Privacy Policy

ZwillGen PLLC Privacy Policy

Last Updated: May 31, 2018

ZwillGen PLLC (the “Firm,” “we,” or “us”) is providing this Privacy Policy to explain our policies and procedures regarding the collection, use, disclosure, and security of certain information received via www.zwillgen.com and blog.zwillgen.com (the “Sites”) and through other means, with a focus on information that would be considered “personal data” within the meaning of the EU General Data Protection Regulation (GDPR) and similar laws (“Data Protection Laws”). As used in this Privacy Policy, “personal data” refers information about an identified or identifiable individual, such as their name or email address. Some information that is automatically disclosed to us or collected by us during your visit to the Sites meets this definition.

In most cases under the Data Protection Laws, ZwillGen PLLC is considered the “data controller” of the personal data that we handle under this Privacy Policy, though we handle certain personal data as a “processor” for clients.

Information We Collect
We collect information that you voluntarily submit to us, such as your name, email address, and other contact information, when you sign up to receive our newsletter, submit a comment in response to a blog posting, email us to ask questions, submit an employment application, or contact us to explore a potential attorney-client relationship. We also receive information from or on behalf of our clients. Because of the nature of our services, this could include any type of personal data.

We use this information to respond to your requests, determine whether to enter into an attorney-client relationship with you, provide you with legal services if you are or become a client of the Firm, monitor and analyze our business operations and Site usage, and for the firm’s educational, networking, marketing, social, recruiting, and other business purposes.

To assist with these uses, we may supplement the information you provide to us with information we obtain from other sources, such as clients and referral sources, as well publicly available sources such as social networking sites.

We never sell or share the personal data with third parties other than: (1) our service providers who assist us in providing our services, transmitting our marketing materials, and maintaining our Sites, (2) with your consent, (3) in connection with the provision of services, (4) to protect our rights, or (5) as otherwise required or permitted by law or our ethical obligations.  We store personal data in the United States and in other countries that may not have data protection laws as protective as those in your location.

Automatically Collected Information
We, or our third-party providers, also collect device information, IP Addresses, http referrer fields, and other information about your computer or device and your usage of our Sites. We use that information for a variety of purposes, including educational, analytics, networking, marketing, social, recruiting, and other business purposes.

We also use third-party web analytics services on the Sites, such as those provided by Leadformix, Google Analytics and others. These service providers use electronic tools to help us analyze how our users use the Sites and may collect information from you (including your IP Address) that can be used to track users over time, for geo-location purposes, and across third party websites. To learn about opting out of Google Analytics, please click here.

This Privacy Policy places no restriction on the use of information we automatically collect from your visit, or de-identified or aggregated information that we may create from information that you submit.

Cookies
We use cookies, web beacons, and other electronic tools to manage and track your interaction with the Sites and our newsletters. A cookie is a piece of data that a website you visit can set on your browser or elsewhere on your device. These technologies collect information that helps us better serve our users and enhance this Site, such as by tracking return visits, collecting Site usage information, and performing research, analysis, and Site analytics. Third parties whose products or services are accessible via links from the Sites may also use cookies or similar tools, and we advise you to check their privacy policies for information about their cookies and other privacy practices. If you prefer not to accept cookies through our Sites, you can set your browser to warn you before accepting cookies or disable them altogether.

Our Legal Bases for Handling Your Personal Data
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data.  To the extent those laws apply, our legal grounds are as follows:

  • Legitimate interests:  In most cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
    • Providing our services pursuant to our contract with our client
    • Marketing
    • Protecting our clients, personnel and property
    • Analyzing and improving our business
    • Processing job applications
    • Addressing legal and ethical issues
  • Legal compliance:  We need to use and disclose personal data in certain ways to comply with our legal obligations.
  • To honor our contractual commitments to an individual:  Some of our processing of personal data is to meet our contractual obligations to the individual to whom the personal data pertains.
  • Consent:  Where required by law, and in some other cases, we handle personal data on the basis of implied or express consent.

Where we act as a processor of personal data on behalf of a client, we process the personal data pursuant to our contract with the client and our legal and ethical obligations.

How Long We Keep Personal Data
We generally retain personal data for so long as it may be relevant to the purposes above, consistent with any applicable agreement with a client.  To dispose of personal data, we may anonymize it, delete it or take other appropriate steps.  Data may persist in copies made for backup and business continuity purposes for additional time.

Security
We maintain administrative, technical, and physical safeguards to protect information that you submit to us. However, no system is completely secure or error-free. We do not, and cannot, guarantee the complete security of your information.

Privacy Choices
We provide individuals with the ability to opt-out of receiving marketing and other communications from us, and to update, supplement or delete the information we have about them by contacting us using the methods provided below.

To the extent Data Protection Laws apply and we hold your personal data in our capacity as a controller,  you may request that we:

  • Provide access to and/or a copy of certain personal data (including, in some cases, in portable form);
  • Prevent the processing of your personal data for direct-marketing purposes (including any direct marketing processing based on profiling);
  • Update personal data that is out of date or incorrect;
  • Delete certain personal data which we are holding about you;
  • Object to our processing of personal data;
  • Restrict the way that we process and disclose certain of your information;
  • Transfer your personal data to a third party; or
  • Honor a revocation of your consent for the processing of your personal data (without retroactive effect).

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with additional information to confirm your identity before responding to your request. You have the right to lodge a complaint with the authorities applicable to your situation, though we invite you to contact us with any concern, as we would be happy to try to resolve it directly.

Children’s Privacy
The Sites are intended for users over the age of 18. If we become aware that a child under 13 (or a higher age threshold where applicable) has provided us with personal data, we will take steps to comply with any applicable legal requirement to remove such information.

Links to Third-Party Websites
Please note that the Sites may contain links to third-party websites, including social networking websites. Since we do not control third-party sites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.

Changes
We reserve the right to change this Policy at any time. Please check this page periodically for updates. If we make any material changes to this Privacy Policy, we will post the changes here and notify you either via email or by notice on this Site.

Contact Us
Should you have any questions or concerns about our Privacy Policy, please send us an email at staff@zwillgen.com; write to us at ZwillGen PLLC, 1900 M Street NW, Suite 250, Washington, DC 20036; or call us at (202) 296-3585.

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