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:

 

  • Filling in forms on our website: When you fill in forms on our Site, including when you contact us to explore a potential legal relationship through our integrated chat provider, we may require that you provide us with certain information such as your name, email address and other contact information, company name, job title, and the name and affiliation of the person who referred you to us, if applicable.

 

  • Registering for an event or webinar: If you register for an event sponsored by our firm, we may collect Personal Information from you including your name, email address and other contact information, company name, job title, and any specific information relevant to the event for which you are registering.

 

  • Signing up to receive email communications from us, subscribing to our blog, or completing a survey: From time to time, we may offer newsletters, client alerts, legal blogs, surveys, and other informational materials that address legal, regulatory, and industry trends. When you sign up to receive any of these materials, we may collect your name, email address and other contact details, company name, job title, the practice areas and industries that you are interested in, and any additional information you choose to provide.

 

  • Contacting us: When you contact us by email; through our branded social media accounts; through our integrated chat providers; or by telephone, SMS, or physical mail, we may collect your name, username, email address and other contact information, company name, job title, and the contents of your communication, which can include any information you choose to provide.

 

  • Communicating with us about a legal matter: If you are client of our firm, we will collect your name; email address and other contact information; company name; job title; payment information; the name and affiliation of the person who referred you to us, if applicable; and any other information pertinent to the legal matter you have asked us to help you with. Because of the nature of our legal services, this could include any type of Personal Information. Common types of information we collect in the course of providing our legal services include information about our clients’ employees, customers, and vendors; communications with our clients; and information we obtain from third parties such as public bodies or opposing counsel.

 

  • Applying to work with us: If you apply to work with us, we will collect any information you chose to share in your application, which may include your name, email address and other contact information, employment history, and education history.

 

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:

 

  • Log information: We may collect log information about your use of our Site including your browser type and language, access times, pages viewed, Internet Protocol (“IP”) address, approximate geographic location, and the webpage or online service you visited before navigating to our Site.

 

  • Device information: We may collect information about the mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.

 

  • Information collected by cookies and similar technologies: We may use cookies and similar technologies to manage and track your interaction with our website. Cookies are small data files that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We use these technologies to better serve our users and to enhance this Site. For example, we may use cookies to tell us whether you have visited us before or if you are a new visitor. You can configure most browsers to notify you when you receive a new cookie, to reject new cookies, and to disable existing cookies. You can learn how to do this by consulting the help section of your browser. Please note that if you choose to stop accepting cookies you may not be able to use all features of our Site.

 

Analytics information: We also use third-party analytics tools to help us measure traffic and usage trends for our Site. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, and other information that assist us in improving our Site.

 

Information We Collect from Other Sources

 

  • Business partners and vendors: We may collect your Personal Information, including your name, contact details, and payment information from our business partners and vendors in the context of the partner or vendor relationship. For instance, when you pay for services, we may receive limited information about your payment card from our payment processors, such as the last four digits of your card, the country of issuance, and the expiration date.

 

  • Event partners: We may receive Personal Information about you from our event partners. For instance, if you register for an event or webinar which we sponsor, the organizer may provide us with your name and contact information in accordance with the disclosure they made to you so that we can communicate with you about future events and provide news and information we think will be of interest to you.

 

  • Another individual at your organization: We may collect your Personal Information from other individual at your organization who may provide us with your business contact information in the course of communicating with us about a legal matter.

 

  • Social media platforms: We may offer social sharing features and other integrated tools such as widgets, which allow you to share content on our Site with third-party social media platforms like Facebook, Twitter, or LinkedIn. If you choose to use these social sharing features, the provider of the third-party social media platform may make certain information available to us. This can include information necessary to facilitate the integration as well as any additional information the provider chooses to share with us or which you have permitted the provider to share through your privacy settings. We encourage you to check the privacy settings and privacy policies of these third-party social media platforms to understand what information might be shared with us.

 

  • Professional services organizations: We may collect Personal Information about you from professional services organizations such as PR firms and other law firms in the course of providing you with legal services and marketing our business.

 

  • Government entities and opposing counsel: If you are a client of our firm, we may receive Personal Information about you from government entities and opposing counsel in relation to the legal matter with which we are assisting you.

 

  • Other sources: We may also obtain Personal Information about you from other sources, including third parties that help us update, expand, and analyze our records and prevent and detect fraud. For example, we may use information from LinkedIn to update information about you in our contact database.

 

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:

 

  • Determine whether to enter into a business relationship with you;

 

  • Provide you with legal services if you are or become a client of CGL, including maintaining or servicing accounts, providing legal advice, processing payments, and verifying client information;

 

  • Send client alerts, newsletters, and other communications to our clients and business contacts. We will send you communications that are relevant to you, based for example on the practice areas and industries you select when you subscribe to receive our communications. We may also use your Personal Information to register you for and confirm your attendance at events; furnish biographical details to other attendees; and assess the effectiveness of our events, promotional campaigns, and publications;

 

  • Post testimonials, with your consent;

 

  • Operate and improve our Site, including monitoring and analyzing usage, trends, and activities related to the Site;

 

  • Respond to your requests, inquiries, comments, and suggestions;

 

  • Send you technical notices, updates, security alerts, and support and administrative messages;

 

  • Identify, fix, and troubleshoot bugs and service errors;

 

  • Enhance our communications and the experience we offer you, including requesting feedback about the Site and Services;

 

  • Improve our educational, networking, marketing, social, and recruiting strategies;

 

  • Support our general business operations (including assessing and communicating with job applicants, maintaining our business and legal recordkeeping, processing invoices, and managing our business relationships with clients, vendors, business partners, cooperating law firms, and other contractors);

 

  • Notify you about any changes to our Services;

 

  • Protect against, identify, investigate, and respond to misuse of our Services or other unlawful behavior; and

 

  • Carry out any other purpose described to you at the time the information was collected.

 

How We Share Your Information

 

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

 

  • Companies under common control: We may share Personal Information between and among CGL’s current and future parents, subsidiaries, affiliates, and other companies under common control and ownership.

 

  • Vendors and service providers: To conduct business operations and to deliver our legal services, we may engage vendors, consultants, and other service providers to work on our behalf. For instance, we may engage accountants, insurance companies, social media managers, and other professional experts and advisors to help us with our business operations. We may share Personal Information with these third parties, but only to the extent necessary to perform these functions and provide these services.

 

  • Business transfers: We may share your Personal Information with another company in connection with or during negotiations of any merger, acquisition, reorganization, bankruptcy, sale of all or a portion of our assets, or transition of services to another provider.

 

  • Legal requirements: We may share Personal Information when we believe it is necessary to comply with a legal obligation, to protect CGL’s rights and property, to protect the safety of our users, and to defend against legal liability.

 

  • Government agencies, regulators, or courts: We may share Personal Information as required by applicable law and/or in the context of legal proceedings.

 

  • Public: If you post information to our website or our branded social media pages, that information may be displayed and viewable by other users.

 

  • Consent: We may share Personal with your consent and at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide that information. For instance, if we host a webinar, we may ask for your consent to share your Personal Information with any event partners who are co-sponsoring the webinar with us. We also rely on your consent to share information in the course of providing you with legal services, such as sharing information with opposing counsel.

 

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:

 

  • Legitimate interest: Most often, we handle Personal Information on the ground that it furthers our legitimate interests in commercial activities such as the following:

 

  • Providing legal services pursuant to our contract with our client;

 

  • Processing billing and payments;

 

  • Marketing our services;

 

  • Protecting our clients, contractors, and property;

 

  • Analyzing and improving our business;

 

  • Processing freelance attorney or other applications; and

 

  • Addressing legal and ethical issues.

 

  • Legal compliance: We need to use and disclose Personal Information in certain ways to comply with our legal obligations, such as complying with our tax, accounting, and anti-money laundering obligations.

 

  • To honor our contractual commitments to an individual: We need to process some Personal Information in order to meet our contractual obligations to the individual to whom the Personal Information pertains.

 

  • Consent: Where required by law, and in some other cases, we handle Personal Information on the basis of implied or express consent. For instance, we will obtain and rely on your consent to send you newsletters or for the use of certain cookies.

 

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.

 

  • Opting out of email marketing. You can opt-out of receiving our promotional emails at any time by following the instructions included in those emails. Please be aware that it may take up to 10 days for us to process your request, and you may continue receiving promotional communications from us during that period. If you opt-out of receiving such communications, please note that we may continue to send you non-promotional emails (such as emails related to our business relationship or emails about changes to our legal terms).

 

  • Restricting cookies/Do Not Track. CGL does not change its behavior in response to web browser “do not track” signals. However, you can configure most browsers to reject cookies or to notify you when you are sent a cookie, giving you a chance to decide whether or not to accept it. You can consult the help section of your browser to find out how to do this. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Service.

 

  • Limiting Information Available Through Social Media Platforms. If you want to limit or stop receipt of information from third-party social media platforms, you can change your privacy settings on those other websites. You also may choose not to use social features we make available.

 

  • Access, Update, or Delete Your Information. To access, update, or delete information we maintain about you please contact us at privacy@cgl-llp.com. Please note that we may keep certain Personal Information as necessary to comply with our legal obligations or for legitimate business purposes, such as to resolve disputes or enforce our agreements. We may also keep cached archived copies of Personal Information for a certain period of time.

 

  • European Privacy Rights: To the extent the European Union’s General Data Protection Regulation and similar laws apply and we hold your Personal Information in our capacity as a controller, you may request that we:

 

  • Provide access to and/or a copy of certain Personal Information (including, in some cases, in portable form);

 

  • Prevent the processing of your Personal Information for direct-marketing purposes (including any direct marketing processing based on profiling);

 

  • Update Personal Information that is out of date or incorrect;

 

  • Delete certain Personal Information which we are holding about you;

 

  • Object to our processing of Personal Information;

 

  • Restrict the way that we process and disclose certain of your Personal Information;

 

  • Transfer your Personal Information to a third party; or

 

  • Honor a revocation of your consent for the processing of your Personal Information (without retroactive effect).

 

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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