The Personal Information we collect may include, but is not limited to:
- Contact Information (such as name, home address, telephone number, email address, demographic data)
- Employment Information (such as title, organization, work address, employment history)
- Applicant Information (such as employment information and references, including information provided to us directly or through other channels for employment opportunities or providing services to Kleinberg Kaplan)
- Compliance Data (such as information regarding personal identity, organization affiliation, date of birth, ownership information, financial information including bank account details, tax information)
- Client Service Data (such as information received from clients regarding their employees, customers, or other individuals, matter details – including correspondence, transaction documents, information processed while providing services and legal advice)
- Marketing Information (such as information regarding your communication with us, marketing preferences, event registration and attendance details, credentials, associations, subscriptions, downloads)
- Technological Information (such as IP address, device type, operating system, browser type, browser settings, language settings, dates and times of connecting to a website, technical communication information, username, password, cookies, usage data)
- Special Categories of Personal Information* (such as health data, racial or ethnic origin, religious or other beliefs, sexual orientation, details of trade union membership)
- Other Data (such as views and opinions shared on social media, information that you or a third party provides to us or make public)
*When we process Special Categories of Personal Information, our legal basis is compliance with applicable law; detection and prevention of crime; establishment, exercise or defense of legal rights; to fulfill a contract; or explicit consent.
We do not sell any Personal Information to third parties, nor do we share Personal Information for targeted advertising with third parties (and have not done so in the preceding 12 months or otherwise).
How and Why We Collect and Use Personal Information
We collect Personal Information from a variety of sources, including directly from individuals, indirectly from individuals (such as interactions with the website), from clients and business contacts, or publicly available sources.
As a law firm, we regularly receive Personal Information in connection with the provision of legal services, firm operations, carrying out our business, and as part of our professional activities.
We collect and use Personal Information for, among other reasons:
- Providing legal services and responding to requests for legal services
- Managing business relationships and administering client relationships, including billing, accounting, invoicing, payment, collections, and support services
- Providing information relating to our services either in response to specific requests or generally to develop our business
- Meeting our legal and regulatory obligations
- Preventing, detecting, and responding to fraud or potential fraud or other illegal activities
- Improving the functionality of our website and other IT services, including security
- Processing employment applications
- Processing employee data
To Whom We Disclose Personal Information
We may retain other companies and individuals to perform functions on our behalf. Such third parties may be provided with access to Personal Information to perform the functions for which they have been retained. Our agreements with these third parties will describe the purpose of the processing, will not permit them to use Personal Information for any purposes other than as is required to perform the function for which they have been retained, and will commit them to comply with applicable data privacy standards. We also enter into data processing agreements and model clauses with our vendors and clients whenever required and appropriate.
Third parties to whom we disclose Personal Information may include, but are not limited to:
- Providers of data services such as website hosting, data hosting, and SaaS tools
- Outsourced IT
- Financial institutions
- Benefits and Human Resources service providers
- Professional services providers
- Building and facilities services
- Shipping or direct mail organization
- Event partners and sponsors
- Paper-based service providers (i.e., storage, shredding, courier, printer, etc.)
- Parties assisting us in recruitment and staffing, including contractors
- Auditors and professional advisers
- Insurers
- Travel service providers
- Clients, as it relates to professional services offerings
- Regulators and public bodies, including in connection with tax and VAT payments, compliance with obligations relating to the prevention and reporting of financial crime and compliance with other applicable laws
We may also disclose any information, including Personal Information, as we deem necessary, in our sole discretion, to comply with a subpoena, any applicable law, regulation, legal process, or governmental request.
How Long We Retain Personal Information
Personal Information will be retained by Kleinberg Kaplan for as long as the information is required to fulfill our legitimate business needs or the purposes for which the information was collected, or for as long as is required by law.
Web Tracking
We currently use some “cookies” (data elements that a website can send to your computer browser and then store on your system). Your browser may allow you to send “do-not-track” requests to websites you visit. If you enable this feature and your browser sends a “do-not-track” request, the website will respond by deactivating all nonessential cookies set on this website. Kleinberg Kaplan uses several services provided by Google, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyze how users use the website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Please note that for the website, we activated the IP anonymization, i.e., Google will truncate/anonymize the last octet of your IP address to ensure an anonymized collection of IP addresses. In exceptional cases only, the full IP address is sent to and shortened by Google servers in the United States. On behalf of the website provider, Google will use this information for the purpose of evaluating your use of the website, compiling analytics, demographics and interest reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore, you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available here.
Further information about how Google uses advertising cookies can be found here.
Our website may contain links to other third-party sites. When you click on one of these links you are visiting a website operated by someone other than Kleinberg Kaplan, and the operator of that website may have a different privacy notice. Kleinberg Kaplan is not responsible for their individual privacy practices. We encourage you to investigate the privacy notices of these third-party operators.
California Residents
Under the California Consumer Privacy Act (“CCPA”), and subject to certain statutory exceptions, California residents have certain consumer privacy rights, including:
- Right to Access: You have the right to know what Personal Information we have collected about you in the preceding 12 months, including the categories of Personal Information; the categories of sources from which the Personal Information is collected; the business or commercial purpose for collecting, selling, or sharing Personal Information and/or sensitive Personal Information; the categories of third parties to whom we disclose Personal Information; and the specific pieces of Personal Information we have collected about you.
- Right to Delete: You have the right to request the deletion of Personal Information that we have collected about you subject to certain exceptions.
- Right to Correct: You have the right to request the correction of inaccurate Personal Information that we maintain about you.
- Right to Opt-Out of the Selling or Sharing of Personal Information: When applicable, you have the right to opt-out of the selling or sharing of Personal Information about you.
- Right to Limit the Use of Sensitive Personal Information about you: When applicable, you have right to limit the use of sensitive Personal Information about you, under certain circumstances, if we use or disclose sensitive Personal Information for reasons other than those set forth in California Civ. Code 1798.7027, subsection (m).
- Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA, including an employee’s, a job applicant’s, or an independent contractor’s right not to be retaliated against for the exercise of their CCPA rights. We will not discriminate against you for exercising any of your CCPA rights. If you exercise any of your CCPA rights, we will not take any of the following actions unless permitted by the CCPA: deny you services; charge you different prices or rates for 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.
We do not collect Personal Information directly from individuals under 16 years of age. Parents and legal guardians may provide the Personal Information of individuals under the age of 16 in connection with our providing legal services. We will delete any Personal Information collected from individuals under 16 years of age if we learn that we have shared the Personal Information from individuals under the age of 16 without verification of their legal guardian, or on the basis of parental consent, as appropriate.
We will effectuate requests to exercise privacy rights under the CCPA insofar as we are able under the CCPA where applicable and not subject to an exception. To exercise applicable rights, please see the section below named “Questions about the Privacy Notice and How to Exercise Applicable Privacy Rights”.
European Economic Area and United Kingdom Data Subjects
The European Union’s General Data Protection Regulation (“EU GDPR”) 2016/679 became effective on May 25, 2018. The United Kingdom’s General Data Protection Regulation (“UK GDPR”) became effective on January 1, 2021, as a result of the UK’s departure from the European Union. In accordance with those laws, we will process Personal Information if and to the extent applicable law provides a lawful basis for us to do so, and in particular where the processing is necessary:
- to perform a contract we have entered into with a data subject or in order to take steps at the data subject’s request prior to entering into a contract;
- to comply with a legal obligation to which we are subject; or
- for our (or a third party’s) legitimate interests which are not overridden by the data subjects’ interests or fundamental rights and freedoms. Such legitimate interests include the provision of legal services by us, administrative or operational processes within Kleinberg Kaplan, direct marketing, the safety and security of our staff, visitors, property, and premises, and promotion of the Firm and Firm events.
Additionally, we may process Personal Information for a specific purpose where we have obtained the data subject’s consent.
Where we process special category data, such as data relating to race, sexual orientation, religion and health, we will do so on the basis that we have obtained the data subject’s explicit consent or the processing is necessary for the establishment, exercise, or defense of legal claims.
- Right of Access: You may be entitled to ask us for a copy of any Personal Information which we process about you. This right is known as an “Subject Access Request.” We will normally send you a copy of the Personal Information within one month of your request. However, that period may be extended by two further months where necessary, taking into account the complexity of the request or the difficulty in accessing the Personal Information that you request. There is usually no charge; but in exceptional circumstances we may make a charge. We will discuss this with you if those circumstances apply.
- Right to Rectification: If the Personal Information we hold about you is inaccurate, you may request rectification. We will review your Personal Information and, where appropriate, inaccuracies will be rectified.
- Right to Erasure: In certain circumstances, you may be entitled to ask us to erase your Personal Information.
- Right to Data Portability: In certain circumstances, you may request to move, copy, or transfer the electronic Personal Information that we hold about you to another organization.
- Right to Object: You may object to your Personal Information being used for direct marketing. You may object to the continued use of your Personal Information in any circumstances where we rely upon consent as the legal basis for processing it. Where we rely upon legitimate interests as the legal basis for processing your Personal Information, you may object to us continuing to process your Personal Information, but you must give us specific reasons for objecting. We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your Personal Information, we may continue to do so. In that event, we will let you know the reasons for our decision.
- Rights Related to Automated Decision-Making including Profiling: We will not use your Personal Information in connection with any automated decision-making process. We use limited contact information to carry out certain business development profiling activities to support and grow our business. When we do so, we rely upon our legitimate interests as the lawful basis for processing your Personal Information and you may exercise the above rights if you do not wish us to process your Personal Information in this way.
To exercise applicable rights, please see the section below named “Questions about the Privacy Notice and How to Exercise Applicable Privacy Rights”.
Changes to this Notice
We reserve the right to change this notice at our discretion and at any time. Please check the website regularly for changes. When we make changes to the 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 acceptance of such changes.
Data Retention
Personal Information will be retained by Kleinberg Kaplan for as long as the information is required to fulfill our legitimate business needs or the purposes for which the information was collected, or for as long as is required by law.
How We Protect Personal Information
Kleinberg Kaplan has appropriate physical, technical, and administrative safeguards in place to protect information you submit on our website from loss, misuse, unauthorized access, disclosure, alteration, or destruction. You should keep in mind, however, that no Internet transmission is ever 100% secure or error-free. In particular, email sent to or from our website may not be secure, and you should therefore take special care in deciding what information you send to us via email. Moreover, where you use passwords, ID numbers, or other special access features to access our website, it is your responsibility to safeguard them.
Questions about the Privacy Notice and How to Exercise Applicable Privacy Rights
If you have questions about this Privacy Notice or wish to effectuate requests under applicable privacy law, please email us at privacy@kkwc.com or call us toll-free at 1-888-789-9250.
No Legal Advice or Services
These materials have been prepared by Kleinberg Kaplan for informational purposes only and are not legal advice. Transmission of the information is not intended to create, and receipt does not constitute an attorney-client relationship. Internet subscribers and online readers should not act or refrain from acting based upon this information without seeking professional counsel, including a detailed review of that person’s particular circumstances. The information contained in this site is provided only as general information which may or may not reflect the most current legal developments. This information is not provided in the course of an attorney-client relationship and is not intended to constitute legal advice or to substitute for obtaining legal advice from an attorney licensed in your state.
The transmission of the site, in part or in whole, and/or communication with Kleinberg Kaplan via Internet e-mail through this site does not constitute or create an attorney-client relationship between Kleinberg Kaplan and any recipients.
This site is not intended to be advertising and Kleinberg Kaplan does not wish to represent anyone desiring representation based upon viewing this site in a state where this site fails to comply with all laws and ethical rules of that state.