Effective Date: May 30, 2019
1. Introduction and Overview.
If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below.
2. Information Collection.
A. Information You Provide.
We collect information you provide directly via the Service, such as when you register a membership account, update your member profile, access our content, subscribe to our mailing list and newsletter or contact us. This information may include contact data, such as your first and last name, e-mail address, postal address, law firm name, phone number and similar contact data, and the content of messages you send to us, such as your feedback or questions and information you provide to us. You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
B. Information Collected Automatically.
We automatically collect information about your device and how your device interacts with our Service. We may use Service Providers to collect this information. Some examples of information we collect include the following:
We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:
Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.
For further information on Tracking Technologies and your rights and choices regarding them, see the sections entitled “Third Parties” and “Your Rights and Choices” below.
C. Information from Other Sources.
For further information on Third Party Services, see the section entitled “Third Parties” below.
3. Use of Information
We use information about you for our legitimate interests, including to:
We also use information about you with your consent, including to:
We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.
4. Sharing of Information.
We share information about you as follows:
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.
5. Public Information.
Certain areas of the Service, such as user profiles and our blog, are designed to help you share information with the world. If you make information public through our Service, other people will have access to it. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information; however, California residents and European data subjects have additional rights as set forth in “Your Rights and Choices” below.
6. Third Parties.
A. Third Party Services.
B. Third Party Features.
C. Analytics and Interest-Based Advertising.
Our Service contains Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics provides, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide us with other services relating to Service activity and internet usage.
For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.
7. Your Rights and Choices.
A. Review and Update of Account Information.
You may access, update, or remove certain account information that you have voluntarily submitted to us through the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents and European data subjects have additional rights as set forth in the sections entitled “Your California Privacy Rights” and “Your European Privacy Rights” below.
B. Tracking Technology Choices.
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.
You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.
You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the section entitled “Contact Us” below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, servicing, or GALA’s ongoing business relations. Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions.
E. Your California Privacy Rights.
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.
GALA may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that GALA is not required to respond to requests made by means other than through the provided e-mail address or mail address.
Any California residents under the age of eighteen (18) who have registered to use the Service and posted content or information on the Service, can request that such information be removed from the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.
F. Your European Privacy Rights.
If you are a data subject in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority.
The Service is intended for a general audience and not directed to children under thirteen (13) years of age. GALA does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe GALA has collected such information in a manner not permitted by COPPA, please contact us as set forth in the section entitled “Contact Us” below, and we will remove such data to the extent required by COPPA.
8. Data Security.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.
9. International Transfer.
10. Privacy Shield and International Transfer.
GALA will comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the EU and Switzerland to the U.S., respectively. GALA will certify that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability.
In accordance with our obligations under Privacy Shield, and subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission, we hereby affirm our commitment to subject to the Privacy Shield Principles all personal data transferred from the EU and Switzerland in reliance on Privacy Shield. This means that, in addition to our other obligations under the Privacy Shield Principles, we shall be liable to you for any third party agent to which we transfer your personal data and that processes such personal data in a manner that violates the Privacy Shield Principles, unless we can demonstrate that we are not responsible for the resulting damages.
In the event that you have any inquiry, dispute, or claim arising out of or relating to our compliance with Privacy Shield, please contact us as set forth in the section entitled “Contact Us” below. If we are unable to resolve your complaint directly, you may submit your complaint at no cost to you to JAMS at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim. In the event there are residual complaints that have not been resolved by JAMS, or any other means, you may seek a non-monetary remedy through binding arbitration to be provided to you in accordance with the Privacy Shield Principles.
To learn more about the Privacy Shield Framework, and to view GALA’s certification, please visit https://www.privacyshield.gov/.
12. Contact Us.
Global Advertising Lawyers Alliance (GALA)
488 Madison Avenue 10th floor
New York NY, 10022
Attention: Stacy D. Bess