Privacy

A. What We Collect

We may collect and use certain information when you voluntarily submit it, automatically when you access or use the Redgrave LLP website, and from other sources, such as third parties (e.g., service providers, affiliates, and organizations with which we may collaborate for certain activities or events), or publicly available sources.  If any such information identifies or is reasonably capable of being associated with a natural person, it will be considered “personal information” for purposes of this Policy.  The term “personal information,” as used in this Policy, has the same meaning as it has under the California Consumer Privacy Act (“CCPA”).

1. What We May Collect Directly From You

The information we collect directly from you varies and depends on the specific activities for which we collect it.  It may include:

• Contact information, such as name, email address, postal address, and phone or text number;
• Education information, such as degrees, languages, professional memberships, qualifications, and certifications; Employment information, such as business unit/division, company name, job status, job title, office location, and LinkedIn profile information;
• Health and health-related information, such as accessibility requirements, dietary restrictions, and, where necessary to protect the health and safety of our guests at our events, information related to symptoms of, or risk of exposure to, certain illnesses;
• Demographic information that could potentially include sensitive personal information or information about protected classifications, such as age, gender, race/ethnic origin, nationality, religious preferences, memberships, and political affiliations; and
• Any other information you voluntarily provide.

2. What We May Collect Automatically

When you interact with the Redgrave LLP website, we may use automatic technologies to collect certain information about your equipment, browsing actions, and patterns.  This may include:

• Technical information, such as your IP address, browser type, and version; information about your operating system; and information about the devices you use to access the website, such as device identification number and device type (“technical information”); and
• Usage and other information about how you use the website (“usage information”).

Redgrave LLP and its service providers may collect information that is considered personal information in some jurisdictions by using cookies and other technologies.  (For example, we use Google Analytics, which places cookies on your device that include a ClientID that is recognized by some laws as a persistent identifier).  You can read our Cookie Policy here.   Cookies are small data files that are transferred to your hard drive, when your browser setting permits, that track how and when you use our website, for example, to recognize and count the number of uses and which pages you visit on the Redgrave LLP website to optimize its performance.

3. What We May Collect From Others

We also may collect information from other sources and combine that information with other information we collect.  For example, we may use information from LinkedIn to update information about you in our contact database, or if you apply for employment with us, we may collect information relating to your background, education, and employment history, among other things.

4. What We May Derive or Infer

We may derive information or draw inferences about you based on the personal information we collect.  For example, we may infer your location based on your IP address or that you are interested in employment or participating in an event based on your browsing behavior on our website.

B. How We May Use Information

We do not sell or rent your personal information, and we do not use your personal information for automated decision-making, including profiling.  However, we may use and disclose it for various purposes:

• Administer and protect our business and the Redgrave LLP website, for example, to operate, maintain, and provide features and functionality of the website, and to conduct data analysis and market research;
• Assess job applicants and make hiring decisions;
• Comply with legal and financial obligations;
• Conduct research and analysis;
• Debug to identify and repair errors in our websites and their services;
• Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Redgrave LLP and others;
• Enter into and perform a contract we may have with you;
• Evaluate or conduct a merger, divestiture restructuring, reorganization, dissolution, or other sale or transfer of assets;
• Manage your online account(s) and send you technical notices, updates, security alerts, and provide support and administrative messages;
• Monitor and analyze usage, trends, and activities related to the websites and use of technologies we use to support our services;
• Notify you about any changes to the websites and their services;
• Provide the information or services you request and send you related information;
• Provide, maintain, and improve the websites;
• Protect the health, safety, and vital interests of our personnel and others;
• Register you for events and other activities;
• Send you advertising, newsletters, updates, and other communications we think will be of interest to you, including about our services, programming, and events; and
• Carry out other purposes described to you when we collect your information.
  

We may also collect information for other reasons with your consent.

1. Data Retention – How Long We Keep Your Information

We will retain your information only for as long as it is reasonably necessary for the purposes for which we collected it, including to satisfy any legal, regulatory, tax, accounting, or reporting requirement.  However, we may retain your information for a longer period if there are valid legal grounds, including responding to a complaint or if litigation is reasonably foreseeable.

We may also anonymize or aggregate your personal information so it can no longer be associated with you.  In that case, we may use this information indefinitely without giving you further notice.

C. When and Why We May Disclose Information

We may share or disclose your personal information in the following circumstances:

• With respect to bar associations, we may share your name and bar number in connection with an application for CLE credit;
• Our service providers, including vendors, consultants, and professional advisors, may need to access your personal information in order to perform work that we deem necessary;
• In connection with the financing, sale, or acquisition of all or any part of our assets;
• As required by law or legal process in response to lawful requests for access to, or production of, information, including national security or law enforcement requests;
• If we believe your actions are inconsistent with our user agreements or policies or to protect the rights, property, and safety of Redgrave LLP, its personnel, or any third party;
• With users of our Services, if you post content to interactive or other publicly accessible areas of those Services, such as blogs; and
• With your consent or at your direction.

In some circumstances, we may share de-identified or aggregated information that cannot reasonably be used to identify you.

D. How We Protect Information and Transfer It

1. Data Security

 We take data security very seriously and therefore use reasonable technical and organizational security measures and processes designed to protect the personal information we collect.  However, transmitting information over the internet is not completely secure, and we therefore cannot guarantee the security of your personal information when it is transmitted to our website.

2. Data Transfers

We use secure methods, including encryption and strong passwords, to transfer personal information to others.  For the reasons described in this Policy, personal information may be transferred to, stored, or otherwise processed in the United States, Canada, and other locations.  We also transfer personal information to our service providers who may also process information inside or outside the United States.  While in another jurisdiction, your personal information could be accessed by the courts, law enforcement, and other national security authorities in that jurisdiction.  These jurisdictions may not provide the same level of protection as your home jurisdiction.

If you are in the European Economic Area (“EEA”), Switzerland, the United Kingdom, or in another jurisdiction having comparable data protection laws, we provide adequate protection for the transfer of personal data to countries outside those jurisdictions by executing Standard Contractual Clauses or other contracts, as authorized under the applicable laws.  In some circumstances, you may be entitled to a copy of those agreements and may inquire by writing to privacy@redgravellp.com.  

E. Children’s Privacy

Our website is not intended for children younger than 18, and we do not knowingly collect personal information from children under 18.  If you are under 18, do not use or provide any information on the Redgrave LLP website or through any of its features.  If we learn that we have collected or received personal information from a child under 18, without verification of parental consent, we will delete that information./p>

F. Third-Party Content

From time to time, we may provide links to or embed video hosted by third-party websites that we do not operate or control.  This Privacy Policy does not apply to any third-party website, and we cannot be responsible for their content, privacy policies, or practices.  You should therefore review their privacy policies before you provide any information about yourself to or through them.  Your interactions with those services will be governed by those third parties’ privacy policies

G. Your Options

Depending on your residence or, in some circumstances, your location, you may have certain options about how we treat your personal information:

1. Corrections

In some circumstances, you may be able to ask us to modify the personal information we have about you.  You may do so by signing onto your online account, if you have one, or by writing to privacy@redgravellp.com

2. Marketing Communications

You may opt out of receiving advertising or promotional communications from us or request changes to your communication preferences by following the instructions in those communications and clicking on the unsubscribe option.  If you opt-out, we may still send you non-promotional communications, such as those that relate to your account or our ongoing business relations.

If you are in the EEA, Switzerland, the United Kingdom, or a jurisdiction with comparable data protection laws, you must opt-in to receive advertising or promotional communications from us.  You may make changes to your communications preferences by following the instructions in those communications and clicking on the appropriate option.  If you do not agree to receive advertising or promotional communications, we may still send you non-promotional communications, such as those that are related to your account or our ongoing business relations.

3. Cookies

Even though your web browser is probably set to accept cookies by default, you can usually set your browser to reject them.  Know, however, that setting your browser to remove or reject cookies could affect the availability and functionality of our website and online services.  For more information, see our Cookies Policy here.

H. Supplemental Policies with Respect to State Laws

This Section supplements our Privacy Notice and describes our additional policies with respect to those U.S. states that have adopted comprehensive consumer data privacy laws.  This Section also serves as a Notice at Collection under the California Privacy Rights Act.

1. Collection, Use, and Disclosure of Personal Information

• Categories of Personal Information: As described in greater detail in “What We Collect,” in the preceding 12 months, we have collected the following categories of information:
  • Identifiers, such as Google Analytics’ ClientID;
  • Professional and employment related information;
  • Education information;
  • Commercial and financial information;
  • Health and medical-related information;
  • Internet and network activity;
  • Information about personal characteristics; and 
  • Other categories of personal information that may reasonably be associated with a particular person.
• Business or Commercial Purpose for Collecting and Using Personal Information
  • We collect and use personal information for all the reasons listed in “How We May Use Your Information” and in “When and Why We May Disclose Your Information.”
• Categories of Sources of Personal Information
  • We collect Personal Information from the following sources:
    • The information you provide to us through our websites or other communications with us;
    • Automated sources such as cookies;
    • Third parties, such as LinkedIn, news media, and other publications; and
    • We may also derive or infer information about you based on other information that we have collected.
• Categories of Personal Information Disclosed and Categories of Third-Party Recipients
  • In the preceding twelve months, we have disclosed the following categories of information:
    • Identifiers;
    • Professional and employment-related information;
    • Education information;
    • Commercial and financial information;
    • Health and medical-related information;
    • Internet and network activity;
    • Information about people’s personal characteristics; and
    • Other categories of personal information that may reasonably be associated with you.
  • And we have shared this information with the following categories of third parties:
    • Consultants;
    • Service providers;
    • Data analytics providers, including Google Analytics;
    • State bar associations;
    • Internet service providers;
    • Courts;
    • Data storage providers; and
    • Operating systems and platforms.

2. Your Rights with Respect to Your Personal Information

Subject to certain limitations, you may have the right to:

• Have access to your personal data and obtain a portable copy of it;
• Have us delete your personal information; 
• Correct your personal information (except residents of Utah and Iowa  )
• Disclosure of:
  • the categories of information we have collected about you;
  • the categories of sources from which we have collected your personal information;
  • the business or commercial purpose for collecting or selling your personal information;
  • the categories of third parties with whom we share personal information; and
  • the specific pieces of personal information we have collected about you.
• Opt-out of the sale or sharing of your personal information;
• Opt-in for processing of sensitive personal information (except California, Utah , and Iowa);
• Not be subject to automated decision-making (except for residents of Utah and Iowa); and
• Not be discriminated against for exercising these rights.

3. How to Exercise Your Rights

You can make a request by calling 833-733-4783 or by visiting this page.  We will verify you are the requesting person by asking you to provide information sufficient for us to confirm your identity.  We will not use or retain that information for any other purpose except to the extent necessary for us to have a record of our having complied with your request.  You may also have a representative, authorized by you, to exercise your rights on your behalf, in which case we will ask the representative to show us that you have provided him or her with a power of attorney or that he or she otherwise has a valid signed authority to make the request on your behalf.  Authorized agents may make a request by writing to privacy@redgravellp.com. 

If your request is denied in whole or in part, you may appeal the denial by also writing to privacy@redgravellp.com.  You should include the word “APPEAL” in the subject line and identify in the text the decision you are appealing.

I. For People Who are in the EEA, Switzerland, the United Kingdom, or Other Jurisdictions Having Comparable Data Protection Laws

This Section applies to you if you are located in the EEA, the United Kingdom, Switzerland, or a jurisdiction with comparable data protection laws.  The laws of those nations give you certain rights and protections as a natural person.

1. Legal Basis for Processing

   If we process your personal data, we will rely on the following legal bases:

   • To perform under a contract with you or to take steps before entering into a contract with you;
   • To comply with a legal obligation to which we are subject as a controller;
   • To protect a vital interest of you or another natural person;
   • To perform a task carried out in the public interest or in the exercise of official authority that is vested in the data controller;
   • When we have a legitimate interest in processing in order to operate our business or protect our interests, unless such interests are overridden by your interests or fundamental rights and freedoms or those of another natural person; and
   • When you have given us your express consent and have not exercised your right to withdraw it.
2. Cross-Border Transfers of Personal Information

   We will only transfer personal data between countries when permitted or required to do so under applicable laws.

3. Your Rights Under These Data Protection Laws

   Subject to certain limitations, laws in the EEA, United Kingdom, Switzerland, and other jurisdictions that have comparable data protection laws give you the following rights with respect to your personal data:

   • To access your personal data;
   • To receive your personal data in a portable format;
   • To ask that your personal data be corrected or erased;
   • To object to certain processing of your personal data or request that processing be restricted;
   • To request, in some circumstances, that your personal data be transferred to you or to a third party;
   • To withdraw your consent; and
   • To exercise these rights and complain to an appropriate authority if you believe we have failed to address your concerns adequately.

   To exercise any of your rights, please contact us at privacy@redgavellp.com.

4. Questions or Complaints

   If you are not able to resolve with us your concerns about our processing of your personal data, you have a right to lodge a complaint with the appropriate Data Protection Authority. The principal ones can be found by using the following links:

   • In the EEA:  https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
   • In the United Kingdom: https://ico.org.uk/global/contact-us/
   • In Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
   • If you are subject to the laws of one of the other jurisdictions and do not know the appropriate authority, please contact us.

J. Cookie Policy

This Cookie Policy gives you information about our use of cookies.  If you are in the U.S. and use the Redgrave LLP website, you consent to the use of cookies in accordance with this Policy.  For our non-U.S. visitors, you may see a pop-up banner to this effect.

We and our service providers may use cookies and other technology to gather information about your use of the websites.  For example, we use Google Analytics, which places cookies on your device that include a ClientID that is recognized by some laws as a persistent identifier.  A cookie is a small file placed on the hard drive of your computer, and web beacons are small electronic files located on Redgrave LLP website pages.  Cookies may be placed on your browser or device by our website (“first-party cookies”) or by other companies (“third-party cookies”).  These technologies collect and store information about your preferences.  For example, they enable us to recognize you and count the number of (and which) pages you visit on our website.

They also enable us to help you navigate our website efficiently and perform certain functions.  You will find information about cookies under each category below.  You can choose to enable or disable some or all of these cookies, but disabling some of them may affect your browsing experience.

Our website may use the following categories of cookies and similar technologies:

• Necessary (cannot be removed): these cookies are necessary for our services to function properly and help us identify and prevent security risks.  Necessary cookies may be either first-party or third-party cookies;
• Functional (available for opt-out):  these cookies help us perform certain functionalities, such as sharing the content of the website on social media platforms, collecting feedback, and other third-party features.  Advertising (available for opt-out):  we use these cookies to provide you with customized advertisements based on the pages you have visited and to analyze the effectiveness of our marketing efforts; and
• Analytics (available for opt-out):  these cookies help us learn which features on our website are most popular and which need improvement.  They provide information on metrics such as the number of visitors, bounce rate, traffic source, and so forth.

Most browsers and devices accept cookies by default, but their settings usually allow you to clear or decline cookies.  Remember that if you change or upgrade your browser or device, or delete your cookies, you may need to use these tools again to avoid the browser’s default setting.  To disable certain cookies, you can use the browser controls discussed above or, for some of our providers, you can use their individual opt-out mechanisms, such as the Google Analytics Opt-Out: https://tools.google.com/dlpage/gaoptout.  Note that if you disable cookies, some features on our website may not function properly. 

Also note that our Cookie Policy does not apply to any third-party websites that may be linked to, or accessed through, our website.  We are not responsible for what they do, and you are responsible for checking their privacy policies. 

Please check the Redgrave LLP website along with the Cookie Policy periodically for any changes because we may update it at any time.  If you have questions about cookies, you may visit www.allaboutcookies.org, and if you have questions about our practices, you may contact us at privacy@redgravellp.com.