Ferruzzo & Ferruzzo, LLP and its affiliates (“Firm,” “we,” “us,” or “our”) is committed to protecting the privacy of personal information that may be collected or obtained in the course of business from individuals and businesses. This Privacy Policy (“Privacy Policy”) describes how we collect, use, and share your personal information and the choices you may have regarding our use of your personal information. We may update and make changes to this policy, so we encourage you to review it periodically. This Privacy Policy describes our practices in connection with Personal Information that we collect through:
1. Our website (“Website”);
2. Social media (“Social Media”);
3. Email messages or other communications (“Emails”);
4. Services we provide to our individual, corporate, institutional, and other clients (“Client Services”);
5. iManage Share site made available to our clients and third parties (“iManage Share”); and
6. Any other client interactions that you may have with the Firm that occur offline (“Offline Interactions”).
Collectively, we refer to the Website, Social Media, Emails, iManage Share, and/or Client Interactions as the “Firm Services.”
A. Personal Information Collected:
The Firm may collect the following personal information (“Personal Information”) of an individual, entity, or client:
1. “Identifiers” such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
2. Personal information, as defined in California Customer Records law, such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, other financial information, medical information, health insurance information.
3. Characteristics of protected classifications under California or federal law such as race, religion, national origin, age, sex, sexual orientation, pregnancy, familial status, disability, military or veteran status, and genetic information.
4. Commercial information such as purchase or transaction history.
5. “Biometric” information such as voice prints or fingerprints.
6. Internet or other electronic network activity information such as browsing history, search history, and information regarding a consumer’s interaction with an internet website application or advertisement.
7. Geolocation data
8. Audio, electronic, visual, thermal, olfactory, or similar information such as security video footage and calls and and/or recordings.
9. Professional or employment-related information
10. Characteristics of protected classifications under California or federal law.
11. Education information
12. Inferences drawn from any of the above information to create a profile about you reflecting your preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.
13. Sensitive personal information such as social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; race, ethnicity, and citizenship or immigration status, religious or philosophical beliefs, sex life or sexual orientation, or union membership; the contents of mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; biometric and health information.
B. How Your Information is Collected. We collect your Personal Information from:
1. You – in person, by telephone, text or email, and/or through our website and mobile apps during transactions or account creation.
2. Publicly accessible sources, such as property records.
3. Third parties such as affiliates, business partners, credit reporting agencies, customer due diligence providers, advertising networks, internet service providers, social networks, data analytics providers, government entities, and data brokers.
4. Third parties with your consent (such as your bank or brokerage account).
5. Automated means through your use of your mobile device or other technology, such as when you visit our websites or use our mobile applications or services or click on advertisements or links in emails you receive from us.
6. Door entry systems and reception logs.
7. Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems.
8. Any other relevant systems.
C. Purpose of Collecting Your Information
We collect and use Personal Information for legitimate business purposes, including:
1. Providing client and legal services including responding to your inquiries and fulfilling your requests for legal services.
2. Administering our services including operational services auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
3. Helping to ensure security and integrity and prevent fraud sanctions and anti-money laundering checks, Know Your Client (KYC) checks.
4. Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider.
5. Providing advertising and marketing services including targeted marketing, newsletters, publications, legal updates, event invitations, seminars, and mailings that we think may be of interest to you.
6. Undertaking internal research for technological development and demonstration.
7. Undertaking activities to verify or maintain the quality or safety of a service or device and to improve, upgrade, or enhance the service or device.
8. To comply with our legal and regulatory obligations.
9. For the performance of our contract with you or to take steps at your request before entering into a contract.
10. Operational reasons, such as improving efficiency, training, and quality control.
11. Conducting checks to identify our customers and verify their identity.
12. Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies.
D. Who We Share Your Personal Information With
1. Our affiliates, including companies within the Firm.
2. Service providers we use to help deliver our products and/or services to you, such as payment service providers, document repositories, and delivery companies.
3. Other third parties we use to help us run the Firm such as marketing agencies or website hosts.
4. Third parties approved by you, including third-party payment providers.
5. Credit reporting agencies.
6. Our insurers and brokers.
7. Our banks.
8. External auditors including State Bar Agencies.
9. We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.
10. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
11. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
E. WE DO NOT INTENDED TO SELL YOUR INFORMATION
The Firm does not intend to sell or share your personal information as defined under the California Consumer Privacy Act (“CCPA”) and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale or sharing. Additionally, the Firm has not engaged in the sale or sharing your Personal Information including the sale or sharing of Personal Information of minors under 16 years of age.
F. CATEGORIES OF PERSONAL INFORMATION WE DISCLOSED FOR A BUSINESS PURPOSE
The Firm may have disclosed some of the following categories of Personal Information for a business purpose:
1. Identifiers.
2. Information of Identifies.
3. Characteristics of protected classifications under California, Texas, or Federal Law.
4. Commercial Information.
5. Biometric information.
6. Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement).
7. Geolocation data.
8. Audio, electronic, visual, thermal, olfactory, or similar information.
9. Professional or employment-related information.
10. Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
11. Sensitive personal information.
G. How Long Your Personal Information Will be Kept
We will keep your personal information while you have an account with us and we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
1. To respond to any questions made by you or on your behalf.
2. To keep records required by law.
3. We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
4. When it is no longer necessary to retain your Personal Information we will destroy, delete or anonymize it.
H. Rights to Personal Information
If you would like to request or access or review your Personal information including correcting, updating, withdrawing of your consent, or would like an electronic copy of your Personal Information please feel free to contact us to complete the necessary forms. You may request that we disclose your Personal Information, correct any inaccuracies, or delete your Personal Information, which we will complete subject to the limitations of the law. To correct, update, or delete your personal information, we will need your contact information, including your name, address, phone number, and email, to verify your identity for access, correction, or deletion requests. We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
I. Contact Us
Contact us at our headquarters in Newport Beach, California if you have any questions or concerns about our privacy policies and information practices.