Privacy Policy: Constangy, Brooks, Smith & Prophete, LLP

Constangy, Brooks, Smith & Prophete LLP (hereinafter referred to as “Constangy,” “us,” “we,” or “our”) has created this Privacy Policy to apply to all users of this website (www.constangy.com) including any information contained, or offered therein (collectively, our “Services”). This Privacy Policy describes, among other things, the types of Information we collect from users when you use our Services, how we use it, and how you can access your Information. This Policy does not apply to any of the legal services provided by Constangy.

This Privacy Policy is integrated into our Terms & Conditions of Use (“Terms & Conditions”).

By using the Services and providing us with your personal Information (defined below), you agree to the practices described in this Privacy Policy and Terms & Conditions referenced below and to the updates to these policies posted here from time to time.

This Privacy Policy does not apply to information collected by or provided in connection with an individual’s application for employment, current or former employment, or independent contractor arrangements with Constangy. If you are a Constangy employee, independent contractor, or applicant for employment, please see the Constangy Employee Privacy Notice or Constangy Prospective Employee Privacy Notice for information about how Constangy collects, uses, processes, discloses, shares, and retains employment information not covered by this Policy.

I. INFORMATION WE COLLECT ABOUT YOU

We may collect the following types of Information about you which are described in more detail below: (A) information you provide to us, (B) information we may automatically collect, and (D) information we may receive from third parties. All of the Information listed in (A)-(B), (D) above, is detailed below, and hereinafter referred to as “Information.”

A. Information You Provide to Us

In using our Services, you may provide us with Information, including, without limitation:

Individual identifiers such as name, company name, title/position, contact information such as mailing address, phone number, and email address;
Communications with us and other Information you provide to us such as any messages (including via online forms), information about your opinions and feedback that you provide to us, your user preferences (such as in receiving updates or marketing information), and other Information that you share with us when you contact us directly (such as for customer support services);
Contact preferences and interests;
Business affiliations;
For events, it may include dietary restrictions, requested accommodations and other event-related preferences;
If you register for, attend, or participate in CLEs that we make available, we may collect your state Bar Number and other information necessary for CLE credit and reporting purposes; and
Additional Information as otherwise described to you at the point of collection or pursuant to your consent.

Sensitive Personal Information. We may need to collect or process Information that is deemed “Sensitive Personal Information” under certain laws. Sensitive Personal Information that we may collect, or process include:

Payment Information including debit or credit card information in combination with any required security or access code collected for purpose of processing payment for our products or Services. Please note that all financial transactions conducted in connection with orders placed are securely and directly collected and processed by our third-party payment processor(s). We do not store any credit card information from such transactions.

When required by applicable law, Constangy will collect consent prior to processing certain categories of sensitive Information.

B. Information We May Automatically Collect About You

We may automatically collect the following categories of usage and technical Information about you. This Information is used by Constangy for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the Services. This Information may include:

IP address, which is the number associated with the service through which you access the Internet, like your ISP (Internet service provider);
Date and time of your visit or use of our Services;
Domain server from which you are using our Services;
Type of computer, web browsers, search engine used, operating system, or platform you use;
Data identifying the web pages you visited prior to and after visiting our website or use of our Services;
Demographics, such as gender and age;
When an app opens or updates;
Session duration;
Geographical location;
Duration of attendance of any webinars;
Information related to business development activities with clients and leads, such as phone calls, emails, and meetings;
Your movement and activity within the website, which is aggregated with other information; and
Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”).

C. Cookies & Technologies Used to Collect Information About You

We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications. We may collect this Information by using certain technologies, such as cookies, web beacons, pixels, software developer kits, third-party libraries, and other similar technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons.

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
Web Beacons. Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf. Our Services use retargeting pixels from Google, Facebook, and other ad networks. We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.
Analytics. Analytics are tools we may use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. You can view Google’s Privacy Practices here: Privacy Policy – Privacy & Terms – Google.
Marketing Platforms. These are platforms that we may use for different marketing and communication needs such as to communicate with our clients and prospective clients, to send out blog email notifications, to host our firm webinars, for lead generation and tools for tracking website visitors.

D. Information We May Receive from Third Parties

We may collect additional Information about you from third party websites, social media platforms, and/or sources providing publicly available information (e.g., from the U.S. postal service) to help us provide services to you, help prevent fraud, and for marketing and advertising purposes.

This Privacy Policy only applies to Information collected by our Services. We are not responsible for the privacy and security practices of those other websites or social media platforms or the Information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, social media platform, and/or content.

II. HOW WE USE YOUR INFORMATION

A. Use and Purpose of Processing Your Information

We use and process your Information for things that may include, but are not limited to, the following:

To provide you with the Services and information you request;
To respond to your inquiries and questions and provide customer service;
For general or targeted marketing and advertising purposes, including sending you at your request, promotional material, such as newsletters, client alerts, and information that may interest you, provided that you have not already opted out of receiving such communications. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them;
To manage, improve, and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;
To maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and services;
To comply with our Terms & Conditions;
Analytics for business purposes and business intelligence;
To comply with any applicable laws and regulations and respond to lawful requests; and/or
For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.

We may also use Information that has been de-identified and/or aggregated for purposes not otherwise listed above.

B. Disclosing Your Information

We may disclose your Information as set forth in the Privacy Policy and in the following circumstances:

Third-Party Service Providers. We may disclose your Information to third-party service providers that perform certain functions or services on our behalf (such as to host the Services, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us). These third-party service providers are authorized to use your Information only as necessary to provide these services to us. In some instances, we may aggregate Information we collect so third parties do not have access to your identifiable Information to identify you individually.
Disclosure of Information for Legal and Administrative Reasons. We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property, or safety of us, our subsidiaries and affiliates, and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and/or (vi) to verify the identity of the user of our Services.
Business Transfers. Your Information may be transferred, sold, or otherwise conveyed (“Conveyed”) to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize.
CLEs. Your Information may be disclosed to content providers we partner with to make available CLEs, training, and other content or resources. We do not share your Information with them for their own independent use; however, if you register for an account with one of these third parties, they will use the information you provide to them subject to their own privacy policy and terms.
Professional Services. We may disclose your Information to our professional advisors, such as lawyers and accountants, as needed.
De-Identified or Aggregated Data. We may disclose your Information on an aggregated basis for any purpose in which your specific personal Information is blinded, masked, or otherwise not identifiable.
With Your Consent. We may disclose Information consistent with this Privacy Policy with your consent.

Constangy does not use or disclosure Sensitive Personal Information, other than for the business purposes permitted by law as described above.

C. Sale and Sharing of your Personal Information

For purposes of this Privacy Policy, “sell,” “sold,” or “sale” means the disclosure of personal Information for monetary or other valuable consideration but does not include, for example, the transfer of personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business, whereas “sharing” means disclosing or making available personal Information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal Information to third parties in exchange for monetary compensation, we may disclose personal Information such as identifiers and Internet and network activity information, to third-party advertising networks and analytics providers for purposes of marketing and advertising and to improve and measure our ad campaigns. Such disclosures may be considered “sales” or “sharing” of personal Information under applicable law. We do not sell or share Sensitive Personal Information, nor do we sell or share personal Information about individuals we know are under the age of sixteen (16).

III. YOUR CHOICES

A. Marketing Communications.

If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt out of marketing email communications or see How to Contact Us below for more information.

B. Opting Out of Direct Marketing by Constangy.

We may send periodic promotional emails to you, and where required by law, we will obtain your consent to do so. You may opt out of such communications at any time by following the opt-out instructions contained in the email or email us at privacy@constangy.com. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

C. Opting Out of Direct Marketing by Third Parties.

To exercise choices regarding the marketing information you receive, you may also review the following links:

You may opt out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at aboutads.info/appchoices.
You may opt out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.
You can opt out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

IV. RIGHTS UNDER APPLICABLE DATA PROTECION LAWS

Residents of certain U.S. states may have rights and choices regarding their Information. To the extent any data protection law applies to our collection of your Information, this section outlines the individual rights you may be entitled to. Depending on where you live and subject to certain exceptions, you may have some or all of the following rights.

Right to Know and Access. You may have the right to request that we confirm whether we process your Information, disclose certain Information to you about our collection and use of your Information, including whether we sell or share your Information, and provide you access to your Information we may process.
Right to Data Portability. Where the processing is carried out by automated means, and subject to certain exceptions, you may have the right to request and obtain a copy of your Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Information to another data controller without hindrance.
Right to request Correction of Inaccurate Information. To the extent that we may maintain inaccurate Information, you may have the right to request that we correct such inaccurate Information taking into account the nature of the Information and the purposes of the processing of the personal Information.
Right to Request Deletion. You may have the right to request that we delete certain of your Information provided by or obtained about you, with certain exceptions and limitations as allowed under law.
Right to Opt-Out of the Sale and Sharing of Personal Information. You may have the right to opt out of the processing of your Information for the purpose of selling or sharing of your Information for cross-context behavioral advertising. To the extent that our use of certain online tracking technologies is deemed to be a “sale” or “sharing” under certain data protection laws, you may opt out of these online tracking technologies.
Right to Opt-Out of the use of Information for Targeted Advertising and Profiling. You may have the right to opt out of the processing of your Information for purposes of targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Right to Limit Use and Disclosure of Sensitive Personal Information. You may have the right to request that we limit the ways we use and disclose your Sensitive Information to uses which are necessary for us to perform the Services, or deliver the goods reasonably expected by you, or and as authorized by law. As noted elsewhere we do not use or disclose your Information other than for the permitted business purposes outlined above.
Right to Non-Discrimination. You may have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We will not discriminate against you for exercising any of your rights in this section including denying goods or Services, charging different prices or rates for goods or Services, or providing a different level of quality of goods and Services. However, we may offer a different price, rate, level, quality, or selection of goods or Services, including offering goods or Services for no fee, if you have exercised your right to opt out or the offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
Right to Disclosure of Direct Marketers. You may have a right to know the categories and names/addresses of third parties that have received personal Information for their direct marketing purposes upon simple request, and free of charge.
Right to Appeal. You may have the right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit an appeal request via the information in the How to Contact Us. Within the certain timeframe of receipt of your appeal, as proscribed by the applicable law we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may contact the Attorney General or another authority which we will help you identify.

To learn more about whether you are guaranteed certain rights, or to submit a request to exercise your rights, please contact us using any of the methods in the How to Contact Us section.

V. EXERCISING YOUR DATA SUBJECT RIGHTS

To exercise any of the rights described above, please submit a verifiable request to us via the methods described below. The verifiable request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Information, or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To help protect your privacy and maintain security, if you request access to or deletion of your Information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your Information or complying with your request. In addition, if you ask us to provide you with specific pieces of Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Information is the subject of the request. Only you or, as permitted by certain data protection laws, your authorized agent may make a verifiable consumer request related to your Information. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above). You may also make a verifiable consumer request on behalf of your minor child.

Email us: privacy@constangy.com

Call us: 1-800-529-7054

Write us: 230 Peachtree Street NW, Suite 2400

Atlanta, GA 30303-1557
United States

VI. LINKS TO OTHER WEBSITES

Our Services may contain links to other websites or services that are not owned or controlled by us, including links to social media platforms such as Facebook, Instagram, or YouTube, or may redirect you off our website away from our Services.

VII. INFORMATION SECURITY

We use commercially reasonable and appropriate administrative, physical, and technical security measures to provide our Services and safeguard your Information. However, no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.

If you believe that your Information has been accessed or acquired by an unauthorized person, you should promptly Contact Us so that necessary measures can quickly be taken.

VII. DATA RETENTION

We will retain your Information for as long as needed to provide you Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted to us. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.

IX. GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING

Our Services are targeted to individuals located in the United States. As such, the Services collect Information and process and store that Information in databases located in the United States. If you are visiting the Services from a country outside the United States, you should be aware that you may transfer personally identifiable Information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Services and submitting any personally identifiable Information, you consent to the transfer of such personally identifiable Information to the United States.

X. CHILDREN’S INFORMATION

The Services are intended only for users over the age of sixteen (16). If we become aware that a user is under sixteen (16) (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such Information. Contact us if you believe that we have mistakenly or unintentionally collected Information from a child under the age of sixteen (16).

XI. DIFFICULTY ACCESSING OUR PRIVACY POLICY

Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to inquire how they can obtain a copy of our policy in another, more easily readable format.

XII. “DO NOT TRACK” SIGNALS

We do not support “Do Not Track.” Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser. Do Not Track is different from Global Privacy Controls (“GPC”), which may notify websites of consumers’ privacy preferences regarding the sale or sharing of personal Information, or the use of Sensitive Personal Information.

XIII. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change, modify, or amend this Privacy Policy at any time to reflect changes in our products and service offerings, accommodate new technologies, regulatory requirements, or other purposes. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting. It is your obligation to check our current Privacy Policy for any changes.

HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Information we have collected about you, please contact us at the following:

Email us: privacy@constangy.com

Call us: 1-800-529-7054

Write us: 230 Peachtree Street NW, Suite 2400

Atlanta, GA 30303-1557

United States

Effective Date: December, 2023