Updated: July 1, 2023
This Policy describes how your personal information will be treated as you use the Clarkson Site. This Policy does not apply to information provided to us during our attorney-client relationships or which is protected by confidentiality, the attorney-client privilege, the attorney work product doctrine or any other applicable protection. Nothing in this Policy should be understood as creating an attorney-client relationship with visitors to the Clarkson Site or, alternatively, to reduce the protections resulting from such relationships.
INFORMATION WE COLLECT FROM YOU WHEN YOU VISIT CLARKSON SITES
Like many websites, our server logs capture the following internet or other electronic network activity information: information regarding Clarkson Site users’ operating systems, browser software, IP (Internet Protocol) addresses, and the full Uniform Resource Locator (URL) clickstreams to, through and from the Clarkson Site, including date and time. We may use this information to improve the services we provide through the Clarkson Site, to monitor and improve the performance of our servers, to administer the Clarkson Site, and to protect and defend our rights, property, or safety or that of our clients and other users of the Clarkson Site.
Cookies are used to track your use of the Site. This enables us to understand how you use the Site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need. Cookies are also used to help us advertise jobs, products, or services to you that we think you will be interested in.
Cookies are either session cookies or persistent cookies. Session cookies are only stored on your computer during your web session and are automatically deleted when you close your browser. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page, but they do not collect any information from your computer. A persistent cookie is stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalization (see below).
Cookies can also be categorized as follows:
- Strictly necessary cookies: These cookies are essential to enable you to use the Site effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on the Site cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
- Performance cookies: These cookies enable us to monitor and improve the performance of our Site. For example, they allow us to count visits, identify traffic sources and see which parts of the Site are most popular.
- Functionality cookies: These cookies allow the Site to remember choices you make (such as your name, language, or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font, and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymized.
- Personalization cookies: These cookies help us to advertise details of potential services that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for services that are similar to services that you have previously browsed.
INFORMATION YOU SUBMIT TO US THROUGH THE CLARKSON SITES
You are not required to submit any information to the Clarkson Site. However, you may choose to do so by completing forms available in several sections of the Clarkson Site, including: the Careers and Connect pages. If you join one or more of our mailing lists or otherwise choose to provide personal information to us through the Clarkson Site, we will collect the following information about users of the Clarkson Site; first name, last name, email address, company name phone number, postal address, personal and professional interests; and professional and employment information; and educational information. We use that information for the purpose for which it was collected and in accordance with the privacy wording on the relevant part of the Clarkson Site. In addition, we may use this information to:
- communicate with you about our business;
- provide publications, products and services you request;
- add you to mailing lists and send you marketing materials we believe will be of interest to you;
- process and respond to requests, enquiries, and complaints; and
- for other purposes and operations which are reasonably related, such as administering, monitoring, and improving the Clarkson Site, our products, and services.
Your information may be accessed by third party service providers who will process that information solely for our benefit and in accordance with our instructions (see Section 6 below for more information). However, we will not provide your personal information to or share it with any third party for their own marketing purposes except in connection with requests you make that clearly involve third parties. This might include publications produced by third parties or events that are presented or sponsored by third parties. This will be made clear to you before you sign up for the publication or event.
YOUR RIGHTS TO ACCESS AND UPDATE YOUR PERSONAL INFORMATION
Clarkson takes appropriate steps to avoid unauthorized changes to personal information you submit to Clarkson Site. For so long as Clarkson elects to continue to provide the Clarkson Site, and provided that you comply with all agreements concerning use of these sites, we will make all reasonable efforts to provide you with online access to your registration data and other personal information so that you may view, update or correct it.
We retain information that is collected through Clarkson Site only for as long as needed for the purpose for which it was provided, or as otherwise required for our legitimate business purposes. Your information may be retained for longer periods if there are valid legal grounds, for example if required by law or court order or to defend or pursue legal claims.
You may opt out of receiving marketing and market research communications at any time by using the unsubscribe links provided or by contacting us at [email protected] You may also change your preferences regarding the communications you receive from us here.
For further information on your Rights, see section 10 below.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
The majority of the personal information collected by Clarkson is provided by you voluntarily on the Clarkson Site, for example when you sign up to receive more information or apply to an open position and is therefore collected with your permission. The remaining personal information is collected for Clarkson’s legitimate business purposes, for example to monitor and improve the quality of the Clarkson Site and our services, and to protect and defend our rights, property or safety or that of our clients and other users of the Clarkson Site.
SHARING OF INFORMATION
Clarkson may use third party companies and individuals to facilitate our Site (“Service Providers”), to provide the Site on our behalf, to perform Site-related services or to assist us in analyzing how our Site is used.
These Service Providers have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use Service Providers to monitor and analyze the use of our Service.
Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Facebook, Custom Audiences and Facebook Marketing Services. Due to our legitimate interest in the analysis, optimization and economic operation of our online offer and for these purposes within the meaning of Article 6(1)(f) of the EU General Data Protection Regulation (“GDPR”), we use the so-called “Facebook pixel” of the social network Facebook, which is operated by Meta Platforms, Inc., 1601 Willow Rd., Menlo Park, CA 94025, USA, or if you are a resident of the EU, Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display our Facebook ads only to Facebook users who have shown an interest in our website or who have specific characteristics (e.g., interests in certain topics or products determined by the websites visited) that we submit to Facebook (so-called “custom audiences”). With the help of the Facebook pixel, we also want to make sure that our Facebook ads are in line with the potential interest of users and do not have a nuisance effect. Using the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion tracking”).
The Facebook pixel is directly integrated into our website by Facebook and can store a so-called cookie (i.e., a small file, on your device). If you then log in to Facebook or visit Facebook when you are logged in, your visit to our online offer will be noted in your profile. The data collected about you is anonymous for us (i.e., it does not allow us to draw conclusions about the identity of the users). However, the data is stored and processed by Facebook so that it can be linked to the respective user profile and used by Facebook as well as for its own market research and advertising purposes. If we transfer data to Facebook for comparison purposes, it is encrypted locally in the browser and only then sent to Facebook via a secure https connection. This is done with the sole purpose of matching the data encrypted by Facebook.
Furthermore, when using the Facebook pixel, we use the additional function “advanced matching”, in which inventory data such as telephone numbers, e-mail addresses or users’ Facebook IDs is transmitted to Facebook (encrypted), but solely to create target groups (“Custom Audiences”). Users agree to our use of the “advanced matching” and the related processing of their data.
Based on our legitimate interests, we also use the “Custom Audiences from File” function of Facebook. in which case inventory data (phone numbers, email addresses, Facebook IDs) will be uploaded to Facebook. The upload process is encrypted. The upload serves solely to identify recipients of our Facebook ads. We want to ensure that the ads are only displayed to users who are interested in our information and services. Users agree to our use of the “Custom Audiences from File” function and the related processing of their data.
Facebook’s processing of the data is governed by Facebooks Data Usage Policy. Accordingly, general instructions on how to display Facebook ads, in the Facebook Data Usage Policy: https://www.facebook.com/policy.php. For specific information and details about the Facebook pixel and how it works, please visit the Facebook Help Center: https://www.facebook.com/business/help/651294705016616.
You may object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set what kind of ads you see on Facebook, you can go to the page set up by Facebook and follow the instructions on how to set up use-based advertising: https://www.facebook.com/settings?tab=ads.The settings are platform-independent (i.e., they are applied to all devices, such as desktop computers or mobile devices).
Each time you access one of our pages that contains LinkedIn’s features, a connection is established to a LinkedIn server. LinkedIn is informed that you have visited our Site with your IP address. With the help of the LinkedIn Insight Tag we are able to analyze the success of our campaigns within the LinkedIn platform or determine target groups for them based on the interaction of the users with the Site. If you are registered with LinkedIn, it is possible for LinkedIn to associate your interaction with our online services with your user account.
You can permanently opt out on this link: https://www.linkedin.com/psettings/guest-controls/ retargeting-opt-out.
LinkedIn advertising cookie is used on the basis of Article 6(1)(f) of the GDPR. We have a legitimate interest in analyzing user behavior to optimize our Site and advertising.
We are committed to complying with the Children’s Online Privacy Protection Act (COPPA). Clarkson Site and services are not directed to children under the age of 16. We do not knowingly collect personal information from children under the age of 16. If we receive personal information that we discover was provided by a child under the age of 16, we will promptly destroy such information. Schools and parents should supervise their children’s online activities and consider the use of other means to provide a child-friendly online environment. Additional information is available on the Direct Marketing Association’s home page at http://www.the-dma.org. If you would like to learn more about COPPA, visit the Federal Trade Commission home page at http://www.ftc.gov.
Clarkson Site uses measures that are appropriate to protect your personal information against unauthorized access, improper use or disclosure, unauthorized or unlawful destruction or accidental loss, and all our employees and any third parties that process your personal information on our behalf are obliged to respect the confidentiality of your information., However, we cannot and do not provide any assurance that these measures will be sufficient to protect the information you choose to transmit to our Site.
Clarkson Site is not designed to store sensitive personal information such as financial, health, criminal, racial or ethnic origin or political affiliation and you should not use Clarkson Site for that purpose.
In certain circumstances, subject to certain exceptions and applicable law, you may have the following rights in relation to personal information about you:
- the right to know: (i) the specific pieces of personal information collected; (ii) the categories of personal information; (iii) the categories of sources of the personal information: (iv) the business or commercial purpose for collecting the personal information; (v) the categories of personal information disclosed for a business purpose; and (vi) the categories of third parties with whom the personal information is shared;
- the right to have personal information corrected, for example if it is incomplete or incorrect;
- the right to opt out of receiving marketing communications at any time;
- the right to request that personal information is deleted;
- the right to restrict or object to the processing of personal information;
- the right to receive a copy of personal information which you have provided to the firm, in a structured, commonly used and machine-readable format (known as “data portability”);
- where you have provided personal information voluntarily, or otherwise consented to its use, the right to withdraw your consent;
- the right not to be discriminated against if you exercise any rights conferred on you by the California Consumer Privacy Act of 2018;
- the right to complain to a Data Protection Authority (see further below).
If you have an online account, you may access, update, and correct your personal information – including your marketing choices – using the account management facilities. You may also opt out of receiving marketing and market research communications at any time by contacting us at [email protected]
YOUR CALIFORNIA PRIVACY RIGHTS
As described above, Clarkson collects certain types of personal information about you during your relationship with Clarkson. Under California law, if you are a resident of California, you have the right to request certain information that we collect about you, including:
1. The categories of personal information we have collected from you;
2. The categories of sources from which we collected the personal information;
3. The business purpose we have for collecting or selling that personal information;
4. The categories of third parties with whom we share such personal information; and
5. The specific pieces of personal information we have collected about you.
In addition, if we sold or disclosed your personal information for a business purpose, you may request that we provide you with:
1. The categories of personal information that we sold about you, and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the information was sold; or if we have not sold consumers’ personal information; and
2. The categories of personal information that we have disclosed about you for a business purpose, and the categories of third parties to whom the personal information was disclosed, by category or categories of personal information for each category of third parties to whom the information was disclosed; or if we have not disclosed consumers’ personal information for a business purpose.
As a California resident, you also have the right, at any time, to tell us not to sell personal information – this is called the “right to opt-out” of the sale of personal information. You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion 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 the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
- 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.
Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.
To exercise the access, data portability, Do Not Sell, and deletion rights described in this section, please submit a verifiable consumer request to us by calling or emailing us with your request at the contact information below. Only you may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You must include your full name, email address, and attest to the fact that you are a California resident by including a California postal address in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in California in order to obtain the information, and you are only entitled to make this request twice a year. We will respond to your request within 45 days or let you know if we need additional time.
Please provide a description of the right(s) you want to exercise and the information to which your request relates to:
- Toll-Free Number for California Privacy Requests: (855)-876-1300
- Email Address: [email protected]
We may be unable to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Clarkson Law Firm, P.C.
22525 Pacific Coast Highway
Malibu, CA 90265
Email: [email protected]