Last revised and effective as of: July 16, 2019
WHAT INFORMATION ABOUT ME IS COLLECTED?
We may collect two types of information: personally identifiable information and non-personally identifiable information.
Personally Identifiable Information.
Personally identifiable information is information that identifies you or can be used to identify or contact you. Such information may include your name, address, occupation, employer, title and position, areas of interest, e-mail address, and telephone number. Additionally, our Outside Contractor (as defined below) that is responsible for billing and payment processing services (the “Payment Services Provider”) may collect your billing and credit card information from you directly. Personally identifiable information amounts to ‘personal data’ for the purposes of and as defined in the GDPR. All references to personally identifiable information shall be deemed to include ‘personal data’ as defined and used in the GDPR (to the extent applicable).
Non-Personally Identifiable Information.
Non-personally identifiable information is information, any single item of which, by itself, cannot be used to identify or contact you, including demographic information (such as age, profession, gender, current location, zip code, birth date, or year of birth), browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, domain names, and statistical data involving the use of the Site. Certain non-personally identifiable information may be considered a part of your personally identifiable information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. However, the same pieces of information are considered non-personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example, your viewing preferences).
We will collect personally identifiable information that you submit to us. We may also receive personally identifiable information about you from third parties providing analytics services as part of your use of the Site.
In the Course of Using the Site.
You may provide personally identifiable information in order to take advantage of certain features of the Site. For example, if you wish to schedule a consultation with us, you may provide us with information (including personally identifiable information and non-personally identifiable information) such as name, e-mail address, telephone number, and a brief statement of your issue. In addition, we may obtain your personally identifiable information from you if you identify yourself to us by sending us an e-mail with questions or comments. Also, we will have access to any personally identifiable information that you choose to share through the Site.
Cookies and Action Tags.
We may collect non-personally identifiable information passively using “cookies” and “action tags.”
“Cookies” are small text files that can be placed on your computer or mobile device in order to identify your Web browser and the activities of your computer on the Site and other websites. Cookies can be used to personalize your experience on the Site (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Site (such as saving time by not having to reenter your name each time you use the Site), to allow us to statistically monitor how you are using the Site to help us improve our offerings or to determine the popularity of certain content.
You do not have to accept cookies to use the Site. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the “Help” section of the toolbar. However, if you reject cookies, certain features or resources of the Site may not work properly or at all, and you may experience some loss of convenience.
For the avoidance of doubt, the Site may use third-party service platforms (including to help analyze how users use the Site). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable “third-party” cookies, you may be able to turn them off by going to the third party’s website.
Here are links to the main third-party platforms we use:
“Action tags,” also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Site or e-mail sent on our behalf, may contain action tags.
By using cookies and action tags together, we are able to gain valuable information to improve the Site.
We also collect non-personally identifiable information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Site. This information may be used to analyze trends, to administer the Site, to monitor the use of the Site, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes such as personalizing your experience on the Site and evaluating the Site in general.
DOES PG COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?
We are committed to protecting the privacy of children. The Site is not designed for or directed to children under the age of 13. We do not collect personally identifiable information from any person we actually know is under the age of 13.
WHAT DOES PG DO WITH THE INFORMATION IT COLLECTS?
We will only use your personally identifiable information to the extent that the law allows us to do so. Pursuant to the GDPR, legal bases for our processing your personally identifiable information may include (without limitation):
(a) where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;
(b) where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Site or otherwise); and/or
(c) where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing the Site, or engaging in Networking Activities, and your interests or fundamental rights and freedoms do not override those legitimate interests.
We use the information collected to provide the Site to you, to engage in Networking Activities, to help us understand who uses the Site, for internal operations such as operating and improving the Site, and so that we can contact you about services that may be of interest to you.
We and third parties on our behalf may send you electronic newsletters and contact you about the Site, Networking Activities, services, information and news that may be of interest to you. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email to: email@example.com.
If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personally identifiable information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference.
We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Site. We may link some of this information to personally identifiable information for internal purposes or to improve your experience with the Site.
WHEN DOES PG DISCLOSE INFORMATION TO THIRD PARTIES?
Laws and Legal Rights.
We may disclose your information (including personally identifiable information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose personally identifiable information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, to meet contractual obligations, to protect our rights or our property, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Site or the general public.
Third Parties Generally.
We may provide to third parties non-personally identifiable information, including where such information is combined with similar information of other users of the Site. For example, we might inform third parties regarding the number of unique users who use the Site or the demographic breakdown of our users of the Site. In addition to the above, when users use our Site, third parties (including without limitation third-party analytics service providers) may directly collect information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect information may include providers of analytics services (including vendors and website tracking services), merchants, affiliates and other actual or potential commercial partners, sponsors, licensees and other similar parties. Please note in particular that the Site may use Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options.
Sale of Business.
We want your information (including personally identifiable information) to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with commercially reasonable standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.
Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.
COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?
Your personally identifiable information may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Site may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. By using the Site and submitting such information on it, or engaging in Networking Activities with us, you voluntarily consent to the trans-border transfer and hosting of such information. Without limitation of the foregoing, you hereby expressly grant consent to PG to:
(b) transfer such information throughout the world, including to the United States or other countries that do not ensure adequate protection for personally identifiable information (as determined by the European Commission); and
(c) disclose such information to comply with lawful requests by public authorities, including to meet national security or law enforcement requirements.
FOR HOW LONG WILL MY PERSONALLY IDENTIFIABLE INFORMATION BE KEPT?
We will only retain your personally identifiable information for as long as necessary to fulfill the purposes for which we collected it.
To determine the appropriate retention period for personally identifiable information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personally identifiable information and whether we can achieve those purposes through other means, and the applicable legal requirements.
WHAT CHOICES DO I HAVE REGARDING MY PERSONALLY IDENTIFIABLE INFORMATION?
Under certain circumstances and in compliance with the GDPR, you have the right to:
Request access to your personally identifiable information (commonly known as ‘subject access request’). This enables you to receive a copy of the personally identifiable information we hold about you and to check that we are lawfully processing it;
Request correction of the personally identifiable information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
Request erasure of your personally identifiable information. This enables you to ask us to delete or remove your personally identifiable information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your personally identifiable information in certain circumstances;
Object to processing of your personally identifiable information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;
Request the restriction of processing of your personally identifiable information. This enables you to ask us to suspend the processing of your personally identifiable information, for example, if you want us to establish its accuracy or the reason for processing it;
Request the transfer of your personally identifiable information to another party; and
Lodge a complaint with the relevant supervisory authority (as defined in the GDPR). If you have any complaints about the way we process your personally identifiable information, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.
If you want to review, verify, correct or request erasure of your personally identifiable information, object to the processing of your personally identifiable information, or request that we transfer a copy of your personally identifiable information to another party, please contact firstname.lastname@example.org.
You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personally identifiable information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all personally identifiable information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.
DO NOT TRACK
The term “Do Not Track” refers to an HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.
WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?
By postal mail or courier:
Attn: Firm Administrator
Parker Gallini LLP
460 Totten Pond Road, Suite 350
Waltham, Massachusetts 02451