INFORMATION WE COLLECT DIRECTLY FROM YOU
We collect personal information about you when you interact with our Sites, including the following:
|Data Collected||Purpose of Collection|
|Any information you provide to us by email or otherwise, including your name, address, email address, telephone number, and company name, when you contacted us, and the contents of your communication||To provide and communicate with you about our services; to send you further information regarding legal developments, our Sites, and our services; to add you to mailing lists and send you marketing materials we believe may be of interest to you.|
Some or all of the information above may be shared with third parties as set forth below.
We collect certain information by automated means when you visit our Sites, such as how many users visited our Sites and the pages accessed. By collecting this information, we learn how to best tailor our Sites to our visitors. We collect this information through various means such as “cookies” and “web beacons”:
LEGAL BASES FOR PROCESSING INFORMATION
We process this information where we have a legal basis to do so. The legal basis that we rely on may be one of the following:
- The majority of the personal information we collect is provided by you voluntarily on the Sites, for example when you sign up to join a mailing list or register for an event, and is therefore collected with your consent and permission;
- The processing is necessary to perform a contract with you or to fulfill a request you have made;
- The processing is necessary to comply with a legal obligation that applies to the Firm under the law of the European Union (EU); or
- The processing is necessary for purposes that are in the Firm’s legitimate interests in order to, for example, protect our business and better understand our customers.
If you notify us that you do not wish to be contacted for marketing purposes, we will not send you marketing information. Our Sites do not collect personal information about your online activities over time and across third-party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our Sites, and we do not alter any of our data collection and use practices upon receipt of such a signal.
INFORMATION WE SHARE
We will not share your information with third parties outside of the international affiliation of Zlatkin Wong without your consent, except as follows:
- Where we are required to by virtue of a legal, regulatory or professional obligation;
- With third parties who perform services on the Firm’s behalf. For example, we share information with vendors, such as those that provide systems, web hosting (including microsites), IT services, marketing support and other internal / external advisors. We may authorize them to collect information on our behalf. Some vendors may be located outside of the United States;
- In accordance with our engagement terms, where you are a client of Zlatkin Wong;
- To law enforcement authorities or other government officials;
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
- If necessary to protect the vital interests of a person;
- To protect our property, services, and legal rights;
- To prevent fraud against the Firm, our affiliates, business partners, or authorized dealers; or
- To support auditing, compliance, and corporate governance functions.
Any such third parties are not authorized by us to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements. These third parties have no independent rights to the data.
LINKS TO OTHER WEBSITES
The Sites may provide links to other websites for your convenience and information. These websites may operate independently from our Sites. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not part of this website, we are not responsible for their content, any use of the websites, or the privacy practices of any of those websites.
INFORMATION WE TRANSFER
EUROPEAN UNION RESIDENTS’ RIGHTS
Natural persons located in the European Union have the right to request access to the personal information we have collected about you for the purposes of reviewing, modifying, or requesting erasure of the information. EU residents also have the right to request a copy of the information we have collected about you. In certain situations, you may also request that we restrict or cease processing your information.
If you would like to make a request to access, review, or correct the personal information we have collected about you, please contact us at email@example.com.
To help protect your privacy and security, we will take reasonable steps to verify your identity before granting access to your information.
EU residents will be notified of any actions taken on your personal information in response to a request submitted for modification, deletion, or restrictions on the processing of your personal information.
When data processing is based on your consent as a resident of the EU, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal. You also have a right to data portability when the data processing is based on a contract between you and the Firm and the data was processed by automated means. You may exercise these rights by submitting a request to firstname.lastname@example.org.
EU residents have the right to lodge a complaint with the appropriate privacy or data protection regulator in your jurisdiction.
HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical, and physical safeguards to protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide when visiting or using the Sites.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California law provides you with certain rights. California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal information by us to third parties for those third parties’ direct marketing purposes. To make such a request, please send a detailed description of the specific content or information to email@example.com or send written request to Management, Zlatkin Wong LLP, 4245 N. Knox, Chicago IL 60641. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal, even when requested.
Beginning on January 1, 2020, pursuant to California Civil Code 1798.100 et seq., the California Consumer Privacy Act of 2018 (“CCPA”), California residents have the following, additional rights:
Your Right to Access to Specific Information and Data Portability. You may request that we disclose certain information to you about our collection and use of your personal information in the past 12 months. Once we receive and confirm your personal information request, we will disclose to you:
- The categories and specific pieces of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting that personal information;
- The categories of third parties with whom we share that personal information; and
- If we sold or disclosed your personal information for a business purpose, two separate lists identifying: (a) the categories of your personal information collected and sold, and the categories of the third parties to whom the data was sold; and (b) the categories of your personal information that was disclosed for business purposes.
To make such a request, please send an email with a detailed description of your request to firstname.lastname@example.org.
Your Right to Request Deletion. You may request that we delete any of the personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your personal information request, we will delete such personal information from our records, unless an exception applies.
We may deny your request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information; provide a good or service that you requested; take actions reasonably anticipated within the context of our ongoing business relationship with you; or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with California Penal Code Section 1546 et seq. (the California Electronic Communications Privacy Act);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Your Right to Opt-Out of Sale. We do not sell personal information to third parties. If that should change, we will make available to you a method to opt-out of such sale.
Exercising Your CCPA Rights. To exercise any of the CCPA rights described above, please submit a verifiable personal information request to us by:
- Calling us at 312-809-6989;
- Emailing us at email@example.com; or
- Writing to us at the mailing address provided below.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may submit a personal information request. You may also make a personal information request on behalf of your minor child.
You may only submit two personal information requests within a 12-month period. The verifiable personal information request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or an authorized representative. For a request by the actual person, we will typically require a copy of a valid state-issued identification card, together with any email or physical address you have submitted to us. For an authorized representative, we will typically require a copy of the registration with the California Secretary of State referenced above, a valid power of attorney or a court appointment document; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Response Timing and Format. We endeavor to respond to a personal information request within 45 days of our receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. If provided electronically, we will select a format to provide your personal information that is in a portable and readily useable format. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your personal information request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Your Right to Non-Discrimination. Unless permitted or required by law, if you exercise any of your rights under the CCPA, we will not:
- Deny you our services;
- Charge you different prices or rates for our services;
- Provide you a different level or quality of services; or
- Suggest that you may receive a different price or rate for services, or a different level or quality of services.
RETENTION OF INFORMATION
We retain all personal information for the duration of the relevant business relationship or, where required, in accordance with our information management policies and schedules. When deleting personal information based on a request by the data subject, we will make reasonable attempts to ensure that all instances of the information are deleted in their entirety. For requests for access, corrections, or deletion, please refer to the “European Union Residents’ Rights” section of this policy.
Zlatkin Wong maintains necessary documentation to demonstrate compliance with its obligations and to allow audits, including inspections, to be carried out by the Firm or another auditor it has mandated.
We shall keep a written data processing activity register, listing data processing activities by category.
HOW TO CONTACT US AND MAKE REQUESTS
BUSINESS STRUCTURE CHANGES
We reserve the right to disclose and transfer all information related to our Sites, including personal data:
- To a subsequent owner, co-owner, or operator of one or more of the Sites; or
- In connection with a merger, consolidation, restructuring or other transaction involving the Firm, including without limitation, during the course of any due diligence process.
Our site is a general audience site not directed at children under the age of 16. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 16, we will promptly delete the information.
Effective Date: February 23, 2020