Effective August 1, 2019
This Policy applies to our collection, use and sharing of your personal information (a) when you visit the Warner website or any of our blogs (collectively, the “Site”), (b) when you register for events or fill out a mailing subscription form; (c) when you receive our communications or participate in our online or offline activities or events, and (d) that we obtain from third parties such as database vendors, content publishers and suppliers. This Policy applies only to information collected by Warner and does not apply to any other information or websites not owned or operated by Warner.
Personal Information We Collect
Information You Give Us
. Personal information you may provide through the Site or otherwise communicate to us includes:
Information We Get From Others
- Contact information. We collect information about you when you provide contact information to us via email, mail, or through the Site, such as when you register for a seminar or webinar. This information may include your first and last name, email address, mailing address, phone number, and credit card information.
- Feedback and correspondence. We may collect information about you when you request information, respond to surveys, or otherwise correspond with us.
- Other information. We may collect other information from you that is not specifically listed here. We may use such information in accordance with this Policy.
. We may obtain additional information about you from third party sources, such as service providers, vendors, social media sites, and advertising agencies to provide you with more relevant information about our services.
Information Automatically Collected
. We use Google Analytics to help us gather statistical information about the visitors to our Site and how they use the Site on an anonymous, aggregate basis. However, we will not associate this data with your personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental request or to comply with law.
We may use this information to gain a better understanding of the users of our Site, to improve our Site, and to improve our services. Depending on the type of browser and device that you use, you may have the ability to control the type of information that Google Analytics use. To understand how Google Analytics collects and processes data, please visit www.google.com/policies/privacy/partners/.
How We Use Your Personal Information
We use your personal information for the following purposes and as otherwise described to you in this Policy or at the time of collection:
To Provide the Site and Communicate With You
. We use your personal information to:
To Send You Marketing Communications
- provide, maintain, and improve the Site;
- better understand your needs and interests and personalize your experience with the Site;
- respond to your requests, questions, comments, and feedback; and
- perform website analytics and database management services.
. We may send you newsletters, promotions or other marketing communications, but you may opt out of receiving them as described in the Your Choices section below.
For Compliance, Fraud Prevention and Safety
. We may use your personal information as we believe appropriate to (a) investigate or prevent violation of the law or your agreements with us; (b) protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims); (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and (e) where permitted by law in connection with a legal investigation. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our site for illegal reasons.
With Your Consent
. In some cases, we may ask for your consent to collect, use or share your personal information.
How We Share your Personal Information
We may use third parties to help us design and operate the Site, provide services to support the Site, process your information, and provide marketing activities on our behalf. For example, we may hire a company to run certain website applications, help us analyze our data, or send information on our behalf about services and events in which you may be interested. Unless otherwise indicated at the time we collect your information, if we allow third parties to access the personal information we collect, we will have contractual provisions or other appropriate protections in place to ensure such access is for limited purposes and in compliance with this Policy.
We do not share your personal information with third parties without your consent, except in the following circumstances:
. We may share your personal information with third party companies and individuals as needed for them to provide us with services that help us with our business activities and to promote our services to you. A list of our current service providers is available upon request.
. We may share your personal information with our business partners who offer a service to you jointly with us. A list of our current business partners that have access to certain personal information we collect is available upon request.
Security, Compliance, Fraud Prevention, Safety; Compliance with Law
. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties for the purposes described above under the following sections: For compliance, fraud prevention and safety and for compliance with law.
. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy.
What are Cookies
? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies set by the website are called “first party cookies.” Cookies set by parties other than the website are called “third party cookies.” Third party cookies enable third party features or functionality, such as advertising or website analytics, to be provided on or through the website. The parties that set these third party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites and/or mobile apps.
What Cookies and Other Tracking Technologies does Warner Use
? We may use several different kinds of cookies on this Site, including strictly necessary cookies, which are cookies that are necessary for the Site to function and cannot be switched off in our systems; and performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our Site. Specifically, the cookies we use are:
Cookies are not the only way to track visitors to a website. We may use similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Sites. These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning.
, Google Analytics
How Can You Disable Cookies and Other Tracking Technology
? Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org
Some Internet browsers also may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Opt Out of Marketing Communications
. You may change your subscription preferences or opt out of marketing-related emails by following the opt-out prompt in the email. To opt out of other forms of marketing communications, please contact us using the contact information provided at the end of this Policy.
Consequences of Not Providing Personal Information
. You are not required to provide all personal information identified in this Policy to use our Site or to interact with us offline, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.
Other Important Privacy Information
Third Party Sites and Services
. The Site may contain links to other websites and services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and we are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and sharing of your personal information. We encourage you to read their privacy policies to learn more.
. The security of your personal information is important to us. We take a number of organizational, technical and physical measures that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your personal information.
International Data Use
. We are headquartered in the United States and may have service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.
Verifying, Changing, and Deleting Your Information
. If the information you provided us is incorrect or if you have an issue with your information that we have collected, you can contact us as detailed at the end of this Policy and ask us to change, update or fix your information in certain cases. You can also request that we erase or delete all or some of your personal information or otherwise object to, limit, or restrict the use of such information (if we have no legal right or legitimate business interest in retaining such information).
. The Site is not intended for use by anyone under the age of 18, nor do we knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, you should not attempt to use the Site or send any information about yourself to us.
Changes to this Policy
. We reserve the right to modify this Policy at any time. If we make changes to this Policy we will post them on the Site and indicate the effective date of the change. If we make material changes to this Policy we will notify you by email or through the Site.
Notice to European Users
The following applies to individuals in the European Economic Area.
. Warner is the controller of your personal information covered by this Policy for purposes of European data protection legislation.
Legal bases for processing
. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us using one of the methods detailed at the end of this Policy.
|To provide the Site and communicate with you.
||You are subject to a contract with us and we need to use your personal information to provide services you have requested or take steps that you request prior to providing services.
|To send you marketing communications.
For compliance, fraud prevention, and safety.
|These processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
|For compliance with law.
||Processing is necessary to comply with our legal obligations.
|With your consent.
||If we expressly ask for your consent prior to processing your information, our processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated on the Site.
|To share your personal information as described in this Policy.
||This sharing constitutes our legitimate interests, and in some cases may be necessary to comply with our legal obligations.
. We will only retain your personal information for as long as necessary to fulfil 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by contacting us as detailed at the end of this Policy. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here
Cross-Border Data Transfers
. Any information you provide to us through the use of the Site may be stored, processed, transferred among, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Policy regardless of where your personal information is kept. Regarding transfers from the European Economic Area ("EEA") to the United States, we rely on the derogations for transfers which are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. If you reside in other non-US jurisdictions outside the EEA, your use of the Site or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified above. If you have questions about cross-border transfers, please contact us as detailed below.
How to Contact Us
Warner Norcross + Judd LLP
900 Fifth Third Center
111 Lyon St., NW
Grand Rapids, MI 49503-2487
Attn: Privacy Officer