Privacy Policy

 

This Privacy Policy applies to the processing of Personal Information of all clients, contacts, vendors, suppliers and agents of WHM Law and all visitors to www.whm-law.com (“Site”) (regardless of where you visit it from) or our mobile application (“App”), except as specified herein. WHM Law LLC is the controller and is responsible for the Site. When we refer to “WHM”, “we”, “us” or “our”, we are referring to the relevant WHM Law entity responsible for processing your data. When we use the term “Personal Information” in this Privacy Policy, we mean information and data that identifies, or can be used on its own or combined with other pieces of information, to identify an individual. This can be, for example, a name, street address, email address, or telephone number(s). It does not include information and data that cannot be linked back to an identifiable individual, even in combination with data from alternative sources (anonymous data).

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Where you are providing Personal Information to us on behalf of another individual or individuals (for example, on behalf of an organization when providing employee details), in doing so, you are confirming that: (a) you are authorized by each such individual to disclose such Personal Information to us for the purposes detailed herein; and (b) you have explained, provided notice and provided copies of this Privacy Policy to all data subjects on whose behalf you are providing information.

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It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your Personal Information. This Privacy Policy supplements these other notices and is not intended to override them.

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Personal Information We Collect and How We Use It

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We may collect Personal Information from individuals through our Site or by other means (such as via email, mail, phone, business partners’ contact information and other third parties, such as commercial data vendors and public databases). The principal ways you may provide the information and the types of information you may submit, as well as the ways we may use the information, are listed below.

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Business Purposes

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On our Site you may be able to register using your Personal Information to gain access to information related to your relationship with us or the services we offer. We use these details to provide you with access to information about your relationship with us and to facilitate your use of the Site or our App. We may also obtain your Personal Information from third parties where such information is provided to us in connection with the relevant purposes set out in this Privacy Policy, as well as from public sources about you or your business. It is in our legitimate business interests to use this Personal Information so that we can manage our business relationships and carry out marketing and sales activities.

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Applications

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Individuals apply for jobs with WHM Law through our Site, third-party job posting sites, job fairs or directly to our various business locations. The Personal Information job seekers provide through this process is often maintained by third-party service providers. This Personal Information may be maintained in locations within the United States, accessible to our recruiting team and shared with our corporate divisions and entities on a need-to-know basis for the purpose of evaluating job seekers for permanent and temporary positions within WHM Law. The Personal Information submitted by job seekers, such as name, contact details and any other information relevant to the application, is used to evaluate their qualifications for employment and to contact them regarding possible employment opportunities. It is in our legitimate business interests to use this Personal Information in the selection process and to communicate with you, and it is necessary to provide us with this Personal Information so that we can assess and evaluate your application. In addition, please note that as a regulated law firm, we are required to undertake screening of all our employees and business professionals. This screening may involve the collection of legal and regulatory records where appropriate and permissible. We also provide employee Personal Information to service providers for human resource purposes. It is in our legitimate business interests to use this Personal Information so that we can manage our employment relationships and carry out our human resource functions.

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Contact

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You may contact us with questions, requests, or comments through the persistent “Contact Us” widget on our Site or via the contact information provided in the “How to Contact Us” section of this Privacy Policy. When you do so, we may ask you for your Personal Information to verify your identity or to track the inquiry internally to ensure we appropriately respond to your questions, requests or comments.

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Contractual Compliance

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If you are a client, vendor, supplier or an independent contractor, we may ask you to provide Personal Information such as your name, contact details or business and financial details to establish and administer your account, process payments and for compliance with internal and legal requirements. It is in our legitimate business interests to use your Personal Information for this purpose so that we can comply with our contractual obligations to you.

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User Feedback

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You may be able to submit feedback on our Site. If you choose to give us your feedback, we may ask you for your Personal Information. We may also ask you about your experience using our Site. It is in our legitimate business interests to use the Personal Information you provide to enhance our Site, evaluate the quality of our services or to communicate with you about our services.

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Security Threats

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We may collect Personal Information when detecting and defending against security threats in accordance with our legitimate business interests and our legal obligations. We use various IT tools to detect and defend against online security threats (e.g., attacks, viruses, malware, spam, phishing, malicious web content), to promote business continuity of our information systems and assets and to maintain optimal performance of our IT systems. To ensure physical security of our facilities, we may, where permitted under local law, utilize video surveillance systems and/or location tracking while you are on our property.

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Internal Uses of Information

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We may use the Personal Information for internal general business purposes in accordance with our legitimate business interests. These purposes include administration of our Site, data analytics, fraud prevention and compliance with our legal obligations, standards, policies and procedures, i.e., due diligence checks and sanctioned and embargoed screening of third parties (including our clients, affiliated parties, vendors and agents), where necessary. We may obtain your explicit consent to collect and use certain types of Personal Information when we are required to do so by law.

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Special Category Information

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In certain limited circumstances we will need to collect sensitive or special category Personal Information (“Sensitive Information”) from you, such as (where appropriate and permissible) details about your race or ethnicity, religious beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Such information may be collected from you or, in those jurisdictions where it is permissible, from third parties. You may also inadvertently disclose Sensitive Information to us. We will only request Sensitive Information where necessary and legally permitted to do so, and we have in place enhanced safeguards to protect such Sensitive Information, whether obtained via request or inadvertent disclosure.

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Failure to Provide Information

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Where we need to collect Personal Information by law, or under the terms of a contract we have with you and you fail to provide that Personal Information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with legal services). In this case, we may have to cancel the contract you have with us, but in such event, we will notify you if this is the case at that time.

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Change of Purpose

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We will only use your Personal Information 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. We may also process your Personal Information without your knowledge or consent, in compliance with the above rules, where such processing is required or permitted by law.

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Information We Collect by Automated Means

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When you visit and interact with our Site and our App, we may collect “Other Information” that does not inherently reveal your specific identity, in order to learn how to best tailor our Site for our visitors’ needs. Examples of what Other Information we may collect and how we and third-party service providers may collect this information include:

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Aggregated Information

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We also collect, use and share aggregated information, such as statistical or demographic data for any purpose. Aggregated information may be derived from your Personal Information but is not considered Personal Information under applicable law as aggregated information does not personally identify you or any other user (for example, we may aggregate user information to calculate the percentage of our users who come from a particular region of the world). However, if we combine or connect aggregated information with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used strictly in accordance with this Privacy Policy.

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Browser and Device Information

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Certain information is collected by most browsers or automatically through your device, such as your computer type, operating system, name and version, device manufacturer and model, internet browser type and version and the name and version of the online services you are using. We use this information to ensure that our Site and App function properly.

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Cookies

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Cookies are pieces of information stored directly on the computer or mobile device that you are using.  Cookies allow us to collect information such as browser type, time spent online, pages visited, referring URL and other aggregated Site traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to collect statistical information and to personalize your experience while online.

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IP Address

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Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the online services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering our online services. We may also derive your approximate location from your IP address to understand from what regions of the world our visitors come.

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Web Beacons and Related Technologies

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Web beacons (also known as pixel tags and clear GIFs) may be used in connection with some online services to, among other things, track the actions of users of the online services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the online services and response rates. We also use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of our services and report on activities and trends. These services may collect information regarding the use of other websites, apps and online resources. You can learn more about Google’s privacy practices by going to www.google.com/policies/privacy/partners/, and opt out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

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We do not use your Personal Information to make automated decisions.

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How We Share Personal Information

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We do not sell or otherwise disclose your Personal Information except as described in this Privacy Policy. We may also share your information as disclosed at the time you provide it and in the following circumstances:

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Acquisition Transfers

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We may disclose your Personal Information, usage information and other information about you to parties acquiring part or all of our assets, as well as to lawyers and consultants. If we transfer your information to an acquirer, we will use reasonable efforts to direct the acquirer to use your information in a manner that is consistent with this Privacy Policy. Also, if any bankruptcy or reorganization proceeding is brought against us, your Personal Information may be considered a company asset that may be acquired by or transferred to third parties.

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Practice Groups, Business Units and Affiliated Offices

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We may share the information you provide (such as information about your service requests, inquiries, applications or use of our Site or App) with our other practice groups, business units, and affiliated offices for the provision of legal services, marketing, recruitment and internal reporting purposes. We do this to run our business more efficiently and to have a better understanding of our business relationships across the business units, practice groups and offices.

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Third-Party Service Providers

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In order to carry out your requests, to make various features and services available to you, to respond to your inquiries and for other purposes described in the “Personal Information We Collect and How We Use It” section of this Privacy Policy, we may share your Personal Information or usage information with third parties that perform functions on our behalf, such as companies or individuals that: host or operate our Site; analyze data; provide client service; manage payments; or other third parties that participate in or administer our marketing promotions or assist with risk management, compliance, legal and audit functions. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.

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Government Authorities, Law Enforcement Agencies, Courts, and Regulators

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We may transfer and disclose your information to third parties (i) to comply with a legal obligation, (ii) when we believe in good faith that the law requires it, (iii) at the request of governmental authorities conducting an investigation, (iv) to verify or enforce our policies, procedures, Terms of Use and other agreements, or to protect the rights, property or safety of WHM Law, our clients, employees, business partners or others, (v) to respond to an emergency, (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (vii) otherwise to protect the rights, property, safety or security of third parties, users of our services, visitors to our Site or App or the public.

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Consent to Share with Third Parties

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The provision of our legal services may present you with the opportunity to opt in to receive information or marketing offers from third parties or to otherwise consent to the sharing of your information with third parties. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the third party and will be subject to the privacy policy and practices of that third party.

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Non-Personal Information

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We may share non-Personal Information, such as aggregate user statistics, demographic information and usage information with third parties.

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Links to Other Sites

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Our Site, App and communications may provide links to other websites, plug-ins and applications, including those of social networks or business partners that may make use of our logo. To the extent that any linked products or services are not provided by WHM Law, we are not responsible for the products or services, or any of the content found on these websites or applications. If you provide information on and use third-party products, services, or websites or applications, the privacy policy and terms of service on those websites and applications are applicable. We encourage you to read the privacy policies of websites and applications that you visit before submitting your Personal Information, as these third parties have their own privacy practices which may be different from those of WHM Law. Also, please be advised that if you disclose Personal Information or Sensitive Information through public forums or message boards, this information may be collected and used by others. We do not monitor these public spaces and take no responsibility for the content, security or confidentiality of any information posted thereon.

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How We Protect Personal Information

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In proportion to the sensitivity of the information, we maintain reasonable physical, technical and administrative safeguards and appropriate security measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration or destruction. However, we cannot absolutely guarantee the security of Personal Information, as no electronic data transmission or processing of Personal Information is completely secure. If an incident is reported affecting your Personal Information, we will investigate and comply with all required reporting obligations.

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How Long is Personal Information Retained

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We will keep your Personal Information for as long as needed to meet the purposes described in the “Personal Information We Collect and How We Use It” section of this Privacy Policy. Once our relationship with you has come to an end, we will retain your Personal Information only for a period of time that enables us to:​

• maintain business records for analysis and/or audit purposes;

• comply with record retention requirements under the law;

• defend or bring any existing or potential legal claims; and

• address any complaints regarding our services.

 

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of your Personal Information; the purposes for which we process your Personal Information; and whether we can achieve those purposes through other means while still meeting any applicable legal requirements.

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In some circumstances, we may anonymize your Personal Information in which case we may use this information indefinitely without further notice to you.

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Please note that you may have the right to request that Personal Information collected from you be erased and forgotten before the end of our information retention periods, although this right is not absolute and may be limited under certain circumstances.

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Your Rights with Respect to Your Personal Information

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In addition to the erasure right addressed above, you have the right to access, correct, object to, port or restrict the processing of your Personal Information that we have received from you. It is important that the Personal Information we hold about you is accurate and current. We encourage you to contact us to update or correct your information if it changes or if you believe the Personal Information we hold about you is inaccurate. Please note that we will likely require additional information from you in order to verify your identity and respond to your change or update requests. If you would like to change or update your information, please contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy. We will timely respond to your request.

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You will not have to pay a fee to access your Personal Information (or to exercise any of these rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We will respond to all legitimate requests within one month, unless your request is particularly complex or you have made a number of requests. In that case, we will notify you and keep you updated.

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Additionally, you have the right to withdraw consent to the processing of your Personal Information, where we only rely on consent as the lawful basis for processing such Personal Information. Further, you are advised that you may not be able to withdraw consent, request that we erase your Personal Information and/or request the we only process for reduced purposes where the Personal Information is necessary for the purpose(s) detailed in the “Personal Information We Collect and How We Use It” section of this Privacy Policy or where another legal justification for processing applies. Where you do legitimately wish to withdraw or restrict your consent, or otherwise object to how we are processing your Personal Information, it may result in us being unable to provide services to you if the fulfillment of these services requires the processing of such Personal Information. If you wish to exercise any of the rights set out in this paragraph, please contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy.

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You also may have the right to make a complaint at any time to your relevant data protection authority. We would, however, appreciate the chance to address your concerns before you approach your data protection authority, so please contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy.

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Children

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Our Site and App are not intended for use by children under the age of sixteen, as our legal services generally are not directed to children under the age of sixteen. We may have the occasion to collect and process the Personal Information of children below the age of sixteen for the purposes of the provision of our legal services for the reasons described in the “Personal Information We Collect and How We Use It” section of this Privacy Policy. However, we do not knowingly collect Personal Information from anyone under sixteen without parental consent. If you become aware that we have collected Personal Information from a child under the age of sixteen without parental consent, please let us know so we can take appropriate action.

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California Residents

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If you are a California resident and have provided us with your Personal Information, you may ask us to refrain from sharing your Personal Information with third parties, including our other business units, practice groups and offices if they are separate legal entities, for direct marketing purposes. Please tell us your preference by contacting us via the contact information in the “How to Contact Us” section of this Privacy Policy. In addition, California residents have access, deletion, knowledge, opt-out and portability rights described in more detail below. In the event of any conflict between this section on California Residents and the rest of this Privacy Policy, this section on California Residents shall prevail.

 

Personal Information

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For purposes of this section on California residents only, “Personal Information” means “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Cal. Civ. Code § 1798.140(o)(1). Personal Information does not include:

• publicly available information from federal, state or local government records;

• de-identified or aggregated consumer information; and

• information excluded from the CCPA’s scope.

 

Categories, Purposes and Disclosure of Data Collected

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The categories and purposes of collection of Personal Information are described in the “Personal Information We Collect and How We Use It” section above and reflect how we intend to and how we have collected and used information in the twelve months prior to the effective date. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you notice. You can find further details about the information that we collect from California residents in the chart below. Please note that while a category may be marked, that does not necessarily mean that we have information in that category about you. Please also note that nothing in this disclosure should be construed to concede that we are a “business” as that term is defined under the CCPA.

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Categories and Purpose of Information Collected from California Residents

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Category                                       Examples                                                                                                                                   Collected

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Sharing Personal Information

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We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose (which we have done in the preceding twelve months), we enter a contract that describes the purpose and prohibits the recipient from (1) selling the Personal Information; (2) retaining, using or disclosing the Personal Information for any purpose other than for the specific business purpose specified in the contract; and (3) retaining, using or disclosing the information outside of the direct business relationship with us.

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We intend to disclose, and in the preceding twelve months have disclosed, the following categories of Personal Information for a business purpose:

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Category A: Identifiers
Category B: California Customer Records Personal Information categories
Category C: Protected classification characteristics under California or federal law
Category D: Commercial information
Category F: Internet or similar network activity
Category I: Current or past job history or performance evaluations
Category K: Inferences drawn from other Personal Information

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We disclose your Personal Information for a business purpose to the following categories of third parties:

• our business units, practice groups and offices;

• service providers; and

• third parties to whom you or your agents authorize us to disclose your Personal Information in connection with services we provide to you.

 

In the preceding twelve months, we have not “sold” any Personal Information in the typical sense of the word. Further, we have not disclosed to other third parties any Personal Information for monetary or other valuable consideration within the twelve months preceding the date of this Global Privacy Policy.

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Access, Knowledge and Portability Rights

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You have the right to request that we disclose certain information to you about our collection and use of your Personal Information. Once we receive and confirm your verifiable consumer request, we will disclose to you, as it pertains to the twelve months prior to the request:

• the categories of Personal Information we collected about you;

• the categories of sources for the Personal Information we collected about you;

• our legitimate business or commercial purpose for collecting or selling that Personal Information;

• the categories of third parties with whom we share that Personal Information;

• the specific pieces of Personal Information we collected about you (also called a data portability request); and

• if we sold or disclosed your Personal Information for a legitimate business purpose, two separate lists disclosing:

  • sales – identifying the Personal Information categories that each category of recipient purchased; and

  • disclosures for a business purpose – identifying the Personal Information categories that each category of recipient obtained.

 

Deletion Rights

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You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

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We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the Personal Information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act.

• Engage in public or peer-reviewed scientific, historical or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Opt Out of the Sale of Personal Information

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California residents have the right to opt out of the sale (or disclosure for other valuable consideration) of Personal Information about them or their household, such as (though not limited to) their name, postal or email address, and other personally identifying information.

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This right is subject to certain exemptions. For example, the law does not apply to information that has been aggregated and/or de-identified such that it could not reasonably be used to identify you. It also does not apply to information that we share with third-party service providers in order for them to perform certain business functions for us. We explicitly do not sell Personal Information to outside parties, including, but not limited to, marketers. If you would, nonetheless, like to opt out, you may use the “Do Not Sell My Information” button located on our Site, or by writing us at info@whm-law.com.

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Exercising Access, Data Portability and Deletion Rights

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To exercise the access, data portability, deletion and the opt-out rights described above, please submit a verifiable consumer request to us by either by calling us at 888.946.0001 or by writing us at info@whm-law.com.

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Only you or (a) a natural person that you authorize to act on your behalf or (b) a business entity registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent to submit a request on your behalf, we will require that you provide written evidence that you have granted the authorized agent permission to make such a request, and we will verify your identity.

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You may only make a verifiable consumer request for access or data portability twice within a twelve-month period. The verifiable consumer request must:

• provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and

• describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

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Nondiscrimination

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We will not discriminate against you for exercising any of your CCPA rights.

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Response Timing and Format

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We will confirm receipt of a verifiable consumer request within ten days of receipt and provide information regarding how we will process the request. We endeavor to respond to a verifiable consumer request within forty-five days of its receipt. If we require more time (up to ninety days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the twelve-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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Updates to Our Global Privacy Policy

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We may modify or update this Privacy Policy from time to time. We will always indicate at the top of this policy when it was most recently updated. If we substantially change this Privacy Policy, we will notify you of the changes. Any changes will be effective immediately upon the posting unless otherwise indicated. Where changes to this Privacy Policy will have a fundamental impact on the nature of processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights.

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How to Contact Us

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Should you have any questions or concerns about our privacy practices and/or our policies, procedures and statements, please do not hesitate to contact one of our Privacy Managers at info@whm-law.com or write to us at:

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WHM Law Offices

Attn:  Privacy Manager

255 S Orange Ave

Orlando, FL 32801