WEBSITE PRIVACY POLICY

EFFECTIVE DATE: July 26, 2020

  • INTRODUCTION
    • PURPOSE OF POLICY.  HERRANENLAW (“us,” “we,” or “Company”) is committed to respecting the privacy rights of its clients, visitors, and other users of the Company Website (the “Site”). We created this Website Privacy Policy (this “Policy”) to give you confidence as you visit and use the Site, and to demonstrate our commitment to fair information practices and the protection of privacy. This Policy is only applicable to the Site and any offline location where we make this Policy available to you, and not to any other websites that you may be able to access from the Site, each of which may have data collection and use practices and policies that differ materially from this Policy.
    • NOTICE CONCERNING CHILDREN    PLEASE NOTE: We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a Site user is under age 13, we will promptly delete any personal information in that user’s account.
  • INFORMATION COLLECTION PRACTICES   In operating the Site, Company may include online forms that ask users to provide their names, e-mail addresses, and other contact information, as well as the following categories of personal information about Site visitors, clients, prospective clients, suppliers and other third parties:
    • Basic data: Name, gender, title, organization, job responsibilities, phone number, mailing address, email address, contact details and information about family life.
    • Specific data: Information necessary for a specific service we are providing to you, such as religious or other beliefs, racial or ethnic origin, sexual orientation, health data and details of trade union membership.
    • Client service data: Personal information received from clients in respect of employees, customers or other individuals known to clients, invoicing details and payment history, and client feedback.
    • Marketing data: Data about individual participation in conferences, credentials, associations, product interests, and preferences.
    • Transactiondata:Personal data contained in documents, correspondence or other materials provided by or relating to transactions conducted by our clients.
    • Compliance data: Government identifiers, passports or other identification documents, dates of birth, beneficial ownership data, and due diligence data.
    • Device data: Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Sites (Usage Data).  
    • We collect personal information from a number of sources, either directly from the data subjects, or from clients, colleagues and publicly available sources. Where the Company receives data from its clients about employees, customers or other individuals, the client is responsible for ensuring that any such data is transferred to us in compliance with applicable data protection laws.
  • USE OF PERSONAL INFORMATION.  The purposes for which we use personal information, and the legal bases for such processing, are as follows:
    • provide legal advice and respond to inquiries we use basic data, registration data, client service data, and device data. We need to process your information in this way in order to perform our obligations under our contracts with our clients.
    • To manage our business operations and administer our client relationships we use basic data, special categories of data, registration data, marketing data and client service data. This processing is necessary in order to perform our obligations under our contracts with our clients (e.g. issuing and processing invoices) and suppliers (e.g. managing the supply of goods and services to the Company).
    • To make our Sites more intuitive and easy to use we use device data. It is necessary for our legitimate interests to monitor how our Sites are used to help us improve the layout and information available on our Sites and provide a better service to our Site users.
    • protect the security and effective functioning of our Sites and information technology systems we use basic data, registration data, transaction data, and device data. It is necessary for our legitimate interests to monitor how our Sites are used to detect and prevent fraud, other crimes and the misuse of our Sites.This helps us to ensure that you can safely use our Sites.
    • To provide relevant marketing such as providing you with information about events or services that may be of interest to you including legal services, legal updates, client conferences or networking events, and groups of specific interest (e.g. specific types of networking groups) we use marketing data, basic data, special categories of data, registration data, client service data, and device data. It is necessary for our legitimate interests to process this information in order to provide you with tailored and relevant marketing, updates and invitations.
    • To address compliance and legal obligations, such as complying with the Company's tax reporting obligations,checking the identity of new clients and to prevent money laundering and/or fraud we use compliance data, basic data, registration data, transaction data, and device data.This processing is necessary for the purposes of complying with legal requirements to which we are subject.
  • SHARING OF PERSONAL INFORMATION.   We may share personal information with the following categories of recipients:
    • Suppliers and service providers: We share personal information with suppliers and service providers to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified above. These include: third party law firms and legal service providers, government agencies and other such parties that have require the information for purposes of providing services to you.
    • Financial institutions: We share personal information with financial institutions in connection with invoicing and payments.
    • Corporate purchasers: We may share personal information with any purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of Company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which personal information would be transferred as an asset of the Company.
    • Mandatory disclosures and legal claims: We share personal information in order tocomply with the Company's tax reporting obligations,comply with any subpoena, court order or other legal process, to comply with a request from our regulators, governmental request or any other legally enforceable demand. We also share personal information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
  • CONTROL OF PERSONAL INFORMATION.   You have control regarding our use of personal information for marketing.  You may choose not to receive marketing communications at any time.  If you no longer wish to receive any marketing communications, remain on a mailing list, or receive any other marketing communication, please use the “unsubscribe” link in the communication or notify us by email or by using the contact form.
  • USE OF COOKIES.   We may use cookies to deliver content specific to your interests, to save your password so you don’t have to re-enter it each time you visit our site, or for other purposes. Promotions or advertisements displayed on our site may contain cookies. We do not have access to or control over information collected by outside advertisers on our site.
  • DATA SUBJECT RIGHTS   If you are in the European Economic Area (EEA) you have the following rights:
    • Access. Subject to certain exceptions , you have the right to request a copy of the Personal Data we are processing about you, which we will provide to you in electronic form. At our discretion we may require you to prove your identity before providing the requested information. If you require multiple copies of your Personal Data, we may charge a reasonable administration fee.
    • Rectification. You have the right to require that any incomplete or inaccurate Personal Data that we process about you is amended.
    • Deletion. You have the right to request that we delete Personal Data that we process about you, unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
    • Restriction. You have the right to request that we restrict our processing of your Personal Data where:
    • you believe such data to be inaccurate;
    • our processing is unlawful; or
    • we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
    • Portability. You have the right to request that we transmit the Personal Data we hold in respect of you to another data controller, where this is:
    • personal information which you have provided to us; and
    • we are processing that data on the basis of your consent or in order to perform our obligations under contract to you (such as to provide legal services).
    • Objection. Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
    • Withdrawing Consent. If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge This includes cases where you wish to opt out from marketing messages that you receive from us.
    • If you are in the EEA you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.
    • See National Data Protections Authorities at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 for more information.
  • DATA SECURITY.  We have implemented organizational measures in an effort to safeguard the personal information in our custody and control.  We restrict access to personal information to staff and service providers on a nee-to-know basis.  While we endeavor to always protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.
  • DATA TRANSFERS ACROSS BORDERS.   We transfer Personal Data to jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. In particular, our Sites are hosted on servers in the United States. If you are located in a non-US jurisdiction, the transfer of Personal Data is necessary to provide you with the requested information and/or to perform any requested transaction. When you submit personal information to us you are transferring your data across borders.
  • FOR RESIDENTS OF CALIFORNIA.  The California Consumer Privacy Act (“CCPA”) provides additional rights to residents of California regarding our information collection and use practices.
    • CATEGORIES OF PERSONAL INFORMATION COLLECTED.  We identify below the categories of personal information that we have collected about our users in the last 12 months, using the categories provided in the CCPA.
      • Identifiers
      • Customer Records Information
      • Characteristics of protected classifications under California or federal law
      • Commercial Information
      • Biometric Information
      • Internet or Other Electronic Network Activity Information
      • Geolocation Data
      • Audio, Visual, Electronic, Thermal, Olfactory, or Similar Information
      • Professional or Employment-related Information
      • Educational Information
      • Inferences
      • For more detail on the information we collect, including the sources we receive information from, please refer to our Information Collection Practices above. We collect and use these categories of personal information for the business purposes described in the Information Collection Practices section above.
    • RIGHTS OF CALIFORNIA RESIDENTS
      • Right to Know.   You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:
        • The categories of personal information we have collected about you;
        • The categories of sources from which the personal information was collected;
        • The categories of personal information about you we disclosed for a business purpose or sold;
        • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
        • The business or commercial purpose for collecting or selling the personal information; and
        • The specific pieces of personal information we have collected about you.
        • To exercise the Right to Know, please submit a request through our Online Form or contact us at attorney@herranenlaw.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know.
      • Right to Delete.  You have the right to request that we delete the personal information we have collected from you in the last 12 months. To exercise the Right to Delete, please submit a request using the online form We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request to delete. If we deny your request, we will explain the reason why in our response.
      • Right to Opt-Out.  You have the right to tell us not to sell your information at any time. You may submit a request to opt-out by submitting your request using the online contact form.   If you are a California resident and we know you are under 16 years of age, we will not sell your personal information unless (i) you are 13 years of age or more and have provided opt-in consent and confirmed that choice, or (ii) you are under 13 years of age and your parent or guardian has provided affirmative authorization of that sale. If you or your parent or guardian has provided opt-in consent, you can change your mind at any time by submitting your request using the online contact form
      • Right to Non-discrimination.  You have the right not to receive discriminatory treatment by us for exercising any of your rights.
      • Authorized Agent.  You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
      • Notice of Financial Incentives.  Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them.   We do not offer any financial incentives.
  • CONTACT INFORMATION AND POLICY UPDATES
    • CONTACTING US.  If you have any questions about this Policy, our practices related to this Site, or if you would like to have us remove your information from our database, please contact us at the following email address:  attorney@herranenlaw.com.
    • UPDATES AND CHANGES.  We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its terms.

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