This Policy applies to our collection, use and sharing of your personal information when you (a) visit the Warner website or any of our blogs (collectively, the “Site”), (b) register for events or fill out a mailing subscription form, (c) receive our communications or participate in our online or offline activities or events, (d) inquire about or receive our services, and (e) inquire about or pursue employment opportunities at Warner. It also applies to information provided to us by third parties such as database vendors, content publishers, and our clients. 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
This section of our Policy describes the categories of personal information we collect about you and the different ways in which we collect your personal information.
Information You Give Us. Personal information you may provide through the Site or otherwise communicate to us includes:
Information We Get From Others. We may obtain additional personal 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. This information may include your contact information and cookie information. We may also obtain personal information about you from the party we are representing in connection with our legal services.
How We Use Your Personal Information
This section of our Policy describes the different purposes for which we may use the personal information we collect about you.
To Provide Client Services. We use your personal 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. We use your contact information, payment information, cookie information, and other personal information to:
To Send You Marketing Communications. We may use your contact information to 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 some or all of 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
This section of our Policy describes the categories of personal information we share with third parties and the types of third parties with whom we share that information. We do not sell your personal information; however, we may share your personal information with third parties for a number of reasons. For example, 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. Specifically, we share your personal information with the following categories of third parties.
Service Providers and Business Partners. 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. This information may include your contact information, payment information, cookie information, and other personal information as necessary for the services they provide. We may also share your contact information and other information you direct with our business partners who offer a service to you jointly with us.
Compliance, Fraud Prevention and Safety. We may disclose some or all of the personal information we have collected about you as we believe appropriate to government or law enforcement officials or private parties for the purposes described above under the sections “For compliance, Fraud Prevention and Safety”.
Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including all of the personal information we have collected about you, 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.
This section of our Policy describes how we and our business partners may collect and store information about you and your use of the Site through cookies and other tracking technologies.
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 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:
How Can You Disable Cookies and Other Tracking Technology? Depending on the type of browser and device that you use, you may have the ability to control the type of information that these tools use. 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.
This section of our Policy describes your choices with respect to the personal information you provide and the marketing communications you may receive. In addition, some states may grant you additional rights as further described in the “Location-Specific Disclosures” section, below.
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 and Cross-Border Transfers. We are located 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. 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, Switzerland or United Kingdom 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, 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 in this Policy. If you have questions about cross-border transfers, please contact us as detailed at the end of this Policy.
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.
The law requires that we provide additional disclosures to residents of certain countries, regions and states. Please see below for disclosures that may be applicable to you.
Notice to European Users
The following applies to individuals in the European Economic Area, Switzerland and United Kingdom.
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.
|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:
You may exercise your rights above by contacting us as detailed at the end of this Policy and specifying your request. 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.
Notice to California Residents
If you are a California resident, this section applies to you in addition to the rest of this Policy.
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.
In the past 12 months, we have collected the following categories of personal information from consumers and have used that information for the following purposes:
|Category of Personal Information Collected
|Business Purpose of Collection
|Source(s) of Information
|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.
|Directly from you when you provide it to us. We also collect unique personal identifiers such as IP address passively from you when you visit our Site
|Information about children, including number of children, names, age, and gender.
|To provide client services and assist in relationship management.
|Directly from you
|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.)
|Directly from you
|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.
|Directly from you when you apply for employment with us
|To assist in marketing and identify Site traffic patterns.
|Passively when you visit our Site
|If you choose to disclose this information, we collect it as part of our employment application process.
|Directly from you when you apply for employment with us
|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.
|Passively when you visit our Site or receive or interact with our communications
|Client information including all of the above categories.
|As relevant and necessary to provide our legal services.
|Directly from you when you provide us the information in connection with our legal representation or from third parties, including our clients, as part of our legal services or in connection with referrals and court appointments.
We will not collect or retain additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.
Retaining Your Information. We will only keep your personal information in an accessible form which can identify you for as long as we need to for the purposes for which it was collected. Because retention periods vary depending on the purpose for collection, we use certain categories and criteria to determine how long we keep personal information, as further described below. Where your personal information is used for more than one purpose, we will retain your Information for the longer of those periods.
|Type of Personal Information
|Personal information processed in connection with client matters
|Up to 7 years after the date of our final bill for the relevant matter, unless:
(a) otherwise required by applicable law;
(b) required for regulatory, compliance or insurance purposes;
(c) a longer limitation period applies in respect of specific types of actions/documents;
(d) there is a dispute that requires it to be kept for longer;
(e) you ask that we retain some of your documents (such as wills and trust documents) on your behalf for safekeeping - in which case, we will retain the documents for the period as agreed between us; or
(f) there is another legitimate reason which requires it to be kept for longer.
|Personal information processed in connection with your employment application
|Unsuccessful applicants - 1 year after the date of notification that application has not been successful, unless:
(a) otherwise required by applicable law;
(b) you consent to us storing it for longer (for example to consider you for future roles); or
(c) there is a dispute or other legitimate reason that requires it to be kept for longer.
Hired applicants –Please see our Employee Handbook for details.
|Personal information processed for marketing purposes
|For as long as you have not opted out of our marketing. If you ask us to no longer use your personal information for marketing purposes, we will need to retain certain of your details in our database to ensure that we do not accidentally send you marketing material.
|Personal information held in our electronic backups
|Our electronic backups are retained for 6 weeks.
When we no longer require your personal information, we will take steps to delete or de-identify it. If the information cannot be permanently deleted or de-identified (for example when it is stored in our electronic backups), we will take appropriate steps to ensure that it is: (a) not used in connection with any decision involving you; (b) not shared with anyone except when we are legally required to do so; (c) kept secure; and (d) permanently deleted once possible.
Sharing Your Information. We do not sell your personal information or share your personal information with third parties for cross-context behavioral advertising purposes, but we may disclose your personal information to third parties for a business purpose. In the past 12 months, we have disclosed the following categories of personal information to certain third party subcontractors and services providers
For a business purpose:
|Category of Personal Information Disclosed
|Category of Third Parties with Whom Information is Disclosed
|Business Purpose for Disclosure
|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
|To help us provide our Site and services and market our services to you.
|The following information about children: number of children, names, age, and gender
|Customer relationship management software
|To help us provide our services and market our services to you.
|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
|To help us provide our Site and market our services to you.
|Marketing intelligence service providers
|To help us provide our Site and market our services to you.
|Third party legal service providers
|As necessary to facilitate our provision of legal services.
Sensitive Personal Information. We do not use or disclose sensitive personal information except as necessary to provide our clients with our legal services.
Personal Information of Children. We have no actual knowledge that we sell or share personal information of consumers under 16 years of age.
Your Rights. California residents have certain rights regarding their personal information:
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 will 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.
Notice to Colorado, Connecticut, Utah and Virginia Residents
If you are a resident of Colorado, Connecticut, Utah or Virginia, this section applies to you in addition to the rest of this Policy.
No Targeted Advertising or Profiling. We do not process your personal information for the purposes of targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.
Sensitive Personal Information. If you have engaged us to provide legal services, we will need to process certain sensitive information about you as necessary to provide that service, which we will do with your consent. We will only process this information as necessary to provide this service and in accordance with applicable law and our data retention policies. We do not use sensitive information to make inferences about you.
Your Rights. State law gives you certain rights regarding your personal information:
Exercising Your Rights. 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 or other individual subject to guardianship, conservatorship, or other protective arrangement under applicable law. To exercise any of your rights described above, please contact us as detailed at the end of this Policy. 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 your name and contact information. We may ask for additional information to verify your identity or your authority as an authorized agent. 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. We will not discriminate against you if you choose to exercise your rights.
Responding to Your Rights Request. After receiving your request, we will use the information you provided to authenticate your identity or your authority as an authorized agent. We will respond to your request using the same method in which it was received, such as via mail or electronically, and we will notify you if your request has been granted or declined, if an exception applies to your request, any reason we cannot comply with your request, or if we need additional information. We will do our best to respond to your request within 45 days. If we need more time, we will contact you with the reason and the extension period. We will 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. You have the right to appeal our refusal to take action on a rights request within 30 days after receiving our decision by contacting us as detailed at the end of this Policy. We will try to inform you of our decision in writing within 45 days after receipt of your appeal, with a written explanation of our decision. If we need more time, we will contact you with the reason and the extension period. If you have concerns about the results of an appeal, you may submit a complaint to your attorney general.
Notice to Nevada Residents
Nevada law gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration to certain other parties. We do not sell your personal information for monetary consideration; however, this right still applies. If you are a Nevada consumer and wish to exercise this right, please submit your request by contacting us as detailed at the end of this Policy.
How to Contact Us
Warner Norcross + Judd LLP
150 Ottawa Avenue NW, Suite 1500
Grand Rapids, MI 49503-2487
Attn: Privacy Officer