- the types of information this Firm collects from you when you visit and use CLF’s website maintained at www.clawfirmpc.com (hereinafter, the “Website”); and
- CLF’s practices and methods applied to the collection, use, storage, processing, disclosure and protection the information obtained from you.
- How CLF collects Personal Data;
- How CLF may create and Process Personal Data;
- The categories and types of Personal Data that CLF may Process;
- CLF’s policy regarding Sensitive Personal Data and its Processing;
- The Purposes and Legal Bases for CLF’s Processing of Personal Data;
- How and why CLF may disclose Personal Data to third parties;
- International transfer of Personal Data;
- CLF’s data security practices;
- How CLF ensures data accuracy and data minimization;
- Your legal rights with regards to Processing of Personal Data;
- CLF’s policies with respect to the following Internet technology: automatically collected information, cookies, interest-based advertising, analytics, as well as widgets and plug-ins;
- How and why CLF uses Personal Data for marketing purposes;
- Third-party websites;
- CLF’s policy regarding collection of Personal Data that pertains to minors; and
- information, which may be collected by CLF offline;
- information, which may be collected by CLF through any other means, including through any other websites operated by third parties; and
- information, which may be collected by any third parties, including third-party websites, applications, apps, content, or advertising that may potentially either (a) be accessible from CLF’s Website or (b) link to CLF’s Website. Any of these third-parties may have their own distinct policies and practices related to the collection, use, storage, processing, disclosure and protection of Personal Data. CLF bears no liability and/or responsibility for any deficiencies in the policies and practices of any such third-party websites, applications, apps, content, or advertising platforms.
c. Data Controller
CLF is the Data Controller in relation to your Personal Data.
d. Data Protection Officer
CLF is not required to appoint a Data Protection Officer, because:
- CLF is not a public authority;
CLF is not engaged in large scale systematic monitoring of anyone’s Personal Data; and
CLF is not engaged in large scale processing of sensitive Personal Data.
2. METHODS OF COLLECTION OF PERSONAL DATA
CLF may receive and collect your Personal Data from the following potential sources:
- Data provided by you directly to CLF – if you contact this Firm through the electronic “Contact” form submission on the Website, by telephone, facsimile (FAX), e-mail, other electronic messaging system, social media post or messaging platform, or by any other method
- Case Review – by reviewing your potential matter and deciding whether CLF can represent you
- Relationship and Representation – in the ordinary course of CLF’s relationship with you, including in the course of representing you
- Public data – if you choose to make your Personal Data public by posting it on any social media or business networking platform (Facebook, Twitter, Instagram, LinkedIn, etc.) or if you decide to share your Personal Data with mainstream public media (television, radio, printed media, etc.)
- Website data – through your visiting and potential use of the Website, and any resources of features available on the Website
- App data – information that can potentially be provided when you download or utilize any CLF’s App
- Information from third-parties – e.g. healthcare providers – e.g. doctors, hospitals, nursing homes, assisted living facilities; law enforcement agencies; fire departments; etc.
3. CREATION OF PERSONAL DATA
CLF may itself created Personal Data related to you. For example, CLF may compile records of your interactions and communications with CLF, including any forms your sign and your written communications with the Firm.
4. CATEGORIES AND TYPES OF PERSONAL DATA THAT CLF MAY PROCESS
CLF may Process the following types of Personal Data related to you (which includes information obtained by submission through this Firm’s electronic “Contact” form or the “Scholarship” application):
- Personal information: first name, middle name, last name, photographs, etc. [as well as given name and preferred name]
- Contact information: address, telephone number, e-mail address, details related to your online biographies, social media profile(s), or business networking profile(s), etc.
- Social media details: information pertaining to your profiles on social media platforms such as Facebook, Instagram, Twitter, etc.
- Demographic data: date of birth, age, nationality, gender, title, salutation, languages spoken and preferred, etc.
- Medical history: information related to medical history, treatment, procedures, hospitalizations, diagnoses, prognosis, etc.
- Identifying information: driver’s license number, passport or national identity number, bank statements, etc.
- Case details: any information related to your verbal or written descriptions of the case facts and details, any verbal or written evidence obtained during the investigation and discovery in your matter, and any other information obtained and processed during the scope of either reviewing your potential case or providing legal representation and services to you.
- Consents and Authorizations: records of any and all consents or authorizations you may provide to CLF for any purpose, including obtaining your medical, employment, and other records, sharing legal fees, etc. This includes information related to the date, time, subject matter, means and any other information pertaining to the consent or authorization.
- Details related to Payments: copies of checks, payment methods and records, billing addresses, bank account numbers, credit card numbers, accountholder or cardholder name, card or account security details, card expiration dates, invoices, payment records, BACS / SWIFT / IBAN details and specifics, amounts of payments, and dates of payments.
- Data related to CLF Website and potential Apps: usage data, type of device, operating system, IP address, type of browser and its settings, language settings, statistics related to the Website usage, statistics related to the usage of any potential CLF’s App(s), settings of any potential CLF’s App(s), information related to the dates and specific times when users connected to the Website or any potential CLF’s App(s), as well as other information related to technical communications such as usernames, passwords, security login details, clickstream data, internet service provider (ISP) specifics, and aggregate statistical / analytical information.
- Opinions: any opinions, views, and reviews, which you decide to send directly to CLF or make public in the form of posts on social media platforms and other websites.
- Academic data: where you apply for a scholarship and provide information related to your records of attendance, schools attended, grades, grade point average (GPA), test results, and other related information.
- Employment data: information related to your interactions with CLF in the capacity of an employee – e.g. name and contact information of your past or present employer(s), employment history, etc., to the extent that this data and information is relevant.
- Advertising and content information:
- records and information pertaining to your interactions with CLF’s online / internet content and advertising;
- records of content and/or advertising displayed on pages or App screens displayed and shown to you; as well as
- any interaction you may have had with any CLF’s advertising or content, including but not limited to, mouse hovers, mouse clicks, any forms completed by you (even if not submitted), and any and all touchscreen interactions.
5. SENSITIVE PERSONAL DATA
Sensitive Personal Data refers to information that pertains to the following:
- Sexual orientation and/or sexual life;
- Data, which is genetic or biometric in nature;
- Mental health;
- Physical health;
- National identification number;
- Political opinions and affiliations;
- Ethnic origin;
- Philosophical and/or religious beliefs;
- Memberships in trade union(s);
- Any alleged or actual criminal offenses or criminal penalties; and
- Any other information, which may potentially be deemed to be sensitive pursuant to applicable laws or regulations.
Sensitive Personal Data may need to be collected or otherwise Processed by CLF in the ordinary course of the Firm’s business. If, for any reason, it becomes necessary for CLF to process your Sensitive Personal Data, CLF relies on the following legal bases:
- Compliance with applicable law: CLF may Process your Sensitive Personal Data in situations where such Processing is required or permitted by applicable law.
- Prevention and detection of crime: CLF may Process your Sensitive Personal Data in situations where the prevention or detection of crime (including fraud) makes it necessary to Process Sensitive Personal Data.
- Establishment, exercise or defense of legal rights: CLF may Process your Sensitive Personal Data in situations where the establishment, exercise or defense of legal rights makes such Processing necessary.
- Examples of cases where Sensitive Personal Data may potentially be collected and Processed pursuant to this legal basis, include but are not limited to, legal cases involving the following: discrimination, medical and other professional malpractice, elder abuse and neglect, personal injuries, sexual assault, and other issues.
- Consent: CLF may Process your Sensitive Personal Data in situations where, prior to such Processing, CLF has obtained your prior and express consent pursuant to applicable law.
If you provide Sensitive Personal Data to CLF, it is your obligation to ensure that it is lawful and legal for you to disclose such Sensitive Personal Data to CLF. Your obligation includes making sure that at least one of the legal bases set forth above is available to CLF in relation to the Processing of your Sensitive Personal Data.
6. PURPOSES AND LEGAL BASES FOR PROCESSING OF PERSONAL DATA
CLF does not use Personal Data to make automated decisions.
a. Purposes for Processing Personal Data
CLF may Process Personal Data for the following purposes:
- CLF Business Operation and Service Provision: providing CLF’s Website and all aspects of CLF’s services (including legal advice and legal services); providing promotional items and information upon your request; and communicating with you with respect to CLF’s Website and services (including legal advice and legal services).
- Website: management and operation of CLF’s Website; displaying and showing advertising and other information to you; provision of content to you; communicating and interacting with you through CLF’s Website; communicating with you with respect to the Website; and notifications for you of any changes to CLF’s Website or services.
- Marketing and Communications: (1) communicating with you through any means (including telephone, e-mail, facsimile (FAX), text message, social media post, or in person communications); (2) providing you with marketing information, news, or any other information in which you may be interested, subject always to ensuring that such marketing efforts and information are provided to you pursuant to the applicable law; (3) taking steps to update and maintain your contact information, whenever it is appropriate; and (4) when required, taking steps to obtain your prior opt-in consent.
- IT operations and communications: operation, management, and monitoring of CLF’s IT security systems and IT security audits, as well as operation, management, and monitoring of CLF’s communication systems and communications.
- Financial management: management of all issues related to finance, corporate audits, sales, as well as vendor relations and management.
- Health and safety: provision of secure and safe environment at CLF’s premises, health and safety assessments and record keeping, as well as compliance with other related legal obligations.
- Surveys: engaging with you in order to obtain your views with respect to CLF’s services.
- Legal compliance: compliance with CLF’s regulatory and legal obligations pursuant to applicable law.
- Legal proceedings: exercising, establishing, and defending legal rights.
- Improvement of Website and Services: identifying issues with CLF’s Website or services; planning improvements to CLF’s Website or services; and creating new CLF’s Website, Apps, or services.
- Job applications and recruitment: advertising of positions at CLF; recruitment activities; interview activities; analysis of applicant suitability for the relevant position; maintenance of records and details related to hiring decisions, offers, and acceptances.
- Scholarship review and awards: reviewing and analyzing CLF scholarship applications; analysis of applicants’ merits for the scholarship award(s); maintenance of records and details related to scholarship decisions and awards.
- Investigations: Prevention, detection, and investigation of fraud, policy breaches, violations of law, and criminal offices, pursuant to applicable law.
- Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).
b. Legal Bases for Processing Personal Data
Depending on the circumstances, the legal bases for CLF’s processing of Personal Data may be as follows:
- Consent: In situations where CLF has obtained your prior and express consent to the Processing of Personal Data, CLF may Process your Personal Data.
- This legal basis is utilized only with respect to entirely and completely voluntary Processing – i.e. it is never used for Processing, which is obligatory or necessary in any manner.
- Contractual necessity: CLF may Process your Personal Data in situations where the Processing of Personal Data is deemed necessary in relation to any contractual agreement that you may enter into with CLF.
- For example, this legal basis applies retain CLF to represent you as legal counsel in a matter.
- Compliance with applicable law: CLF may Process your Personal Data in situations where applicable law requires such Processing.
- Vital interests: CLF may Process your Personal Data in situations where the need to protect any individual’s vital interests makes such Processing necessary.
- Legitimate interests: CLF may Process your Personal Data in situations where CLF has a legitimate interest in the Personal Data Processing. In every case where this legal basis is used, CLF performs the following balancing test:
- CLF ensures that that it has a legitimate business need to perform the Processing; and;
- CLF ensures that, as a result of the Processing of your Personal Data, there will be no material likelihood of any adverse impact on your fundamental rights, interests, or freedoms.
7. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
CLF will not, without your prior consent, disclose your Personal Data to unaffiliated third parties for the third parties’ direct marketing purposes.
Pursuant to applicable laws and subject to applicable regulatory, professional, and ethical requirements pertaining to confidentiality, CLF may disclose and reserves the right to disclose your Personal Data as follows:
- To you or, if appropriate, to your appointed representative;
- For legitimate business purposes, including but not limited to, reviewing your potential matter or providing legal services and representation to you;
- When CLF is required to disclosure Personal Data by law;
- In responding to a subpoena, a court order, or other valid process;
- When requested by legal and regulatory authorities, including law enforcement agencies or courts;
- For the purposes of reporting any suspected or actual violation of any applicable law or regulation, as well as for the purposes of investigation, prevention, detection or prosecution of any criminal offences or execution of criminal penalties. This includes disclosure for the purpose of safeguarding against and the prevention of threats to public security;
- To physicians, nurses, physical rehabilitation specialists, physical therapists, life care planners, economists, accountants, lawyers, and other outside CLF’s professional advisors, consultants, and experts, subject to obligations of confidentiality;
- To third-party Processors (e.g. document review service providers). If CLF does request the services of a third-party Processor with respect to your Personal Data, the Processor will be contractually obligated to: (1) Process the Personal Data only according to CLF’s prior written instructions; (2) use measures to ensure the protection of security, privacy, and confidentiality of the Personal Data; and (3) comply with any additional pertinent legal requirements;
- To respond to any claims that any content on the Website violates the rights of any third parties. This includes, without limitation, providing any information that is necessary to satisfy the notice and counter-notice procedures according to the Digital Millennium Copyright Act;
- Any relevant party, if CLF deems it appropriate and necessary to make the disclosure in order to prevent financial, physical, or other type of injury, harm, or loss; and
- To any relevant party, court, or law enforcement agency, to the extent necessary for the establishment, exercise or defense of legal rights.
8. INTERNATIONAL TRANSFER OF PERSONAL DATA
CLF operates this website from the United States and in accordance with the laws and regulations of the United States. CLF’s website is designed to be used primarily by the residents of the United States. The laws and regulations of the country where you reside may be different from the U.S. laws and regulations. If you reside or are located anywhere outside of the United States of America, including the European Union and the EEA, please be aware that your use of CLF’s Website is at your own risk.
By using or accessing CLF’s Website and providing CLF with any of your Personal Data or information, you understand and acknowledge that the laws and regulations of the United States may potentially apply a lower standard for Personal Data protection than the laws and regulations of other countries, including the European Union and the EEA. By using or accessing CLF’s Website and providing CLF with any of your Personal Data or information, you waive any and all claims that may potentially arise pursuant to the laws and regulations applicable to you in any non-U.S. jurisdiction, including the European Union and the EEA.
9. DATA SECURITY
This Firm takes reasonable steps to protect your Personal Data to the best of CLF’s and its third-party providers’ technological capabilities. Specifically, in accordance with applicable law, CLF has implemented appropriate organizational and technical security measures, which are designed and developed to protect your Personal Data from the following accidental, unlawful or unauthorized damage:
- loss; and
- other accidental, unlawful or unauthorized types of Processing of Personal Data.
Nevertheless, due to the fact that the Internet is an open system, the transmission of data and information through the Internet cannot be and is not completely secure. Despite best data protection efforts, no electronic storage, security system or means of transmitting data over the Internet can be guaranteed to be entirely secure. Potential data security threats include, but are not limited to, the following:
- hacker attacks;
- malicious software; and
- computer viruses.
Therefore, there is always a certain risk that CLF’s data security systems may potentially be circumvented by an unauthorized third party, or that the transmission of your Personal Data over the Internet will be somehow intercepted.
Although CLF will implement and utilize all reasonable measures to protect your Personal Data, CLF cannot and does not guarantee or warrant the security of your Personal Data transmitted to CLF over the Internet. Any transmission of your Personal Data to CLF via the Internet is at your own risk, and you are responsible for ensuring that any Personal Data that you send to CLF are sent in a secure manner.
10. DATA ACCURACY
CLF takes every reasonable step in order to ensure the following:
- that your Personal Data that are Processed by CLF – are accurate and, where necessary, kept up to date; and
- that if any of your Personal Data that are Processed by CLF are inaccurate (having regard to the purposes for which they are Processed) – then all such inaccurate Personal Data are erased or rectified without any delay.
CLF may periodically request that you confirm that your Personal Data are accurate.
11. DATA MINIMIZATION
12. DATA RETENTION
The determination of the duration of the period of time, during which CLF will keep your Personal Data is determined by the following criteria:
- Specifically, CLF may retain your Personal Data during the period of time, which is necessary in order to exercise, establish or defend any legal rights.
In addition, to the extent it is permissible by applicable law, CLF will retain your Personal Data for a period of time, which is necessary to fulfill or satisfy the following:
- an ongoing and identifiable business need (this includes record keeping and handling legal matters);
- a specific regulatory or legal requirement;
- for those purposes, for which the Personal Data was provided; and/or
- any requirement to retain those records, which may be relevant to any notified active legal proceedings or regulatory investigations.
13. YOUR LEGAL RIGHTS
Subject to applicable laws and regulations, you may have a number of rights with respect to CLF’s Processing of your relevant Personal Data. These rights include the following:
- The right to refuse providing Personal Data – the right not to provide your Personal Data to CLF
- Please note: if you refuse to provide CLF with your Personal Data, CLF may be unable to provide you with the full benefit of CLF’s Website, CLF’s services, and any potential Apps.
- The right to access – the right to request copies of, or access to, your Personal Data, along with information pertaining to the Processing, nature and disclosure of that Personal Data;
- The right to rectification – the right to request that any inaccuracies in your Personal Data be rectified;
- The right to erasure and restriction – the right to request [provided that there are legitimate grounds for it]:
- to have your Personal Data erased; or
- to have the Processing of your Personal Data restricted.
- The right to data portability – the right to have your certain Personal Data transferred to another Controller or directly to you. To the extent it is applicable, this right includes requesting that the transfer of Personal Data be provided in a commonly used, structured, and machine-readable format;
- The right to withdraw consent – in situations where CLF Processes your Personal Data on the basis of your consent, the right to withdraw that consent
- Please note: such withdrawal (1) does not affect the lawfulness of any Personal Data Processing performed by CLF prior to the date on which CLF receives notice of the withdrawal, and (2) does not prevent CLF’s Processing of your Personal Data in reliance on any other available legal bases; and
- The right to complain – the right to lodge complaints with a Data Protection Authority with respect to the Processing of your Personal Data by CLF or on behalf of CLF.
- Please note: if applicable, this right includes lodging complaints with the Data Protection Authority of the European Union (EU) Member State in which you reside, or in which you work, or in which the alleged data infringement occurred.
Subject to applicable law, you may also have additional rights with respect to the Processing of your Personal Data as follows:
- the right to object, on legitimate grounds related to your particular situation, to the Processing of your Relevant Personal Data by CLF or on behalf of CLF; and
- the right to object to the Processing of your Relevant Personal Data by CLF or on behalf of CLF for the purposes of direct marketing.
- before CLF can give effect to any of your rights, CLF may require proof of your identity; and
- in situations where your request requires that additional facts be established, before deciding what action to take, CLF will investigate your request reasonably promptly.
- For example, if your request involves a determination of whether or not any specific Processing of Personal Data is non-compliant with applicable law.
14. AUTOMATICALLY COLLECTED INFORMATION
Whenever you navigate through, interact with, and otherwise visit this Website, CLF and its service providers may utilize the following automatic data collection technologies to collect information about your visit and store that information:
- cookies (see Section 15 below);
- web server logs (files, which document the activities on the Website); and
- other automatic data collection technologies.
Examples of the information CLF may automatically collect include, but are not limited to, the following:
A. Information about your visits to the Website that includes:
- search terms;
- page requests;
- the referring page;
- traffic data;
- various communication data;
- the timing-related information regarding your visits to the Website (this information pertains to the duration as well as the specific date and time of each visit);
- the types of links that you click within the site;
- clickstream data;
- the types of searches and/or queries that you performed on the Website;
- the pages you viewed on the Website;
- the web page from which you arrived to the Website;
- the location from which you access the Website (this information may include the country, state, county, town or city, and other location information); and
- the content and resources that you access and use on the Website.
B. Information about your Internet connection, as well as your computer or other devices used to access the Website, which includes:
- the name of your Internet Service Provider (ISP);
- your unique Internet Protocol (IP) address;
- the operating system of your computer or device;
- the platform of your computer or device;
- the kind of computer you use;
- your browser type; and
- mobile identifiers:
- e.g. Android Advertising ID and
- e.g. Apple identifier for advertisers (IFDA).
C. Technologically-relevant statistical information that includes:
- information about traffic patterns;
- the number of visits to certain pages;
- the number of links you click within the Website;
- information pertaining to website visits such as:
- i. visits to the Website from other websites and/or
- ii. visits to third-party websites by using hyperlinks / links located on the Website;
- information regarding visitors’ use of the specific services provided by the Website;
- information pertaining to visitors’ interest in the specific services provided by the Website; and
- information pertaining to visitors’ interest in the features and information provided by the Website.
The information CLF automatically collects helps this Firm with the following:
- administration of the Website;
- analysis of the Website’s usage;
- protection of the Website’s content and the Website in general from use, which is unauthorized and inappropriate; and
- overall improvement of the user’s experience.
The automatically-collected information – does not include your Personal Data and other personal information. However, CLF may potentially maintain and associate the automatically-collected information with your Personal Data that you provide to CLF or that CLF potentially receives from third parties.
Similar to multiple other websites, the Website may utilize cookies in order to do the following:
- record information about your computer or mobile device;
- record information pertaining to your browser;
- obtain information with respect to your visits to the Website;
- analyze your patterns with respect to visits to the Website;
- facilitate functions related to social media platforms;
- personalize your specific experience when visiting and interacting with the Website;
- record data pertaining to your interests, preferences and browsing habits;
- provide mobile and online content and advertisements, which are tailored to your apparent preferences and interests (see Section 16 below); and
- perform advertising and website analytics (see Section 17 below).
The term “Cookies” refers to small text files. Whenever you visit a website, as long as the settings of your computer web browser or mobile device permit cookies, these files get stored on your computer or mobile device. In terms of their “lifespan”, cookies are divided into two types:
- Session cookies – these temporary cookies are stored only during you Internet browsing sessions. As soon as you close your brother, these cookies are deleted.
- Persistent cookies – these cookies are not automatically deleted whenever you close your browser. Instead, they are saved on your mobile device or computer for a certain fixed period of time. You have the ability to manually delete persistent cookies before this fixed time period expires. Every time you return to the Website, the server that originally set the persistent cookie – will “recognize” it on your mobile device or computer.
In terms of their intended purpose, the categories of cookies that may be used by CLF on the Website include, but are not limited to, the following:
- Functionality-related cookies – these cookies are necessary to:
- enable the Website to work, function and operate properly;
- enable you to navigate through the Website and use its features;
- personalize the content, which is presented to you;
- provide a better understanding of how visitors utilize the Website; and
- provide a better understanding of how CLF can improve at meeting your needs;
- Advertising cookies – the functions of these cookies are to:
- assist CLF with understanding and improving the way the Website performs;
- collect information pertaining to your use of the Website;
- collect information regarding your interaction with CLF’s advertisement and content;
- provide aggregated information with respect to various metrics (e.g. the most frequently visited pages on the Website);
- demonstrate how visitors reach the Website;
- provide information regarding the frequency of visits of various pages of the Website;
- show specific patterns with respect to the usage of the Website;
- provide CLF with the overall understanding as to whether or not the Firm’s advertising efforts are effective; and
- assist CLF in tracking and improving the Firm’s advertising campaigns.
- Analytics cookies – these cookies are used to:
- collect information with respect to your computer or mobile device, browser type, and IP address;
- collect information regarding your visit to the Website;
- collect information pertaining to the content you viewed and the links you followed when you visited and navigated the Website;
- allow CLF and its third-party vendors to provide you with advertisements;
- provide you with the content on the Website, which is tailored to serve your apparent preferences, needs, and interests;
- enable CLF’s service providers to provide you with advertisements when you are engaged in browsing other websites and mobile applications/platforms. Some of these advertisements are based on your history of activities and browsing patterns on various websites and mobile applications/platforms and your demonstrated apparent preferences, needs, and interests; and
- assist CLF in making efforts to make sure you do not see the same advertisement twice.
In addition, CLF may use social media cookies, which serve to demonstrate to various social media platforms whether or not their users are signed in to those platforms. CLF does not set or control these types of cookies. Social media platforms set and control such cookies themselves.
Initially, multiple web browsers may be set up to allow acceptance of cookies. If you prefer, however, you can have your browser set up to do the following:
(1) notify you when a cookie is received; or
(2) refuse to accept cookies.
In addition, you may delete cookies manually from your hard drive or mobile device. This can be done via your Internet browser or by using other programs / applications. If you want to learn more about managing browser cookies, you can visit this website: http://www.allaboutcookies.org. For information related to opting-out of advertising and analytics cookies, please see Sections 16 and 17 below.
Please note the following: If you disable cookies in your browser, you will still be able to visit, access, navigate, and use the Website. However, if cookies are disabled or cleared, it may negatively affect your user experience as follows:
- it may prevent you from being able to use certain features of the Website; and
- it may clear your pre-set cookie-based opt-outs or prevent you from using them. If this occurs, you may have to manually renew your cookie-based opt-outs by re-visiting all pertinent pages.
In addition, please note that, if cookies are managed, it will still not disable Non-cookie technologies that may be present on the Website. Such Non-cookie technologies may potentially be utilized on the Website in order to allow CLF and its third-party providers of service to perform tasks which include, but are not limited to, the following:
- provide CLF’s service providers with an ability to compile and analyze aggregated statistical data with respect to advertising campaigns;
- track customer response to CLF’s Website content and advertisements;
- enhance and improve the usability of the Website; and
- enable CLF to provide better interest-based advertising that CLF believes may suit your preferences and interests.
16. INTEREST-BASED ADVERTISING
CLF may potentially engage in interest-based advertising, which is provided by various vendors such as ad servers and advertising networks. This may be done in order to provide personalized content and advertisements, which CLF believes will be of interest to you.
After your visit to CLF’s Website, CLF may utilize Google AdWords remarketing service or other vendors in order to continue to show advertisements / ads to you throughout the Internet, on third-party websites, including the Google Display Network (formerly known as the “Google Content Network”), and on mobile applications / platforms. By using this service, CLF may show its advertisements to previous visitors of the Website who just browsed its content and have not performed any task on the Website (e.g. did not fill out the electronic “contact” form). Such advertisements may be provided to you based on your geographic location, your search activity, and the patterns of your online / Internet behavior – i.e. your visits to, interactions, and activities on CLF’s Website as well as third-party websites and mobile applications / platforms. This process is entitled “retargeting”, and its forms and formats include, but are not limited to, the following:
- advertisements on the Google Search Engine Results Page (SERP);
- advertisements on the Website; and
- advertisements on third-party websites and mobile applications / platforms.
- you visit the Website;
- you visit other third-party websites and mobile applications / platforms; and /or
- you view or interact with the advertisement(s) vendors place on various websites or on mobile applications / platforms.
Google and other third-party vendors utilize the above information in order to: (1) make certain predictions with respect to your preferences and interests and then (2) based on your apparent preferences and interests, show advertisements throughout the Internet, on third-party websites, including the Google Display Network, and on mobile applications / platforms. Remarketing with Google and other third-party vendors allows CLF to narrowly tailor CLF’s marketing efforts in order to suit your needs and display only those advertisements that are relevant and/or of interest to you. CLF may also utilize the DoubleClick cookie in relation to the Google AdWords remarketing service.
Some third-party advertising networks are included in the membership list at the Network Advertising Initiative (NAI). NAI is a non-profit organization, which is self-regulatory. Its goal is to promote responsible collection and use of data for the purposes of digital advertising. NAI provides a single location to opt-out of advertisement retargeting / remarketing from member companies. If you are interested in learning more information with respect to interest-based advertising and your options in terms of opting-out, please visit http://www.networkadvertising.org or http://aboutads.info (maintained by the Digital Advertising Alliance or “DAA”).
Please note: Even if you take steps to opt out of receiving advertisements that are based on your interests, you may still continue to see advertisements from various online advertising networks. After you opt out, however, the advertising networks will be unable to tailor their advertisements to your apparent preferences and interests; accordingly, the advertisements displayed to you may end up being much less relevant to your preferences and interests.
CLF engages service providers to provide CLF with analytics data pertaining to the use of the Website and this Firm’s advertising. In order to collect information about you when you (1) use the Website and/or (2) interact with CLF’s advertisements on third-party websites, these service providers may utilize cookies (see Section 15 above) alone or in conjunction with Non-cookie Technologies.
For instance, CLF utilizes Google Analytics in order to analyze, measure and report how Internet users interact with the Website and CLF’s advertisements for the following purposes:
- to better understand web usage;
- to optimize web usage;
- to measure conversion tracking;
- to optimize, enhance, and measure the effectiveness of CLF’s advertising and content campaigns and interest-based advertising; and
- for other market research and business purposes.
CLF does not combine the information collected via the use of Google Analytics with any of your Personal Data.
18. WIDGETS AND PLUG-INS
The Website may use widgets and plug-ins that include, but are not limited to, the following:
- buttons that allow you to share CLF’s Website content on Facebook, Twitter, LinkedIn, and other social media and business networking platforms;
- “link to” buttons to Youtube, Facebook, Instagram, Twitter, LinkedIn, and other social media and business networking platforms and CLF’s profiles on those platforms;
- the Facebook “like” button;
- the Instagram “follow” button;
- the Twitter “Follow Us” feature; and/or
- similar features and mechanisms from LinkedIn, Google+, Pinterest, and other social media and business networking platforms.
Such widgets and plug-ins are mini computer programs, which are interactive and which, if used by CLF, run on CLF’s Website in order to make another company’s services available to you. Such third-party widgets and plug-ins may potentially collect the following types of information about you:
- your IP address;
- the page(s) you visit on the Website; as well as
- some of your personal information (e.g. your e-mail address).
These widgets and plug-ins also may place cookies or other automatically tracking mechanisms on your browser or device in order to enable the widget or plug-in to function and operate properly.
Your interactions with such widgets and plug-ins are subject to the privacy policies of those third parties, which created them as well as the privacy policies of the companies whose services are being provided by these widgets and plug-ins (e.g. Facebook, Instagram, etc.) CLF encourages you to review the privacy policies of the applicable third party before using such widgets and plug-ins.
Throughout this Policy, the terms “plugin(s)” and “plug-in(s)” are used interchangeably.
19. DIRECT MARKETING
In order to provide you with information pertaining to the services, which might be of interest to you, CLF may Process your Personal Data in order to contact you via any of the following means:
- social media platforms;
- direct mail; and/or
- other formats and means of communication.
In compliance with and as permitted by applicable law, if CLF provides or provided services to you, CLF may use the contact information that you have provided to CLF in order to send the following to you:
- information pertaining to CLF’s services and/or
- other information, which may be of interest to you.
If you wish to unsubscribe from CLF’s promotional e-mail, you may do so at any time by doing the following: clicking on the “unsubscribe” link, which is included in every promotional e-mail sent by CLF.
After you unsubscribe, CLF will not send you any further promotional e-mails; however, CLF may continue to contact you to the extent it is necessary for the purposes of any services that you have requested to be performed by CLF on your behalf.
20. THIRD-PARTY WEBSITES AND THEIR PRIVACY POLICIES
CLF’s Website may contain links / hyperlinks to third-party websites. Third-party websites include any social media or business networking sites or platforms (Facebook, Twitter, Instagram, LinkedIn, etc.) on which CLF may have accounts or other websites, sites, platforms and pages where you may be able to post materials and information.
By clicking on these links / hyperlinks to third-party websites, you are visiting websites, which are outside of CLF’s control. With respect to any third-party websites, CLF is not responsible for the following:
- any content on third-party websites; and/or
- any Processing of any information and Personal Data by the operators of third-party websites, including but not limited to, collection, maintenance, use, disclosure or sharing of information and data.
CLF urges you: Before you submit any of your Personal Data or other information to any third-party websites, read the privacy policies, statements or notices of those third-party websites with respect to their data Processing practices. If you have any questions or concerns with respect to the privacy practices of third-party websites, you should contact the operators of those websites and request more information.
While CLF may perform services on behalf of individuals under the age of 18 (“minors”) through their parents or appropriate guardians, CLF collects information and Personal Data pertaining to minors only from their parents or guardians and with the consent of those parents or guardians.
This Website is not intended to be used by minors.
CLF does not knowingly collect any Personal Data directly from minors. If CLF is notified that CLF has received or collected Personal Data directly from a minor, CLF will take reasonable steps in order to delete that Personal Data pursuant to applicable laws.
- add to;
- update; and/ or
23. CONTACT DETAILS
Cherepinskiy Law Firm, PC
1875 Century Park East, Suite 600
Los Angeles, CA 90067
Telephone: +1 (800) 927-0216
Email: [email protected]
- “App” – means and refers to any application [for any iPhone, iPad, any iOS device, any android device, and any smart phone or tablet device] made available by CLF. This definition includes situations where CLF makes such applications available through third-party stores or marketplaces, or via any other means.
- “Controller” – means and refers to the entity that makes decisions with respect to how and why Personal Data are Processed.
- “Data Protection Authority” – means and refers to an independent public authority that, by law, is responsible for implementation, oversight, and enforcement of compliance with applicable data protection laws.
- “EEA” – means and refers to the European Economic Area (the Member States of the European Union, along with Iceland, Liechtenstein, and Norway).
- “Non-cookie Technologies” – means and refers to beacons, anonymous identifiers, scripts, pixel tags, as well as other similar technologies.
- “Personal Data” – means and refers to any information that is about any individual, or from which any individual is or can be directly or indirectly identifiable. Specifically, Personal Data refers:
- to identifying information such as a name, an identification number, an online identifier, location data or
- to one or more factors, which are specific to the physiological, physical, mental, genetic, economic, social or cultural identity of that individual.
- “Process”, “Processing” or “Processed” – means and refers to any activity, which is performed with any Personal Data, manually or by automated means. This definition includes activities such as recording, collection, structuring, organization, storage, alteration or adaptation, consultation, retrieval, utilization, use, combination or alignment, disclosure by transmission and other methods, dissemination or otherwise making available, as well as erasure, restriction or destruction.
- “Processor” – means and refers to any person or entity that Processes Personal Data on behalf of the Controller (other than Controller’s employees).