Harris Beach PLLC Safe Harbor Privacy Policy

Last Updated November 8, 2011

General

Harris Beach PLLC (the “Firm”) provides legal services to clients in transactional, litigation and other matters where it is often necessary for the client to provide the Firm with information that is subject to the European Union Directive on Data Protection or subject to Swiss data protection law. In addition, the Firm collects information (e.g. name, email, and other contact information) directly from individuals who submit inquiries via our Web site’s “Contact” feature. This privacy policy is intended to comply with the framework of the Safe Harbor privacy principles contained in the above-referenced directive and the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce. The frameworks can be found at http://export.gov/safeharbor/. This privacy policy outlines the Firm’s privacy practices including the types of information we gather, how we use personal information we receive from you, to whom such information may be disclosed, and the notice and choice which affected individuals may have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by the Firm from the EU or Switzerland whether in electronic or paper format, including information collected on our Web site at www.harrisbeach.com. All information received from sources which are not subject to the EU’s Directive on Data Protection or Swiss data protection law is subject to use and disclosure in accordance with the Firm’s general privacy policy.

As attorneys licensed and practicing in various states, prior to and in addition to adhering to the Safe Harbor, the Firm complies with the applicable Rules of Professional Conduct for the states in which it practices. Information we receive from clients located in the United States is protected according to The Model Rules of Professional Conduct, and that information may be shared with courts and others as required by law, or as may be required during our legal representation of those clients.

The Information We Collect and How We Use It

Users do not need to provide personal information to make general use of the Firm’s Web site. Access to certain information may require users to provide certain personal information (such as name, e-mail address and/or other contact information). Such information may be used to monitor use of the website and may be used to assist in development and improvements to the design and layout of the Web site. We may also use the contact information supplied by visitors to send periodic Legal Alerts and other information which may be of interest. Users may opt-out of receiving future mailings in accordance with the opt-out provisions located elsewhere in this policy.

By using our Web site, users consent to the terms of this privacy policy and to the collection and use of the information by us. Privacy policies may be updated from time-to-time. Updated policies will be posted on this page as changes are made. The effective date of the most recent policy change is located at the top of this page.

The Firm does not have any service providers with whom it shares personal information. We may however, in limited circumstances, share personal information with government authorities or others as required to protect the interests of the Firm, as necessary in connection with business transactions or as required by applicable law or court order.

Use of Information Collected

The Firm uses the information collected via our Web site’s “Contact” feature to respond to inquiries by users. Users may not opt-out from receiving these responses as they are not promotional emails.

Onward Transfers

Prior to disclosing personal information to a third-party, the Firm shall notify the user of such disclosure and allow the user the choice (opt-out) of such disclosure except as described above in this privacy policy.

Data Security

The Firm shall take reasonable steps, including the placement of appropriate physical, technical, and administrative procedures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Firm cannot guarantee the security of personal information on or transmitted via the Internet.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. Thereafter, we may retain your information for a period of time, but reserve the right for various reasons including the minimization of unnecessary storage expenses, to destroy or otherwise dispose of your information once we have completed our services for you. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at privacy@harrisbeach.com. We will retain and use your information as necessary to comply with our legal and professional obligations, resolve disputes, and enforce our agreements. Our own files pertaining to the services we perform, including, for example, firm administrative records; internal lawyers' work product such as drafts, notes, internal memoranda; and legal and factual research, including investigative reports, prepared by or for the internal use of lawyers, may be retained by the firm.

Data Integrity

The Firm shall manage personal information only in a way that is compatible with and relevant to the purpose for which it was collected and authorized by the individual. To the extent necessary for those purposes, the Firm shall take reasonable steps to ensure that its management of personal information does not affect the content of information supplied.

Log Files

As is true of most Web sites, the Firm gathers certain information automatically, and stores it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. The Firm uses this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.

Cookies

A cookie is a small text file that is stored on a user’s computer. The Firm uses cookies on this site. We do not link the information we store in cookies to any personally identifiable information users submit while on our site. The Firm uses session ID cookies, to make it easier for users to navigate our site. A session ID cookie expires when the user closes their browser. Some of our business partners (e.g. tracking utility company) use cookies and Web beacons on our site. The Firm has no access to, or control over these third-party tracking utilities.

Web Beacons

Our third-party tracking utility company employs a software technology called Web beacons, which help the Firm to manage content on our site by informing us what content is effective. Web beacons are similar in function to cookies and are used to track the online movements of Web users. Our tracking utility company does not link the information gathered by Web beacons to our customers’ personally identifiable information.

Links to Third Party Sites

Our Web site may contain links to other sites. The Firm is not responsible for the privacy practices or the content of such sites. If users link to, or otherwise visit any other site we encourage users to review the privacy policies posted at that site.

Changes to Information

The Firm allows users to update, correct, amend or delete previously provided information. To correct, update, or delete inaccurate information please contact us at privacy@harrisbeach.com with change requests. We will respond to all requests for access within 30 days.

Enforcement

The Firm uses a self-assessment approach to assure compliance with this privacy policy.

The Firm has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and the practices at www.harrisbeach.com have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability, and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. TRUSTe's mission, as an independent third-party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions.

We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information. If a complaint or dispute cannot be resolved through our internal processes, we agree to dispute resolution using a third-party resolution provider, TRUSTe. You may raise your complaint with TRUSTe here, by fax at 415-520-3420, or by mail at Watchdog Complaints, TRUSTe, 55 2nd Street, 2nd Floor, San Francisco, CA, 94105 USA. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the Firm’s name, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the Firm.

Amendments

The Firm reserves the right to modify this privacy policy at any time consistent with the requirements of the U.S.-EU Safe Harbor Frameworkand the U.S.-Swiss Safe Harbor Framework. If the Firm decides to materially change its privacy policy, we will post those changes to this privacy policy and other places we deem appropriate so that users are aware of what information we collect, how we use it, and under what circumstances, if any, we may disclose it.

Questions about this Privacy Policy, Opting Out and Contacting Us

If you wish to discontinue or opt-out of the use of your personal information by the Firm, or to unsubscribe from any newsletter or other information, please contact us by e-mail at using our Web site’s “Contact” feature. You may also follow the unsubscribe instructions included in each newsletter.

Questions, comments, or complaints regarding this Privacy Policy or data collection and processing practices can be mailed or emailed to:

Harris Beach PLLC
Attn: Chief Operating Officer
99 Garnsey Rd
Pittsford NY 14534
privacy@harrisbeach.com