rev. March 1, 2022
- social media properties
- events, marketing and business development activities
- business communications and other online and offline business interactions
- legal and professional services
Collectively, we refer to the above as our “Services.”
2. Information we collect
We may collect information directly, as well as from third parties or automatically related to the use of our Sites and Services.
Information collected directly
We may collect personal information about you—such as your name, address, telephone number, fax number, e-mail address, etc.—directly from you. For example, personal information may be collected when you fill out a ‘Contact Us’ form, sign up for our mailing lists, register for events we host or sponsor, submit information as part of certain online services, post comments on our blogs, or otherwise provide us personal information through the Sites and Services. Generally, the information we collect includes your:
- Name, company name and title/position
- Email address, phone number, mailing address and contact details
- Contact preferences and interests
- Business affiliations
- For events, it may include dietary restrictions, requested accommodations and other event-related preferences
- Information provided in conjunction with our Services
- Other information related to your request or inquiry, or that you provide when you communicate, engage or otherwise interact with us or the Services
Information received from third parties
We may collect or receive information about individuals from service providers, and other third parties, such as our clients, representatives and professional advisers, content providers, government authorities, and public sources and records.
3. Use of personal information
We use the personal information we collect in order to respond to your request or inquiry and in the ordinary course of conducting our business. Generally, we use the personal information that we collect as follows:
- Providing support and services: To operate our Sites, provide our Services, communicate with you about your use of the Sites or Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.
- Responding to your requests: To respond to your inquiries, fulfill your orders and requests, and otherwise consider or process your request.
- Personalization: To tailor content we may send or display to you, including to offer location customization and personalized help and instructions on our Sites, and to otherwise personalize your experiences.
- Newsletters, mailing lists, and direct marketing: For direct marketing purposes, including sending you newsletters, client alerts, and information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them.
- Analytics and improvement: To better understand how users access and use our Sites and other Services, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations and to develop services and features.
- Comply with legal and ethical obligations: In order to respond to legal process (e.g., court orders, subpoenas or warrants) or regulator investigations and inquiries, or where otherwise required by law or our legal, regulatory or ethical obligations.
- General business operations: Where necessary, for the administration of our general business, accounting, recordkeeping, audit, compliance, and legal functions.
- Anonymous and de-identified information: We create and use anonymous and de-identified information to assess, improve and develop our business, products, and services, and for similar research and analytics purposes.
4. Disclosure of personal information
We will not rent or sell your personal information, nor will we share it with third parties, outside of Newman & Lickstein, for their own marketing purposes.
We may share personal information with the following categories of third parties:
- Third-party service providers that provide services to us or to whom we outsource certain services, such as data hosting or software or technology services
- Our professional advisers, such as lawyers and accountants
- Government and/or regulatory authorities
- Professional indemnity insurers
- Regulators, tax authorities and/or corporate registries
In addition, we may disclose personal information to other third parties under the following circumstances:
- Business transfers: As part of any actual or potential merger, sale and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law.
- Comply with law, legal process, and ethical obligations: To comply with the law and our ethical obligations or respond to legal process or regulator investigations and inquiries, or where otherwise required by law or our ethical obligations. For example, we may disclose information in response to subpoenas, court orders, and/or other lawful requests by regulators and/or law enforcement, including responding to national security or law enforcement disclosure requirements.
- Performance of legal services: To the extent required or necessary for our provision of legal services. For example, to our clients, with respect to the relevant legal services we provide to them, or to respond to other parties in legal matters for which we have been engaged as legal counsel.
- Protect and defend rights: Where we believe it necessary to respond to claims asserted against us, enforce or administer our agreements and terms, or for fraud prevention, risk assessment, and investigation, and to protect and defend the rights, property or safety of Newman & Lickstein, our clients and customers, or others.
We may also share aggregate or de-identified information with third parties for research, marketing, analytics, and other purposes, provided such information does not identify a particular individual.
5. Cookies and similar devices
- Cookies: Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
- Clear GIFs, pixel tags, and other technologies: Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our services to, among other things, track the activities of users of our services, help us manage content, and compile statistics about usage of our services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, to identify when our emails are viewed, and to track whether our emails are forwarded.
- Log files: Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.
6. Direct marketing
As noted, we may send periodic promotional emails to you, and where required by law, we will obtain your consent to do so. You may opt-out of such communications at any time by following the opt-out instructions contained in the email or email us at firstname.lastname@example.org. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.
7. International transfers
When you submit personal information to us, or when others provide personal information to us, we will receive it and process it in the United States, or where we have service providers. In order to provide services, we also may need to transfer your personal information to locations in other jurisdictions.
If you are based within European Economic Area (EEA), please note that where necessary to deliver the services, we will transfer personal information to countries outside the EEA.
You have a right to obtain details of the mechanism under which your personal information is transferred outside of the EEA; you may request such details by contacting us.
8. Access and correction
If you would like to review the personal information we have collected about you via the Site, or request that we update or delete it, please contact us at email@example.com.
9. Third-party websites and links
Our Site may contain links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as we have no control over information that is submitted to, or collected by, these third parties.
10. Co-sponsored events
11. Our commitment to security
We employ security measures to prevent unauthorized access to information that we collect online. However, we cannot guarantee the security of your personal information.
12. How to contact us
14. Additional Privacy Information for California Residents
If you are a California resident, you have certain data protection rights. Under the California Consumer Privacy Act of 2018 (CCPA) and California Civil Code § 1798.83, you have the right to exercise the following rights:
Disclosures of Personal Information We Collect
You have the right to know:
- The categories of personal information we have collected about you
- The categories of sources from which we have collected personal information
- Our business or commercial purpose for collecting or selling personal information
- The categories of third parties with whom we share personal information
- The specific pieces of personal information we have collected about you
Personal Data We Sell or Use for a Business Purpose
In connection with any personal information we may sell or disclose to a third party for business purposes, you have the right to know:
- The categories of personal information that we sold
- The categories of third parties to whom personal information was sold
- The categories of personal information that we disclosed for a business purpose
We do not sell (as is defined in the CCPA) the personal information we collect, and will not sell it without providing a right to opt-out.
Right to Deletion
Subject to certain exceptions set out below, upon receipt of a verifiable request from you, we will:
- Delete your personal information from our records; and
- Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
- Complete the transaction for which your personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 us and you
- Detect and protect against security incidents, fraudulent or illegal activity, or for prosecuting those responsible for such activity
- Debug, identify, or repair errors that impair existing functionality
- Exercise free speech
- Comply with the California Electronic Communications Privacy Act
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all applicable ethics and privacy laws
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
- Comply with an existing legal obligation
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information
Protection Against Discrimination
You have the right not to be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot:
- Deny goods or services to you
- Provide a different level or quality of services to you
Please note that we may charge a different price or rate to you if that difference is reasonably related to the value provided to us by your personal information.
California’s Shine the Light Law
In addition to CCPA, California Civil Code § 1798.83 permits users that are residents of California to request the following information regarding our disclosure of your personal information to third parties for those third parties’ direct marketing purposes: (i) a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year; and (iii) where the nature of the third parties’ business is not reasonably determinable, examples of the products or services marketed (if we have that information). If you are a California resident and would like to make such a request, please contact us.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Site does not respond to or support Do Not Track (DNT) signals. Do Not Track is a preference you can set in your web browser to inform websites you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
15. European General Date Privacy Regulation (GDPR)
If you are a resident of the European Union (EU), you have certain data protection rights under the European General Data Protection Regulation (GDPR).
Legal Basis for Processing Your Personal Information Under GDPR
To process your personal information, we must have a legal basis for doing so. We may process your personal information under the following conditions:
- Performance of a Contract: when your personal information is necessary for the performance of an agreement that we make with you and/or for any contractual obligations thereof
- Legal Obligation: when your personal information is necessary for compliance with a legal obligation to which Newman & Lickstein is subject
- Legitimate Interests: when processing your personal information is necessary for the purpose of the legitimate interests pursued by Newman & Lickstein
- Consent: you have given your consent for processing personal information for one or more specific purposes
- Vital Interests: when your personal information is processed in order to protect your vital interests or those of another natural person
- Public Interests: when your personal information is processed relating to a task that is carried out in the public interest or in the exercise of official authority vested in Newman & Lickstein
Your Data Protection Rights Under GDPR
In certain circumstances, you have the following data protection rights with respect to your personal information that we collect and process:
- The Right to Request Access: You have the right to access, update, or delete the information we have about you.
- The Right of Rectification: You have the right to have any incomplete or inaccurate information we hold about you corrected.
- The Right to Object: You have the right to object to our processing of your personal information.
- The Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information.
- The Right of Erasure: In certain circumstances, you have the right to ask us to remove or delete your personal information.
- The Right to be Forgotten: You have the right to request that we delete your personal information, in certain situations.
- The Right to Transfer: Upon request we will provide you (or a third-party you have chosen) the personal information we have collected about you. Your personal information will be provided in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the personal information to perform a contract with you.
- Withdraw Your Consent: You have the right to withdraw your consent at any time where Newman & Lickstein relied on your consent to process your personal information.
Exercising Your Rights Under GDPR
You may exercise any of the rights enumerated above by contacting us at firstname.lastname@example.org. Please note that we may ask you to verify your identity before responding to such requests.
You also have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, please contact your local data protection authority in the European Economic Area.
If a Data Processing Addendum (DPA) is required, that can be requested using the information below.
For more information about our privacy practices, you may contact us as set forth on the “Contact Us” page.