Overview of our Privacy Policy
Brown & Streza, LLP, a California limited liability partnership (herein, “Brown & Streza,” “we,” or “us”) is committed to respecting and protecting your privacy. The following statement (our “Privacy Policy”) applies to all individuals who: (i) access or use this website hosted at www.brownandstreza.com and any other online or mobile services or applications provided by us that link to this Privacy Policy (each a “Site” and collectively “Sites”), and/or (ii) engage our firm for legal services, attend presentations and events we host, or otherwise interact with us.

 
The following privacy policy sets out the principles governing our use of personal information we may obtain about you, as well as the rights that you have in relation to how such personal information may be used, maintained and shared. 


It is important that you read this Privacy Policy together with any other privacy policy or 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 information. This privacy policy supplements any other privacy policy or notices we may provide and is not intended to supersede them.


In this Privacy Policy, “personal information” generally means information that (either in isolation or in combination with other information held by us) enables you to be identified or recognized, and with respect to California residents using our Sites, means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household, subject to the exceptions set forth in the California Consumer Privacy Act.


By accessing or using any of our Sites, or by providing personal information to us on or through any of the Sites, or in connection with any service we provide to you, you agree to be bound by all of the terms and conditions contained in this Privacy Policy.

Collection of Information
Although you are not required to provide any personal information to use the public areas of any of our Sites, you may choose to do so by completing certain contact or marketing forms. Should you do so, we may, for example, keep a record of personal information, such as your name, email address, phone number, and address, together with any other information you voluntarily provide to us.

 

Additionally, we may collect the following categories of personal information from you in the course of business, including through your use of our Sites, when you contact or request information from us, when we provide legal or other services to you, or when we interact with you.

  • contact information, including your name, phone numbers, email addresses, mailing addresses, and other relevant contact information.

  • identification and background information, as may be required for identity verification purposes.

  • financial data, such as bank account information or information related to your assets which is deemed necessary in connection with any services we are asked to provide.

  • legal and regulatory compliance data as required for purposes such as know your client (KYC), anti-money laundering, and market abuse regulations requirements, or as part of our client onboarding process, which may include passport or other identification data, date of birth, home address, and other due diligence data.

  • event registration or mailing list data, such as dietary requirements (which may reveal information about your health or religious beliefs), preferences and interests, subscriptions, and download activity.

  • job applicant data, such as identification data and contact information, resumé and other data provided by you or third parties (e.g. recruiters) on our Sites, online recruitment portal (when applicable) or offline in connection with job openings, which may be subject to additional requirements.

  • device data, such as information about your visit to our Sites, IP address, the URLs of the pages you visit on our Sites, the times and dates of such visits, information about the computer hardware and software you use, device identifier, location and time zone setting, even when you are not logged in. We also may place “cookies” on your computing devices to recognize you on return visits to our Sites, which in some instances enables us to enhance or target your experience using our Sites, as well as to collect information about you. As further described below, you may adjust your browser settings or use other means to prevent cookies from being placed on your computer, but doing so may result in reduced functionality and a less personalized experience.

  • other personally identifiable data necessary for our provision of services, such as information about your mental or physical health, civil litigation history, alleged criminal activities, and in general, any other personally identifiable data deemed necessary in connection with any service we are asked to provide you or your organization.

We may supplement the information that you provide to us with information that we receive or obtain from other sources, such as from our staff or personnel, clients, professional advisers, partners, and our agents, third parties with whom we interact, and publicly available sources.


If you choose not to provide such information, you may not be permitted to access certain features and content of our Sites, or the services we offer to you may be limited.


Use of Personal Information
We may use your personal information for the following purposes:

  • In connection with an engagement for our services: We use personal information that you voluntarily submit to us on our Sites, or during the course of any engagement for our services, regardless of the media used, such as identification data, contact details, and other data that we may process in connection with the provision of services we are asked to provide. The services we provide to you may also involve providing such information to third parties, such as other professional advisers and service providers in order to represent your interests most effectively.

  • Administration of client and vendor relationships: We use identification data, contact details, financial data, and other service data, including for the processing of invoices, the updating of client records, and the management of our vendor relationships.

  • Addressing client inquiries/feedback: We use identification data, contact details, and other service data for this purpose. This process is necessary to perform our contract with you. It may also be necessary for our legitimate interests to establish or maintain a relationship with you.

  • Sending relevant marketing messages and inviting you to events/seminars: We use identification data, contact details, cookie and device data, and mailing list data to communicate with you by way of email alerts and post to provide you with information about our events, seminars, or services that may be of interest to you. This processing is necessary for our legitimate interest to send you tailored marketing messages, client newsletters, and invitations to relevant events and seminars.

  • Improving our Sites: We use cookie and device data to improve the functionality and user-friendliness of our Sites. This is necessary for our legitimate interests to constantly monitor and improve our online presence and services to you.

  • Keeping our Sites and IT systems and processes safe: We use identification data, contact details, financial data, cookie and device data, and other service data. This is necessary to perform our contract with you and to ensure the security and confidentiality of your data. It is also necessary for our legitimate interests to prevent illegal activities, including fraud, which could harm you and us.

  • Complying with legal or regulatory inquiries and requests: We use identification data, contact details, financial data, cookie and device data, and legal and regulatory compliance data (including for anti-money laundering or fraud detection purposes, statutory returns and fulfillment of our ethical obligations). This is necessary for the purpose of complying with legal requirements that apply to us.

  • Recruitment: Personal information about job applicants is collected and processed for purposes of screening, identifying, and evaluating candidates for positions; record-keeping related to hiring processes; analyzing the hiring process and outcomes; and conducting background checks, where and to the extent permitted by applicable law, which may also be subject to relevant local recruitment privacy policy. If you are hired by Brown & Streza, this data will be transferred to our employee record files for the purpose of your employment. This is necessary in order to take steps at the request of the job applicant in the context of recruitment prior to entering into a contract. In addition, job applicant data and legal and regulatory compliance data may be used as necessary to comply with legal, regulatory, and corporate governance requirements.

Information Sharing
We may share your personal information with the following categories of recipients:

  • Professional advisers, partners, and agents of Brown & Streza to provide you with legal services, as required, and to administer our relationship with you;

  • Vendors that will process your personal information on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, financial institutions, customer relationship management databases and other cloud-based solutions, third-party companies providing us with business analytics and statistics to assist with our marketing campaigns, and third-party venues in which we may host events and seminars. We contract with such vendors to ensure that they only process your personal information under our instructions and ensure the security and confidentiality of your personal information by implementing the appropriate technical and organizational measures for such processing;

  • Any law enforcement, regulatory, or government agency requesting personal information in connection with any inquiry, subpoena, court order, or other legal or regulatory procedures, with which we would need to comply. We may also share personal information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims;

  • Any third party connected with business transfers; we may transfer your personal information to third parties in connection with a reorganization, restructuring, merger, acquisition, or transfer of assets of involving us, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Policy.

  • We are not responsible for the data policies or procedures or content of any linked websites. We recommend that you check the privacy and security policies of each website you visit.

Transfers of Information
Your personal information may be transferred to or shared across computer networks within our offices, or carefully selected service providers that Brown & Streza may engage to host the Sites or to provide other services that may not be subject to data protection laws similar to those prevailing in the jurisdiction in which such information is provided to or received by us. All of our offices adhere to the same procedures with respect to your personal information, including this Privacy Policy, and Brown & Streza will require all such service providers to use the information solely to provide the specified services, and otherwise to conform to the requirements of this Privacy Policy.


Cookies and Tracking Technologies
Our Sites use certain tags, log files, web beacons, and similar tracking technologies from third parties. Cookies are text files containing small amounts of information that can be downloaded to your device when you visit a website. Cookies enable us to analyze how our Sites are used, to monitor site performance, and facilitate an experience on our Sites that is targeted to you. We may also use cookies to personalize settings or to enable certain features offered by our Sites.


In addition to the cookies used by us, some cookies are placed by our third parties vendors, such as Google Analytics, as described below.


By using our Sites, you agree to the use of cookies for the following purposes:

  • Essential Cookies: these are essential in order to enable you to efficiently navigate our Sites, and use Site features, such as accessing secure areas.

  • Analytics Cookies: Google Analytics (“Analytics”) is a web analytics tool offered by Google LLC that helps us understand how our visitors engage with our Sites. Analytics collects information anonymously and reports website trends without identifying individual visitors. Analytics uses its own set of cookies to track visitor interactions. These cookies are used to store information, such as what time a site visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the site. Analytics customers can view a variety of reports about how visitors interact with their website so they can improve their website and how people find it. A different set of cookies is used for each website, and visitors are not tracked across multiple sites. Analytics customers are obliged to notify users of their use of analytics software. To disable this type of cookie, some browsers will indicate when a cookie is being sent and allow you to decline cookies on a case-by-case basis. In addition to declining cookies, you can also install an Analytics “Opt-out Add-on” in a supported browser, which prevents Analytics from collecting information about your website visits, by clicking here.

  • Functionality Cookies: they remember your preferences with respect to a Site, such as language options or your current region. 

  • You can block or disable cookies on your device at any time by indicating this in the preferences or options menus in a supported browser. You can also delete the cookies that are stored on your device. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages of our Sites or use online services that require registration. You may opt out of Google’s use of cookies by visiting their Ad Settings page. You may also opt out of a third-party vendor’s use of cookies at the Network Advertising Initiative opt-out page. You can find more information about cookies at allaboutcookies.org.

Security
We have put in place appropriate security measures to protect personal information from unlawful or unauthorized processing and accidental loss, destruction or damage. However, in relation to any personal information you submit to us online, you should keep in mind that the Sites are run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. While we take steps to protect your personal information and keep it secure, you also play a role in protecting your information. You must maintain the security of your online activities by not sharing your passwords and account information with any unauthorized parties, as applicable. Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of any information you transmit to us or from our Sites, and therefore you use our Sites at your own risk.


Information Retention
We will only store your personal information for as long as necessary for the purposes for which that information was collected as set out in this Privacy Policy or for longer as required under any applicable legal, regulatory, accounting, or reporting requirements, provided however that we may retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights.


Links to Third Party Sites
Our Sites may contain links to other websites. This privacy policy only addresses the use and disclosure of your personal information collected through our Sites, if any. If you choose to visit an external website linked from a Site, you will leave our Site. While we try to link only to websites that share our standards and respect for privacy, we are not responsible for the privacy practices of any third parties or the content of linked websites. We encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.


Privacy of Minors
If you are under the age of majority in your home jurisdiction, please do not use or access our Sites. It is not our intention to collect or use personal information from anyone under the age of majority, and we will not knowingly do so. If we are made aware that we have collected any personal information from minors, and are asked to delete such information from our databases, we will promptly do so.


Sending Information Does Not Form an Attorney-Client Relationship
Transmission of information from our Sites does not create an attorney-client relationship between you and Brown & Streza, nor is it intended to do so. The transmission of content over our Sites in part or in whole, and/or any communication with us through our Sites does not constitute or create an attorney-client relationship between us and any recipients.


Opting Out of Communications
We may send you direct marketing messages including by way of email alerts and postal mail. If you no longer wish to receive our email alerts, be part of our mailing list, or receive any marketing or similar communications, you can opt-out of such communications at any time by clicking on the unsubscribe link in the relevant communication or contacting us at info@brownandstreza.com. Please note that even if you opt-out of receiving emails, you may still receive communications related to your interaction with us as required by law.


California Privacy Rights
This below sections of our Privacy Policy for California residents supplements the information contained above and applies solely to all visitors, users, and others who reside in the State of California.


Shine The Light
California Civil Code §1798.83, also known as the “Shine The Light” law, permits California residents to request and obtain information about their personally identifiable information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year, if any. If you are a California resident and would like to make such a request, please submit an email to privacy@brownandstreza.com, and we will respond with the information and disclosure as required by California law.


California Consumer Privacy Act Rights (CCPA)
We adopt the below to comply with the California Consumer Privacy Act (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Privacy Policy. 


If you are a verified California resident, you have the following rights, subject to certain exceptions as set forth in the CCPA:

  • Right to access personal information. You have the right to receive the specific pieces of your personal information we have collected about you in the 12 months preceding your request.

  • Right to data portability. You have the right to receive a copy of your electronic personal information in a readily-usable format.

  • Right to know. You have the right to receive information from us regarding the categories of personal information we collected, the sources from which we collect personal information, the purposes for which we collected and shared personal information, the categories of any personal information we sold as well as the categories of third parties to whom such personal information was sold, and the categories of personal information that we disclosed for a business purpose in the 12 months preceding your “right to know” request.

  • Right to request deletion. You have the right to request the deletion of the personal information that you provided to us. Please note that in certain instances we may not be able to process your request, such as (i) due to the existence of a legal obligation, (ii) to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, or (iii) in order to complete a transaction for which your personal information was collected.

  • Right to non-discrimination. You have the right to be free from discrimination by us as a result of you exercising your rights under the CCPA.

If you wish to exercise these rights, you must submit a request by emailing privacy@brownandstreza.com. The CCPA requires us to verify requests we receive when one is seeking to exercise certain of the rights listed above. We may ask you to provide certain information in order for us to verify your request. When addressing any such requests, we will follow the rules set forth in the CCPA.


Information We Collect
Brown & Streza has collected the following types of personal information from California residents in the last 12 months:

Use of Personal Information
More specifically, our business purpose use (as referenced in the chart above) includes one or more of the following purposes:

 

  • To fulfill or meet the reason you provided the information, including to carry out our obligations under any engagement or other agreement we have with you. For example, if you share your name and contact information to ask a question about our legal services, we will use that personal information to respond to your inquiry. If you provide your personal information to engage us for services, we will use that information to setup your file, work on your matter and requests, and for invoicing and accounting purposes. We may also save your information to facilitate the services we are requested to provide to you. 

  • To provide, support, personalize, and develop our Sites, and services.

  • To respond to your inquiries and requests.

  • To create, maintain, customize, and secure your any account you have with us.

  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.

  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

  • To personalize your experience on our Sites and to deliver content and product and service offerings relevant to your interests.

  • To provide you with information about our services, including any upcoming changes.

  • To help maintain the safety, security, and integrity of our Sites, services, databases and other technology assets, and business.

  • To ensure the physical security of our premises through the monitoring of video surveillance.

  • To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or to comply with our legal obligations.

  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

No Sale of Personal Information
In the preceding 12 months, we have not sold any personal information. We do not sell or disclose your information for monetary consideration.


Do Not Track Disclosure
California Business & Professions Code §22575(b) provides that California residents are entitled to know how a website operator responds to “Do Not Track” browser settings. Some browsers include features which, when turned on, send a signal to websites you visit indicating that you do not wish to be tracked across websites over time. Brown & Streza does not currently take actions on any of its Sites which respond to a “Do Not Track” signal, however, we may change our policy in the future once an official standard for responding to such a signal is adopted.


This sentence concludes the section of our Privacy Policy applicable to California residents.


Governing Law
This Privacy Policy, including without limitation its interpretation, construction, performance and enforcement shall be governed by the laws of the State of California, in the United States of America, including its statutes of limitations, but without reference to conflict or choice of law provisions, as applicable to contracts made and performed entirely within such state. You also agree to abide by any limitation on damages and forum selection clause contained in our Terms of Use, or any other agreements that we have with you.


Changes to our Privacy Policy
We may occasionally update this Privacy Policy as our services and privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, the last update date is posted above, and we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information. Your continued use of our Sites following the posting of changes constitutes your acceptance of such change.


Questions and Feedback
If you have questions about this Privacy Policy or any other feedback relating to any of our Sites, please contact us at: Brown & Streza LLP, ATTN: Site Administrator, 40 Pacifica, 15th Floor, Irvine, CA 92618, United States, or by email at: info@brownandstreza.com.

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