Harris Beach PLLC Privacy Shield Privacy Policy 

June 27, 2018

 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 Website’s “Contact” feature. 

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 personal information received by the Firm from the EU or Switzerland whether in electronic or paper format, including information collected on our Website at www.harrisbeach.com

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. 

By using our Website, 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. 

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. 

Onward Transfers 

We will not share your personal information with other companies so that they can market their products or services to you. 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 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. 

Tracking Technologies 

Harris Beach PLLC and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. 

Behavioral Advertising 

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 privacy@harrisbeach.com. 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 

Our Website includes Social Media Features, such as the Facebook and Twitter button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it. 

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 privacy@harrisbeach.com with change requests. We will respond to requests for access within 30 days. 

Enforcement 

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

Amendments 

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 prior to the change becoming effective 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 Website’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