About This Policy
This Policy describes the privacy practices of the Firm (collectively and/or individually, “Firm”, “our”, or “we”). Except as otherwise provided, it applies to our interactions with our customers and visitors, including, but not limited to:
- Use of our websites, including mobile applications
- Visits to our offices or attendance at one of our events
- Phone, video conference, and email communications
- Social media interactions, such as through LinkedIn
- Viewing our online advertisements or emails
Personal Information We Collect
As described below, Firm may collect or has collected in the preceding 12 months the following categories of personal information (“PI” or “personal information”). We may add to the categories of personal information that we collect. In that case, we will add information to our website or inform you directly.
- Identifiers. Examples include real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
- Other elements. Examples include name, signature, characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number.
- Characteristics of protected classifications under California or federal law. Examples include race, religion, and age.
- Commercial information. This includeslegal andrelated services provided, purchased, obtained, or considered, or other purchasing or consuming histories, needs, or tendencies.
- Education information. This includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
- Internet or other electronic network activity. Examples include browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation data. This might include location information while using one of our apps.
- Audio, electronic, visual, thermal, olfactory, or similar information. Examples of this category including identifiable information obtained about you while attending our seminars and leaving voicemails for our professionals.
- Professional or employment-related information.
- Consumer profile. This includes inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.
- Biometric information. This information includes an individual’s physiological, biological, or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information can also include, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Purposes We Collect Your Personal Information .
Set forth below are the business or commercial purposes for which we have collected your PI. We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent when required by law.
- To provide you with information about our Firm.
- To deliver the products or services you request from us.
- To fulfill or meet the reason for which the information is provided. For example, if you engage the Firm to perform legal services for you, we will collect your address and other contact information to communicate with you. We also may collect PI about you to conduct legal research or make certain filings on your behalf. We may also collect PI about you to generate, prosecute and obtain an allowance of various Intellectual Property, including patents, copyrights, utility models and trademarks, in the United States and around the world. We may also collect PI about you to perfect your rights, title and interest in conveyed Intellectual Property. We may also collect PI about you to represent you in various Federal and State legal proceedings and other court related actions.
- To contact you and/or provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To engage in marketing activities, including to help design products and services appropriate for our clients.
- To communicate with you in social media concerning our products and services, legal alerts and other announcements.
- To carry out our obligations and enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
- To review, improve, and monitor our website, applications, online services, and overall client experience, including to provide customization to meet the specific needs, ensure a consistent experience, and to assess trends, interests, and the demands of clients.
- To provide customer service and engage in quality control activities concerning our products and services.
- For testing, research, analysis and product and service development.
- To respond to government agency and/or law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To process resumes and applications for employment, as well as to evaluate and improve our recruiting efforts.
- As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Sources of Personal Information
The categories of sources of PI are described below. The examples provided are for illustration purposes and are not exhaustive.
You. Examples of when we collect that information include:
- During a website visit or when you visit one of our offices
- If you engage our services and provide information we request to provide those services
- When you engage with the firm or its professionals online, such as in social media activities in LinkedIn or Twitter
- If you register for our seminars, webinars, legal updates, Continuing Legal Education (CLE) events and notices, or other services
- If you participate in a promotion, program, clinic or workshop
- If you request information about our services
- We may use tracking tools like browser cookies, flash cookies, and web beacons.
- Your contractors, business partners, agents, or other counsel . When you obtain services from us, we may collect your PI from your business partners, such as accountants, engineers, attorneys, or other professionals who have information about you that is needed to provide those services.
- News outlets, social media, surveys, and related services . In the course of performing our services or marketing activities, we or third parties on our behalf may conduct research and other activities resulting in the collection of PI about you.
Sharing Personal Information
Of the categories of PI noted above, during the past 12 months, we shared the following:
|Categories of Personal Information Disclosed||Categories of Third Parties to Whom Disclosed|
Characteristics of protected classifications under California or federal law
Internet or other electronic network activity
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
We do not sell your PI and do not have actual knowledge that we have sold personal information of minors under age 16.
Using of Your Personal Information on Our Website.
As is true of most websites, we gather some PI automatically and store it in log files. This information may include the Internet Protocol (IP) address, browser type, language, internet service provider (ISP), referring and exit page, operating system, and date/time stamp. In addition to the purposes above, we use this PI to understand and analyze trends, to administer the Website, to learn about user behavior on the Website, and to gather demographic information about our user base as a whole. To monitor use of the Website and improve its quality, we may compile statistical information concerning the use of the Website through analytics services, such as those provided by Google Analytics. Examples of this information may include: the number of visitors to the Website or to sections or pages within the Website, patterns of traffic flowing through the Website, length of time spent on the Website, or in sections or pages of the Website, the other sites that refer visitors to the Website, the pages of the Website that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Website. We also may use this PI in our marketing and advertising services.
We may use various kinds of software devices to collect PI about use of our Website. Small files called “cookies” may be attached to your Web browser. These files identify your browser and save information such as passwords so that websites can recognize you. You can set your browser to disable cookies, but some portions of this Website (and possibly other sites) may not work properly if you do this. We may also use web beacons to review how visitors navigate the Website. If you would like more information about this practice, and your choices and how they relate to this practice, please contact us.
This Website may use social media plugins (e.g. Facebook and LinkedIn) to enable you to easily share information with others. When you visit our Website, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Website. If you are logged into the social media website (e.g. Facebook, Twitter) while browsing our Website, the social plugins allow that social media website to share data about your activities on our Website with other users of their social media website. For example, Facebook Social Plugins allow Facebook to show your likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our website. We do not control any of the content form the social media plugins. For more information about social plugins from other media websites you should refer to those sites’ privacy and data/information sharing statements/policies.
IMPORTANT: By using the Website, you consent to the processing of any PI provided or collected for the analytics purposes and functions described above.
Do Not Track
“Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Website is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.
Our Sites and Children
We do not knowingly collect or solicit PI from children under 13 years of age. We are concerned about the safety of children when they use the Internet and will never knowingly request PI from anyone under the age of 13. If the parent or guardian of a child under 13 believes that the child has provided us with any PI, the parent or guardian of that child should contact us and ask to have this PI deleted from our files. If we otherwise obtain knowledge that we have PI about a child under 13 in our files, we will delete that information from our existing files so that it is not in retrievable form.
While we use reasonable measures to protect our websites and your information, the Internet is never 100% secure. The measures we use are appropriate for the type of information we collect. We cannot guarantee use of our websites or mobile applications are 100% secure. We encourage you to use caution when using the Internet.
Notice to Website Users Located Outside the U.S.
The Firm operates in accordance with the laws of the U.S. When you access our Website from outside the U.S., we may transfer the PI that we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this Website you acknowledge that these laws may provide a different standard of protection, and you consent to the transfer of your personal data to other jurisdictions, including the U.S.
If you have additional questions you may call us at 888-782-1568 or reach us by email at [email protected] You can write to us at: P+S LLP Privacy Manager, 24 Greenway Plaza, Suite 1600, Houston, TX 77046 .
Effective Date: 7/10/2020
For California Residents
The CA Policy describes Firm’s policies and practices regarding the personal information we collect, use, and disclose about you, including personal information you submit or we obtain when you access the Site and other sources. This CA Policy is adopted in part to comply with the California Consumer Privacy Act (“CCPA”).
Any terms defined within the CCPA have the same meaning when utilized within this CA Policy. The other provisions of the Policy continue to apply except as modified in this CA Policy. Note, however, that personal information as used in this CA Policy does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Consumer Rights. Pursuant to the CCPA, and as detailed below, consumers have various rights with respect to their PI.
Request to Delete. You have the right to request that we delete your PI from our records and direct any service providers to delete your PI from their records, subject to certain exceptions. Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers to delete your personal information from our records.
The Firm is not required to comply with your request to delete your PI if it is necessary for us (or its service provider) to maintain your PI in order to:
- 1) Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between the Firm and you.
- 2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- 3) Debug to identify and repair errors that impair existing intended functionality.
- 4) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- 5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- 6) 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 Firm’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
- 7) To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Firm.
- 8) Comply with a legal obligation.
- 9) Otherwise use your PI, internally, in a lawful manner that is compatible with the context in which you provided the information.
- Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
Request to Know. You have the right to request that we disclose the following to you as it relates to the 12-month period preceding its receipt of your verifiable consumer request:
- 1) The categories of PI we have collected about you.
- 2) The categories of sources from which the PI was collected.
- 3) The business or commercial purpose for collecting PI.
- 4) The categories of PI we disclosed for a business purpose.
- 5) The categories of third parties with whom we share PI.
- 6) The specific pieces of PI we collected about you.
- Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
Nondiscrimination. We will not discriminate against you in violation of the CCPA for exercising any of your CCPA rights.
Submitting Consumer Rights Requests. To submit any of the Consumer Rights requests as outlined above, please contact us at 888-782-1568 or [email protected].We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual who is:
- i. the consumer who is the subject of the request,
- ii. a consumer on behalf of the consumer’s minor child, or
- iii. by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.
If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. PI collected from an individual to determine whether a request is a verifiable consumer request may not be used or disclosed for any other purpose except as required by law. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.
You may authorize a natural person or a business registered with the California Secretary of State to act on your behalf with respect to the right under this CA Policy. When you submit a Request to Know or a Request to Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.