June 27, 2018
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 Website’s “Contact” feature.
As attorneys licensed and practicing in various states, prior to and in addition to adhering to the Privacy Shield, 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.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Harris Beach PLLC participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov]
Harris Beach PLLC is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Harris Beach PLLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Harris Beach PLLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
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 Website. 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 Website. 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.
We may, in limited circumstances, share personal information with government authorities or others as required by law, such as to comply with a subpoena, or similar legal properties, to protect the interests of the Firm, as necessary in connection with business transactions or as required by applicable law or court order, or to meet national security or law enforcement requirements. If the Firm is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Sharing with Service Providers
We may share your information with third parties who provide cloud computing infrastructure services and send marketing communications on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us.
Use of Information Collected
The Firm uses the information collected via our Website’s “Contact” feature to respond to inquiries by users. Users may not opt-out from receiving these responses as they are not promotional emails.
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.
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 email@example.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.
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.
As is true of most Websites, 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 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 partner with a third party to display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide advertising to you based upon your browsing activities and interests. If you wish not to have this information used for the purpose of displaying interest-based ads to you, you may opt-out by clicking http://preferences-mgr.truste.com/or if located in the European Union click www.youronlinechoices.eu/. Please note this does not opt you out of being served all ads. You will continue to receive generic ads.
Links to Third Party Sites
Our Website 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.
Blog / Forum
Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Social Media Widgets
Changes to Information
Upon request The Firm will provide you with information about whether we hold any of your personal 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 email@example.com with change requests. We will respond to requests for access within 30 days.
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 Website’s “Contact” feature. You may also follow the unsubscribe instructions included in each newsletter.
Harris Beach PLLC
Attn: Chief Operating Officer
99 Garnsey Rd
Pittsford NY 14534