PRIVACY AND COOKIES POLICY
Effective Date: December 26, 2018
1. THE INFORMATION HARRIS BRICKEN OBTAINS
Personal Data: “Personal Data” (or “Personal Information”) is any information that can be used to identify, locate or contact natural persons. Personal Data includes, but is not limited to, your name, telephone number, email address, or home or other physical address. It also includes other information that may be associated with your Personal Data, such as your internet connection, the physical equipment you use to access the Websites, and usage details.
Sensitive Personal Data: “Sensitive Personal Data” means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data that uniquely identifies a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation.
Payment Data: “Payment Data” includes any information you may transmit to us to effect payment for any services provided by us. This includes, but is not limited to, your credit or debit card number, card expiration date, CVV code, check payment information, and billing/payment account address.
For purposes of the Policy, we refer to Personal Data, Sensitive Personal Data, and Payment Data collectively as “Data” unless otherwise specified.
2. CONTACT INFORMATION
To ask questions or provide comments about the Policy our privacy practices, or to exercise any rights identified in the Policy, please contact us at:
— United States:
555 W. 5th Street, Suite 3110
Los Angeles, CA 90013
Telephone: (424) 273-5500
Av. Diagonal 463 BIS
Telephone: +34 935439609
If you are a resident of Europe and wish to contact a Data Protection Authority (“DPA”) in your resident country, please see the following list: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
3. COLLECTION OF DATA
Websites: If you fill out the contact form or blog subscription forms on the Websites, you will be asked to provide us with certain Data, including your email, address, name, or phone number. Please do not submit any confidential or proprietary information, Sensitive Personal Data, or Payment Data through these contact or subscription portals.
Some of our Websites includes links to a page where users can pay for our legal services. While these links originate on our Websites, and while it may appear that Data you provide will be provided to us, any Data provided through this portal will be provided to a third-party payment processor. We do not obtain full credit or debit card numbers, but may be provided with partial credit or debit numbers, or other Data that is inputted (such as client name) to, among other things, verify payment.
In Connection with Our Services: We may request or obtain Data from you to provide legal or other services to you, or to collect payment from you for our services.
Information Provided by Third Parties: We may collect Data about you from various third parties, such as third parties whom we use to provide services to you. From time to time, we may use third-party Data to supplement the Data of yours which we possess.
Children’s Online Data: The Website is not directed at children, and we do not solicit or knowingly collect any personal information from children under the age of thirteen (13) without verifiable parental consent. If we learn that we have obtained Data from a person under the age of thirteen (13), we will delete that Data.
For residents of the European Economic Union, please see our policy below concerning consent by children under the age of sixteen (16).
4. COOKIES AND OTHER AUTOMATED DATA COLLECTION
The Websites use a number of automated data collection methods that help improve your experience on the Website, and help us administer the Websites, analyze their usage, and improve the overall user experience. These methods of automatic collection may include:
Cookies: Cookies are small pieces of data sent to your browser from a web server and stored on your computer’s hard drive. Your web browser may include a function that permits you to refuse the setting of all or some cookies. If you do so, you may not be able to access all or parts of the Websites.
Flash Cookies: Certain features of the Websites may use local stored objects (or “Flash cookies”) to collect and store information. To learn how you can manage your Flash cookie settings, visit Adobe’s website.
Web Beacons: Pages of the Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics.
Google Analytics: The Websites, as well as third parties, may use Google Analytics cookies to collect aggregate information about how users visit the Websites. You can review Google Analytics’ data practices here, and many install a Google Analytics Opt-out Browser Add-on here.
Server Logs: We may track information about your visit to the Websites and store that information in web server logs.
Social Media Plugins: Some of the Websites may use social media plugins to aid social media sharing. These plugins do not track personal information about users. We do not control any of the content from the social media plugins and recommend that you review these third parties’ privacy policies. These plugins include:
5. DO NOT TRACK SIGNALS
Certain web browsers allow users to provide “do not track” signals to websites. The Websites do not respond to “do not track” signals.
6. USE OR PROCESSING OF DATA
We may use the Data that we collect for the following purposes:
7. SHARING OF DATA
We do not sell, rent, or lease your Data to others, with the following exceptions:
8. DATA PROTECTION
We maintain physical, technical, and administrative safeguards to protect your Data from unauthorized access, use, disclosure, alteration or destruction. We regularly update and test our data security technology, restrict access to your Data to our employees with the need access such Data in the course and scope of their employment. We also train employees concerning the privacy and security of your Data.
9. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California Civil Code section 1798.83 allows you to request information about our disclosure of your Data to third parties for those third parties’ direct marketing purposes. You can make such requests of us at the following contact information:
555 W. 5th Street, Suite 3110
Los Angeles, CA 90013
Telephone: (424) 273-5500
Within thirty (30) days of receiving an express written request, we will provide a list of the categories of Data disclosed to third parties for third-party direct marketing purposes during the immediately preceding year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted in ways other than those specified above.
If you are a resident of California and do not want us to disclose your Data to third parties for the third parties’ direct marketing purposes, please notify us of such using the contact information provided above, and clearly state your request, name, mailing address, email address, and phone number. Upon receipt of your express written request, we will remove your name from lists we share with other companies as soon as reasonably practicable.
Additionally, if you are a California resident under the age of eighteen (18), and have registered to use the Websites, California Business and Professions Code section 22581 permits you to request and obtain removal of content or information you have publicly posted. You can do so by contacting us at email@example.com. If you make such a request, please identify where the content or information is posted on the Websites so that we can attempt to remove the post from public view or anonymize the content or information such that you cannot be identified. This removal process cannot ensure complete removal, for example, if content or information remains visible because a third party has copied the posting or reposted the content or information posted by the minor.
10. OTHER PRIVACY RIGHTS
Connecticut Residents: To the extent that we collect Social Security numbers of Connecticut residents, we protect the confidentiality of those Social Security numbers, (2) prohibit unlawful disclosure of those Social Security numbers, and (3) limit access to those Social Security numbers.
Right to Opt Out: You have the right to opt out of receiving future marketing, promotional, or emails from us by following the instructions set forth in any such emails. Even if you opt out of such communications, we may nevertheless transmit non-promotional communications to you, such as communications concerning ongoing representations or business relationships. We may not accommodate a request to change information if it believes that the requested change would violate any law or legal requirement or cause the information to be incorrect.
Exercising Your Rights: You may exercise any of the foregoing rights by contacting us at the address and/or email address identified in the Policy above.
11. RESIDENTS OF THE EUROPEAN ECONOMIC UNION
Pursuant to the European Union’s General Data Protection Regulation (“GDPR”), we are the “Controller” with respect to your Data that we process. If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under applicable law regarding the processing of your Data, including:
Children’s Consent: If residents of the EEA under the age of sixteen (16) provide consent for us to process their Data, we will process that Data if and to the extent that consent is given or authorized by the holder of parental responsibility over the person under the age of sixteen (16).
Data Transfers: We may transfer your Data to countries which are not recognized by the European Commission as providing an adequate level of data protection. We transfer Data outside the EEA when it is necessary for the services that we provide to you, when you have consented to such a transfer, when it is necessary for Harris Bricken to establish, exercise, or defend legal claims, or based on a derogation specified in Article 49 of the GDPR.
Processors: Harris Bricken is the “Controller” with respect to your Data, meaning Harris Bricken determines the purposes and means of processing your Data. Harris Bricken may engage third parties to process Data, who will act as “Processors” with respect to your data. Harris Bricken may engage these processors to provide the following services:
Automatic Decision-Making or Profiling: Harris Bricken does not use automatic decision-making or profiling.
12. DATA RETENTION AND STORAGE
Your Data is stored on our servers, and on the servers of the cloud-based database management services we engage, which are located in the United States.
We retain your Data for the duration of your business or other relationship with us, and for a period thereafter to allow you to continue to your business relationship with us in the future, to analyze the data for our own operations, and for historical and archiving purposes.
13. CHANGES TO THE POLICY
We reserve the right to revise the Policy. The Effective Date of this Policy is set forth at the top of this webpage, and this Policy supersedes any and all prior versions. If we materially change the way we collect, use, or disclose your Data, we will notify you prior to said change by email and/or by inserting a prominent notice on the Websites.