Robbins Geller Rudman & Dowd LLP Privacy Shield Notice and Policy
Effective Date: November 1, 2019
This Privacy Shield Notice applies to personal data transferred from the European Union (EU), European Economic Area (EEA), or Switzerland to the United States on a Privacy Shield basis and not to data transferred to Robbins Geller on any other legal basis. It describes the types of personal information and data we collect, how we may use that information and with whom we may share it, how we protect your information and your rights in respect of your information. In addition to this Privacy Shield Notice, we may separately provide you with other specific information regarding personal information, its collection and processing, depending on the nature of personal information and its intended use.
I. Information We May Collect
We may collect and process your personal information in the course of our business, in particular when (i) your personal information is provided to us in the course of providing services either to you or to one or more of our clients (as a result of your relationship with one or more of our clients) or when your personal information is provided to us in the course of providing services to us either by you or by our agents and contractors (as a result of your relationship with one or more of our agents or contractors); and/or (ii) your personal information is obtained from other sources including publicly available sources; and/or (iii) when you contact us and/or request information from us or when you use our website.
II. Use of Information
We collect and process your personal information as follows:
- We use your personal information for the following business interests:
- the provision of legal or other services (including use of personal information of other persons on behalf of our clients);
- the administration of our business (including fulfilling and exercising our legal, regulatory and risk management obligations and rights, exercising or defending legal claims and managing the relationship with you and our clients);
- the maintenance of records; and
- marketing and promotion of our services to clients and potential clients.
- Where you register with us and provide personal information about yourself or if you provide us with personal information about yourself in other ways, we will use your personal information for the purposes for which it was provided, which may include contacting you and providing you with the information that you have requested from Robbins Geller. We may also use your personal information to keep you informed about events, publications, and services provided by Robbins Geller that may be of interest to you. You can opt out of receiving such direct marketing communications at any time by following the unsubscribe instructions for the particular mode of communication.
- Information that is provided by your computer or mobile device when you browse our website is used by Robbins Geller solely for internal purposes (such as evaluation of site use, assessment and improvement of site performance, and improvement of the functionality and services that we are able to offer) and is not used to target individuals for marketing unless §II(b) above applies.
- We may combine personal information collected from different sources for any of the purposes listed above.
III. Disclosure of Information
- We may share your personal information among Robbins Geller offices. We may also share your personal information with our agents or contractors in connection with services that these individuals or entities perform for Robbins Geller. These individuals or entities are not authorized by us to use or disclose this personal information except as necessary to provide services to Robbins Geller, or if required to do so under applicable law. We may, for example, provide your personal information to agents or contractors for hosting our databases, for data processing services, for processing online registration forms for events, or so that they can mail you information you requested. Robbins Geller has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Robbins Geller shall remain responsible and liable under the Privacy Shield Principles if its agent processes such personal information on Robbins Geller’s behalf in a manner inconsistent with the Privacy Shield Principles, unless Robbins Geller proves that it is not responsible for the event giving rise to the damage.
- We reserve the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information you have provided to us in a manner that is consistent with this Privacy Shield Notice.
- We may disclose personal information we have about you (i) if we are required to do so by law or pursuant to legal process, (ii) in response to a request from law enforcement authorities or other government officials, including to meet national security requirements, or (iii) when we believe disclosure is reasonably necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected illegal activity.
IV. Your Rights Regarding Your Personal Information
You have the following rights with respect to your personal information:
- access to a copy of your personal information;
- objecting to processing of your personal information, including objecting to processing of your personal information on the grounds that processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party and objection to processing of your personal information for direct marketing (in cases where such personal information is processed for direct marketing purposes);
- objecting to automated decision-making and profiling;
- restricting processing of your personal information;
- your personal information portability;
- rectification of your personal information;
- erasure of your personal information; and
- withdrawal of the consent to the processing of your personal information (if the processing is based on this consent).
In some cases, these rights are subject to conditions and limitations. These rights are in more detail described in the General Data Protection Regulation (Regulation (EU) 2016/679 on the Protection of Natural Persons with Regard to the Processing of Personal Data and on the Free Movement of Such Data, and repealing Directive 95/46/EC (General Data Protection Regulation)) and other applicable laws.
If you wish to exercise any of the rights listed above please write to us at firstname.lastname@example.org. We will consider each such request in accordance with all applicable data protection laws and regulations. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be manifestly unfounded or excessive. If you are unhappy with our response to such a request, please refer to §VI below.
V. How to Contact Us
If you have any questions or complaints about our Privacy Shield-related (or general privacy-related) practices, please contact us by:
writing to us at:
Robbins Geller Rudman & Dowd LLP
Attn: General Counsel
655 West Broadway
San Diego, CA 92101
We take your privacy concerns seriously. If you believe that Robbins Geller has not adhered to this Privacy Shield Notice, please contact Robbins Geller as described in §V above. In your correspondence, please describe in as much detail as possible the ways in which you believe that this Privacy Shield Notice has not been complied with. We will respond to you within the maximum time limit prescribed by applicable law upon receipt of your correspondence and will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.
Robbins Geller has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution body based in the United States, JAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Robbins Geller, please visit the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint. This independent recourse mechanism by which your complaints and disputes can be investigated and expeditiously resolved will be provided at no cost to you.
Under certain conditions, you may have the right to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
VII. Verification and Enforcement
Robbins Geller conducts periodic self-assessments to verify that the attestations and assertions it makes about its privacy practices are true and that such privacy practices have been implemented as presented. Robbins Geller will take steps to remedy any problems arising out of failure to comply with the Privacy Shield Principles.
The Federal Trade Commission has jurisdiction over Robbins Geller’s compliance with the Privacy Shield.
VIII. Updates to Our Privacy Shield Notice
We may update or change this Privacy Shield Notice. The Effective Date at the top of this page states when this Privacy Shield Notice was last revised. Any change to this Privacy Shield Notice will become effective when we post the revised Privacy Shield Notice on our website. Your use of our website means that you accept our Privacy Shield Notice.
If any change may materially and negatively affect the privacy of your personal information, we will use reasonable efforts to notify you in advance and give you a reasonable period of time to object to any changes.
We encourage you to periodically review this Privacy Shield Notice to stay informed about how we collect, use, and share personal information.