We respect your privacy.
1. HOW WE PROTECT YOUR INFORMATION
We take reasonable measures to protect your personally identifiable information (“Personal Information”) to prevent against unauthorized use, access, disclosure, and destruction. Your name and email address, along with other information that can be used to identify you, constitute your Personal Information. Please be aware that, despite our best efforts, security measures are not impenetrable, and we can’t guarantee against misuse.
2. WHAT INFORMATION WE COLLECT
If you choose to contact us through the Website or by email through an email address provided on our Website, we’ll collect your contact information, such as your name, email address, phone number, or other contact information that you provide to us so we can communicate with you. If you write a message to us, we will store the message so we can reference it to tailor our responses to you. If you inquire about a career opportunity, we will collect and store the information you share related to that opportunity.
If you provide us with payment information through the Website, or create or open an account to process payments through the website, we will collect and store your credit card or bank account information; name and other contact details; and user name and password associated with the account or the payment, as applicable. If you have access to an extranet account through the Website, we will store your user name and password associated with the extranet account.
Website Visitor Data
Directly or through the use of third-party data analytics services (including Google Analytics), we collect visitor information, including your IP address and server log data (the address of the web page you visited before using the Website, your browser type and settings, the date and time of your use of the Website, language preferences). We may gather your information about the device you are using to access our Website, including what type of device it is, what operating system you are using, device settings, application IDs, location, unique device identifiers, and crash data. Other data is collected, including data generated by your use of the Website and links you interact with. Further information on how Google uses data collected by Google Analytics can be found at https://support.google.com/analytics/answer/6004245?hl=en. Information about how to opt out of Google Analytics can be found at https://tools.google.com/dlpage/gaoptout/.
3. HOW WE USE YOUR INFORMATION
- If you communicate with us, we may send you newsletters and marketing information, until you decide to opt out. We may also send you notifications, updates, and changes about our Website, and contact you to provide customer service and support.
- We use your information to operate, manage, and improve our Website, and for marketing and administrative purposes.
- If you provide us with payment information, we will use that information to process payments.
- We may use your Personal Information to improve our programs and services.
- We may use your Personal Information to comply with legal or regulatory requirements; to respond to lawful requests; court orders, and legal process; to enforce our rights; to prevent fraud; to protect the security of the Website; and for safety.
- We may use your IP address and location data to analyze usage, administer our Website, and gather demographic information for aggregate use.
- We may use your Personal Information for employment-related purposes if you make a career-related inquiry.
- With your consent, we may use your Personal Information in other ways.
4. HOW WE SHARE YOUR INFORMATION
5. SOCIAL MEDIA
6. COOKIES AND OTHER TECHNOLOGIES
What are cookies?
A cookie is a small file that can be placed on your computer’s hard disk or on a website server. Cookies do not retrieve information stored on your hard drive and do not corrupt or damage your computer or computer files. For those using our Website, we may link cookie information to your email address to maintain and recall your preferences within the Website.
How to manage cookie preferences
Depending on their purpose, some cookies will only operate for the length of a single browsing session, while others have a longer life span to ensure that they fulfill their longer-term purposes. Your web browser can be set to allow you to control whether you will accept cookies or reject cookies, to notify you each time a cookie is sent to your browser, or to delete cookies that have already been set. If your browser is set to reject cookies, certain aspects of the Website that are cookie-enabled will not recognize you when you return to the Website, and some Website functionality may be lost. The “Help” section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, you may visit http://www.aboutcookies.org.
7. OPT-IN/OPT OUT OF COMMUNICATIONS
Our Website is not directed at nor intended for use by minors. If you learn that a child under 13 has provided us with Personal Information without consent, please contact us. If we become aware that a child under 13 has provided us with his or her Personal Information, we will promptly delete such data.
10. BUSINESS TRANSITIONS
You may have implemented a “do-not-track” signal through your browser. As there currently is no fixed standard for do-not-track signals, we currently do not respond to do-not-track signals from your web browser.
12. DATA RETENTION AND DESTRUCTION
14. CONTACT US
Wiggin and Dana LLP
265 Church Street
New Haven, CT 06510
Attn: Kevin Kennedy
INFORMATION WE COLLECT AS A BUSINESS
We collect the following categories of Personal Information:
|Type of Information||Examples||Collected by Us|
|Commercial information||Records of personal property, products, services purchased, or purchasing histories||Yes, if voluntarily provided through the Website or in connection with our services|
|Biometric information||Genetic, physical, behavioral, or biological characteristics, such as fingerprints, iris scans, voiceprints, health/exercise, or sleep data||No|
|Internet and similar network activity||Browsing history, website analytics, Website interactions. See Sections 2 and 6 of this Policy for details.||Yes|
|Geolocation data||Physical locations and/or movements||No|
|Sensory data||Audio, visual, or similar data related to physical characteristics||No|
|Professional or employment-related information||Current employment or job history||Yes, if voluntarily provided through the Website or an employment application|
|Non-public educational information||Educational records under federal law||No|
|Inferences drawn from other Personal Information||Profiling of preferences, personal characteristics, behavior, attitudes, or aptitudes||No|
1. CATEGORIES OF SOURCES OF INFORMATION WE COLLECT
- With regard to employment inquiries or applications, we may collect your Personal Information from references you provide or from publicly available sources.
- With regard to service inquiries or service delivery, we may collect Personal Information from third parties or from publicly available sources.
OUR USE OF YOUR PERSONAL INFORMATION
2. OUR DISCLOSURE OF PERSONAL INFORMATION
3. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
The CCPA gives certain rights to California residents regarding their Personal Information. To the extent that we are subject to the CCPA, you do not need to have an account with us to exercise these rights.
- Right to Know About the Collection, Use, Disclosure, and Sale of Personal Information
- Upon providing us with a verified consumer request, you may ask us to disclose certain types of your Personal Information we have collected and used over the 12-month period prior to the date of your request. You may make this request only twice within any 12-month period. You may request:
- The categories of Personal Information we collected about you
- The categories of sources of the Personal Information we collected about you
- The business or commercial purpose for collecting that Personal Information
- The categories of third parties with whom we shared that information
- The specific pieces of Personal Information we collected about you (except to the extent prohibited under CCPA including, for example, disclosure of Social Security numbers or other government, health insurance, or medical identification numbers, account passwords)
- If we disclosed your Personal Information for a business purpose, a list identifying the Personal Information we disclosed to each category of recipient.
- Right to Request Deletion of Personal Information
- You have the right to submit a verified consumer request at any time that we delete any of your Personal Information collected and retained by us, unless an exception under the CCPA applies.
- If no exception applies, and if we have been able to verify your consumer request, we will delete, aggregate, or de-identify your Personal Information from our records in accordance with the CCPA. We will also direct third parties to whom we have disclosed your Personal Information to delete it, although we cannot guarantee that such third parties will comply with our direction.
Please note that we may deny your deletion request if your Personal Information based on certain provisions of the CCPA, including where it is necessary for us or our service providers to carry out certain business functions, comply with laws, or to engage in other internal and lawful uses of the information within the context in which you provided it to us.
You also have the right to opt out of (or for minors under 16, the ability to opt in to) sales of your Personal Information. However, we do not and will not sell your Personal Information. If, in the future, we decide to sell Personal Information, we will provide you with notice and the right to opt out of (or for minors, opt in to) such sales.
4. MAKING A VERIFIED CONSUMER REQUEST TO US
To make a request to exercise your rights under CCPA described above, please submit a verifiable request to us by either:
A verifiable consumer request must be made by you or a person registered with the California Secretary of State whom you have authorized to make the request on your behalf. (A representative must be authorized by you in writing or have a valid power of attorney under California probate law.) You may also make a verifiable request to us on behalf of your minor child.
To be considered a proper verified request, your request must:
(1) provide us with sufficient information allowing us to reasonably verify that you are the same person about whom we collected the Personal Information or the authorized representative, and
(2) describe your request in reasonable detail so we can correctly understand, evaluate, and respond to the request.
We may ask you for additional information if needed in order to verify your request, but if we do, we will use such additional information only to verify your identity (or the authority of the representative) and for security and fraud-prevention purposes.
We may also ask you to separately confirm, by email directed to firstname.lastname@example.org, to confirm any request to delete Personal Information.
5. RESPONDING TO YOUR VERIFIABLE CONSUMER REQUEST
We will respond to your verifiable consumer request within the timeframes required by law. We will not be able to fulfill your request if we cannot verify your identity (or the authority of your representative) and confirm that the Personal Information subject to the request relates to you. If we deny part or all of a verified consumer request, we will provide a reasonable explanation for the denial.
We will not discriminate against you for exercising any of your rights under the CCPA. This means that, except where permitted under the CCPA, if you make a request for disclosure or to delete your Personal Information, we will not (i) deny you goods or services, (ii) charge you different prices for goods or services (e.g., through penalties or withholding of otherwise available discounts), (iii) give you a different level of goods or services, or (iv) suggest to you that we will take any of the actions in (i) through (iii).
7. HOW TO CONTACT US TO EXERCISE YOUR CALIFORNIA RIGHTS
This Supplement was last updated on April 15, 2021.