Privacy Policy

Updated and Effective as of May 25, 2018

We take privacy very seriously and are committed to safeguarding personal information. This privacy policy (“Privacy Policy”) sets out how we obtain, use, share, and protect personal information, including through your use of our website and any services we may provide (“Services”). It also explains what rights you have to access, change or delete your personal data. By using our Services, you consent to such use of your personal information and agree to the terms of this Privacy Policy.

We will only process your personal information in accordance with applicable data protection and privacy laws.  For the purposes of UK and EU data protection legislation, the data controller is Cowan, Liebowitz & Latman, P.C., 114 West 47^th Street, New York, NY 10036, U.S.A., (212) 790-9200, law@cll.com.

Types of personal information collected.  We may collect personal information in different ways.  We may collect information you provide to us when you are introduced to us, when we meet you in person, or when we are in contact by phone, email, via our website or otherwise.   The types of personal data you may provide includes: first and last name; job title and company name; email address; phone number; postal address; employment and background data; information contained in correspondence; and marketing and communications data, including your preferences in receiving marketing from us and your communication preferences.  We also may collect information about you from public records and third party sources of information,   We also may collect information which you have made public on websites associated with you or your company or on social media platforms such as LinkedIn and from third parties, such as a person who has introduced you to us or other professionals (such as accountants) you may engage.  We also may collect, store and use information about your visits to our website and information relating to the communications we sent to you, such as:

• technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information,  time zone setting, browser plug-in types and versions, operating system and platform, and geographical location;
• information about your visits and use of the our websites, including the full Uniform Resource Locators (URL), clickstream to, through and from our websites, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms used;
• information collected by cookies on our website (for more information on cookies, please see the section on cookies below).

Use of personal information. We may use your personal information to provide you with information and services that you request from us; to send you updates, alerts, newsletters, blogs, bulletins, announcements, and other communications concerning our firm, legal developments or notifications we believe may be of interest to you; to invite you to programs, seminars, events, or other functions we believe may be of interest to you; to enforce the terms and conditions and any contracts entered into with you; to send you information regarding changes to our policies, other terms and conditions and other administrative information;  to administer our Services, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to improve our Services to ensure that consent is presented in the most effective manner for you and your computer, mobile device or other item of hardware through which you access our Services; and to keep our Services operating, safe and secure.

If you do not wish to provide us with your personal data and processing such information is necessary for the performance of a contract with you, we may not be able to perform our obligations under the contract between us.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose.

Cookies.

Cookies and local storage may be set and accessed on your computer. Upon your first visit to the Services, a cookie or local storage may be sent to your computer that uniquely identifies your browser. “Cookies” and local storage are small files containing a string of characters that is sent to your computer's browser and stored on your device when you visit a website. Many major Web services use cookies to provide useful features for their users. Each Web site can send its own cookie to your browser. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent; however, if you reject cookies, you will not be able to sign in to the Services or take full advantage of our Services. Additionally, if you clear all cookies on your browser at any point after setting your browser to refuse all cookies or indicate when a cookie is being sent, you will have to again reset your browser to refuse all cookies or indicate when a cookie is being sent.

To support our Services we or our service providers may use one or more of the following cookies for the purposes set forth below:

You can find more information about cookies and how they work, what cookies have been set on your computer or mobile device and how to manage and delete them at http://www.allaboutcookies.org/ and www.youronlinechoices.com/uk.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

Disclosure of personal information to third parties. We will disclose information we maintain when required to do so by law or where reasonably necessary to protect our rights or a third party's rights, for example, in response to a court order, a subpoena, a request by a law enforcement agency or to respond to claims that any content violates the rights of any third party. We also reserve the right to disclose the information to any third party to prevent, investigate, detect or prosecute criminal offenses or attacks on the technical integrity of our websites or our network; and to protect the rights, property and safety of our firm, the users of our websites and the public.  We may also disclose personal information in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, or if all or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.  We may also disclose personal information  to enforce or apply our terms and conditions or to establish, exercise or defend the rights of our firm, our staff, customers or others.

Sharing of personal information. We do not share your personal data with third parties except as provided in this Privacy Policy.  We may share your information with our shareholders/partners, employees and staff;; suppliers providing marketing services to us; with our third party data processors and service providers  who assist with the running of our websites and our office services including our IT support services, client reception and telephone answering services and data storage/back up services.  Our third party processors and service providers are subject to security and confidentiality obligations and are only permitted to process your personal data for specified purposes and in accordance with our instructions.

Protection of personal information. We make reasonable efforts to maintain the security, integrity and privacy of any personal information you choose to give us. Although we will strive to take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that personally identifiable information that we collect will never be disclosed in a manner inconsistent with this Privacy Policy. Inadvertent disclosures may occur. If you send us unsolicited information that information may not be treated as confidential or privileged unless we already have a previously-established attorney-client relationship with you.  Unless you otherwise instruct us, we will retain your personal information for as long as is reasonably necessary to provide you with our Services, for our lawful business purposes or pursuant to applicable law or regulation.

Security of personal information on other websites. Our websites contains links to sites operated by third parties that are not under our control or supervision. Neither we nor our employees, agents or representatives are responsible for the privacy practices of these sites. These sites may have their own privacy policies and customer service policies, or no policies at all. We encourage you to read the privacy policies of the other sites to see how your personal information will be handled on the third party sites before providing them with your personal information.

Changes to the personal information we have collected. If you wish to know what personal information we have about you and request a copy of the same, to update or change any incorrect personal information, to ask us to stop collecting, processing and using your personal information in certain ways, to request the portability of your personal information, or to raise concerns regarding automated decision making processes, please send an email request to law@cll.com.  We may refuse to comply with a request if the request is manifestly unfounded or excessive or repetitive in nature.  We may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. We may refuse a request for erasure of personal information, for example, where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defense of legal claims or for record-keeping and research purposes.

Email marketing and newsletters.  You may opt out of receiving email marketing communications from us at any time by using the “unsubscribe” link in emails.

Information from users outside the U.S.A. and consent to transfer information.  Our Services are operated in the U.S.A.  If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to, stored and processed in the U.S.A.  By using the Services or providing us with any information, you consent to this transfer, processing, and storage of your information in the U.S.A., a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Application of the Privacy Policy to children. Our websites are not directed to children under the age of 13. We prohibit children under the age of 13 from using all interactive portions of the website. We will not knowingly collect personally identifiable information from children under 13. We understand that young people need special safeguards and privacy protection. We realize that they may not understand all the provisions of our Privacy Policy or be able to make thoughtful decisions about the choices that are made available to our adult users. We strongly urge all parents to participate in their children's exploration of the Internet and any online services, and to teach their children about protecting their personal information while online.

California Privacy Rights requirements.  We do not share personal information with third parties for their direct marketing purposes, as defined by California Civil Code Section 1798.83, unless we give you choice (opt-in or opt-out) before sharing with those third parties.  If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please contact us by sending an email to law@cll.com. You must put the statement “My California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. Please note that we will not accept inquiries via the telephone or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings.  There currently is no consensus among industry participants as to what “Do Not Track” means in this context. Therefore, like many websites and online services, the Services do not alter their practices when they receive a “Do Not Track” signal from a visitor's browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Modifications. We may modify this Privacy Policy at any time and at our sole discretion, by posting the modifications on our websites. The modifications will be effective upon posting (unless some other date is specified). You should review this Privacy Policy periodically so that you are aware of any modifications. Your use of any of our websites constitutes your full acceptance of the Privacy Policy in its then-current form each time you use of any of our websites.

Dispute Resolution. Any disputes, actions or proceedings relating to this Privacy Policy, or to our handling of personal information, will be governed by the laws of the State of New York, without regard to its conflict of law rules, and must be brought in the federal or state courts in the City and County of New York. By using any of our websites, you irrevocably consent to the exclusive jurisdiction and venue of those courts.

Questions or Comments. Feel free to address any questions or comments regarding our Privacy Policy to law@cll.com.