Effective Date: July 23, 2020
About This Policy
This Policy describes the privacy practices of Anchin and its subsidiaries, divisions, and affiliates (collectively and/or individually, “Anchin”, “our”, or “we”). Except as otherwise provided, it applies to our interactions with our customers and visitors, including, but not limited to:
- Use of our websites, including this website (“Site”), mobile websites, and Client Portal
- Visits to our offices or attendance at one of our events
- Phone and email communications
- Social media interactions on our websites and other third party websites like Facebook, YouTube, Pinterest, Google+, Instagram and Twitter
- Viewing our online advertisements or emails
- Through our authorized service providers
Personal Information We Collect
As described below, Anchin may collect or has collected in the preceding 12 months the following categories of personal information (“PI” or “personal information”). We may add to the categories of personal information we collect personal information. In that case, we will inform you.
- Identifiers. Examples include real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
- Other elements. Examples include name, signature, characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number.
- Characteristics of protected classifications under California or federal law. Examples include race, religion, and age.
- Commercial information. This includes services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Education information. This includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
- Internet or other electronic network activity. Examples include browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation data. This might include location information while using our website.
- Audio, electronic, visual, thermal, olfactory, or similar information. Examples of this category including identifiable information obtained about you while speaking with our customer service representatives on the telephone.
- Professional or employment-related information.
- Consumer profile. This includes inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.
Purposes We Collect Your Personal Information.
Set forth below are the business or commercial purposes we have collected your PI. 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.
- To provide you with information or services that you request from us.
- To fulfill or meet the reason for which the information is provided. For example, if you purchase tax services from us, we will collect your address in connection with preparing your tax returns.
- To contact you and/or provide you with email alerts, event registrations and other notices concerning our services, or events or news, that may be of interest to you.
- To engage in marketing activities.
- To communicate with you in social media concerning our services.
- To carry out our obligations and enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
- To review, improve, and monitor our website, online services, and overall client experience, including to provide customization to meet the specific needs, ensure a consistent experience, and to assess trends, interests, and the demands of clients.
- To provide customer service and engage in quality control activities concerning our services.
- To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To process applications for employment, as well as to evaluate and improve our recruiting efforts.
- As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Sources of Personal Information
The categories of sources of PI are described below. The examples provided are for illustration purposes and are not exhaustive.
- You. Examples of when we collect that information include:
- During a website visit or completed form, or when you visit us at our office or at one of our events.
- If you upload or share a photo, submit a request, submit information, or post other digital content through one of our websites or via social media interactions on third party websites like Facebook or Twitter
- If you participate in a program, clinic or workshop
- If you request a quote or other information
- If you apply or inquire about employment.
- In connection with your interactions with us as a registered user of our websites
- We may use tracking tools like browser cookies, flash cookies, and web beacons.
- News outlets
- Social media and related services
Sharing Personal Information
Of the categories of PI noted above, during the past 12 months, we shared the following:
We do not sell your PI and do not have actual knowledge that we have sold personal information of minors under age 16.
Use of Your Personal Information on Our Site.
As is true of most websites, we gather some PI automatically and store it in log files. This information may include the Internet Protocol (IP) address, browser type, language, internet service provider (ISP), referring and exit page, operating system, and date/time stamp. In addition to the purposes above, we use this PI to understand and analyze trends, to administer the Site, to learn about user behavior on the Site, and to gather demographic information about our user base as a whole. To monitor use of the Site and improve its quality, we may compile statistical information concerning the use of the Site through analytics services, such as those provided by Google Analytics. Examples of this information may include: the number of visitors to the Site or to sections or pages within the Site, patterns of traffic flowing through the Site, length of time spent on the Site, or in sections or pages of the Site, the other sites that refer visitors to the Site, the pages of the Site that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Site. We also may use this PI in our marketing and advertising services.
Use of Google Analytics
We may also use Google Analytics Advertiser Features (or other similar services) to optimize our business. Advertiser features include:
- Remarketing with Google Analytics;
- Google Display Network Impression Reporting;
- DoubleClick Platform Integrations; and
- Google Analytics Demographics and Interest Reporting
By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Site.
Social Media Networks
This Site may use social media plugins (e.g. Facebook and LinkedIn) to enable you to easily share information with others. When you visit our Site, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Site. If you are logged into the social media website (e.g. Facebook, Twitter) while browsing our Site, the social plugins allow that social media website to share data about your activities on our Site with other users of their social media website. For example, Facebook Social Plugins allow Facebook to show your likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our website. We do not control any of the content form the social media plugins. For more information about social plugins from other media websites you should refer to those sites’ privacy and data/information sharing statements/policies.
IMPORTANT: By using the Site, you consent to the processing of any PI provided or collected for the analytics purposes and functions described above.
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.
Our Sites and Children
We do not knowingly collect or solicit PI from children under 13 years of age. We are concerned about the safety of children when they use the Internet and will never knowingly request PI from anyone under the age of 13. If the parent or guardian of a child under 13 believes that the child has provided us with any PI, the parent or guardian of that child should contact us and ask to have this PI deleted from our files. If we otherwise obtain knowledge that we have PI about a child under 13 in our files, we will delete that information from our existing files so that it is not in retrievable form.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed without proper authorization, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who require access to it in order to process your personal data pursuant to our instructions. However, we do not guarantee the adequacy or efficacy of the security measures taken by such agents, contractors or third parties who may be granted access to your personal data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Any electronic communication sent to us through the Site or via e-mail may not be secure, as transmissions over the Internet are not 100% secure at all times. Please also be aware that the sending of electronic mail to our professionals or through other contact information provided in the Site does not create a client relationship between you and Anchin, which can only be created by through an engagement letter or similar agreement. Accordingly, the contents of any such electronic mail are not confidential.
We reserve the right to retain your personal data for 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.
Email Marketing and Opt-Out
To the extent required by the United States’ Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (CAN-SPAM Act), or other similar domestic and international regulation, all of the commercial emails sent to you by us will include an unsubscribe link in them. You can remove yourself at any time from our mailing list by clicking on the unsubscribe link that can be found in every communication that we send you. Please note that changes to your email marketing preferences may not be effective immediately.
Notice to Site Users Located Outside the U.S.
Anchin 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.
If you have additional questions you may call us at (888) 523-2603 or reach us by email: [email protected]. You can write to us at: Anchin, Block & Anchin LLP, 3 Times Square, New York, NY 10036, Attn: Privacy.
For California Residents
The CA Policy describes Anchin’s policies and practices regarding the personal information we collect, use, and disclose about you, including personal information you submit or we obtain when you access the Site and other sources. This CA Policy is adopted in part to comply with the California Consumer Privacy Act (“CCPA”).
Any terms defined within the CCPA have the same meaning when utilized within this CA Policy. The other provisions of the Policy continue to apply except as modified in this CA Policy. Note, however, that personal information as used in this CA Policy does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Consumer Rights. Pursuant to the CCPA, and as detailed below, consumers have various rights with respect to their PI.
- Request to Delete. You have the right to request that we delete your PI from our records and direct any service providers to delete your PI from their records, subject to certain exceptions. Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers to delete your personal information from our records.
Anchin is not required to comply with your request to delete your PI if it is necessary for us (or its service provider) to maintain your PI in order to:
- Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between Anchin and you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when Anchin’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Anchin.
- Comply with a legal obligation.
- Otherwise use your PI, internally, in a lawful manner that is compatible with the context in which you provided the information.
Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
- Request to Know. You have the right to request that we disclose the following to you as it relates to the 12-month period preceding its receipt of your verifiable consumer request:
- The categories of PI we have collected about you.
- The categories of sources from which the PI was collected.
- The business or commercial purpose for collecting PI.
- The categories of PI we disclosed for a business purpose.
- The categories of third parties with whom we share PI.
- The specific pieces of PI we collected about you.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
In addition to the CCPA, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of Anchin to third parties for the third parties’ direct marketing purposes. Consumers who have provided their personal information to us may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such request must be submitted to us by calling (888) 523-2603 or reach us by email at [email protected]. Please mention in your call or email that you are making a “California Shine the Light” inquiry. Within 30 days of receiving such a request, we will provide a list of the categories of such personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
- Nondiscrimination. We will not discriminate against you in violation of the CCPA 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 any of the Consumer Rights requests as outlined above, please contact us at (888) 523-2603 or [email protected]. We reserve the right to only respond to verifiable consumer requests. 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 the 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. PI collected from an individual to determine whether a request is a verifiable consumer request may not be used or disclosed for any other purpose except as required by law. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.
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. 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.
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 CA Policy. When you submit a Request to Know or a Request to 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.