ADVOS | Strategy + Law 

Privacy Matters


Last updated October 2, 2018

Introduction

Well, hello there! Welcome to our Website. Allow us to introduce ourselves: We are ADVOS legal pllc (or “ADVOS” to our friends, or “Company” “We,”Us” or “Our”), a Florida limited liablity company, and we do things a little differently. We help our clients grow their businesses by providing strategic legal counsel and turning the traditional law firm model on its head. You can read more about us on our Website (“Website” or “Site”) https://www.advoslegal.com/, which this Privacy Policy (“Policy”) governs.

This document sets forth a lot of legalese, which makes sense: after all, we are a law firm. However, this document is more about you; it’s to describe how we value and respect Your privacy and are committed to protecting it through Our compliance with this Policy.

Specifically, this Policy describes the types of information We may collect from you (“You” or “Your”) or that You may provide when You visit the Site as well as Our practices for collecting, using, maintaining, protecting, and disclosing that information. Finally, this Policy covers Our processing activities as a data controller under the General Data Protection Regulation (EU) 2016/679.

This Policy applies to information We collect:

  • On the Site; and
  • In email, text, and other electronic messages between You and the Site.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
  • Us offline or through any other means; or
  • Us through any other Site or website operated by the Company or any third party (including Our affiliates and subsidiaries).
  • any third party (including Our affiliates and subsidiaries), including through any application or content (including advertising) that may link to any of the Site.
  • Us that You may provide in the context of an attorney-client relationship or related to payment processing.
  • Web Beacons. Pages of the Site and Our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Site statistics (for example, recording the popularity of certain content on the Sites and verifying system and server integrity).
  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when Cookies are being sent. To learn how you can manage your “Flash Cookies” settings, visit the Flash Player settings page on Adobe’s website. If you disable or refuse Cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Promotional Offers from the Company. If you do not wish to have your email address or contact information used by us to promote our own or third parties’ products or services, you can opt-out by emailing support@advoslegal.com or if we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request to support@advoslegal.com.
  • You can opt out of the behavioral targeting component of online ads by consulting the Digital Advertising Alliance at http://www.aboutads.info/choices/ or the Network Advertising Initiative (“NAI”) at http://www.networkadvertising.org/choices/. If you delete your cookies, though, you must opt-out again through the Digital Advertising Alliance of Network Advertising Initiative after said cookie deletion.
  • For all users of the Site, you may send us an email at the email address listed in the “Contacts” section of this document to request access to, correct, or delete any Personal Information that you have provided to us, or any other information relating to you. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Absent our receipt of written notice from you making a request described in this section, which you are responsible for verifying that we received, we are not under any obligation to update or change any Personal Information that is out of date or inaccurate, or any other information relating to you or your profile, and disclaim any liability, to the fullest extent allowed by law, for failing to do so.

It does not apply to information collected by:

Please read this Policy carefully to understand Our policies and practices regarding Your information and how We will treat it. Because we respect Your privacy, We have to implement a strict If-You-Don’t-Agree-with-the-Policy-Come-Back-When-You-Do policy. In other words: by accessing or using any of the Site, You agree to this Privacy Policy, which may change from time to time (see Changes to Our Privacy Policy). We also note that your continued use of the Site after we make any changes means you agree to what we have done differently, so please check the Policy periodically for updates.

Under current data protection laws, we are not required to appoint a Data Protection Officer. However, we have appointed a Data Protection Contact who you may contact with questions in relation to this Privacy Policy.

CONTACT

If you have any questions about our Privacy Policy or your personal information, or you wish to exercise any rights described in this policy or pursuant to data protection laws, contact:

Lauren Kiley
ADVOS legal pllc
Strategic Legal Counsel
5000 Sawgrass Village Circle, Suite 7
Ponte Vedra Beach, Florida 32082
By email: lauren.kiley@advoslegal.com
Phone: 904.567.5311

No Attorney-Client Relationship

Please understand that all information and materials provided on this site are solely for educational or informational purposes, and are not legal advice, legal opinions, or any other type of advice regarding your specific facts or circumstances. While we are thrilled you have visited our Site, any browsing, transmission, or request for information on this site does not form an attorney-client relationship with ADVOS or any of its attorneys.

Children Under the Age of 13

Our Site is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Site. We do not knowingly collect Personal Information (defined below) from children under 13. If We learn We have collected or received Personal Information from a child under 13 without verification of parental consent, subject to applicable law, We will either 1) delete that information, or, 2), pursuant to the Children’s Online Protection Act, obtain verifiable parental consent. If You believe We might have any information from or about a child under 13, please contact Us . See the “Contact” Information section above.

Adherence to GDPR

ADVOS adheres to the following guidelines while processing your data.

  1. Lawfulness, fairness and transparency. Data must be processed lawfully, fairly, and in a transparent fashion.
  2. Purpose limitation. Data is collected for specified, explicit, and legitimate purposes.
  3. Data minimization. Data collected on a subject should be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  4. Accuracy. Data is accurate and where necessary kept up to date.
  5. Storage limitations. Data is in a form which permits identification of data subjects for no longer than necessary.
  6. Integrity and confidentiality. Data is processed in a manner that ensures appropriate security of the personal information, including protection against unlawful processing or accidental loss, destruction or damage.

Information We Collect About You and How We Collect It

Personal information, for purposes of this Policy, is information that can be used to identify You either directly or indirectly. Personal information does not include data where the identify has been removed (anonymous data). While you are not required to provide any personal information on any areas of the Site, You may choose to provide us with personal information as you interact with our Site. If we combine or connect data that does not directly or indirectly identify You with personal data so that it can directly or indirectly identify You, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We collect and store information from and about users of Our Site, including personal information:

  • by which You may be personally identified, such as name; company name, job title and company name, size, location, and industry; postal address, e-mail address, telephone number, or other personally identifiable information by applicable law or any other identifier by which You may be contacted online or offline.
  • about Your internet connection and the equipment You use to access Our Site.

We also collect information that is about You, such as usage history from the Site.

We collect this information:

  • Directly from You when You provide it to Us;
  • Automatically as You navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and information collected through cookies, web beacons, and other tracking technologies; and
    From third parties, for example, Our business partners.

We do not, as a standard practice, attempt to collect sensitive personal information or data through our Site. For purposes of this Policy, sensitive personal information is information relating to racial origin, ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health, sex life, sexual orientation, genetic or biometric information. Before collecting any sensitive personal information, we will ask for our explicit consent as required by law for our proposed use of that information at the time of collection.

Information We Collect.

The information We collect and store on or through Our Site may include:

  • Information that You provide on Our Site by uploading forms or documents or inputting information. This includes information provided at the time of registering to use Our Site, if applicable; posting or uploading material; or requesting further services. We may also ask You for information when You report a problem with Our Site;
  • Records and copies of Your correspondence (including email addresses), if You contact Us;
  • When you sign up to receive emails or other communications;
  • Your search queries on the Site;
  • Anonymous details of Your visits to Our Site that do not identify you directly or indirectly, including statistical information such as traffic data, location data, logs, and other communication data concerning how you use our Site and information linked to a cookie identifier or other identifier not paired in our system with your identifiable information or data, including your name, phone number, or email address; and
  • Information about Your computer and internet connection, including Your IP address, operating system, and browser type, information regarding the content you view and features you access on the Site.

We may also may use these technologies to collect information about Your online activities over time and across third-party websites or other online services (behavioral tracking). At this time, the Site is not set up to honor web browser do-not-track settings or other similar mechanisms.

Other Websites

The Site may contain links that connect you to and from websites of third parties including advertisers and other affiliates. If you click on or follow the links to any of those websites, please note that those parties’ websites have their own privacy policies. ADVOS disclaims any liability or responsibility for those websites’ privacy policies or data collection practices. It’s smart to review the content of those policies before you submit Personal Information to those websites.

Third Parties

Our third-party service providers may collect your Personal Information or information that does not identify you from our Site. We require each third party with whom we contract to assist in administering a product or service to agree in writing to abide by the same privacy standards we do.

How We Use Your Personal Information

We only use information that We collect about You or that You provide to us, including any Personal Information or Data, when allowed by law. We will use your personal information or data, and the legal basis for which we carry out each type of processing, as follows:

Purpose/activity for which we will process
The information
Lawful basis for processing including basis of
legitimate interest
To enable you to access information on and register for our Sites It is in our interests to provide services to you and register you on our Site at your request.
To manage our relationship with you which will include:
(a)Notifying you about changes to our terms or privacy policy< (b) Asking you to leave a review or take a survey (c) enforcing the terms of our Term of Use (d) enforcing the terms of this Privacy Policy; (e) enforcing the terms of any contract entered into with You.
It is in our legitimate interests to:
(a) perform pursuant to the terms of a contract with You
(b) keep our records updated and to study how customers use our products/services
(c)-(e) to comply with a legal obligation and enforce our rights under contract(s) with You
To send you newsletters, e-announcements, and other Communications concerning ADVOS news It is in our legitimate interests to promote our services to existing customers.
To administer, protect, and improve our business and this website(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) It is in our legitimate interests to improve and police our site and services to ensure the security of information transmitted on this Site and to run our business, effectively. This monitoring may also be necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
To make suggestions and recommendations to you about goods or services that may be of interest to you To assist law enforcement or other regulatory bodies or legal Process in any investigations relating to suspected illegal or wrongful activity,and to protect our rights, property, and safety, or the rights, property, and safety of third parties. Necessary for our legitimate interests (to develop our products/services and grow our business) It is in our legitimate interests to cooperate in any investigations relating to illegal or wrongful acitivity and to protect our rights or the rights and remedies of third parties.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Please note that you may withdraw consent at any time and free of charge, but that withdrawal does not affect the lawfulness of processing based on consent before you withdrew it. You can update your details and change you privacy preferences by contacting us as provided in the “Contact” section on the first page of this document.

MARKETING

You may receive marketing materials or communications from us if You have requested information from us or registered to use the Site and, in each case, where you have not opted out of receiving that marketing.

You have the right to opt out of receiving marketing communications at any time by contacting us pursuant to the “Contact” section set forth above.

Disclosure of Your Information

We only share your personal information as provided in this Privacy Policy, and to the extent allowed by law. We may, but are not obligated to, share your personal information with the following third parties:

  • To Our subsidiaries and affiliates to carry out the purposes for which the information was provided;
  • To contractors, service providers, and other third parties We use to support Our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which We disclose it to them;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about Site users is among the assets transferred.

Additionally, ADVOS may disclose information about you:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • To enforce the terms of this Privacy Policy or the Terms of Use or to exercise or defend our rights in any legal process;
  • If necessary to protect the interests of a third party.

We may disclose aggregated information about Our users, and information that is not personal information, without restriction.

INTERNATIONAL TRANSFERS

If you are located in the European Economic Area (“EEA”):

To deliver services and products to you, we must transfer your Personal Information outside of the EEA to our affiliated firms and our third-party service providers located in the United States of America (USA)

You hereby consent to the transfer of your Personal Information from the EEA to the USA. Please note that the European Commission has determined that allowing non-EU data controllers who are not members of the U.S.-E.U. Privacy Shield to transfer personal data from the EEA to the USA present risks to the security of your personal data. The Commission has assessed this risk based on its failure to determine that the United States ensures an adequate level of protection and safeguards for personal data in accordance with Article 45 of the GDPR.

COOKIES AND ANALYTICS

The technologies We or Our Third-Party Service Providers use may include:

  • 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 Site. 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 Site.
  • Flash Cookies. Certain features of Our Site may use local stored objects (or Flash cookies) to collect and store information about Your preferences and navigation to, from, and on Our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing Your privacy and security settings for Flash cookies, see Choice Regarding How We Use and Disclose Your Information.

Choices Regarding How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. To that end, We have created mechanisms to provide you with the following control over your information:

Accessing and Correcting Your Information

Data Security

We have implemented physical, technical, and organizational security measures designed to protect Your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information You provide to Us is stored on Our secure servers behind firewalls.

The safety and security of Your information also depends on You. Where We have given You (or where You have chosen) a password for access to certain parts of Our Sites, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone. We attempt to ensure that any third-party vendors that process Personal Information put adequate security measures in place to ensure the security of your Personal Information.

Unfortunately, however, the transmission of information via the internet is not completely secure. Although We do Our best to protect Your Personal Information, We cannot guarantee the security of Your Personal Information transmitted on or to Our Site. Any transmission of Personal Information is at Your own risk. We are not responsible for circumvention of any privacy settings or security measures contained the Sites.

How Long We Retain Your Personal Data

We will retain your Personal Information only as long as reasonably necessary to fulfill the purposes for which it was collected, including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain Your Personal Information longer in the event of a complaint. Nothing herein shall alter the obligations that We have under the Rules of Professional Responsibility related to the attorney-client relationship.

YOUR RIGHTS

REQUEST ACCESS TO YOUR PERSONAL DATA

You have the right to access your personal information. You may do so here [INSERT LINK TO DATA SUBJECT ACCESS REQUEST][A1] . You may also have the right to receive personal information you provided to us in a commonly used and structured format in order for it to be transferred to another data controller. This right applies if your personal data is processed by us with your consent. It also applies for the performance of a contract and when processing is carried out by automated means.

REQUEST CORRECTION OF YOUR PERSONAL DATA

You may ask us to correct or remove any data that is inaccurate by contacting us as provided in the “Contacts” section at the top of this document. Please keep us informed if your personal information changes during your engagement, relationship, or contact with us.

REQUEST ERASURE OF YOUR PERSONAL DATA

In certain circumstances, You may request the erasure of your personal information, which is referred to as the right to be forgotten.

OBJECT TO PROCESSING OF YOUR PERSONAL DATA

You may object to processing your personal data for direct marketing purposes. You also have the right to object at any time to processing of your personal information which is based on our legitimate interests, pursuant to grounds relating to your particular situation. If you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for such processing, and those grounds override your interests, rights, and freedoms; or, to establish, exercise, or defend legal claims.

REQUEST RESTRICTION OF PROCESSING YOUR PERSONAL DATA

You may restrict the processing of your personal information to processing in certain circumstances.

REQUEST TRANSFER OF YOUR PERSONAL DATA

You may request the transfer of your personal data to you or to a third party. We will provide to You, or a third party You have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

RIGHT TO WITHDRAW CONSENT

You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You can exercise any of your rights as described in this Privacy Policy and under applicable data protection laws by contacting us as provided in the “Contact” section above.

Except as described in this Privacy Policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.

Changes to Our Privacy Policy

It is Our policy to post any changes We make to Our Privacy Policy on this page with a prominent notice that the Privacy Policy has been updated on the Site’s home page prior to the change becoming effective. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting Our Website and/or Sites and this Privacy Policy to check for any changes, as they are binding on You. Your continued use of any Site is subject to the revised Privacy Policy.

Complaints

To ask questions, concerns, or complaints about this Privacy Policy and Our privacy practices, please send Us an email, writing “Privacy Policy” in the subject line, to the “Contacts” section at the beginning of this document. If you are in located in the EEA, you also have the right to complain to the relevant supervisory authority in the EEA.