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Privacy Policy

Last updated: December 3, 2020

 

Thanks for visiting CGL! CGL, LLP (“CGL,” “we,” “us,” and/or “our”) is a full-service virtual law firm. This Privacy Policy describes how CGL handles personal information we collect from and about you when you use this website (the “Site”); engage with us through our newsletters, emails, and branded social media accounts; or otherwise interact with us. It also describes how we handle personal information we obtain in the course of managing our business and providing legal services to our clients (collectively, the “Services”).

For purposes of this Privacy Policy, “Personal Information” means information about an identified or identifiable individual, such as their name or email address and includes “personal data” as defined by the European Union’s General Data Protection Regulation (“GDPR”) and “personal information” as defined by the California Consumer Privacy Act (“CCPA”). Some information that is automatically disclosed to us or collected by us through your use of our Services meets this definition.

By using CGL’s Services, you confirm you have agreed to our Terms of Use and have read and understood this Privacy Policy.

Please be aware that if you have entered into an attorney-client relationship with CGL, the terms of additional agreements between you and CGL may apply and will govern in the event of a conflict with this Privacy Policy.

Information We Collect

Information You Voluntarily Provide to Us

We collect some information directly from you in the following ways:

Information We Collect Automatically

We also collect certain information about you automatically as you navigate our Site or interact with our emails. The type of information we collect automatically includes the following:

Information We Collect from Other Sources

We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.

How We Use Your Information

CGL collects the data described above so that we can:

How We Share Your Information

We may share information about you with certain third parties in the following circumstances:

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you, for various purposes including compliance with various reporting obligations; for business or marketing purposes; or to assist third parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through our Services.

 

Our Legal Bases for Handling Your Personal Data

Data protection laws in certain jurisdictions require businesses to tell you about the legal grounds they rely on to use or disclose your Personal Information. To the extent those laws apply, our legal grounds are as follows:

In most cases, under the GDPR and similar data protection laws, CGL is considered the “data controller” of the Personal Information that we handle under this Privacy Policy, though we may handle certain Personal Information as a “processor” for clients. Where we act as a processor of Personal Information on behalf of a client, we process the Personal Information pursuant to our contract with the client and our legal and ethical obligations.

Your Rights and Choices

Depending on applicable law, you may have certain rights and choices with respect to your Personal Information. Those rights may be limited by local law requirements. You may exercise these rights by contacting us as specified below:

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may also request you provide us with additional information to confirm your identity before responding to your request. You have the right to lodge a complaint with the authorities applicable to your situation, though we invite you to contact us with any concern, as we would be happy to try to resolve it directly.

California Privacy Rights: If you are a resident of California, California law requires us to disclose the following information with respect to our collection, use, and disclosure of your Personal Information.

Notice of Collection. Although the information we collect is described in greater detail in the “Information We Collect” section above, the categories of Personal Information that we have collected – as described by the CCPA – including in the past 12 months are:

Identifiers, such as name, email address, mailing address, and IP address. We collect this information directly from you, from third-party sources, or indirectly through your actions on our Site or from your devices.

Other individual customer records, such as phone number, billing address, signature, education, employment, bank account and payment card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code § 1798.80(e)), and overlaps with other categories listed here. We collect this information directly from you, from third-party sources, or indirectly through your actions on our Site or from your devices.

Commercial information, such as invoicing information and engagement with our Service. We collect this information directly from you.

Demographic information, such as age and gender. We collect this information directly from you, typically in the context of providing legal services.

Biometric information, such as voice recordings. We collect this information directly from you.

Internet activity, such as referring and exiting pages and your interactions with our Service. We collect this information directly from your device.

Geolocation data, such as your precise physical location. We collect this information directly from you or from your device.

Financial Information, such as payment information or financial account numbers in order to provide you with services. We collect this information directly from you.

Employment information, such as company name and job title. We collect this information directly from you or from third-party sources.

Sensory information, such as photos or voice recordings. We collect this information directly from you or from third-party sources.

Inferences, such as information about your interests and preferences. We collect this information directly from you or indirectly from your activity on our Site or from your device.

Business or Commercial Purpose for Collecting and Using Personal Information. We collect each category of Personal Information listed above for the business or commercial purposes described in the “How We Use Your Information” section above.

Categories of Sources of Personal Information. We collect each category of Personal Information listed above directly from you, through automatic data collection means, or through the third-party sources described in the “Information We Collect” section above.

Categories of Personal Information Disclosed. In the preceding 12 months, we have disclosed the categories of Personal Information listed above in the circumstances described in the “How We Share Your Information” section above.

Categories of Third Parties With Whom We Share Personal Information. We may share each category of Personal Information listed above with the third parties described in the “How We Share Your Information” section above.

Right to Know. California residents may request disclosure of the specific pieces and/or categories of Personal Information that we have collected about them, the categories of sources for that Personal Information, the business or commercial purposes for collecting the information, the categories of Personal Information that we have disclosed, and the categories of third parties with which the information was shared. To request this information please contact us at privacy@cgl-llp.com

Right to Opt-Out. CGL does not sell Personal Information to third parties for monetary value. However, the term “sale” is defined broadly in the CCPA. To the extent that “sale” under the CCPA is interpreted to include any of the data uses described in the “How We Use Your Information” section above, California residents are entitled to opt-out of the “sale” of data at any time.

Deletion. You may request that we delete the Personal Information we have collected about you (subject to certain exceptions). Please be aware that we may keep certain information as required or permitted by applicable law. To exercise this right, please contact us at privacy@cgl-llp.com or using our contact information below.

Authorized Agent. You may designate an authorized agent to make a request on your behalf. To do so, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification. To verify the request, we may contact you directly.

Right to Non-Discrimination. Limiting use of, or deleting, your Personal Information may affect features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services.

Shine the Light. California Civil Code § 1798.83, also known as the “Shine The Light” law, permits California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below

Children’s Privacy

Our Services are intended for adults and we do not knowingly collect Personal Information from children. If you are a parent or legal guardian and think your child under the age of 13 (or a higher age threshold where applicable) has given us Personal Information without your consent, please contact us at privacy@cgl-llp.com.

Data Transfers

CGL is a virtual law firm with a remote network of attorneys who provide their services from all over the world, including the United States, Canada, and Europe. Personal Information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States where we are based or in any country where we have operations, provide legal services, or engage vendors or service providers. These countries may have different data protection and government surveillance laws than your country. By using our Services and submitting your Personal Information to us, you agree to such transfers.

We are commited to protecting the privacy and confidentiality of personal information when it is transferred. If you reside or are located in the European Economic Area (“EEA”) and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law.

You may contact us at privacy@cgl-llp.com to obtain a copy of the relevant mechanism we use to transfer Personal Information outside the European Economic Area.

Links to Other Websites and Third-Party Content

We may provide links to third-party websites, services, and applications that are not operated or controlled by CGL. This Privacy Policy does not apply to the privacy practices of those third parties. The fact that we link to a website, service, or application is not an endorsement, authorization, or representation of our affiliation with that third party. We encourage you to review the privacy policies of any third-party service before providing any information to or through them.

Data Retention

We only keep your Personal Information for so long as reasonably necessary for the purposes described in this Privacy Policy, as required by law, or as necessary to resolve disputes and enforce our rights and agreements. We may, however, retain data in copies made for backup or business continuity purposes for additional time. To dispose of personal data, we may anonymize it, delete it, or take other appropriate steps.

Security

CGL uses generally accepted administrative and technical safeguards we believe are appropriate to protect the confidentiality, integrity, and availability of your Personal Information. Although we make reasonable efforts to protect Personal Information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk in any system for transmitting and storing information electronically. CGL cannot and does not guarantee absolute security. If you believe your Personal Information has been compromised through your use of our Services, please contact us immediately at privacy@cgl-llp.com.

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time to reflect changes in our practices or in the law. If we make changes to this policy, we will post the updated Privacy Policy on our Site and indicate when it was last revised. You are advised to review this policy periodically to stay informed of our practices.

If we make material changes, we may provide you with additional notice, such as posting a statement on our homepage or sending you an email notification, if we have your email address on file. Your continued use of the Services after the revised Privacy Policy has become effective indicates that you have read, understood, and agreed to the current version of this Privacy Policy, to the extent permitted by law.

Contacting CGL

If you have any questions about our Privacy Policy or how we protect your Personal Information, please contact us at privacy@cgl-llp.com or you may write us at 1035 Fountain Drive, West Sacramento, CA 95605.

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