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Privacy Policy.

Fennemore Privacy Policy

California Privacy Statement

CCPA Notice


Fennemore Privacy Policy

Effective Date October 30, 2020

INTRODUCTION
Fennemore Craig PC (“Fennemore”, “We”, “Our”, “Us”) is committed to protecting your privacy. By visiting www.fennemorelaw.com, or any physical place that we do business (the “Site”) you are accepting and consenting to this privacy policy.

We, as the controllers of your data, collect, use, and are responsible for certain Personal Information about you, and have created this Privacy Policy (this “Privacy Policy”) to demonstrate our commitment to fair information practices and the protection of privacy. This Privacy Policy is applicable to the data we collect when you visit and use our Website, visit and engage with our Site, and any services and products that you may request or that we may ultimately provide you (the “Services”).

INFORMATION WE COLLECT

A. Personal information
We collect personal information about you, such as your name, physical address, and email address, if you voluntarily provide this information to us whether by subscribing to certain updates and alerts on the Site, requesting more information from us, or for other purposes. We may add the information you voluntarily provide to us to our databases, subscriber lists, and contact lists to better improve our services to you. As discussed in more detail below, we may also associate information provided by cookies with personal information you have voluntarily provided to us to better tailor our services.

B. Non-Personal information

The Site automatically collects non-personal information from you when you use the Site. This information is collected through cookies and may include, but is not limited to, the following: your internet service provider, the type of browser and operating system that you use, and information about your Site visit, including date and time, length of stay, pages viewed, the website address, if any, from which you linked directly to the Site, the website address, if any, to which you travel from the Site, and other traffic information.

This non-personal information is used to help us improve the Site and the services we provide through it. We may do this by aggregating your non-personal information with similar information collected from other users.

C. IP Address

We also use cookies to collect the IP address of your computer automatically when you visit the Site. We do not use your IP address to identify you personally, except that the cookies discussed below may use your IP address to associate Site usage information with personal information you have voluntarily given to us. You can restrict or block our use of cookies to collect your IP address and for other purposes as discussed below.

USE OF COOKIES

A. Overview
Our Site uses cookies, which are small files sent from our Site to your browser or your computer, tablet, or mobile phone (“Device”) and then stored on your Device’s hard drive. A cookie records on your Device information relating to your internet activity, such as whether you have visited the Site before.

We use the cookies to support Site functionality. We may also use them to collect statistical information that we analyze for insights on Site usage. We do not use the cookies to collect any personal information about you.

B. Cookies That Collect Statistical Information

We may use the following cookies to collect statistical information on Site usage:

  • Google Analytics We use Google Analytics, a web-analytics service provided by Google Inc., to understand how visitors use the Site.The Google Analytics cookie collects information about, among other things, which pages are visited the most often, how people move from one link to another, and when users get error messages. The cookies do not gather any information that identifies you. We may aggregate your usage information from these cookies with information from other users on an anonymous basis to gather analytical data on Site performance and in support of potential improvements.In addition to using your browser settings to restrict or block this Site’s use of Google Analytics cookies, you can restrict or block their use by every website you visit. To do this, visit this Google page.

C. Cookie Opt Out

When first accessing any page of our Site, a banner containing a simplified policy statement is displayed. This banner could include an unmarked box or toggle that requires you to affirmatively “opt-in” to our use of non-necessary cookies. Additionally, you may change and manage your cookie preferences in the following manner:

  • You may give or withdraw your consent to the use of non-necessary cookies here.
  • You may give or withdraw your consent through your browser’s settings. The following are some common browsers and the instructions on how the settings can be changed.

Internet Explorer, instructions can be found here.
Google Chrome, instructions can be found here.
Mozilla Firefox, instruction can be found here.
Opera, instructions can be found here.
Apple Safari, instructions can be found here.

OUR USE OF PERSONAL INFORMATION
We use personal information collected by this Site to:

  • Respond to your inquiries and comments
  • Send you information regarding updates, developments, seminars and other events that we think may be of interest to you
  • Administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.

OUR DISCLOSURE OF PERSONAL INFORMATION
Generally, we do not disclose personal information collected through the Site to unaffiliated third parties without your consent. However, we reserve the right to provide this information to our employees, contractors, agents, and designees so that they can perform Services on our behalf or assist us in providing you more robust Services.

We also may disclose such information to a third party if we believe that we are required to do so: (i) by law; (ii) to comply with legal processes or governmental requests; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of the Site or our network; or (iv) to protect the rights, property, or safety of Fennemore and its directors, employees, contractors, agents, users of the Site, or the public.

Fennemore reserves the right to transfer any and all information we collect from users, or that we otherwise collect in connection with the Site, including, without limitation, to unaffiliated third parties, in the event of a sale or transfer of assets or portion of our business.

WHERE WE STORE PERSONAL INFORMATION

The personal information that you give us or that we collect from you is transferred, stored, or processed in the United States. The laws and regulations regarding data protection and privacy in the United States may be different than in other parts of the world. By submitting this information to us, you agree to this transfer, storing, or processing. We take all steps reasonably necessary to ensure that your personal information is treated and stored securely and in accordance with this Privacy Policy.

SECURITY

Fennemore employs security measures designed to protect against the loss, misuse, or alteration of personal information under our control. No security system, or system of transmitting data over the internet can be completely secure at all times. For that reason, we do not guarantee the absolute security of our servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the Site.

LINKS TO OTHER WEBSITE

The Site may contain links to websites owned by third parties. If you choose to use these links, you will be leaving our Site and are doing so at your own risk. We do not control and are not responsible for the privacy practices of third parties, which may differ from our policy, and any information you disclose on their sites is not subject to this Privacy Policy. You should consult the privacy policies of each website you visit. A link on this Site to one owned by a third party does not constitute endorsement, approval, association, sponsorship, or affiliation with the linked site.

CHILDREN UNDER 18

We do not direct any of our content specifically at children under the age of 18 years, nor do we collect any personal information from anyone who we know to be under the age of 18 years. If we learn or have reason to suspect that a particular user is under the age of 18 years, we will use our best efforts to prevent access to the Website of such user and to delete any personal information in such user’s account on our Website.

California Civil Code Section 22581 permits minors under the age of 18 years, or their parents or guardians, to request and obtain removal of their information. To request removal of your personal information please contact us using the methods described in this Policy. Note that removal under the law does not ensure complete or comprehensive removal of your information.

CHANGES TO PRIVACY POLICY

We reserve the right to update, revise, or otherwise change this Privacy Policy at any time, and any changes to the Privacy Policy will be effective upon posting. Use of the Site constitutes acceptance of the currently posted Privacy Policy, and users should review this Privacy Policy regularly to ensure that they are aware of its terms.

ACCESS TO PERSONAL INFORMATION

You may request a copy of the information that we hold about you by contacting us pursuant to the Contact Us section of this Privacy Policy.

CONTACT US

If you have any questions about this Privacy Policy or our practices related to the Site, or if you would like to request that we disclose or delete your Personal Information stored in our database, or you wish to exercise any rights granted to you by statute (such as those granted to you by the CCPA, or other applicable statute), please feel free to contact us at:

Fennemore Craig, PC

Attn: Privacy Officer
2394 E Camelback Rd
Suite 600
Phoenix, AZ 85016
privacyofficer@fennemorelaw.com
[1-833-522-0655]

Alternatively, when you receive materials from us by email, you may make use of any other “opt out” instructions we provide to stop receiving materials from us.

CALIFORNIA PRIVACY POLICY

California residents are afforded certain additional rights with respect to their Personal Information under the California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et. seq.) and the “Shine the Light” Law (California Civil Code section 1798.83). To learn more about your rights under these laws, please visit our “California Privacy Policy” at California Privacy Statement or contact us pursuant to the Contact Us section of this Privacy Policy. In the case of any discrepancies between this Privacy Policy and your rights under the California Privacy Policy, your rights under the California Privacy Policy will govern.

NEVADA PRIVACY POLICY

If you are a Nevada resident, Nevada Senate Bill No. 220 requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. We do not sell your personal information to third-parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. To make such a request or learn more about our compliance with Nevada law, please contact us using the methods described in this Policy. In the case of any discrepancies between this Privacy Policy and your rights under relevant Nevada statutes, your rights under the statutes will govern.


California Privacy Statement

Effective Date October 30, 2020

This California Privacy Statement is for California Residents and supplements Fennemore Dowling Aaron’s privacy policy. This policy describes the personal information that Fennemore Dowling Aaron LLP (“we,” “our,” or “us”) collects in the course of its business, explains how this information is collected, used, shared, and disclosed, describes rights provided by the California Consumer Privacy Act (California Civil Code Section 1798.100 et. seq.) (“CCPA”), “Shine the Light” Law (California Civil Code section 1798.83), and other California privacy laws to California Residents (“consumers” or “you”) regarding their personal information, and explains how consumers can exercise those rights.

WHAT IS PERSONAL INFORMATION?
We may collect, use, or share your personal information. Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“personal information”). “Personal information” does not include: (1) publicly available information, such as information that is lawfully made available from federal, state, or local records, and (2) de-identified or aggregate consumer information.

With a limited exception, and as noted in other sections of this privacy policy, certain provisions of the CCPA do not apply to:

 

  • Certain personal information covered by or collected under industry-specific federal and state privacy laws including, but not limited to, the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.
  • Personal information that we collect about you when you are acting as our job applicant, employee, owner, director, officer, or contractor to the extent that we collect and use your personal information solely within the context of that role. This also includes your emergency contact information and personal information that is necessary for us to retain to administer benefits for you. However, you will still receive a notice at the time of collection, which outlines the categories of personal information we collect and the purposes for which we collect the categories of personal information.
  • Personal information we receive from you reflecting a communication or transaction between us and another business when you are acting as an employee, owner, director, officer, or contractor of such company, partnership, sole proprietorship, nonprofit, or government agency and you are seeking a product or service from us for the company, partnership, sole proprietorship, nonprofit, or government agency (Business Consumer). We have outlined the limited rights afforded to Business Consumers below.

 

PERSONAL INFORMATION WE COLLECT, USE, OR SHARE
The CCPA requires us to disclose certain information regarding our collection, use, and sharing of personal information.

Collecting Your Personal Information

In the past 12 months, we may have collected the following categories of personal information for business purposes depending on the nature of the interaction with or the services provided by Fennemore Dowling Aaron:

 

  • Identifiers. This may include a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
  • Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)). This may include a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
  • Characteristics of Protected Classification under California or Federal Law. This may include age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  • Commercial Information. This may include records of personal property, products or services purchased, obtained or considered, or other purchasing or consumer history or tendencies.
  • Biometric Information. This may include genetic, physiological, behavioral, or biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, hand or face geometry scan, or other physical patterns, and sleep, health and exercise data.
  • Internet or other similar network activity. This may include browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.
  • Geolocation data. This may include physical location or movements.
  • Professional or employment-related information. This may include current or past job history or performance evaluations.
  • Non-public education information. This may include education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information or student disciplinary records.
  • Inferences drawn from other personal information. This may include profiles reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

 

In the past 12 months, we have collected personal information from the following categories of sources:

  • You as a consumer
  • Data analytics services.
  • Service providers.
  • Lead generation services.

 

We may collect your personal information for the following business or commercial purposes:

  • Account Services. We use personal information to offer our account services, including: (1) establishing, maintaining, supporting, and servicing an account you may have opened with us and for which you provided the information or that you may have applied for or established with us; (2) providing services, products, or information you may have requested from us; and (3) performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on our own behalf or on the service provider’s behalf.
  • Security and Fraud Detection. We use personal information for our security and fraud detection services including: detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
  • Debugging. We use personal information to engage in debugging to identify and repair errors that impair existing intended functionality.
  • Improvement of Products and Services. We use personal information to verify, maintain, and improve our products and services.
  • Internal Research. We use personal information for our internal research related to technological development and demonstration.
  • Advertising and Marketing Services. We use personal information to provide advertising or marketing services on our own behalf.
  • Legal Obligations. We use personal information to comply with legal obligations.
  • Audits. We use personal information to audit current interactions with you and related transactions (e.g., counting and verifying ad impressions, auditing compliance).
  • Merger/Acquisition/Bankruptcy, etc. We may use your personal information as part of a merger, acquisition, bankruptcy, or other transaction where a third party assumes control of us.
  • Commercial/Economic Interests. We use personal information to advance our commercial or economic interest.

 

Disclosing Your Personal Information for a Business or Commercial Purpose

We may disclose your personal information to service providers and third parties in order to carry out specific business or commercial purposes. In the preceding 12 months, we have disclosed the following categories of consumer personal information for business or commercial purposes to service providers and the following categories of third parties:

  • Identifiers to data analytics providers and lead generation services.
  • Personal information described in the California Customer Records Statute to lead generation services.
  • Internet or other similar network activity to data analytics providers.
  • Geolocation data to data analytics providers.

 

We do not sell your personal information.

YOUR RIGHTS UNDER THE CCPA
As described in more detail below, the CCPA provides you with certain rights regarding the collection, use, and disclosure of your personal information.

The Right to Know About Personal Information Collected, Used, or Disclosed

You have the right to request that we provide you with certain information about the personal information we collect, use, or disclose about you as well as the categories and specific pieces of information that we have collected about you in the 12 months before your submission of a verifiable consumer request. Specifically, you have the right to request the following information:

  • The specific pieces of personal information we have about you.
  • The categories of personal information we have collected about you, including:
  • The categories of personal information we have collected about you in the past 12 months.
  • The categories of sources from which the personal information about you was collected.
  • Our business or commercial purpose for collecting your personal information.
  • If we shared your personal information:
    • The categories of personal information that we disclosed about you for a business purpose in the past 12 months and, for each category identified, the categories of third parties to which it disclosed that particular category of personal information; and
    • The categories of third parties that we share personal information.
  • If we sold your personal information:
    • Our business or commercial purpose for selling your personal information.
    • The categories of your personal information that we have sold about you in the past 12 months and, for each category identified, the categories of third parties to which it sold that particular category of personal information.

A household may request to know aggregate household personal information by submitting a verifiable consumer request. Also, unless the household has a password-protected account, if all consumers in a household jointly request access to specific pieces of information for the household, we can individually verify the identity of all the members of the household, and we can verify that each member is a current member of the household, then we will comply with the request.

However, there is certain information that we will not disclose to you. This information includes but is not limited to your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics.

The Right to Request Deletion of Personal Information
You have the right to request that we delete any personal information that we have collected from you and maintained about you. Once we receive and confirm your verifiable consumer request, if we determine that we must comply with a deletion request and delete your personal information from our records, we will also direct any service providers we work with to also delete your personal information from their records. If we store any of your personal information in our archives or back-up systems, we will delete your information once the systems are accessed, restored, and/or used.

A household may request the deletion of aggregate household personal information by submitting a verifiable consumer request. In addition, unless the household has a password-protected account, if all consumers in a household jointly request deletion of household personal information, we can individually verify the identity of all the members of the household, and we can verify that each member is a current member of the household, then we will comply with the request.

Please note that we may deny your deletion request for a number of different reasons, which are identified in the CCPA.

This right does not apply to Business Consumers.

 

EXERCISING YOUR RIGHTS UNDER THE CCPA

Submitting a Verifiable Request to Know or Request to Delete

To exercise your Right to Know or your Right to Delete, please submit a verifiable consumer request to us by either:

 

 

To submit a verifiable consumer request, you (or your authorized agent) will be asked to provide identifying information that enables us to verify you with information in our system.

Only you (or an authorized agent) may make a verifiable consumer request. You may also make a verifiable consumer request on behalf of your minor child.

NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights.

SHINE THE LIGHT LAW
California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding the disclosure of Personal Information to third-parties, including our information sharing practices, including the names and addresses of those businesses with whom we have shared your Personal Information, for direct marketing purposes. To make such a request, please contact us pursuant to the Contact Us section of this Privacy Policy.

CONTACT US
If you have any questions regarding our privacy policies, our California Privacy Statement, the ways in which we collect, use, disclose, and sell your personal information, or how to exercise your rights under the CCPA, please do not hesitate to contact us at:

Fennemore Dowling Aaron LLP
Attn: Privacy Officer
8080 North Palm Ave
Third Floor
Fresno, CA 93711
privacyofficer@fennemorelaw.com
[1-833-522-0655]