Effective Date: September 17, 2021
Should we decide to make material changes to this Policy which may have an adverse impact on you, we will notify you by posting the changes, to this Policy, on the aforementioned websites in a clear and conspicuous manner or to your most recent email or physical address currently on file.
While using our Services, DLG may collect personal information about your use of our Services and information that you send us. The term “personal information,” is generally defined as information that identiﬁes you or makes you identiﬁable, and will have the meaning throughout as deﬁned under applicable law. Redacted information that does not identify a speciﬁc individual is not “personal information.”
DLG may collect and store the following information when using our Services:
Information Voluntarily Provided. We collect information that you voluntarily provide to us, including when you communicate via email or other channels, such as google text, regular mail, fax, and any on-line fillable forms on the DLG websites; when you elect to receive information from us; when you seek career information; when you submit an application for a position with us; when you respond to our communications or requests for information. The information you provide may include your name, contact information, title, and information about your affiliated organization and any personal information provided in relation to any matter being handled by DLG. We only collect and process the personal information we need to allow us to respond to your request and/or provide the particular service you seek.
Information DLG Automatically Collects. We may automatically collect information about you when you use our Services such as, but not limited to:
Device Information. DLG may collect information about devices you use to access the Services and how you use the Services, such as your Internet Protocol (“IP”) address.
Performance and Log Data. Our servers may automatically record information created when you access our services, which may include information such as, but not limited to, your IP address, browser type, operating system, command line information, diagnostic information related to the Services (e.g., crash activity reports), the referring web page, pages visited, location, your mobile carrier, device and application IDs, and search terms.
Do Not Track. Please note that we do not currently respond to web browser “do not track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Privacy Notice.
Information We Receive From Third Parties. DLG receives personal information about you from third parties and use such information, including but not limited to: names, contact information, name of business, titles, business and home address, background information, professional experience, ﬁnancial information, such as payment related information and shareholdings, and other personal information, including health information.
If you connect to us from a social network, such as LinkedIn or Facebook, we will collect personal information from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with personal information as located on the applicable profiled including but not limited to name, proﬁle picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list, and any other information you agreed the social network can share or that the social network provides to us. We assume that such social networks or other third parties are entitled to collect and share such personal information with DLG.
Sensitive Information. From time to time, DLG may collect sensitive information about you when using our Services. Any use of such information is limited to such purposes at the time it is collected.
Providing Services to You. DLG may use your personal information to inform you about our Services, new legal and policy developments, relevant information in the industries we serve, and our marketing events. Without this information, DLG may not be able to provide our Services.
Responding to Your Inquiries. DLG uses your personal information when you contact us, such as with questions, concerns, feedback, disputes or issues. Without this information, DLG may not be able to respond to you or ensure your continued use and enjoyment of our Services.
Enforcing Our Terms or Agreements. DLG uses your personal information to actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities in connection with our Services; to investigate, prevent, or mitigate violations of our terms, agreements or policies; and enforce our agreements with third parties and partners. DLG may not be able perform our Services in accordance with the terms, agreements or policies without processing this information for such purposes.
Ensuring the Security of our Services. DLG is committed to ensuring your safety and continued enjoyment of our Services. As such, we use your personal information to: combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not access your information with us or the information in our possession. We may not be able to ensure the security of our Services if we do not have this information for security purposes.
Research and Development Purposes. DLG continues to strive to provide you with our innovative Services, to help us with this we collect information about the way you use and interact with our Services for research and development purposes. Research and development helps us improve our Services and build new Services and customized features. DLG therefore takes additional security measures when processing personal information for such purposes, by anonymizing your information, limiting access to personnel that may conduct research and development, and applying various security measures.
Potential Employment. DLG uses your personal information when you seek employment with DLG to evaluate your qualifications for the position. Without this personal information, DLG may not be able to evaluate you for employment.
Marketing Activities. DLG uses personal information to inform you about our Services, new legal and policy developments, relevant information in the industries we serve and our marketing events (including by electronic means, such as email). To do so we may process your contact information or information about your interactions on our Services.. To opt-out of receiving our marketing information at any time click the unsubscribe link in our emails.
DLG does not sell, exchange, transfer, or give your personal information to any other company or individual for any reason except as set forth in this Privacy Notice and as described below:
DLG Afﬁliated Entities. As a large organization that provides services globally, we may share your information with our ofﬁces and affiliates throughout the world to provide our Services (e.g., the United States, Europe, Latin America, the Middle East, and Asia).
Our Service Providers. DLG may share information with our service providers, suppliers, subcontractors, and similar third parties who provide services to us, or act on our behalf so that they can assist us with the maintenance of our Service. Our contracts with these service providers prohibit them from sharing your personal information with others for other purposes than as directed by us.
Your Consent. We will disclose your information to a person you have given us your consent to disclose to or as required to complete the Services.
DLG’s Services may include links to third party services where you might be able to post comments, reviews, or view third party information. The use of these third party services may result in the collection and sharing of your personal information by these third party services.
This Privacy Notice does not address the data processing practices of any third party, unless as speciﬁed otherwise. DLG is not responsible for the privacy practices of these entities.
DLG encourages you to be aware when you leave our Services, and to read the privacy statements or notices of each website or application on which you land after you click on a link or social networking button.
DLG takes reasonable steps to ensure that the personal information is accurate and complete. You may access and update your personal information that we hold by contacting us directly at email@example.com. For your protection, we will verify your identity before implementing your request. DLG will implement your request as soon as reasonably practicable.
Please specify what information you want changed, whether you would like the personal information suppressed from our database, or other limitations put on our use of the personal information, including discontinuing any onward transfers or sharing with business partners. We may only implement requests with respect to personal information that is associated with the particular email address that you use to send your request.
However, please be advised we reserve the right to refuse to act on a request that is manifestly unfounded or excessive (for example because it is repetitive).
For individuals located outside the United States during data collection, please refer to Section 10 below for more information about your rights.
DLG uses reasonable technical, organizational, and administrative measures to protect user information within our organization against unauthorized access or processing, and against accidental loss, destruction, or damage. These measures are reasonably adapted to the nature of the information in our custody. Additionally, we protect personal information by taking measures: (i) to protect the ongoing conﬁdentiality, integrity, availability, and resilience of our processing systems and services; (ii) to restore the availability of and access to personal information in a timely manner in the event of a physical or technical incident; and (iii) to regularly test, assess, and evaluate the effectiveness of our technical and organizational measures.
Even though DLG makes reasonable efforts to protect information in its custody, no security system or data storage or transmission over the Internet or otherwise is fully secure. Thus, DLG does not guarantee the security of any information collected or received from you or transmitted to you.
If you believe your information is not secure, please immediately notify us of the problem as provided below.
DLG retains information about you for as long as necessary to perform the activities described in this Privacy Notice, or where we have an ongoing legitimate business need to do so, such as for legal, regulatory, accounting or reporting requirements.
When our legitimate interest for retention ceases, we will either delete or anonymize your information so that it can no longer be attributed to a particular individual. To the extent residual information remains within our databases, back-ups or other records and we are unable to anonymize it we will isolate such information from further processing until deletion is possible. If you have any questions, please feel free to contact us.
Because the nature of our Services, DLG may from time to time collect information regarding children and minors. However, DLG does not knowingly collect any personal information from children under 16. If we become aware that an individual under the age of 16 is submitting information without consent from their parent or legal guardian or as permitted under applicable law, we will delete the information as soon as possible from our database. If you believe we are collecting information about an individual under 16, please notify us immediately so that we can take appropriate action.
This section only applies to individuals who do not reside in the United States. As a global organization, we may store, process and transmit personal information in locations around the world, including locations outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, please notify us and we will respond accordingly.
If living outside of the United States, DLG may ask you to identify the country in which you are located when you use our Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located outside of the United States. If any terms in this section conﬂict with other terms contained in this Policy, the terms in this section shall apply to individuals outside the United States.
For those residing in the European Union, for the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the data controller for the personal information you provide or that we collect in connection with the Services is The Downs Law Group, P.A.
Legal Basis. Article 6(1) of the GDPR describes when processing can be done lawfully. When we process your personal information for a speciﬁed purpose, we shall apply one of the Article 6 legal bases described below, including any Article 9 conditions for processing special categories of personal information.
Whenever we require your consent for the processing of your personal information such processing will be based on Article 6(1)(a) GDPR.
If the processing of your personal information is necessary for the performance of a contract between you and DLG or for taking any pre-contractual steps upon your request, such processing will be based on Article 6(1)(b) GDPR. If this data is not processed, DLG will not be able to execute the contract with you.
Where the processing is necessary for us to comply with a legal obligation, we will process your information on the basis of Article 6(1)(c) GDPR, for example for complying with obligations under anti-money laundering laws.
Where the processing is necessary for the purposes of DLG’s or another party’s legitimate interests, such processing will be made in accordance with Article 6(1)(f) GDPR, for example to enforce legal claims.
Below is a chart indicating the legal bases we rely on in processing personal information.
Purposes of Processing
Legal Basis for Processing
To Provide Services;
To Respond to Your Inquiries;
To Enforce our Terms and Agreements Provide Customer Support;
To Ensure the Security of the Service; and
Share with DLG’s Afﬁliated Entities.
Processing is based on our contract obligations or to take steps at the request of the individual prior to entering into a contract.
To Personalize Your Experience on the Services For Research and Development Purposes Sharing Due to Corporate Reorganization
Processing is based on our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services.
To Ensure the Security of the Service.
To Share Due to Law Enforcement Requests To Enforce our Terms and Agreements
Processing is necessary for compliance with our legal obligations, the public interest, or in your vital interests.
DLG will make every effort to notify you if we use personal information not described in this Privacy Notice. Upon receipt of this notification, you can choose not to allow us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected or subsequently obtained your consent. Choosing to limit the ways we can use your personal information,may result in our Services being unavailable to you.. Also, we may have legitimate reasons to still use your personal information even though you did not allow us to.
Marketing. We contact individuals by electronic means (including email or SMS) and traditional postal mailings based on our legitimate interests, as permitted by applicable law, or after obtaining the individual’s consent. If you do not want us to use your personal information in this way please click an unsubscribe link in our emails or send us an email at firstname.lastname@example.org or notify us in writing at: The Downs Law Group, P.A., 3250 Mary Street, Suite 307, Miami, Florida 33133.
Individual Rights. We take reasonable steps to ensure that your personal information is accurate, complete, and up to date. You have the right to access, correct, or delete the personal information that we collect. You are also entitled to restrict or object, at any time, to the further processing of your personal information. You have the right to receive your personal information in a structured and standard format and, where technically and legally feasible, the right to have your personal information transmitted directly to a third party. If you would like to exercise your rights under applicable law, or if you believe we infringed or violated your privacy rights, please contact us at email@example.com so that we may resolve your dispute directly. You also have a right to lodge a complaint with a competent supervisory authority situated in a State of your habitual residence or place of alleged infringement.
International Transfers of Personal Information. If we share your personal information with entities located in the United States or other non-EEA jurisdictions which, according to the European Commission, do not offer an adequate level of protection to personal information we implement speciﬁc contracts, approved by the European Commission, which ensure the same protection to personal information as granted in the EEA, or other appropriate solutions to address cross-border transfers as required or permitted by Articles 46 and 49 of the GDPR. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us.
As a result of the July 16, 2020, judgment from the Court of Justice of the European Union, invalidating the EU-US Privacy Shield Framework, DLG no longer rely on our EU-US Privacy Shield Framework certiﬁcation for transfers of personal information from the European members countries to the U.S. Rather, DLG relies on other appropriate safeguards recognized by the GDPR to make such transfers. We will continue to apply the Privacy Shield Principles to the personal information that we received from the European member countries prior to July 16, 2020.
DLG makes every effort to comply with all Federal, State Law and International Conventions regulating the use and transfer of personal information. By participating in such frameworks DLG agrees to subject their compliance to the regulatory enforcement of the Federal Trade Commission (“FTC”) or any other statutory body empowered to enforce compliance with those frameworks.
If there is any conﬂict between the policies in this Privacy Notice and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern in relation to DLG.
If you believe DLG infringed or violated your privacy rights, please contact us at firstname.lastname@example.org so that we may resolve your dispute directly. If you have an unresolved complaint or dispute arising under the requirements of the Privacy Shield Framework, we agree to refer your complaint under the Framework to an independent dispute resolution mechanism. Our independent dispute resolution mechanism is the International Centre for Dispute Resolution (“ICDR”), operated by the American Arbitration Association (“AAA”).
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), below is a summary for the last twelve (12) months of the “Personal Information” categories, as identiﬁed and deﬁned by the CCPA (see California Civil Code section 1798.140(o)), that we collect, the reason we collect the Personal Information, where we obtain the Personal Information, and the other entities with whom we may share the Personal Information. Under the CCPA, Personal Information is deﬁned as any 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 (“Personal Information”).
DLG will generally collect the following categories of Personal Information in providing our Services:
identiﬁers such as a name, address, unique personal identiﬁer, email, phone number, your device’s IP address, software, and identiﬁcation numbers associated with your devices; characteristics of protected classiﬁcations under California or federal law, such as gender; commercial information such as records of products or services purchased, obtained, or considered by you; Internet or other electronic information regarding your browsing history, search history, the webpages visited before you came to our website, length of visit and number of page views, click- stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system conﬁguration information; professional or employment-related information; your geolocation, to the extent you have conﬁgured your device to permit us to collect such information; and inferences about your preferences, characteristics, behavior and attitudes.
For more information about the Personal Information we collect and how we collect it, please refer to this Privacy Notice above.
DLG collects Personal Information for the business purposes described in this Privacy Notice above. The CCPA deﬁnes a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notiﬁed purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.
If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose speciﬁc pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us, or the security of our network systems.
To assert your right to know, to access, or to delete your Personal Information, please contact us by email at email@example.com or contact us at 1-305-444-8226. To conﬁrm your identity, we may ask you to verify Personal Information on ﬁle for you. If we cannot verify your identity based on the information on ﬁle, DLG may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
Right Against Discrimination. DLG will not discriminate against you for exercising your right to know, delete or opt-out of Services.
Right to Know. You have the right to request in writing: (i) a list of the categories of Personal Information that a business disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of Personal Information DLG collected about you, (ii) the categories of sources from which Personal Information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom DLG shared Personal Information, and (v) the speciﬁc pieces of Personal Information DLG holds about an individual.
Right to Access. You have the right to request a copy of the speciﬁc Personal Information DLG collected about you during the twelve (12) months before your request.
Right to Delete. You have the right to request us delete any Personal Information DLG collected from you or maintain about you, subject to certain exceptions.
Right to Opt-Out of Selling. California residents have the right to opt-out of having their Personal Information sold. DLG does not sell your Personal Information.
Under the CCPA, a California customer may use an authorized agent to make a CCPA privacy request on the consumer’s behalf. To make a request on behalf of a California consumer whose personal information was collected by DLG, the authorized agent must ﬁrst provide a copy of either (a) a letter signed by the customer authorizing the agent to submit a CCPA request on his or her behalf, or (b) a valid power of attorney issued pursuant to California Probate Code sections 4000 to 4465. An authorized agent must email one of these documents to firstname.lastname@example.org and include a phone number where the agent may be reached during regular business hours.
You can contact us via email at email@example.com If you prefer to contact us by postal mail, and you are in the United States or in any country other than the countries listed in the chart below, please contact us at: The Downs Law Group, PA, 3250 Mary Street, Suite 307, Miami, Florida 33133.