WENDEL ROSEN LLP WEBSITE PRIVACY POLICY
Effective Date: 12/31/19

Wendel Rosen (the “Firm,” “We,” “Us,” or “Our”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.wendel.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

It does not apply to information collected by:

Throughout this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy, below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@wendel.com. California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights, below, for more information.

Information We Collect About You and How We Collect It

In most cases, we collect Personal Information directly from you. Below are descriptions of the different types of Personal Information we process and the sources from which we obtain them:

However, we may also obtain several types of information from and about users of our Website, including information:

We collect this information:

Information You Provide to Us

The information we collect on or through our Website may include:

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website such as our blogs, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

The technologies we use for this automatic data collection may include:

The following shows the function of each of those cookies:

_ga
Expiration Time: 2 years
This cookie is used to collect information about how visitors use our website and our services through Google Analytics. We use this information to compile reports and to help us improve our sites. The cookie collects information, including the number of visitors to the website, where visitors have come to the website from and the pages they visited. To learn more about how Google uses data when you visit our Website, go to https://policies.google.com/technologies/partner-sites. To opt-out from these cookies across all websites, go to http://tools.google.com/dlpage/gaoptout.

_gid
Expiration Time: 24 hours
This cookie is used to collect information about how visitors use our website and our services through Google Analytics. We use this information to compile reports and to help us improve our sites. The cookie collects information, including the number of visitors to the website, where visitors have come to the website from and the pages they visited. See above information to learn more about how Google Analytics looks after your data and how you can disable it.

_gat_gtag
Expiration Time: 1 minute
This cookie is used to collect information about how visitors use our website and our services through Google Analytics. We use this information to compile reports and to help us improve our sites. The cookie collects information, including the number of visitors to the website, where visitors have come to the website from and the pages they visited. See above information to learn more about how Google Analytics looks after your data and how you can disable it.

nmstat
Expiration Time: 1,000 days
This cookie name is associated with the website analytics service provided by SiteImprove. It enables us to gather usage statistics about our website.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose Personal Information that we collect or you provide as described in this privacy policy:

We may also disclose your personal information:

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

Additionally, we take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. For example, we keep client records for the length of the client relationship and for maximum of ten (10) years after we close the matter. When determining the retention period, we take into account various criteria, such as the nature and length of our relationship with you, mandatory retention periods provided by law and the statute of limitations, the type of legal services requested by or provided to you, the possible ongoing relationship of you with our firm, and the impact on our legal services if we delete some information from or about you.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. The date the privacy policy was last revised is identified at the top of the page. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

If you have any questions or comments about this privacy policy, the ways in which we collect and use your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 510.834.6600
Website: www.wendel.com
Email: privacy@wendel.com

Postal Address:
Wendel Rosen LLP
Attn: Ms. Ginger Wilson
1111 Broadway, 24th Fl
Oakland, CA 94607

 

Wendel Rosen LLP Privacy Notice for California Residents
Effective Date: December 31, 2019

This Privacy Notice for California Residents supplements the information contained Wendel Rosen LLP’s general privacy policy and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, Wendel Rosen LLP’s website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A name, email address, or other similar identifiers. Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, telephone number, education or employment.

Some personal information included in this category may overlap with other categories.

Yes
C. Protected classification characteristics under California or federal law. Age (18 years or older) and gender. Yes
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes
G. Geolocation data. Physical location. Yes
H. Sensory data. Electronic or thermal information. Yes
I. Professional or employment-related information. Current or past job history. Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No

‌Personal information does not include:

‌Wendel Rosen LLP obtains the categories of personal information listed above from the following categories of sources:

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

Wendel Rosen LLP will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Wendel Rosen may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Wendel Rosen has not disclosed personal information for a business purpose.

Sales of Personal Information

In the preceding twelve (12) months, Wendel Rosen has not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Wendel Rosen LLP disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

Deletion Request Rights

You have the right to request that Wendel Rosen LLP delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related 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:

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@wendel.com or write us at: 1111 Broadway, 24th Fl, Oakland, CA 94607.

Changes to Our Privacy Notice

Wendel Rosen LLP reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Wendel Rosen LLP collects and uses your information described below [and in the Privacy], your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 510.834.6600
Website: www.wendel.com
Email: privacy@wendel.com

Postal Address:
Wendel Rosen LLP
Attn: Ms. Ginger Wilson
1111 Broadway, 24th Fl
Oakland, CA 94607