Our Privacy Commitment
Privacy Policy Last Updated: April 29, 2021

Thank you for visiting the HartGinney®, LLP (“CHartGinney,” “we,” “us,” or “our”) website (the “Website”) and trusting us to handle your Personal Information (defined below).  Your privacy is important to us, and we seek to be transparent about what and how we collect, use, and share information about you.

Please read this Privacy Policy carefully.  This Privacy Policy applies only to the Website and does not apply to information collected offline, or by any third-party, including through any content that may be linked to or accessible from the Website.  This Privacy Policy does not apply to information provided to us in the course an established attorney-client relationship; such information is subject to separate attorney-client privilege protections.

If you do not agree with this Privacy Policy, please do not access or use our Website or provide us with any information.

When used in this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual.

• Information We Collect

When You Contact Us
If you join our mailing list or otherwise submit information to us directly through this Website, we may collect the following Personal Information about you:

• Your first and last name,
• Your email address,
• Your affiliate Company name,
• Your phone number, and
• Any information you submit to us as a “Message” through the “Contact Us” form on the Website, or as part of an email message to a Crown attorney or employee.

Cookies, Device Id, and Tracking Information
We may also collect the basic Personal Information that most websites collect through common Internet technologies, such as cookies and web server logs.  The information we collect about visitors to our Website includes the visitor’s device identifier, Internet Protocol (IP) address, geolocation, language preference, referring site, additional websites requested, and the date and time of each visitor request. Cookies can track the type of browser, operating system, and Internet service provider you are using and allow us to tabulate the total number of visitors to our Website, conduct various analytics, and track originating IP address. We collect this information to better understand our visitors, to enhance your experience and provide increased functionality on our Website, and to monitor and protect the security of our Website. We do not collect information about your online activities over time and across different websites or authorize third parties to do so.
Cookies on our Website are generally divided into the following categories:

• Strictly Necessary Cookies: These are required for the operation of our Website. These cookies are session cookies that are erased when you close your browser.
• Analytical/Performance Cookies: These allow us to recognize and count the number of users on the Website and understand how such users navigate through the Website (e.g., when and which pages are visited, in what order the pages are visited, how long a user may stay on a particular page, and where a user is located). This helps to improve how the Website works, for example, by ensuring that users can easily find what they are looking for.  These cookies are session cookies which are erased when you close your browser.  To learn more about the analytics services we use and how to control any of your Personal Information that they collect, please use the following links:

Google Analytics https://policies.google.com/privacy

You can accept or decline cookies. While most web browsers automatically accept cookies, you can usually modify your browser setting to decline cookies if you prefer. You may also have the ability to turn location-based services on and off by adjusting the settings of your Internet browser or mobile device. If you choose to decline cookies or location-based services, you may not be able to fully experience the features of the Website.

In compliance with California Business and Professions Code § 22575, we honor the request of “do not track” signals sent by your browser when you visit the Website.  For more information about DNT signals, visit http://allaboutdnt.com.

Third-Party Collected Personal Information
We may also collect your Personal Information from third parties to whom you have provided that information, including when you reach out to us via our social media profiles.

What Happens if You do not Provide Personal Information?
It is not necessary that you provide all Personal Information identified in this Privacy Policy to use our Website or to engage with us offline, but certain functionality of the Website will not be available if you do not provide certain Personal Information.  For example, we may not be able to respond to your requests or provide you with alerts and other information we believe you may find interesting or valuable.

• Minors

This Website is not intended for use by people under 16 years of age.  We will not knowingly collect information from minors in the United States or elsewhere with or without the consent of their parents or guardians.  If we become aware that a person under the age of 16 has provided us with Personal Information or that we have gathered Personal Information about that person (for example, using cookies), we reserve the right to immediately delete that information.  We are committed to protecting the online privacy of children and complying with the Children’s Online Privacy Protection Act.  If you have questions or concerns about the Internet and privacy rights of children, we encourage you to review http://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online.

• How We Use and Share Your Information

We may use information that we collect about you or that you submit to us, including any Personal Information in the following ways:

Purpose of Use	Legal Basis for Processing	Categories of Personal Information
To present our Website and its contents to you	Necessary for legitimate interests	Cookies, Device Id, and Tracking Information
To communicate with you regarding any inquiry you provide	Necessary for legitimate interestsConsent (where you have provided consent as appropriate under applicable law)	First and last name; Email address; Company name; Phone number; Any information you submit as a “Message” through the “Contact Us” form on the Website or as part of an email message to an attorney
To contact you regarding the possible provision of legal services, events for which you have registered, or other opportunities for interaction with our business	Necessary for legitimate interestsConsent (where you have provided consent as appropriate under applicable law)	First and last name; Email address; Company name; Phone number; Any information you submit as a “Message” through the “Contact Us” form on the Website or as part of an email message to an attorney
For marketing purposes, including providing client alerts and other communications;	Necessary for legitimate interestsConsent (where you have provided consent as appropriate under applicable law)	First and last name; Email address; Company name
To notify you about changes to our Website;	Necessary for legitimate interestsNecessary for compliance with a legal obligation	First and last name; Email address; Company name
To evaluate your eligibility for employment;	Necessary for legitimate interestsNecessary for compliance with a legal obligationNecessary to perform a contract or to take steps at your request to enter into a contractConsent (where you have provided consent as appropriate under applicable law)	First and last name; Email address; Phone number; Resume and other applicant information
For other business purposes, such as operating the Website; detecting, preventing, and responding to actual or possible fraud or illegal activities; defending our legal rights; and complying with our legal obligations.	Necessary for legitimate interestsNecessary for compliance with a legal obligation	Cookies

We may share your Personal Information in the following ways:

• Technical Support and Service Providers: We work with service providers who help with some of our processing and storage. For example, if you choose to join our mailing list, we may use one or more service providers to administer communications to you, and we will provide some of your Personal Information to them in order to facilitate this process. Also, we may use service providers to assist with monitoring our servers for technical problems. These technicians (as well as Crown employees) can access certain information about you in line with this work, but these service providers are not allowed to use this data for non-Crown purposes.
• Legal Reasons: We may provide information to a third-party if we believe in good faith that we are required to do so for legal reasons. For example, to respond to a legal process or comply with state and federal laws (or the applicable laws of foreign countries other than the United States). When permitted, we will make a reasonable effort to notify you of any disclosure of your information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined in our sole discretion.
• Professional Advisors: We may provide certain Personal Information to our lawyers, accountants, bankers and other outside professional advisors in the course of the services they provide to us.
• Asset Transfers: If we are involved in a merger, acquisition or other transaction involving the sale of some or all of Crown’s assets, user information, including Personal Information collected from you through your use of the Website, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you through email and/or a notice on the Website.
• Third-Party Websites and Features

Our Website may contain links to other websites operated by third parties. These third-party websites may collect information about you if you click on a link.  Your interactions with these features are governed by the privacy policy of the company providing the feature, not by this Privacy Policy. We do not control what information these third parties collect.  Please think carefully before clicking on links which may take you to a third-party website.

• Your Right to Opt-Out of Marketing or Other Promotional Correspondence

If you no longer wish to receive certain correspondence from Crown, you can opt-out or unsubscribe by using the “unsubscribe” link at the bottom of the applicable email or by contacting us via the methods provided in Section 11 below.

• Data Security

We maintain reasonable technical and organizational measures necessary to (i) protect your Personal Information from unauthorized access, alteration, or destruction; (ii) maintain data accuracy; and (iii) help ensure the appropriate use of Personal Information.  All information you provide to us is stored in securely managed servers.  In the event of a data breach that affects your Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected users without undue delay.

However, no server, network, system, or data transmission over the Internet can be guaranteed to be 100% secure.  Accordingly, while we strive to protect user information, we cannot ensure or warrant the security of any such information that you transmit to us. By using our Website, you acknowledge and understand that, despite our best efforts, we cannot guarantee the security of any data provided to or received by us through the Website and that any Personal Information, general information, or other data or information received from you through the Website is provided at your own risk.  It is impossible to guarantee its absolute security and we cannot provide you that guarantee here.

• For our European Users

International data transfer.
We take steps to ensure that we handle your Personal Information subject to appropriate safeguards. As a US law firm, the majority of our operations are conducted in the United States and Personal Information may be processed in the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers. Where required by such laws, you may request a copy of the suitable safeguards we have in place by contacting us as detailed below.

Retention of your Personal Information.
We typically retain Personal Information related to our marketing and outreach activities for as long as you accept such communications from us.  However, upon request, we will delete such data in accordance with applicable law.  For Personal Information that we collect and process for other purposes, as described above, we typically retain such Personal Information for no longer than the period necessary to fulfill the purposes outlined in this Privacy Policy, and as otherwise needed to address tax, compliance, employment, litigation, and other legal rights and obligations.
Automated decision-making.

We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or that otherwise significantly affects you.

Your Rights

To the extent required under applicable law, you have the right of:

• Access. You have the right to request a copy of the Personal Information we are processing about you, which we will provide to you in electronic form.
• Rectification. You have the right to require that any incomplete or inaccurate Personal Information that we process about you is amended.
• Erasure. You have the right to request that we delete Personal Information that we process about you, unless, for example, we are required to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims.
• Restriction. You have the right to request that we restrict our processing of your Personal Information where: (i) you believe such data to be inaccurate; (ii) our processing is unlawful; or (iii) we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
• Portability. You have the right to request that we transmit the Personal Information we hold with respect to you to another data controller.
• Objection. Where the legal justification for our processing of your Personal Information is our legitimate interest, you have the right to object to such processing on grounds relating to your situation (e.g., direct marketing). We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
• Withdrawing Consent. If you have consented to our processing of your Personal Information, you have the right to withdraw your consent at any time, free of charge. If you withdraw your consent, this will not affect the lawfulness of our use and processing of your information prior to withdrawal of your consent.

Some rights may be limited, and we may need to retain certain Personal Information, as required or permitted by applicable law. To inquire about or exercise the rights listed above, at any time, contact us at info@hartginney.com with the subject line “Privacy” so that we can get your inquiry to the correct team member and respond to your request consistent with applicable law.

If you feel that we have not satisfactorily resolved your request, you have the right to lodge a complaint with your local data protection authority.

• Terms of Use

Please read the Terms of Use governing your use of the Website.  This Privacy Policy is made in conjunction with and subject to the Terms of Use.

• Governing Law

This Privacy Policy and our privacy practices will be subject exclusively to the laws of the State of California within the United States of America.  By using our Website, you hereby irrevocably submit to the exclusive jurisdiction of the competent state or federal courts located in the state of California in the County of San Francisco for any claim or matter arising under or in connection with the Website.

• Changes to Our Privacy Policy

This Privacy Policy will remain in effect until superseded by a new policy.  We may choose to update this Privacy Policy at our discretion, so you should check this page periodically as the terms may change from time-to-time.  If we make material changes to this Privacy Policy, we will notify you via a notice posted on our Website, or another method, such as email.

The most recent version of the Privacy Policy will be reflected by the “Last Updated” date noted at the top of the page.  Your continued use of the Website will constitute your acknowledgment of the Privacy Policy in its current version and your understanding of the terms of the Privacy Policy.

• Contact Us

To ask questions or provide any comments about this Privacy Policy, please contact info@hartginney.com with the word “Webmaster” in the subject line or send written correspondence to:

HartGinney
Attn: Webmaster
1939 Harrison Street, Suite 210
Oakland, CA 94612

If you choose to contact HartGinney via  you agree that HartGinney may provide any responsive correspondence solely via email and you waive any right to any other method of communication or legal service of process (unless such right cannot be waived).

Sending any communication to the above email and physical addresses will not create an attorney-client relationship.