California Privacy Disclosures: Hodgson Russ LLP

Hodgson Russ LLP

PRIVACY DISCLOSURES FOR CALIFORNIA RESIDENTS

These disclosures supplement the Privacy Policy (the “Policy”) of Hodgson Russ LLP, a New York limited liability partnership, (the “Firm”), which can be found at www.hodgsonruss.com (the “Site”). They are provided pursuant to the California Consumer Privacy Act (the “CCPA”) and apply only to residents of California. Each capitalized term used, but not defined, in these disclosures shall have the meaning given to such term in the CCPA.

Required Disclosures

Categories of Personal Information Collected

The following categories of personal information are collected by the Firm:

Identifiers (e.g. name, Internet protocol address, email address, physical address, and phone number);
Professional or Employment-Related Information;
Education Information;
Bank account number, credit card number, debit card number, or other financial information
Internet and Network Activity Information; and
Commercial Information.

Categories of Sources of Personal Information Collected

The Firm obtains personal information from consumers using the Site, individuals or entities using the Site on behalf of consumers, or individuals or entities with whom or which the Firm has a business relationship. The Firm may also obtain personal information from clients and employees in the ordinary course of business.

Purposes for Collecting Personal Information

The Firm uses personal information collected by it for one or more of the following purposes:

To achieve the purposes for which you, an individual or entity acting on your behalf, or an individual or entity with whom or which the Firm has a business relationship, provided personal information;
To enable the lawyers at the Firm to render a legal analysis or provide legal services;
To provide you with support, and to respond to your questions, regarding the services of the Firm;
To record use of the Firm’s website, to diagnose problems with the website, and to improve and make the website more useful to consumers;
To send e-mail messages, newsletters and other relevant information about the Firm’s legal services;
To process payments for the Firm’s legal services;
To consider consumers for employment or employ consumers;
To administer employment benefits or distribute wages;
To respond to requests from law enforcement or other governmental authorities;
To comply with any applicable law or legal obligation;
To prosecute or defend itself in a legal dispute or proceeding; and
For any other business purpose permitted by the CCPA.

Categories of Third Parties with whom The Firm Shares Personal Information

The Firm does not sell any personal information to Third Parties. The Firm may share personal information—including any category of personal information collected by the Firm—with Third Parties that enable the Firm to render legal services. Categories of Third Parties with whom the Firm may share personal information include vendors that provide the following services to the Firm: credit card processing, electronic billing systems, law firm accounting systems, business intelligence/financial analysis, document management systems, collaboration sites, document production, faxing, email, email management and security, learning management systems, project management, digital dictation, scheduling systems, payroll and benefits systems, contact relationship management systems, conflict of interest and new business intake systems, information governance systems, bankruptcy data tracking application, Cloud storage, applications for tracking and managing employee benefits data, applications for preparing governmental forms for estates and trusts, applications for managing and preparing forms for immigration, electronic discovery applications, docketing software, case/practice Management software, applications used for preparing required tax forms, applications used for intellectual property or trademark management, government entities and data brokers.

Summary of Consumers’ Rights

The following is a summary of a consumer’s rights under the CCPA:

Access to Specific Information and Data Portability Rights

You have the right to request that the Firm disclose certain information to you regarding your personal information collected by the Firm as follows:

The categories of personal information collected about you;
The categories of sources of the personal information collected about you;
The Firm’s business or commercial purpose for collecting or, if applicable, sharing your personal information;
The categories of third parties with which or whom the Firm shares your personal information;
The specific pieces of personal information collected about you;
The categories of personal information, if any, the Firm disclosed for a business purpose to a third party in the preceding 12 months.

Deletion Rights

You may request that the Firm delete any of your personal information retained by the Firm, subject to certain exceptions. Upon receiving and confirming your verifiable consumer request, the Firm will delete (and direct its service providers to delete) such personal information from the Firm’s (or such service providers’) records, except that the Firm may deny your request if retaining the personal information is necessary for the Firm or one of its service providers to:

Complete the transaction for which the Firm collected the personal information, provide the legal service requested by you, take actions reasonably anticipated within the context of the Firm’s ongoing business relationship with you, or otherwise perform a contract between the Firm and you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activity;
Debug products to identify and repair errors that impair intended functionality;
Exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided by law;
Enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer’s relationship with the Firm;
Comply with a legal obligation; and
Make other internal and lawful uses of personal information that are compatible with the context in which you provided it.

Verifiable Consumer Requests

To exercise your rights described in these disclosures, you must submit a verifiable consumer request to the Firm as set forth in the Policy. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request relating to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows the Firm to reasonably determine you are the person about whom the Firm collected personal information or an authorized representative.
Describe your request with sufficient detail that allows the Firm to properly understand, evaluate, and respond to it.

The Firm cannot respond to your request or provide you with personal information if it cannot verify your identity or authority to make the request and confirm the personal information relates to you. The Firm will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

The Firm’s Response

The Firm endeavors to respond to a verifiable consumer request within 45 days of its receipt. If the Firm requires more time (up to an additional 45 days), the Firm will inform you of the reason and extension period in writing. The Firm will deliver its written response by mail or electronically, at your option. Any disclosures provided by the Firm will only cover the 12-month period preceding receipt of the verifiable consumer request. The response provided by the Firm will, if applicable, also explain the reasons it cannot comply with a request. For data portability requests, the Firm will select a format to provide your personal information that is readily useable and should allow you to electronically transmit the information from one entity to another entity without hindrance.

The Firm does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If the Firm determines that any request warrants a fee, it will tell you why a fee is warranted and provide you with a cost estimate before completing your request.

No Discrimination

The Firm will not discriminate against you for exercising any rights under the CCPA. In particular, if you exercise any such rights, the Firm will not:

Deny you services or access to your client file;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of services; or
Suggest that you may receive a different price or rate for services, or a different level or quality of services.

Revisions

The Firm may revise these disclosures from time to time by posting the revisions on the Site. Any such revision will take effect immediately upon such posting, but will only relate to personal information collected after such revision is posted. It is your responsibility to periodically check the Site for revisions to these disclosures.

Dated: July 1, 2020