EFFECTIVE DATE OF CURRENT POLICY: 9/9/2019
Information You Provide to Us
We may collect, store and process personal or other information that you supply to us through your use of the Site. For example, Anchin collects personally identifying information from our users through the Site’s “Contact Us” page (https://www.anchin.com/contact/), and from time to time there may be other pages where information may be sought which will seek similar information. Generally, this information includes:
- Identity Data, which includes first name, last name, username or similar identifier or title.
- Contact Data, which includes email address and telephone numbers.
- Profile Data, which includes your username and password, your interests, preferences and feedback.
- Usage Data, which includes information about how you use our Site, products and services.
- Marketing and Communications Data, which includes your preferences in receiving marketing from us and third parties, and your communication preferences.
Except as may occur during our hiring process, when criminal history or ethnic background may be disclosed, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, health, genetic and biometric data, or about criminal convictions and offenses).
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.
Information Collected Through Automatic Data Collection Technologies
We also collect and store information that is generated automatically as you navigate online through the Site. For example, we may collect Technical Data, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site. This information allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Site.
Information Collected Through Third parties or Publicly Available Sources
We or our service providers also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). If you would like to find out how you can opt-out of behavioral tracking on our Site, you can visit the Digital Advertising Alliance (“DAA”) opt-out program or the Network Advertising Initiative (“NAI”) opt-out program.
The information we collect automatically is statistical data and is not intended to identify you personally. It helps us to improve our Site and to deliver a better and more personalized experience, by enabling us to estimate our audience size and usage patterns, store information about your preferences and recognize you when you return to our Site.
How We Use and Disclose Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Site and its contents to you;
- To provide you with information, products, or services that you request from us;
- To market our products and services to visitors;
- To analyze data or metrics about our Site to send more targeted messages to visitors of our Site;
- To conduct research to improve our products and services and Site;
- To allow you to participate in interactive features on our Site;
- To respond to your inquiries and to deliver email messages like special offers, updates, newsletters, and service announcements; and
- To fulfill any other purpose for which you provide your information or for any other purpose with your consent.
- To our subsidiaries and affiliates;
- To contractors, service providers, and other third parties we use to support our business or who provide important services to us;
- To the extent that such disclosure is required by law, legal process, professional standards or to such an extent as we reasonably believe such disclosure is necessary to protect our legal interests;
- To fulfill the purpose for which you provide it; and
- For any other purpose disclosed by us when you provide the information.
We have created mechanisms to provide you with the following control over your information, in the event you do not wish your information to be used for any of the above described purposes, except that you cannot restrict us from providing your information to the extent disclosure is required by law, legal process or professional standards:
- Tracking Technologies: You can set your web browser to refuse all or some browser cookies or to alert you when cookies are being sent.
- Promotional Offers from the Anchin: If you do not wish to have your email address or contact information used by us to promote our own or third parties’ products or services, you can use the “unsubscribe” feature found in any marketing emails we send to you or send us an email stating your request to the email address listed in the Contact Information section below. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to us as a result of a product purchase, warranty registration, product service experience or other transactions.
We use a standard browser software feature called a “cookie” in order to enhance your experience with the Site. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Site, cookies help identify how many unique users visit us, track user trends and patterns, and may help deliver content of the Site in the best possible fashion, including customizing features and advertising that may appear on the Site. They also may prevent you from having to re-enter your preferences on certain areas of the Site where you may have entered preference information before.
- “Session” cookies remain in your browser during your browser session only, i.e. until you leave the website.
- “Persistent” cookies remain in your browser after the session (unless deleted by you).
- “Performance” cookies collect information about your use of the Site, such as webpages visited and any error messages; they do not collect personally identifiable information, and the information collected is aggregated such that it is anonymous. Performance cookies are used to improve how a website works.
- “Functionality” cookies allow the Site to remember any choices you make about the Site (such as changes to text size, customized pages) or enable services such as commenting on a blog.
Cookies may not expire unless you manually delete them or set your browser to reject them. If you do not accept cookies, you may have difficulty navigating the Site, or the performance may not be the same. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider’s website via your help screen, or visit http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers.
The Site also may use web beacons (single-pixel graphic files also known as “transparent GIFs”) to access cookies and to count users who visit the Site or open HTML-formatted email messages.
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
Location of Your Information
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.
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.
Your Privacy Rights
You have the right to access, transport, update, correct and delete your personal data, as well as the right to object to or restrict its processing, transform it into anonymous form, or opt-out of the “sale” of your personal information as defined under the California Consumer Privacy Act (CCPA). Minors (up to 16 years old) and their parents or guardians (for minors 13 and under) have the right to opt-in before their personal information may be “sold” under the CCPA. These rights may be exercised by emailing email@example.com. You also have a right to complain to your local data protection authorities if you believe your privacy rights related to your personal information have not been properly observed.
Additionally, California’s “Shine the Light” Law (CA Civil Code § 1798.83) allows California residents to request certain information regarding our disclosures, if any, of your personally identifiable information to third parties for their own direct marketing purposes in the prior calendar year. To make such a request, please email firstname.lastname@example.org with “Request for California Privacy” in the letter subject line. When contacting us regarding your rights, you must include sufficient detail for us to locate your file; at a minimum, your name, email and postal address.
We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that the California Shine the Light law does not cover all information sharing, and our disclosure may only include information covered by the law.
© 2019 Anchin, Block & Anchin LLP