Krugliak, Wilkins, Griffiths &Dougherty Co., LPA (“KWGD”, “we” or “us”) is committed to protecting your privacy. This Privacy Statement (“Statement”) informs you how we collect, use, secure and share your personal identifying information (“Personal Data”) collected by us when you:
- Visit our website;
- Submit an inquiry through our “Contact Us,” apply for a job, or other interactive pages; and
- Receive communications from us, including invitations, resources, materials, emails, phone calls, texts or faxes.
The activities above are referred to interactions with us (“Interactions”). Please note that Personal Data does not include publicly available information about you or information that has been de-identified, anonymized or aggregated in a way that your Personal Data cannot be traced back to you individually. This Privacy Statement is part of, and is governed by, the terms and conditions set forth in our Terms of Use. Terms not defined in this Privacy Statement have the meaning given to them in our Terms of Use. If you do not feel comfortable with any part of this Privacy Statement or our Terms of Use, you must not Interact with us through our website (“Site”). Please use our Contact Us feature to call or write to us. Please note that this Statement does not cover other communications with you pursuant to the attorney-client relationship. Interacting with us does not form or imply an attorney-client relationship. We strongly recommend that you take care not to share any sensitive personal or other confidential information through this site.
Changes to Our Privacy Statement
This Privacy Statement may change from time to time. By continuing to Interact with us after those changes become effective, you agree to be bound by the revised Privacy Statement. You should revisit this page from time to time to check the Effective Date at the top of this page to determine whether there have been any updates since your last visit.
The Information We Collect and Store
Personal Data is any information that identifies your or makes you identifiable. We may collect and store the following Personal Data in connection with our Interactions with you:
- User-provided information. When you use one of our interactive features on our site, some of the information that we request is Personal Data. If you do not want to provide Personal Data through the features on our site, please Contact Us to speak with us directly.
- Geo-Location Information. Some devices allow applications to access real-time location-based information, such as an IP address, can sometimes be used to approximate a device’s location.
- Cookies. We use “cookies” to collect information and improve our Interactions with you. A cookie is a small data file that we transfer to your device. We may use “session ID cookies” to enable certain features of the Service, to better understand how your Interactions with us and to monitor aggregate usage and web traffic routing on our website. For more information on cookies and similar technologies, please see our Cookie Statement .
How We Use Personal Data
Your Personal Data may be used for the following purposes:
- To engage with you. We want to share information about our firm with you, and to do so we may process your contact information to send you marketing or legal update communications or to respond to your request for a consultation. You can opt-out of our communications at any time and free of charge.
- We use a proprietary system made available by our marketing firm to collect basic information about your visit, namely your IP address. This data is immediately aggregated for analytics purposes to learn more about which pages our visitors are reading the most, among other analytics that help us continually improve relevant content on our site.
- If you sign up to receive marketing or informational announcements and updates from us, our emails will include the capability to opt-out of receiving such e-mails in the future. Marketing and informational announcements include any communications to you that are only based on promoting our Products. Transactional communications about an Interaction are not considered “marketing” or “informational” communications.
- Evaluate employment opportunities. When you submit an application through the email link on our Site, we will utilize the Personal Data provided to evaluate whether the available employment opportunities and your Personal Data are a good fit. We may further process your data in our systems for on-boarding and other employment purposes.
If, in the future, we use your Personal Data in any way that is not described in this Privacy Statement, we will notify you at the point of collection, and you can choose not to allow us to use your Personal Data for the new or different purpose. If you choose to limit the ways we can use your Personal Data, some or the entire Site may not be available to you, and we may not be able to Interact with you.
Information Sharing and Disclosure
We share and disclose your Personal Data as described below.
- Service Providers, Business Partners and Others. We use certain trusted third-parties to help us provide more relevant content to you, including maintaining this Site and update our resources on our site based on your browsing history, respond to inquiries, and Interact with you for employment and recruitment tracking purposes. We enable you to share certain materials on our Products through social networking services, such as Facebook, Instagram, and Twitter, where the link is provided.
- Compliance with Laws and Law Enforcement Requests; Protection of KWGD’s Rights. We may use or disclose Personal Data to third parties when we have a good faith belief that disclosure is reasonably necessary to: (a) comply with a law, regulation or legal requests including to meet national security or law enforcement requirements; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse, or (d) protect our rights.
Online Tracking
Some browsers have incorporated Do Not Track (“DNT”) preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. As there is not yet a common agreement about how to interpret DNT signals, we do not honor DNT signals from website browsers at this time. Implementing a DNT preference also does not signify a “do not sell/contact” request. We understand that various parties are developing “do not sell/contact” signals, and we may recognize certain such signals if we conclude such a program is appropriate.
You may refuse or delete cookies; however, some of our website functionality may be not work properly.
Accessing, Changing or Deleting Your Personal Data
We may retain copies of your Personal Data if required by law or in the normal course of our relationship with you. For questions about your Personal Data related to our Interactions with you or in connection with our company, please Contact Us. We will respond to your inquiry as soon as possible. If your communication relates to your Personal Data, we may ask you to verify your identify before we can act on your request.
Security
We employ appropriate technical and organizational measures to ensure a level of security that is appropriate to our Interactions with you. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee its absolute security and cannot be responsible for unencrypted information that you send if it is subsequently subjected to unauthorized access.
Protecting Children
Our website and legal services are not directed to or provided to persons under 18. We do not knowingly collect Personal Data from children under 18. Any individuals under the age of 18 must have consent to Interact with us or use the Services from their parent or guardian. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should Contact Us. If we become aware that a child under 18 has provided us with Personal Data, we will take steps to delete such information.
Transfer of Personal Data
The following sections below describe additional rights that certain individuals have with respect to safeguarding their privacy.
United States – State Laws and Regulations Regarding Individual Consumers’ Privacy Rights
If you are an individual consumer and are a resident of one of the states listed below, you may have additional privacy rights granted to you by your state of residence.
- California. Under the California Consumer Privacy Act (“CCPA”), California consumers have certain rights they may exercise either independently or through an authorized agent. CCPA rights requests are subject to an identification and verification process. We will not fulfill a CCPA request unless we have been provided sufficient information for us to reasonably verify that the requestor is the consumer about whom we collected Personal Data. If you are an individual consumer residing in the state of California, these rights may apply to you.
- Some Personal Data we maintain about consumers (e.g., clickstream data) is not sufficiently associated with enough Personal Data about the consumer for us to be able to verify that it is a particular individual. Accordingly, we will not include such information in response to consumer requests. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create an account with us to make a request. We will use Personal Data provided in your request only to verify your identity or authority to make the request and to track and document request responses, unless you also provided the Personal Data to us for another purpose.
- Disclosure Rights. You have the right to request that we disclose the following Personal Data for the 12-month period prior to the request date. Consumer requests of this nature may be made no more than once in a 12-month period. With respect to (1) and (2) below, we will provide this information in a portable and, if technically feasible, readily usable format.
- The categories of Personal Data we have collected about you. �The categories of sources from which we collected your Personal Data and the purpose for collection.
- The specific pieces of Personal Data we have collected about you.
- The categories of third parties to whom we have disclosed your Personal Data.
- Although we do not sell your Personal Data, in the event that our practices change, we will provide a list of the categories of Personal Data we sold about you in the prior 12 months, including the categories of third parties to whom we sold your Personal Data and the business or commercial purposes for the sale (or a statement that no such sale occurred).
- “Do Not Sell” Rights. As stated above, we do not sell California consumer Personal Data as defined under the CCPA, and until such time as we change our practices by updating this Privacy Statement, will treat Personal Data collected under this Statement as subject to a “do not sell” request. Please see Section 7 regarding “do not track” mechanisms.
- Deletion Rights. You may request that we delete your Personal Data that we have collected directly from you. Under the CCPA, we may decline to delete your Personal Data under certain circumstances, for example, if we need the Personal Data to complete transactions or provide services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes (including maintaining business and employment records), to comply with law, or to exercise or defend legal claims or other legal rights. Note also that we are not required to delete your Personal Data that we did not collect directly from you.
- Non-Discrimination. We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.
- Nevada. “Do Not Sell” Rights. We do not sell Personal Data. Until such time as we change our practices by updating this Privacy Statement, we will treat Personal Data of Nevada residents that is collected on the website as subject to a “do not sell” request.
General Data Protection Regulation
This section only applies to Interactions with individuals who are located in the European Economic Area, United Kingdom and/or Switzerland (collectively, the “Designated Countries”) at the time of data collection.
We may ask you to identify which country you are located in when you Interact with us, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Statement, the terms in this section shall apply to users in the Designated Countries.
- Our Relationship with You. KWGD is a data controller with regard to any Personal Data collected from you pursuant to an Interaction. A “data controller” is an entity that determines the purposes for which and the manner in which any Personal Data is processed. Any third parties that handle your Personal Data in accordance with our instructions are our service providers and are “data processors.” You are a “user.” Users are individuals providing Personal Data to us via an Interaction, such as signing up for our newsletter(s), requesting Product information, or otherwise accessing or using the information or features on this Site.
- Marketing. We will only contact individuals located in the Designated Countries by electronic means (including email or SMS) as permitted by applicable law or your consent. If you do not want us to use your Personal Data in this way, or to disclose your Personal Data to third parties for marketing purposes, click an unsubscribe link in your email, or Contact Us.
- Individual Rights. We may limit your individual rights requests (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on others’ privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or burdensome.
- Right to withdraw consent. For any consent-based processing of your Personal Data, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
- Right of access. Upon your request, we will provide you with a copy of your Personal Data in our files without undue delay and free of charge. Your access may limited to the extent it would adversely affect the rights and freedoms of other individuals.
- Right to rectification (or “correction”). You may request to correct or update any of your Personal Data in our files. To update your Personal Data, Contact Us.
- Right to erasure (or the “Right to be Forgotten”). Upon your request, we will erase any of your Personal Data in our files that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities or Interactions with us to which you object, and there are no overriding legitimate grounds for our processing.
- Right to Restrict and Object. You have the right to restrict or object to our processing of your Personal Data.
- Right to data portability. If we process your Personal Data based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your Personal Data, with certain legal limitations.
- Notification to third parties. We will notify third parties also handling the relevant Personal Data of any request by you pursuant to this section. Upon your request, we will identify such third parties.
Other Countries
- Residents of Australia. Australian residents have the option to deal anonymously or by pseudonym if you contact us by telephone and you merely seek information about our Products but you do not wish to enter into any further discussions with us. However, if you wish to deal with us in this way, you may not be able to fully interact with us. We may transfer your Personal Data to service providers, and other parties described in this Statement. We rely on your consent or opt-in to send you direct marketing messages about our Products and to deliver targeted advertisements to you. You can withdraw your consent, as us a question, or make a complaint at any time by Contacting Us. If you are not satisfied with our handling of your problem or complaint you may make a complaint to the Australian Information Commissioner – for further details please visit http://www.oaic.gov.au/
- Residents of Mexico. As a resident of Mexico, you may object to the processing of your Personal Data for the following voluntary uses of such Personal Data: to communicate or send you promotions; to provide you with relevant Product advertising; or to determine the effectiveness of our advertising through analytical tools described above. You have a right to access and correct your Personal Data. Local law may provide you the right to cancel or oppose the collection and processing of your Personal Data; limit the scope of processing; and to revoke your consent. Please Contact Us to explain what right you want to exercise and provide proof of identity. We will reply in accordance with applicable law. If you would like to correct or update your Personal Data, please provide us the corrected information.
- Residents of Canada. If you are a resident of Canada, the Personal Data Protection and Electronic Documents Act (PIPEDA) set forth by the Office of the Privacy Commissioner of Canada applies to you. To learn more about PIPEDA, visit https://www.priv.gc.ca/information/pub/guide_ind_e.asp. If you have questions about PIPEDA as it pertains to the use or storage of, and access to your Personal Data, please Contact Us.
- If you are a resident of a country other than those listed above, please Contact Us regarding any legal rights that may apply to you.
Cookie Statement
A cookie is a small file that may be stored on your computer or other device. A cookie enables the entity that put the cookie on your device to recognize it across different websites, services, devices, and browsing sessions. We use certain cookies to enhance your Interactions as described in “How We Use Personal Data.”
When you use a web browser to access the Services, you may configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Click the “Help” menu of your browser to learn more about how to change your cookie preferences. The operating system of your device may contain additional controls for cookies. If you are interested in learning more about cookies, click here: www.aboutcookies.org or www.allaboutcookies.org.
Please note that disabling cookies may affect your ability to access and use this Site.
Contact Us
If you have any questions or comments about our Products, website or this Statement, we would like to hear from you.
General Inquiries Contact Us or legal@kwgd.com
Toll-Free Telephone Number: (ask for Privacy Counsel) 877.876.9958
Privacy Office Email Address: privacy@kwgd.com