingly collect or solicit personal information from children under the age of 13.

Security

We employ reasonable and appropriate administrative, physical and technical measures designed to protect the security of personal information we collect from you. However, no data transmitted over the Internet or stored digitally can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us or receive from us. We encourage you to use caution when using the Internet.

Applicable law

This Policy is governed by the laws of the State of New Jersey without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the state and federal courts within New Jersey. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.

Notice to Site Users Located Outside the U.S

The Company operates in accordance with the laws of the U.S. When you access our Site from outside the U.S., we may transfer the PI that we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this Site, you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the U.S.

Contact Us
If you have additional questions, you may contact us at:
Benedict Miller, LLC
908-497-1477
info@benemiller.com

Notice to California Residents

Shine the Light. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by the Company to a third party for the third party’s own direct marketing purposes. Requests may be made one time per calendar year. If applicable, this information would include the categories of customer information and the names and addresses of those businesses to whom we disclosed customer information for the immediately prior calendar year (e.g., requests made in 2025 will receive information regarding 2024 sharing activities). You may submit your request using the contact information in this Policy.

Eraser Law. If you are a California resident under the age of 18, and a registered user of any Site where this Policy is posted, California law permits you to request and obtain removal of content or information you have publicly posted. You may submit your request using the contact information in this Policy. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

California Consumer Privacy Act of 2018, as amended ("CCPA"). This CCPA section describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about California consumers when they access or use the Site, or through other channels including but not limited to visiting one of our locations, phone and email conversations, attending our events, social media interactions, viewing our emails, or through our authorized services providers.

This CCPA Section supplements and amends the information contained in the Policy with respect to California consumers. The other provisions of the Policy continue to apply except as modified in this CCPA section. Any terms defined within the CCPA have the same meaning when utilized within this CCPA section. All other terms shall have the meaning set forth in the Policy or Terms of Use as applicable.

Consumer Rights

The CCPA provides California consumers with the following rights, subject to certain exceptions and verification where required:

Right to Request Deletion. You have the right to request that we delete your PI from our records.
Right to Know. You have the right to request that we disclose the following to you as it relates to the 12-month period preceding our receipt of your verifiable consumer request:
1. The categories of PI we have collected about you.
2. The categories of sources from which the PI was collected.
3. The business or commercial purpose for collecting, selling, or sharing PI.
4. The categories of PI we disclosed, sold, or shared for a business purpose.
5. The categories of third parties to whom we disclosed, sold or shared PI, by the category of PI.
6. The specific pieces of PI we collected about you.
Right to Request Correction. You have the right to request that we correct any inaccurate personal information we maintain about you.
Right to Opt Out of the Sale or Sharing of Your Personal Information. We do not sell or share personal information nor do we have actual knowledge that we have sold or shared the personal information of minors under the age of 16 years old.
[Please note that sell means an exchange of California consumer personal information for money or other valuable consideration. Share means making available or disclosing California personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.]
Right to Limit the Use or Disclosure of Your Sensitive Personal Information. We do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary in order to provide our products and services as are reasonably expected by an average consumer requesting those goods and services.

We will not retaliate against you for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of goods or services if you exercise your rights under the CCPA.

Submitting Consumer Rights Requests. To submit a California Consumer Rights request as outlined in this CCPA section, please contact us at Benedict-Miller: 908-497-1477, info@benemiller.com

Verifiable Requests. We reserve the right to respond only to a verifiable consumer request. A verifiable consumer request is one made by any individual who is:

the consumer who is the subject of the request,
a consumer on behalf of the consumer’s minor child, or
by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.

If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us.

Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use the PI we collect from an individual to determine a verifiable request for any other purpose, except as required by law.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to Personal Information collected on and after January 1, 2022, and to the extent expressly permitted by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not be impossible or require a disproportionate effort by us. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.

Authorized Agents. You may authorize a natural person, or a business registered with the California Secretary of State to act on your behalf with respect to the right under this CCPA Section. When you submit a Request to Know, Correct or Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

This Statement is available in alternative formats upon request. Please contact us to request this Statement in an alternative format at Benedict-Miller: 908-497-1477, info@benemiller.com