FORDHARRISON LLP ONLINE PRIVACY POLICY
1. Introduction
At FordHarrison LLP ("FordHarrison,” "us", "we", or "our"), we understand your concerns about privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy describes the types of information we may collect from users ("users" or "you") or that users may voluntarily provide to us when they visit our website, including the webpages and services delivered through the domain www.fordharrison.com and any other domain used by FordHarrison that specifically incorporates the terms of this Privacy Policy (collectively, the "Site"), and in e-mail, text and other electronic messages between the users and the Site. This Privacy Policy also describes certain rights and options that you have with regard to your personal information.
1.1. Applicability of this Privacy Policy.
1.1.1. This Privacy Policy does not address our other obligations to you as our client, if applicable. Those obligations are described in our terms of engagement or otherwise arise as a result of applicable law or ethics.
1.1.2. This Privacy Policy does not apply to: (i) information collected by FordHarrison offline or through any other means, including any other website operated by FordHarrison or any third party (including our affiliates and subsidiaries) unless such website specifically incorporates the terms of this Privacy Policy; or (ii) any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site or (iii) any other publicly available personal information.
1.2. Voluntary submission of Information. We do not collect any personal information about you unless you voluntarily provide it to us for the purpose of receiving additional information, thought leadership content, and/or updates on recent FordHarrison news and events. When you sign up for FordHarrison publications through our Subscriptions page, you can make choices about the information you will receive based on industries and practice groups, and you can also unsubscribe from communications. The information you provide through our Subscriptions page is used only to provide you with the content in the area(s) you have selected. If you register for one of our events (including webinars and in-person events), we use information you provide solely for contacting you about the event, and to let you know about our future events if you have indicated that you would like to receive that information. Users of our Site are under no statutory or contractual requirement or other obligation to provide personal information to us via our website.
1.3. Your Consent. By choosing to provide personal information to FordHarrison through our website, you consent to the collection, use, and disclosure of your personal information as outlined in this Privacy Policy. Our Subscriptions page reminds you about this when you sign up for communications. IF YOU DO NOT CONSENT TO OUR USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY, PLEASE DO NOT PROVIDE YOUR PERSONAL INFORMATION OR, WHERE APPLICABLE, EXERCISE THE OPT-IN OR OPT-OUT OPTIONS OFFERED. IF YOU CONSENT TO OUR USE OF YOUR PERSONAL INFORMATION AND LATER CHANGE YOUR MIND, YOU MAY WITHDRAW YOUR CONSENT TO OUR FURTHER COLLECTION, USE, DISCLOSURE AND STORAGE OF INFORMATION ABOUT YOU, BY CONTACTING US AT UNSUBSCRIBE@FORDHARRISON.COM OR BY MAIL TO FORDHARRISON LLP, ATTN: MARKETING DEPARTMENT, 271 17TH STREET, NW, SUITE 1900, ATLANTA, GA 30363. BE SURE TO INCLUDE YOUR EMAIL ADDRESS IF SUBMITTING BY POSTAL MAIL. WE WILL KEEP YOUR NAME, COMPANY NAME AND EMAIL ADDRESS IN OUR DATABASE IN ORDER TO PREVENT FUTURE COMMUNICATIONS. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide you with information that you have requested or invite you to webinars or events.
1.4. Changes to this Privacy Policy. We reserve the right to update and change this Privacy Policy from time to time in our sole discretion in order to reflect any changes to the way in which we treat your personal information or in response to changes in law. We will provide notice by, at a minimum, updating this posting. You are expected to carefully review this Privacy Policy from time to time so you are aware of any changes. If we make material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by means of a prominent notice on the Site.
1.5. Who Is Responsible for Your Personal Information? FordHarrison is the controller and is responsible for the personal information you provide through the Site. Contact Information: If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways: FordHarrison LLP, 271 17th Street NW, Suite 1900, Atlanta, Georgia 30363, clientservice@fordharrison.com or 1-404-888-3800.
2. What Information Do We Collect and Why?
2.1. Personal information that you provide voluntarily: As discussed above, we collect personal information that you provide voluntarily through our site, by, for example, completing online forms to contact us, subscribing to a newsletter, subscribing to receive marketing communications from us, registering for events that we are organizing, or inquiring about material available for purchase. As a general rule, we use personal information only for the purpose for which you have divulged the data to us, such as to answer your inquiries or to grant you access to password protected portions of the Site. The information we collect about you may include the following:
- Name
- Job title, job level or job function or role
- Company or organization
- Company data
- Contact information, including email address and telephone numbers
- Demographic information, such as industry, country, postcode, preferences and interests
- Information relating to events captured through event-related forms, such as dietary restrictions, and hotel and flight information
- Information pertinent to fulfilling our services to you
- Any other personal data that you voluntarily choose to provide to us.
- Please note, however, we do not intentionally collect sensitive category personal data, unless you provide us with such data. Sensitive category personal data is personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation. While there may be free text boxes on the Subscription page where you are able to enter additional information, we do not intend to process sensitive information. You are not required to provide, and should not disclose, sensitive personal information in the free text boxes. If you choose to provide any sensitive personal information in this manner, you acknowledge you consent to the collection and processing of this sensitive information.
2.2. Information collected automatically:
2.2.1. We may use Google Analytics or other similar technologies (the "Analytics Technologies") to collect and process certain information about you and your use of the Site. The information collected by the Analytics Technologies is statistical data and does not include personal information, and we do not maintain it or associate it with personal information we collect in other ways or receive from third parties. You may learn more about how Google uses the information it collects by visiting the following site "How Google uses data when you use our partners' sites or apps" (located at https://www.google.com/policies/privacy/partners/). Google's ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Privacy Policy (located at https://www.google.com/policies/privacy/). If you do not want your information collected with Google Analytics, you can install the Google Analytics opt-out browser add-on. To opt-out of Google Analytics, visit the Google Analytics opt-out page (located at https://tools.google.com/dlpage/gaoptout) and install the add-on for your browser. For more details, visit the "Google Analytics opt-out browser add-on" page (located at https://support.google.com/analytics/answer/181881?hl=en).
2.2.2. Our web servers and/or the Analytics Technologies may collect and store the following general information about you: the originating name of the domain from which you access the Internet; the date and time you access the Site; the pages of the Site you visit; your search queries; the Internet address of the website from which you linked directly to us; and the type of device, device ID and web browser you use to access the Site. This information is collected automatically. It is used to help us improve the Site by tabulating the number of visitors to the Site in terms of new users, origin of referrers, popularity of pages, amount of use, types of errors, and to make the Site more useful to you.
2.2.3. We may also use "cookies" and "web beacons." Cookies are small files stored on your computer's hard drive that are used to store and track personal information. Cookies are used to remind us of who you are in order to deliver you better service. Web beacons are small electronic files (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit FordHarrison, for example, to count users who have visited certain pages and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
2.2.4. We may also use these automatic data collection technologies to collect information about your online activities over time and across third-party websites or other online services. The information we collect automatically is statistical data and does not include personal information, and we do not maintain it or associate it with personal information we collect in other ways or receive from third parties.
2.2.5. Do Not Track - "Do Not Track" is a proposed standard that is currently under development. As it is not yet finalized, we adhere to the standards set out in this Privacy Notice and we do not currently respond to "Do Not Track" signals on the Site or on third-party websites or online services where we may collect information.
3. How Will We Use Your Information?
3.1. In addition to the uses described above, we may use the information that we collect about you or that you provide to us, including any personal information, in the following ways:
3.1.1. To present and improve Site content and functionality;
3.1.2. To provide you with information, products, or services that you request from us, including newsletters, Legal Alerts, event and webinar invitations and other material in which you have indicated an interest (for more information on our marketing practices, see the Additional Marketing Notice below);
3.1.3. To determine user interests, needs, and preferences;
3.1.4. To manage and maintain the security of our Site and services;
3.1.5. To respond to an email from you to receive information on open positions with FordHarrison;
3.1.6. To comply with our legal and compliance obligations;
3.1.7. To exercise and defend our legal rights, or to comply with court orders;
3.1.8. For any other purpose related to and/or ancillary to any of the purposes and uses described in this Privacy Policy for which your personal information was provided to us;
3.1.9. In any other way we may describe when you provide the information; and
3.1.10. For any other purpose to which you have consented.
3.2. We may process your personal information in connection with any of the purposes and uses set out in this Privacy Policy on one or more of the following legal grounds:
3.2.1. Because it is necessary for us to do so to provide the information or perform the services you have requested, to comply with your instructions, or other contractual obligations between you and FordHarrison;
3.2.2. To comply with our legal obligations as well as to keep records of our compliance processes;
3.2.3. Because our legitimate interests make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
3.2.4. Because it is necessary to protect your vital interests;
3.2.5. Because it is necessary in the public interest; or
3.2.6. Because you have expressly given us your consent to process your personal information in a particular manner.
We do not use your personal information for making any automated decisions affecting or creating profiles other than as described above.
4. Disclosure of Your Personal Information
4.1. We do not disclose any data details, personal or usage, to third parties, unless required to do so by law (e.g., to law enforcement, courts or others, including, but not limited to, in response to a subpoena or court order) or to protect our rights (e.g. where we believe it necessary to respond to claims asserted against us, comply with legal processes (such as subpoenas or warrants)), enforce or administer our agreements and terms, or for fraud prevention, risk assessment, investigation, and to protect the rights, property or safety of FordHarrison, our clients and customers, or others.
4.2. FordHarrison does not share your personal information with unaffiliated third parties for promotional purposes.
4.3. Business reorganization - FordHarrison may sell, transfer or otherwise share some or all of its assets in connection with a merger, reorganization or sale of assets, or in the event of bankruptcy, without your permission. In such an event, personal information may be one of the assets transferred.
5. How Long Do We Store Your Personal Information?
5.1. FordHarrison will retain your personal information for as long as needed to fulfill the purposes for which it was collected. We also will retain and use your personal information as long as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, provide our services, and enforce our agreements.
5.2. When we no longer have a purpose to retain your personal information, we will securely destroy your personal information in accordance with applicable law and our policies.
6. Security of Your Personal Information
6.1. We are committed to keeping personal information secure and have implemented appropriate information security policies, rules and technical measures to protect the personal information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss. Please be aware, however, that no transmission over the Internet is completely secure or error-free, and no one can guarantee that no unauthorized access will ever occur on any Site. Accordingly, you should consider your own risks and benefits of providing and not providing any personal information to this Site. While we will strive to protect your personal information, we cannot and do not guarantee or warrant the security of any of your personal information. We will not be and are not liable for disclosures of your personal information due to errors in transmission, networks that we do not control, or unauthorized acts of third parties.
6.2. The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Site, you are responsible for keeping this password confidential. Do not to share your password with anyone.
6.3. If a security breach causes an unauthorized intrusion into our Site or systems that compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.
6.4. All employees across FordHarrison offices with a proper need to utilize the information have access to this data and are obliged to respect the confidentiality of such personal information.
7. Additional marketing notice
7.1. As noted, we may send periodic promotional emails to you, and where required by law, we will obtain your consent to do so, either by providing you with the opportunity to opt-in to our mailing list or when you voluntarily subscribe to receive communications from us through the Subscription page on our Site.
7.2. You may unsubscribe at any time by sending an email to unsubscribe@fordharrison.com or by mail to FordHarrison LLP, Attn: Marketing Department, 271 17th Street, NW, Suite 1900, Atlanta, GA 30363. Be sure to include your email address if submitting by postal mail. We will keep your name, company name and email address in our database in order to prevent future communications.
7.3. Information on how to unsubscribe is also available on the Subscription page on our Site and is included at the bottom of each email communication.
8. Your Rights to Access and Control Your Personal Information
8.1. If you are in the European Economic Area, or are otherwise a data subject covered by the European Union’s General Data Protection Regulation (“GDPR”) or similar laws in other countries, you have certain rights in relation to your personal information. Those rights may include the right to:
8.1.1. request access to, and rectification or erasure of, your personal information;
8.1.2. ask us to restrict the processing of your personal information;
8.1.3. withdraw consent to the collection, processing, and transfer of your personal information and to opt-out of receiving certain communications; and
8.1.4. object to processing of your personal information where carried out for our legitimate interests or direct marketing unless there are compelling legitimate grounds for further processing that override your interests, rights, and freedoms, or for the establishment, exercise, prosecution or defense of legal claims.
8.2. To exercise your rights under this Privacy Notice, please contact us using the "Contact Information," in paragraph 1.5, above or by emailing us at clientservice@fordharrison.com.
8.3. You may also have a right to lodge a complaint about the processing of your personal information with your local data protection or supervisory authority.
9. Cross Border Transfers of Personal Information
FordHarrison is located and established in the United States and therefore, your personal information will be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the security and privacy of your personal information. By using our Site or requesting services from us, you understand and consent to the collection, storage, processing, and transfer of your personal information to our facilities in the United States.
10. Limitations of Data Protection Laws and this Privacy Notice
FordHarrison makes reasonable efforts to comply with applicable data protection and privacy laws and regulations. FordHarrison’s adherence to certain data protection and privacy laws, including GDPR, and this Privacy Policy will be limited as permitted by such laws: (i) to the extent necessary to meet national security, public interest, or law enforcement requirements, (ii) by statute, government regulation, or case law that creates conflicting obligations or authorizations, provided that, in exercising any such authorization, our non-adherence is limited to the extent necessary to comply with such laws and regulations and meet FordHarrison’s overriding legitimate interests, or (iii) if the effect of such laws is to allow exceptions or derogations, provided that FordHarrison applies such exceptions or derogations in comparable contexts.
11. Protecting Children
The Site is not intended for children under 13 years of age. FordHarrison does not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Site or provide any information about yourself to us, including your name, telephone number, email address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at clientservice@fordharrison.com.