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.
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;
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
Cookies and Tracking Technologies
In addition to the cookies used by us, some cookies are placed by our third parties vendors, such as Google Analytics, as described below.
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.
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.
Links to Third Party Sites
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 firstname.lastname@example.org. 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
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 email@example.com, and we will respond with the information and disclosure as required by California law.
California Consumer Privacy Act Rights (CCPA)
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 firstname.lastname@example.org. 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.
Questions and Feedback