Privacy
Florida Counsel and Consulting, Inc., Privacy Policy

Last Updated: August 28, 2018

Please note that throughout this Privacy Policy we use “[at]” instead of “@” in email addresses. This is to avoid search routines or “bots” from collecting our email addresses, spamming us, and negatively impacting the Services.  Where you see “[at]” in an email address, please substitute it with “@” when contacting us.

“Services” Defined

Florida Counsel & Consulting, Inc., and its affiliates want you to be aware of the manner in which we collect, use, and disclose information.  This Privacy Policy details our practices and procedures in connection with information that we collect online and offline through our websites (“Websites”), computer and mobile software applications, if any (“Apps”), through social media, emails, shared sites (e.g., SFTP), and through services to our clients, all of which we refer to collectively as our “Services.”

The collection of Personal Information from you is necessary to provide the requested Services to you.  If the information is not provided, we may not be able to provide our Services.  In the event you disclose any Personal Information regarding other persons to us or to our service providers, you represent that you have the authority to do so and that you are granting permission to use the information in accordance with this Privacy Policy.

Collection of Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.  Personal Information includes, but is not limited to:
  • Name
  • Postal address (including personal, business, billing, and shipping addresses)
  • Telephone number (including landline, cellular number, and VOIP)
  • Email address (personal and business)
  • Employment information (job title and employer)
We and our service providers collect Personal Information in a variety of ways, including:
  • Through this Website
  • Through the provision of our Services
  • Offline (where interactions take place through a representation contract for Services, or when information is provided via offline contact or interaction).
  • Other Sources (which may include, but not be limited to, public databases, joint marketing entities, partners or event sponsors who share information with us, other entities or individuals to whom we provide Services, which may include your employer or agent, and social media platforms).
Use of Personal Information

We and our service providers may use Personal Information for our legitimate business purposes (including managing our contractual relationship with you, complying with legal obligations, where we have a legitimate interest, and/or, in some cases related to marketing, with your consent if required by applicable law), including:
  • Providing the functionality of our Services and to fulfill your requests via online contact forms or otherwise (e.g., when you send us blog comments, suggestions, questions or concerns, or when you request other information about our Services).
  • Providing you with access to our blog and/or other marketing materials, facilitating social media interaction or sharing, to fulfill calendaring or scheduling requests, or to send information about our Services, news or events.
  • Providing our Services, which includes contacting individuals (and/or their agents and employees) in connection with the provision of Services, responding to inquiries and fulfilling requests from clients, administering client files, and managing relationships.
  • Accomplishing our business purposes, which includes but is not limited to the provision of our Services, operating and expanding business activities, data analysis, audits, fraud and security monitoring, identifying usage trends and the effectiveness of marketing campaigns.
  • Aggregating and/or anonymizing information so that it will no longer be considered Personal Information under relevant provisions of law or authority, and in turn which we may use and disclose for any purpose.
Disclosure of Personal Information

We disclose Personal Information:
  • To our agents, consultants and affiliates for all purposes as described in this Privacy Policy.
  • To provide legal and related services requested by you or a related individual or entity.
  • To third-party service providers in relation to services they provide for and to us, which may include web hosting, electronic communication and delivery, data analysis, information technology, customer service and other interaction related to the representation of clients.
  • At your election by virtue of use of comment pages, social media platforms, message boards, chat pages, profile pages, blogs and other services to which you are able to post information and content (all information you post or disclose through these services will become public and may be available to other users or the general public).
We also use and disclose your Personal Information as necessary and appropriate, especially when we have a legal obligation or legitimate interest to do so:
  • To comply with applicable laws and regulations, which can include laws and regulations outside your country of residence.
  • To cooperate with public and government authorities, including law enforcement, which can include authorities outside your country of residence.
  • For other legal reasons, such as to enforce our terms and conditions; and to protect our, our affiliates’, your or others’ rights, privacy, safety or property, including intellectual property.
  • In relation or as part of a sale or business transaction (including any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings).
Other Information and How We May Collect, Use and Disclose It

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, and which we and our third-party service providers may collect in a variety of ways:

  • Browser and device information.  Most browsers collect certain information and some is collected automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App you are using). We use this information to ensure that the Services function properly.
  • App usage data.  If we provide an App, and you download and use such App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device identifier.
  • Information collected through cookies.  Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect and store certain information about you.  We may use both session cookies (which expire when you close your web browser) and persistent cookies (which stay on your computer until you delete them).  You may be able change your Internet browser settings regarding cookies, however, if you set your browser preferences to block all cookies, you may not be able to access some or all of the Services or your use of the Services may be impacted. By using the Services, you consent to the use of cookies as set forth in our Privacy Policy.  

                     Our Site uses the following types of cookies:

               (a) 'session cookies' which are stored only temporarily during a browsing session in order to allow
                        normal use of the system and are deleted from your device when the browser is closed; 
                 (b) 'persistent cookies' which are read only by the Site, saved on your computer for a fixed period
                       and are not deleted when the browser is closed. Such cookies are used where we need to know
                       who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 
                 (c) 'third party cookies' which are set by other online services who run content on the page you are 
                        viewing, for example by third party analytics companies who monitor and analyze our web access.

  • Information collected through web beacons and other technologies.  Pixel tags, web bugs, clear GIFs, and other similar technologies (called “web beacons”) that contain content and ads that we deliver to you, which we will use to collect information regarding your interaction with our content and ads to measure the success of our marketing campaigns and compile statistics about usage of the Services.
  • Information collected via (embedded) script or font libraries. In order to present our contents correctly and graphically appealing across all browsers, this Website may use script libraries and font libraries such as Google Web Fonts, (see https://www.google.com/webfonts). Google Web Fonts are transferred to your browser's cache to avoid multiple loading.  If your browser does not support Google Web Fonts or does not allow access, content will be displayed in a default font.  Calling script libraries or font libraries automatically triggers a connection to the library operator. In theory, it is possible - but currently also unclear whether and, if so, for what purposes - that operators of corresponding libraries collect data. The privacy policy of Google’s library operator can be found here: https://www.google.com/policies/privacy.
  • Analytics. We may use products, including Google Analytics, to analyze activity on our Services. We may use these products to understand how users use our Services in order to enhance the user experience.  If you wish to opt-out of Google Analytics, go to https://support.google.com/analytics/answer/181881?hl=en.
  • Demographic information. Demographic information and other information provided by you that does not reveal your specific identity.
  • IP addresses.  Your IP address and/or the IP address of any device used by you, or your affiliate, agent, consultant, employer, employee or vendor to access this web site or utilize our Services.
  • Aggregated or anonymized information. Information that has been aggregated or for which parts have been removed in a manner such that it no longer reveals your specific identity.

We may use and disclose Other Information for any purpose, except where required by applicable law to do otherwise.  We may be required to treat Other Information as Personal Information under applicable law or where we may combine Other Information with Personal Information, in which cases we may use and disclose such information for the purposes described in our Privacy Policy related to Personal Information.

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

Security

We use reasonable administrative, technical, and organizational measures in an effort to protect your Personal Information within our firm.  However, no method of transmission or storage of information is 100% secure, particularly on the Internet, and despite these measures, we cannot guarantee the security of Personal Information.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us as provided under “Contact Us” below.
 
Opt-out Process

If, after contacting us or requesting information from us, you no longer want to receive marketing-related communications or emails from us, you may opt-out by contacting us by email at privacy[at]floridacounsel.com or following the unsubscribe instructions in any communication received from us.  After you opt-out, you may still receive important administrative messages from us, unrelated to marketing, from which you cannot opt out.

Access to Your Information

You may also request to access, change, update or delete your Personal Information, at any time.  To do so, or to request an electronic copy of your Personal Information for purposes of providing it to another provider of same or similar services (to extent the same is permitted by applicable law), you may contact us at privacy[at]floridacounsel.com.  The transmission of a request of this nature does not guarantee a response from us, other than as would be consistent with applicable law.

Data Retention

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.  To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information you have provided, 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 applicable legal requirements including, but not limited to, legally mandated retention periods and litigation hold requirements.

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the policies and practices of third parties that are not operating on our behalf.  The inclusion of a link from our Services to third parties (including, but not limited to, social media platforms is not an endorsement of those third parties.  The privacy and data protection practices of those third parties is subject to their own privacy policies and are not covered by our Privacy Policy.

Advertisements

We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).  You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites at http://optout.networkadvertising.org  and  http://optout.aboutads.info. 

Use of Services By Minors

The Services are not directed to individuals under the age of eighteen (18), and particularly not to those under the age of thirteen (13).  We do not knowingly collect Personal Information from individuals under 18, particularly not those under 13, and request that these individuals not provide Personal Information through the Services.

Any California residents under the age of eighteen (18) who used the Service, and who posted content or information on the Service, can request removal by contacting us in writing at privacy[at]floridacounsel.com, providing as much detail as possible as to where the content or information is posted and attesting that you posted it.  We will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. The removal process cannot ensure complete or comprehensive removal (i.e. third-parties may have republished or archived content by search engines and others that we do not control).

Cross-Border Transfer

We are based in the United States and the Personal Information we and our service providers collect is governed by the laws of the United States.  If you are accessing the Services from outside of the United States, please be aware that information collected through the Services may be transferred to, processed, stored, and used in the United States.  Data protection laws in the United States may be different from those of your country of residence.  Your use of the Services or provision of any information therefore constitutes your consent to the transfer to and from processing, usage, sharing, and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

Your California Privacy Rights

We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine the Light” law) with third parties for their direct marketing purposes absent your consent.  If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us at privacy[at]floridacounsel.com or by sending a letter to Florida Counsel & Consulting, Inc., P.O. Box 784058, Winter Garden, FL 34778 (Attn: Privacy Inquiry).  Any such request must include ‘California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.  Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by any means other than the indicated email address or postal address.

Sensitive Information

We ask that you not send us, and that you not disclose, any Sensitive Personal Information (e.g. social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics, health information, genetic characteristics, criminal background or trade union or association membership, on or through the Website, Services or otherwise to us.  In some circumstances, depending on the nature of the Services you are seeking, we may have to process certain Sensitive Personal Information.  In the event certain Sensitive Personal Information is received and is processed to provide Services to you, the retention and processing of the same will be undertaken in accord with this Privacy Policy.

Attorney-Client Communications

Any communications between us and our clients through this Website or an email address utilizing a hosting service associated with this Website are attorney-client communications. Any content or communications otherwise submitted to us, such as through contact us tools, posting comments on blogs, creating a user profile, etc., are not intended to create an attorney-client relationship and should not be used for attorney-client communications.

Do Not Track Signals

At this time, we do not respond to browser “Do Not Track” or “DNT” signals.  For more information about do-not-track signals, please go to www.allaboutdnt.com.

Updates to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy.  The “Last Updated” label at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at privacy[at]floridacounsel.com.  Please note that email communications are not always secure, so please do not include credit card information or Sensitive Information in your emails to us.

Your EEA Privacy Rights

If you are visiting the Services from the European Economic Area (“EEA”), you have certain privacy rights described below:

Personal Information.  With respect to EEA data subjects, “Personal Information”, as used in this Privacy Policy, is equivalent to “personal data” as defined in the European Union General Data Protection Regulation. 

You may ask us to take the following actions in relation to your Personal Information that we hold:

Opt-out. You may request that we stop sending you direct marketing communications, which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.

Access. Provide you with information about our processing of your personal information and give you access to your personal information.

Correct.  You may request that we update or correct inaccuracies in your personal information.

Delete.  You may request that we delete your personal information.

Transfer.  You may request that we transfer a machine-readable copy of your personal information to you or a third-party of your choice.

Restrict.  You may restrict the processing of your personal information.

Object.  You may object to our reliance on our legitimate interests as the basis of  our processing of your personal information that impacts your rights.

You can submit these requests by email to privacy[at]floridacounsel.com. 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. 

Individuals located in the EEA have the right to lodge a complaint with a supervisory authority of the EEA state where you work or live or where any alleged infringement of data protection laws occurred.  A list of the supervisory authorities can be found here:
 

Additional information regarding data protection authority for your country or region, or where an alleged infringement occurs can be found here: 



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