Effective: April 20, 2019
Last Updated: March 21, 2024
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Hosch & Morris, PLLC (“HM”, “we”, “us”, “our”) is a boutique law firm dedicated to data privacy, information security, the Internet and technology. This Privacy & Cookie Statement (“Statement”) means a lot to us, and we encourage you to read it fully, download a copy, or click on each section below.
THIS STATEMENT IS PART OF OUR NOTICES AND TERMS
This Statement is part of our Legal Notices and Terms of Use (“Notices and Terms”), which you should also read. Capitalized terms not defined here (e.g. the word “Site”) have the meaning set out in our Notices and Terms, and the word “including” means “including but not limited to.”
This Statement is meant to tell you who we are, how we collect, use, share, and otherwise process personal information about you, and the rights and choices that may be available to you with respect to your personal information (namely, any information that enables us to identify you, directly or indirectly). We’ll also address some “Other Privacy Issues,” and tell you how you can contact us.
WHAT THIS PRIVACY STATEMENT COVERS
This Statement covers our Site, our legal services (“Services”), our operations, and our recruiting activities. It applies to all individuals who visit our Site, engage our Services, supply goods or services to us, or participate in our recruitment activities, as well as any other individuals about whom we obtain personal information, unless we specifically state otherwise. Our privacy practices with respect to our employees and contractors are addressed through internal policies and are outside the scope of this Statement.
WHAT PERSONAL INFORMATION WE COLLECT, AND WHY
We collect personal information in connection with the day-to-day operations of our Firm. Exactly what we collect depends on how you engage with us, but generally we collect personal information that broadly falls into two categories:
Personal information you give us: When you contact or engage us (usually by email or phone), we collect information such as:
- Identity and Contact Data, e.g. your name, job title or function, company or organization, educational or professional background, postal address, email address, telephone number(s), and other personal information concerning your preferences relevant to our Services;
- Financial and Payment Data, including your bank account, credit/debit card numbers, security code numbers and other related billing information and other information necessary to process payments and prevent fraud;
- Client Service Data, including personal information we need in order to perform and provide our Services (e.g., personal information and/or prospective clients about clients, prospective clients, and/or their individual representatives, employees, customers or other individuals known to clients, client feedback, emails/communications, and call record details). Our clients are responsible for ensuring that any such information is transferred to us in compliance with applicable data protection laws;
- Job Applicant Data, including Identity and Contact Data, resumes, identification documents, academic records, employment history, and references relevant to our determination about your suitability to a particular position. We may also collect special categories of personal information where we are legally obligated to do so, or with the individual’s explicit consent.
- Compliance Data, e.g. government identifiers, passports or other identification documents, dates of birth, beneficial ownership data, and due diligence data.
Personal information that is collected automatically when you visit our Site: Our Site is a website hosted and supported by service providers located in the United States.
- Hosting and tools. We offer our Site for informational and education purposes only, and not to interact with Site visitors except as described below. But we must rely on hosting, tools, and templates provided by certain service providers such as Squarespace (for hosting), Google Analytics (for reports on Site use), and Google reCAPTCHA (to help secure certain parts of the Site) whose work requires them to process some of your personal information (e.g. IP addresses, preferences, web pages you visited before coming to our Site, information about your browser, network or device, timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and loading errors or other problems. See our section below on Cookies.). We try to eliminate scripts, social media integrations, and similar technologies from our Site because we do not use them, but some may remain embedded on our Site unused by us.
- Log Data. We also rely on your consent to our use of cookies on the Site and use a service provider to store such Log Data on our behalf, including information about your browser, network, and device, and your IP address.
If we ask you to provide any other personal information not described above, we will endeavor to make clear to you what personal information you are asked to provide, and why, when you are asked to provide it.
HOW WE USE THE INFORMATION WE COLLECT FROM YOU
We use personal information to improve our Site, to render our Services, to respond to inquiries, to provide, manage, and market our Services, to operate our Firm, and to administer our recruitment activities. Personal information will only be processed for purposes stated herein, where you have provided consent, or as required by law or regulation.
We may process personal information for multiple purposes based on multiple legal bases for processing, including:
Consent (which can be revoked); and
When processing is necessary to fulfill a contract, or take steps linked to a contract with you or your organization. This includes:
- to administer our conflicts checks and engagements processes;
- to communicate with you, your organization, or third parties in connection with our Services, and the fulfillment of legal or regulatory requirements to which we are subject;
- to provide, manage, and market our Services;
- to process and complete transactions, and send related information, including invoices in connection with our Services; and
- to process applications for employment with HM, including assessing your suitability for the position for which you are applying, communicating with you about your application, and administering our recruitment process.
When processing is necessary to conduct our business and pursue our legitimate interests, in particular:
- to provide, administer, operate, maintain, analyze, and improve our Site;
- to respond to inquiries and requests and to provide you with information and access to resources that you have requested;
- to administer and manage our relationship with you or your organization, including identifying persons authorized to represent our clients, suppliers or service providers, pursuing related accounting activities, auditing activities, and taking other steps linked to the performance of our business relationships and recruiting activities;
- to carry out background checks, where permitted;
- to protect the security of our premises, our communications, our Site, and other systems and to prevent and detect security threats, frauds, other criminal or malicious activities or other liabilities;
- for insurance purposes;
- to monitor compliance with our policies and standards;
- to protect, exercise, or defend our legal rights;
- to monitor compliance with our policies and standards;
- to protect, exercise, or defend our legal rights; to provide, administer, operate, maintain, analyze, and improve our Site;
When processing is necessary to protect vital or public interests; and
As otherwise required to fulfil legal or regulatory requirements to which we are subject.
DOES HM SHARE YOUR PERSONAL INFORMATION?
Yes, but not with any third parties for the purposes of direct marketing. We may share your personal information as necessary to provide our Site, Services, or to fulfill other business and compliance purposes. We may also share your personal information outside of HM, as described in this Statement, under the following circumstances:
- When our suppliers or service providers are helping us carry out the purposes described above;
- When we believe it is appropriate in order to provide our Services to you or your organization;
- When we believe we are must do so in order to comply with law, applicable regulations, governmental or quasi-governmental requests, or in response to a subpoena, court order, or other applicable law or legal process; or
- When we have a good faith belief that disclosure is necessary to protect our own, our users’, or others’ rights, property or safety.
We also reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets, as well as in the event of insolvency, bankruptcy, or receivership in which personal information would be transferred as an asset of HM.
SECURITY OF YOUR PERSONAL INFORMATION
We have put in place technical and organizational safeguards designed to protect your personal information against loss, misuse or unauthorized access, alteration, or unintentional destruction. These safeguards include limiting access to data, storing personal information on servers and computers believed to be secure, utilizing encryption, and having procedures for responding to a suspected breach of personal information. In addition, we maintain contractual data security and privacy obligations with our suppliers, and our employees are subject to access, use, and confidentiality policies. However, no security controls are 100% effective, and we cannot ensure or warrant the security of your personal information. If we believe the security of your personal information in our possession or control may have been compromised, we may seek to notify you by email, and you consent to our use of email as a means of such notification.
INTERNATIONAL DATA TRANSFERS
Should it become advisable to transfer personal information to other countries, we do so by Standard Contractual Clauses where recognized by law, obtaining your consent, or other lawful means.
YOUR RIGHTS
Depending on where you reside, you may have particular rights regarding your personal information (e.g. the right to request access, correction, deletion, transfer, or take other actions), and how to exercise those rights.
To exercise your rights (including to make a request to access, delete, update or correct your personal information, to ask for portability of your personal information, or to object to processing on grounds relating to your specific situation), please contact us. We will consider your request in accordance with applicable laws. Some of your rights may be subject to exception and limitation. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
COOKIES
In connection with our Site, we use cookies, web beacons, and similar tracking technologies (collectively, "cookies").
What are cookies?: “Cookies” are small files or pieces of text that download to a device when a user accesses a website or app. These technologies store a unique identifier which allows a website to recognize the device whenever the device is used to visit the website. We collect information using cookies and similar tracking technologies provided to us by our service providers.
We may use these tracking technologies to remember information that will make your use of the Site more convenient, to track the aggregate number of users of our Site, or similar purposes. You can find more information about cookies and how they work at www.allaboutcookies.org.
How do we use cookies? We use cookies to help us understand how many users are visiting the Site, how they are using it, to see how it is performing, and to learn how we may improve it. For example, cookies on the Site help us to understand usage patterns so that we can improve the Site’s content.
Use of third-party cookies: When visiting our Site, you many encounter embedded content on our Site (e.g. YouTube videos), or you may be directed to other websites that use their own cookies. We do not have control over the placement of cookies by other websites, even if you are directed to them from our Site.
We also use Google Analytics. Google collects information about your online activities on our Site over time and across different websites you visit in order to provide advertising tailored to your interests. We are unable to prevent Google Analytics from doing so, but you may be able to opt-out of certain actions. To learn more and to exercise choice regarding such cookies, please visit the Google Analytics Opt-out Browser Add-on.
Additionally, we have implemented Google reCAPTCHA to help secure certain parts of the Site. reCAPTCHA collects hardware and software information, such as device and application data, and sends it to Google for purposes of providing, maintaining, and improving reCAPTCHA and for general security purposes. This information is not used by Google for personalized advertising. Your use of reCAPTCHA is subject to Google’s Privacy Policy and Terms of Use.
How to control cookies: When you first access the Site, you will receive a pop-up message advising you that cookies and similar technologies are in use. By continuing to browse the Site, you signify that you understand and agree to the use of these technologies, as described in this Statement. Using the cookie control that we have activated on the Site, you may also choose not to receive certain cookies.
You can also review your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise choices you have for certain cookies. If you disable or delete certain cookies, you may not be able to access or use features of this Site.
OTHER PRIVACY ISSUES
Children’s information: Our Site, Services, operations and recruiting activities are not directed at children under the age of eighteen (18) and we do not knowingly collect personal information from children under the age of eighteen (18).
Data Retention. We do not intend to retain your personal information longer than is necessary for the purpose it was collected, which may include purposes of satisfying any legal, accounting, or reporting requirements and, where required for HM to assert or defend against legal claims, until the longer of the relevant retention period or until the claims in question have been finally resolved.
Disclaimer of linked websites: The Site contains links to other websites administered by third parties. This Statement does not apply to the privacy practices of other websites. We encourage you to read the privacy statements on the other websites you visit.
“Do Not Track” Signals: We do not track our Site’s visitors over time or across third party websites to provide targeted advertising, and therefore we do not respond to Do Not Track (DNT) signals at this time. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, you can learn more about “Do Not Track” by visiting www.allaboutdnt.com.
Automated decision-making: We do not use automated decision-making without human intervention, including profiling.
CHANGES TO THIS STATEMENT
We may occasionally amend this Statement to reflect our activities, and we reserve the right to revise this Statement at any time. Please check the “Last Updated” legend at the top of this page to see when this Statement was last revised. The provisions contained in this Statement supersede all previous notices or policies regarding our privacy practices. You should periodically check this page to stay informed about our privacy practices.
CONTACT INFORMATION
HM is organized as a professional limited liability company under the laws of the State of Texas, U.S.A. Our principal place of business is 8117 Preston Rd., Ste. 300, Dallas, Texas 75225. We have appointed a Chief Privacy Officer for you to contact if you have a privacy concern, complaint or question, and her contact information follows:
Hosch & Morris, PLLC
8117 Preston Rd., Ste. 300
Dallas, Texas 75225
1-888-660-0570
privacy@hoschmorris.com