(last update June 1, 2023)

Your privacy is important to us. This Privacy Policy (“Policy”) applies to services provided by Wolf Wallenstein, PC. (“we”, “us”, or “Firm”) and our website, mobile platform, or other application (collectively, the “Services”) and explains what information we collect from users of our Services (a “user”, “you”, or “your”), including information that may be used to personally identify you (“Personal Information”) and how we use it. We encourage you to read the details below. This Policy applies to any user or visitor to or user of our Content and Site, wolfwallenstein.com (the “Services”). We will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services.

We reserve the right to change this Policy at any time. Non-material changes or clarifications will take effect immediately. You should periodically check our website, including this privacy page, for updates. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of your Personal Information is subject to the updated Policy.

What Information Do We Collect?

We will only collect and process Personal Information about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested)) and “legitimate interests”.

We collect information that you give us when you contact us or otherwise access or use our Services, any information you voluntarily submit to us, and information regarding how you use the Services. Specifically, the foregoing includes:

• Your internet protocol address (i.e., IP address) and, if you access the Services from a mobile application, mobile device, your unique mobile device ID number.
• Your name, email address, postal address, telephone number, profession, profile picture, credit card information and your responses to surveys that we may ask you to complete for research purposes or to help direct Firm activities, the contact information of your representative, your social media account information.
• Details of any financial transactions you participate in on the Services, including the amount, currency, and method of payment.
• Browser and device information and information collected through technologies such as cookies.

How Do We Use The Information We Collect?

We use the information we collect to:

• Deliver and improve the Services and your overall user experience.
• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
• To link or combine user information with other Personal Information.
• To compare and verify information for accuracy and update our records. Email, text, message, or otherwise contact you with information and updates about us and the Services.
• To respond to your comments and questions and provide customer service.
• To send you information including confirmations, billing and invoices, technical notices, updates, security alerts, and support and administrative messages.
• Analyze how you use the Services with tools such as Google Analytics and other tools to help us understand traffic patterns and know if there are problems with the Services.
• Create targeted advertising to promote the Services and engage our users.

Do We Share Your Personal Information?

We do not rent, sell, or share your Personal Information with other people or non-affiliated third parties except with your consent or as necessary to complete any transaction or provide any service you have requested or authorized.

To help us do our work, we may provide limited access to some of your Personal Information to the following third parties:

• Partners: Sometimes we collaborate with other organizations to deliver the Services. In these cases, we may share your name, contact information and other details you provided when making an account with our partners.
• Service Providers: We work with a wide range of third-party providers, notably our database administrators, cloud computing services, advertising services, data analysts, application service providers, bulk SMS services, and other non-governmental organizations.
• Payment processors: We work with payment processors to help process credit card transactions and other payment methods made through the Services. These payment processors will store certain information about you. Please refer to their privacy policies to learn more about how they use your Personal Information.

We may store information such as survey responses and contact information, that are necessary to enable us to operate effectively and deliver our services to you. We may also transfer your Personal Information to a third party as a result of a merger, acquisition, reorganization or similar transaction; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Services; and to protect the rights or property of the Firm.  In such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Information, give you an opportunity to consent to such changes.

Protection of Company and Others

We will also share Personal Information with companies, organizations or individuals outside of the Firm if we have a good-faith belief that access, use, preservation, or disclosure of your Personal Information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims, or protect against harm to our legal rights or safety.

How Do We Use Tracking Technologies?

A “cookie” is a small file placed on your hard drive by some of our web pages. We, or third parties we do business with, may use cookies to help us analyze our web page flow, customize our services, content and advertising, measure promotional effectiveness and promote trust and safety. Cookies are commonly used at most major transactional websites in much the same way we use them in our Services.

You may delete and block all cookies from our Services, but parts of the Services may not work. We want to be open about our cookie use.

Even if you are only browsing the Services, certain information (including computer and connection information, browser type and version, operating system and platform details, and the time of accessing the Services) is automatically collected about you. This information will be collected every time you access the Services and it will be used for the purposes outlined in this Privacy Policy.

You can reduce the information cookies collect from your device. An easy way of doing this is often to change the settings in your browser or mobile device. You find out how to make these changes to your browser at this site: www.allaboutcookies.org/manage-cookies/. Unless you have adjusted your browser settings so that it will refuse cookies, our system will send cookies as soon as you access our Services.

How Do We Secure Your Personal Information?

We take reasonable steps to protect your Personal Information against unauthorized access, alteration, disclosure, misuse, or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. The safety and security of your Personal Information also depends on you. We protect your Personal Information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your Personal Information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using the Services, you acknowledge that you understand and agree to assume these risks.

We retain your personal data as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of the Services.

Your Choices Regarding Information

You have several choices regarding the use of Personal Information on the Services:

Changing or Deleting Your Personal Data.

All users may review, update, correct or delete the Personal Information furnished by a user by contacting us at privacy@wolfwallenstein.com. For your protection, we may only share and update the Personal Information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. . Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Download or Access Personal Information.

You can ask us for a copy of your Personal Information and can ask for a copy of Personal Information you provided in machine readable form by emailing us at privacy@wolfwallenstein.com.

Opting Out of Email Communications.

We may use some of the information we collect for marketing purposes, including to send you promotional communications about new Firm capabilities, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please contact us at privacy@wolfwallenstein.com to opt out.

Links to Third Party Websites

We may provide links to other websites. We have no control over these websites, and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, these third-party websites. By using the Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third-party websites.

How We Respond to Do Not Track Signals

Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.

Children Under 16

The Services are not directed to individuals who are under the age of sixteen (16) and we do not solicit nor knowingly collect Personal Information from children under the age of sixteen (16). If you believe that we have unknowingly collected any Personal Information from someone under the age of sixteen (16), please contact us immediately at privacy@wolfwallenstein.com and the information will be deleted.

Third Party Direct Marketing

We currently do not share personal data with third parties for their direct marketing purposes and will not do so without your consent.

A Note to Users Outside the United States

Our Firm is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Additional Disclosures for California, Colorado, and Virginia Residents

Unless otherwise required by applicable law, the following terms shall have the following meaning:

“Targeted advertising” or “Cross-context behavioral advertising” means displaying advertisements to a consumer where the advertisement is selected based on personal data obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests.

“Sale” means renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to a third party for monetary or other valuable consideration.

“Profiling” means any form of automated processing of Personal Information to evaluate certain personal aspects relating to a natural person and in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

U.S. data protection laws grant California, Colorado, and Virginia residents the following data rights:

1. Notice of Collection. In the 12 months prior to the last update of this Privacy Policy, we have collected the following categories of Personal Information:
   • Identifiers, including name, email address, and phone number.
   • Customer records, billing and shipping address, and credit or debit card information.
   • Commercial information, including billings and engagement with the Service.
   • Internet activity, including your interactions with our Service.
   • Employment and education data, including information you provide when you apply for a job with us.
   • Inferences, including information about your interests, preferences and favorites.

For more detail on information we collect, including the sources we receive information from, review in this Privacy Policy, What Information We Collect. We collect and use these categories of Personal Information for the business purposes described in the How Do We Use The Information We Collect section, including to provide and manage our Service.

1. Right to Know and Delete. Consumers who are California, Colorado, or Virginia residents have the right to request that we delete the Personal Information we have collected about them (subject to certain exemptions) and the right to know certain information about our data practices in the preceding 12 months. Specifically, you have the right to request the following from us:
   • The categories of Personal Information we have collected about you;
   • The categories of sources from which the Personal Information was collected;
   • The categories of Personal Information about you we disclosed for a business purpose or sold;
   • The categories of third parties to whom the Personal Information was disclosed for a business purpose or sold;
   • The business or commercial purpose for collecting or selling the Personal Information; and
   • The specific pieces of Personal Information we have collected about you.

To exercise any of these rights, please email us at privacy@wolfwallenstein.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require additional information from you to help us verify your identity and process your request. The verification steps may vary depending on the sensitivity of the Personal Information and whether you have a client relationship with us. If we are unable to verify your identity, we may deny your requests to know or delete.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate your requests. Except as otherwise provided by applicable law, for purposes of these requests under this Section, Personal Information does not include information we have collected as a service provider to our customers.

If Personal Information about you has been processed by us as a service provider on behalf of a client and you wish to exercise any rights you have with such Personal Information, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your Personal Information. We will refer your request to that client.

1. • Right to Correct. Subject to certain exceptions, you have the right to request that we correct inaccurate Personal Information that we have collected about you. Once we receive your request and confirm your identity, we will review your request, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information to see if we can correct the data. We may also request additional information showing that the information you want to correct is inaccurate.
   • Right to Opt-Out. You have the right to opt-out of processing of your Personal Information for the purpose of (i) targeted advertising, (ii) “sale” or “sharing” of Personal Information, or (iii) profiling to provide you with tailored content, including suggested advertising. You may submit a request to opt-out by emailing us at privacy@wolfwallenstein.com.
   • Authorized Agent. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
   • Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

California Shine the Light.

Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of Personal Information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of Personal Information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Wolf Wallenstein, PC pursuant to Section 1798.83 of the California Civil Code, please contact us via email at privacy@wolfwallenstein.com.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

Contact Us

If you have any questions about this Policy, your Personal Information, or the Services, you can contact privacy@wolfwallenstein.com.