Porzio, Bromberg & Newman, P.C. (“Porzio”) is a law firm that provides counselling and representation to its clients. Porzio has also created subsidiaries that provide services complementary to, but distinct from, our legal services.
Porzio and its subsidiaries, Porzio Compliance Services and Porzio Governmental Affairs, as well as Porzio, Bromberg & Newman (PR), LLC (collectively “Porzio”) recognize and respect the privacy rights of individuals regarding their personal data. This Policy explains the types of personal data or personal information (used interchangeably herein unless otherwise expressly noted) that Porzio may collect from you and how we use it. It also explains the policies and practices we have developed to safeguard personal data and to comply with applicable data protection laws. Please read this Policy carefully to understand what personal data we collect, how we collect it, how we use it, who we may disclose it to, and how you can manage it.
If you have any questions about this Policy or wish to access or correct personal data that Porzio may have collected from you, please contact us at: Porzio, Bromberg & Newman, PC, 100 Southgate Parkway, Morristown, NJ 07962, Attn: Christine N. Bradshaw or at CNBradshaw@pbnlaw.com and include the words “Privacy Inquiry” in your communication.
DATA WE COLLECT ABOUT YOU
We may collect, use, store and disclose different categories of personal data about you which we have grouped together as follows:
- Identity Data includes, for example, first name, maiden name, last name, username or similar identifier, marital status, title, or date of birth.
- Contact Data includes, for example, billing address, delivery address, email address or telephone numbers.
- Financial Data includes, for example, bank account, payment card details, or payroll data.
- Transaction Data includes, for example, details about payments and other details of products and services you have purchased and/or received from us.
- Technical Data includes, for example, internet protocol address, your login data, or technology on the devices you use to access our website.
- Profile Data includes, for example, your username and password on any Porzio website, purchases made by you, your preferences, or your feedback and survey responses.
- Usage Data includes, for example, information about how you use our website, products, and services.
- Marketing and Communications Data includes, for example, your preferences in receiving marketing from us and your communication preferences regarding same.
- Special Categories of Data Protected by Law: includes, for example, details about race or ethnicity, religious or philosophical beliefs, or information about your health.
HOW WE COLLECT INFORMATION ABOUT YOU
Direct interactions. You may give us your personal data by filling out forms or other materials or by corresponding with us by mail, phone, e-mail, social media, or otherwise. This includes, for example, personal data you provide us when you:
- Request information from Porzio about our products or services;
- Request Porzio to provide you with products or services;
- Request marketing materials to be sent to you;
- Participate in a survey;
- Provide us with feedback;
- Share information with us as part of our provision of products and/or services to you;
- Provide unsolicited information to us; or
- Apply for employment with us or when you become an employee.
Automated interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies and other similar technologies.
Third parties (or publicly available sources). We may receive categories of personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers; advertising networks and search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers, aggregators or recruitment agencies.
- Identity and Contact Data from publicly availably sources.
HOW WE USE YOUR PERSONAL DATA
We use your personal data, and may share your personal data (see below on sharing of personal data) to:
- Operate our business;
- Deliver our products and services to you;
- Process, complete and fulfill your requests;
- Provide client/customer service and respond to requests or inquiries;
- Communicate with you;
- Perform a contract we have entered into or are about to enter into with you;
- Tailor our marketing programs and campaigns;
- Comply with governing laws;
- Cooperate with law enforcement;
- When necessary, to exercise or defend legal claims;
- For other legal reasons; or
- Provide you with newsletters, articles, alerts, announcements, invitations, and other information.
We also use your personal data for data analysis, to better understand how our products and services impact you, to track and respond to concerns, for fraud prevention and to enhance our services and products. For those visiting this site that provide personal data from within the European Economic Area, please see the “Supplemental European Privacy Notice” below for additional information.
We strive to provide you with choices regarding certain types of use of your information concerning marketing and advertising. We use personal information you share with us to promote our services and products to you if:
- You request information about our services or products;
- You express an interest in receiving communications on various topics from us;
- You respond to invitations to our conferences, meetings, events and other similar gatherings;
- You interact with us on social media; or
- You otherwise express an interest in receiving such communications.
- You can tell us to not process your personal information for marketing purposes and can do so by contacting us as set forth above or by following the link in the marketing emails we send to opt out or manage your email preferences.
HOW WE SHARE YOUR PERSONAL DATA
We may share your personal data with the parties set out below:
- External Third Parties: service providers who provide IT and system administration services and data analytics or third parties to Porzio.
- Professional Advisers: advisors (e.g., lawyers, bankers, auditors and insurers) who provide consultancy, banking, legal, insurance and accounting and payroll services.
- Supervisory Authorities: Governmental authorities who may require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
HOW WE SECURE YOUR PERSONAL DATA
We have put in place reasonable security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. Employees are subject to a duty of confidentiality and non-employees only process your personal data as per our instructions.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach in accordance with governing law or other applicable duties or contractual obligations.
COOKIES AND SIMILAR TECHNOLOGIES
“Cookies” are small text files that are placed on your computer or mobile device in order to identify your web browser and the activities of your computer or mobile device when using this website. Cookies are used to personalize your experience, to assist you in using the website (such as saving time by not having to re-enter your name each time you use the website), and to allow us to statistically monitor how you are using the website to help us improve our products and services.
CALIFORNIA PRIVACY RIGHTS
Categories of personal information collected: The personal information that Porzio collects or has collected from California consumers in the preceding twelve months may fall under the following categories of information that are included within the scope of the CCPA:
- Identifiers including, for example, your name, address, phone number, e-mail, or IP address;
- Personal information, including, for example, an address, phone number, or credit card number;
- Protected classification information, including, for example, age or gender;
- Commercial information, including, for example, purchase information;
- Internet or other electronic network activity information, including, for example, content interaction information or search history information;
- Geolocation information, including, for example, the location of your device or computer;
- Sensory information, including, for example, audio or visual information; and
- Professional or employment related information, including, for example, data you may provide us.
- Directly from you when you provide us information and engage our services;
- Directly and indirectly from you when using our services or visiting our website.
- To fulfill or meet the reason for which the information is provided.
- To provide you with e-mail alerts and other notices concerning our services.
- To improve our website and the services we provide to you.
- To provide you with information, products, or services you request.
- To audit a current interaction with the consumer and concurrent transactions.
- To perform services, including providing customer service.
- To undertake internal research for technological development.
- To detect and address any potential security incidents.
- To carry out and fulfill contractual obligations.
- To protect the rights, property or safety of our consumers and Porzio employees as necessary and appropriate.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
The rights of California residents under the CCPA include:
- Consumers have the right to know about the personal information Porzio collected or disclosed about them. Consumers can request access to such personal information about themselves for the 12 months preceding the date Porzio received such a request.
- Consumers have the right to request deletion of their personal information collected or maintained by Porzio. Please note that there may be reasons why Porzio would not be able to honor a deletion request. Such reasons could include those identified in the CCPA; for example, to complete the transaction for which the personal information was collected or to comply with a legal obligation.
- Consumers have the right to not be discriminated against if they choose to exercise any of their CCPA privacy rights. Porzio will not discriminate against California consumers who choose to exercise their CCPA privacy rights.
If you would like to exercise any of these rights, please email CNBradshaw@pbnlaw.com with the words “California Privacy Rights” in the subject line. Alternatively, please write to us at the following address: Porzio, Bromberg & Newman, PC, 100 Southgate Parkway, Morristown, NJ 07962, Attn: Christine N. Bradshaw. We will provide you with a form to complete that will ask you for certain information to confirm your identity. The information collected will only be used to respond to your request and for record-keeping purposes to demonstrate compliance with the CCPA. Porzio will respond to a verified request pursuant to the 45-day timeframe established in the CCPA.
If the consumer prefers, he or she may designate an authorized agent to make a request under the CCPA on the consumer’s behalf.
While in some instances we may collect personal data about children with the consent of a parent or guardian, we do not otherwise knowingly solicit data from, or market to, children.
LINKS TO OTHER SITES
SUPPLEMENTAL EUROPEAN ECONOMIC AREA (“EEA”) / UNITED KINGDOM (“UK”) PRIVACY NOTICE
European Union (“EU”) Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “General Data Protection Regulation” or “EU GDPR”) and the Retained Regulation (EU) 2016/679 (“UK GDPR”) require Porzio as the data controller to provide additional and different information about its data processing practices to data subjects in the EEA or the UK. If you are a data subject within the EEA or the UK, this Supplemental EEA / UK Privacy Notice applies to you in addition to the provisions above.
1. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to so. Most commonly, we will use your personal data in the following circumstances:
- We need to perform the contract we are about to enter into or have entered into with you.
- It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- We need to comply with a legal or regulatory obligation.
We may also use your personal data in the following situations, which are likely to be rare:
- We need to protect your interests (or someone else’s interests).
- It is needed in the public interest or for official purposes.
We may also rely on consent as a legal basis for processing your personal data in certain circumstances, like sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
2. HOW LONG WE RETAIN YOUR PERSONAL DATA
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
3. ONWARD TRANSFERS
We may transfer your personal data outside the EEA or the UK. To ensure a degree of protection similar to that within the EEA or the UK, we will only transfer your personal data:
- To countries that have been deemed to provide an adequate level of protection for personal data, or
- To countries:
- Pursuant to binding agreement to and compliance with standard contractual clauses or binding corporate rules, each as approved by the European Commission or other regulators, as applicable;
- Pursuant to the consent of the individual to whom the personal information pertains; or
- As otherwise authorized by the EEA or UK or permitted by applicable EEA or UK requirements.
4. YOUR DATA PROTECTION RIGHTS
Under certain circumstances, visitors from within the EEA or the UK have the following data protection rights:
- Access to your personal data.
- Correction of your personal data.
- Erasure of your personal data.
- Object to processing of your personal data.
- Restrict processing of your personal data.
- Transfer of your personal data.
- Withdraw any consent that you have previously given.
If you wish to exercise any of the rights set out above, please email CNBradshaw@pbnlaw.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee or refuse to comply with your request if it is clearly unfounded, repetitive or excessive.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
For additional details, please refer to Porzio’s Data Privacy Framework Policy at https://pbnlaw.com/data-privacy-framework-policy. For advice or to make a complaint, you can also contact the applicable Supervisory Authority within the EEA at this link https://edpb.europa.eu/about-edpb/board/members_en or the Information Commissioner’s Office within the UK at this link https://ico.org.uk/make-a-complaint/.
Porzio may update this Policy from time to time. Please check this Policy periodically for changes. We encourage you to periodically review this page for the latest information on our privacy practices.
Last revised and effective date: October 10, 2023