Effective January 1, 2020
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, (d) that we obtain from third parties such as database vendors, content publishers and suppliers, (e) when you receive our services, and (f) when you inquire about or pursue employment opportunities at Warner. 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. This Policy also does not cover information we collect about you as an employee of Warner. For more information about our privacy practices for employee information, please see our Employee Handbook.
Personal Information We Collect
Information You Give Us. Personal information you may provide online or offline to us includes:
- 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.
- Client information. We collect information from you and about you in connection with our legal services. For prospective clients, we may also collect information such as your name and other contact details as part of our client intake process.
- Employment information. We collect information about you when you provide it in connection with employment opportunities at Warner.
- 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.
Information We Get From Others. 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. We may also obtain information about you from the party we are representing in connection with our services.
Statistical Analyses. 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 Client Services. We use your personal information, and other information you or others provide us, to provide legal advice and services and to manage our business operations and client relationships.
To Provide the Site and Communicate With You. We use your personal information to:
- 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.
To Send You Marketing Communications. 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 Recruiting.We may use your personal information that you provide us in connection with employment opportunities to conduct our recruiting and on-boarding processes.
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:
Service Providers. 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.
Business Partners. 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.
Business Transfers. 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:
|Cookie Name||Domain||Cookies Category|
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.
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 and www.youronlinechoices.com.
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, consider you for employment, 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.
Security. 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).
Children. 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.
Controller. 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.
|Processing Purpose||Legal Basis|
|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.|
Retention. 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.
Your Rights. 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.
Notice to California Residents
The following section applies to California residents.
Shine the Light. Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes. To make a request please contact us as instructed in the “How to Contact Us” section below and specify you are making a Shine the Light request.
California Consumer Privacy Act (“CCPA”). The CCPA creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CCPA, both our privacy practices and your privacy rights are discussed in detail in the following information. This section does not cover information we collect about you as an employee of Warner. For more information about our privacy practices relating to employee information, please see our Employee Handbook.
Personal Information We Collect. We collect your personal information when you interact with our Site or otherwise communicate with us. For the purposes of this Privacy Notice, “personal information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.
We have collected the following categories of personal information covered by the CCPA from consumers within the past 12 months, and have used it for the following business purposes:
|Category of Personal Information Collected||Business Purpose of Collection|
|Identifiers, including real name, alias, mailing address, email address, account name, telephone numbers, and unique personal identifiers such as online identifiers and IP address||To provide client services and marketing.|
|Information about children, including number of children, names, age, and gender.||To provide client services and assist in relationship management.|
|Characteristics of protected classifications under California or federal law, including age or date of birth, race, color, national origin, physical disabilities, mental disabilities, medical condition, gender, gender identity, gender expression, sexual orientation, military or veteran status, and criminal conviction history||If you choose to disclose this information, we collect it as part of our employment application process.|
We also collect gender information to assist in relationship management and ensuring we properly address individuals in our communications (e.g., whether to call someone Ms., Mrs., Mr., etc.)
|Occupation, professional, or employment-related information||To market and provide our services to you and to communicate with you. In addition, if you choose to disclose this information, we collect it as part of our employment application process.|
|Geolocation data||To assist in marketing and identify Site traffic patterns.|
|Education information||If you choose to disclose this information, we collect it as part of our employment application process.|
|Internet or other electronic network activity information, including browsing history, search history, and information regarding an individual’s interaction with an internet site, application, or advertisement||To provide you more relevant content, track original Site visits, and optimize your Site experience as well as to ensure our systems are properly functioning.|
|Client information including name; contact information; financial information; sensitive information including age, date of birth, race, color, national origin, ancestry, religion, marital status, sex, gender, gender identity, gender expression, sexual orientation, military or veteran status; and occupational, professional or employment information.||As relevant and necessary to provide our legal services.|
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.
Sharing Your Information. We do not sell your personal information, but may disclose it to third parties for a business purpose.
We disclose the following categories of personal information covered by the CCPA for a business purpose:
|Category of Personal Information Disclosed||Category of Third Parties with Whom Information is Disclosed|
|The following identifiers: real name, alias, mailing address, email, account name, phone number, and unique personal identifiers such as online identifiers and IP address||Customer relationship management software, internet service providers, email marketing provider, operating systems and platforms, marketing intelligence tools, mail houses or printers, and payment processors|
|The following information about children: number of children, names, age, and gender||Customer relationship management software|
|The following internet or electronic information: browsing history, search history, and information regarding an individual’s interaction with an internet site, application or advertisement||Customer relationship management software, internet service providers, email marketing provider, operating systems and platforms, marketing intelligence service providers, and payment processors|
|Geolocation data||Marketing intelligence service providers|
Directly from You. We collect the following categories of personal information directly from you: identifiers, information about children, sensitive personal information, occupational information, employment information, and other client information. We collect this information when you:
- Make a purchase on our Site or register for one of our events.
- Sign up to receive marketing emails or text messages or client alerts.
- Apply for employment with us.
- Provide your contact information to us.
- Submit a request to us.
- Participate in one of our surveys.
- Interact with our social media pages.
- Apply for a job with us.
- Provide us with information in connection with our provision of legal services.
Passively. We collect the following categories of personal information passively: internet or electronic information such as browsing history, search history, IP address, and other information regarding an individual’s interaction with a site, application, or advertisement. We collect this information when you:
- Visit and navigate our Site on any device.
- Click on sponsored links or third-party advertisements.
- Receive or interact with our communications and Site that may contain cookies.
From Third Parties. We may receive any of the categories of information listed above about you from other sources in the course of providing our legal services. For example, we get information from:
- Our business partners, including online advertising networks.
- Social media platforms.
- Companies that provide information to supplement what we already know about you, including data brokers.
- Our clients, as part of our legal services.
- Client referrals and court appointments
Your Rights. The CCPA gives you certain rights regarding your personal information:
- Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
- Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.
Exercising Your Rights. To exercise your rights above, please submit a request to us here, by emailing us at email@example.com, or by calling us at 866-221-3811. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide the following information: name, email address, and the type of request you wish to make. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request.
After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request.
Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. You may also make a request on behalf of your minor child.
We may not discriminate against you if you choose to exercise your rights.
Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. We will deliver our written response by mail or electronically, at your option. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable.
We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.
How to Contact Us
Warner Norcross + Judd LLP
150 Ottawa Avenue NW, Suite 1500
Grand Rapids, MI 49503-2487
Attn: Privacy Officer