LAST REVISED: SEPTEMBER 30, 2020
(a) the www.neumannbusinesslaw.com website (the “Website”);
(b) our newsletter or other email notifications (“Emails”); and
(c) the legal services we provide to clients (the “Legal Services”).
What Information We Collect
When you use our Services, we may collect two types of information: Personal Information and Anonymous Data, each as defined below.
A. Personal Information. “Personal Information” means any information that can identify, relate to, describe, be associated with, or be reasonably capable of being associated with a particular individual or household. The types of Personal Information we collect may include, among other things, the following categories of Personal Information:
- contact information, such as your name, email address, telephone and facsimile numbers, and/or postal address, or the contact information of any third-party that you provide us;
- your company name, title, business license number, and other information about your company and job function;
- the contents of any communication you send us;
- information necessary to provide the Legal Services to you; and
- other information specific to you which you voluntarily provide to us.
Neumann & Associates and our service providers collect Personal Information from you as follows:
Information you provide through the Website. We collect Personal Information that you enter when using the Website. Providing Personal Information on the Website is voluntary, and you can use the Website without providing us with any Personal Information. When you send us an email, fill out the “Contact Us” form on our Website, sign up for our newsletter, or comment on our blog, we collect Personal Information from you, including your name, email address, and the contents of your communication.
Information you provide through our Legal Services. When you become a client and request that we provide you with Legal Services, or when you contact us as an existing client regarding a legal issue, we will collect Personal Information in order to provide the specific Legal Services you requested. We are unable to provide you with Legal Services unless we collect Personal Information from you. In connection with the Legal Services, we collect your name, mailing address, telephone number, email address, details about your business or legal issue, billing or financial information, Personal Information of third-parties, such as your employees, service providers, or vendors, and any other Personal Information you provide to us in order for us to perform the Legal Services you requested.
Information you provide to apply for employment with Neumann & Associates. If you apply for employment with our firm, we collect the Personal Information on your resume, including without limitation your name, address, telephone number, email addresses, professional and educational history, and any other Personal information you provide.
Information from other sources. We may collect Personal Information about you from other third-party sources and combine it with the information we already hold about you. These other sources include, but are not limited to, third-parties with whom you have requested we communicate in order to provide the Legal Services to you and publicly-available sources, such as government or other public records.
B. Anonymous Data. Anonymous Data is information about your use of the Services and cannot be used to personally identify you. Anonymous Data includes the following information:
- internet protocol (IP) address;
- browser language and type;
- domain name system requests;
- material and pages viewed;
- time and date of access to the Website;
- number of bytes transferred;
- number of clicks per visit;
- operating system and platform, device type, and device identifiers; and
- MAC address, device ID/UDID, or similar device-specific code.
Neumann & Associates collects Anonymous Data from you as follows:
Your use of the Website. Your visit to and use of the Website triggers the automatic collection of certain Anonymous Data about your computer system, including but not limited to your general location, browser type, operating system, the pages of the Website you visited, and the duration of your visit.
Cookies. From time to time, we may use “cookies” to keep track of your visit to and use of the Website. Cookies are small files that websites save to your hard disk or to your browser’s memory. We may use them to track the number of times you have visited the site, to track the number of visitors to the Website, to determine and analyze your use of the Website, and to store technical information useful for your interactions with the Website. You have the ability to accept or decline cookies, and you may continue to use the Website if you decline to accept cookies. Most Internet browsers automatically accept cookies, but you may be able to modify your browser settings to reject cookies or to notify you when a cookie is being placed on your computer.
How We Use Your Information
We only use your Personal Information for the purposes for which it was collected, unless otherwise required by law. Personal Information we collect from you may be used in the following ways:
- manage, prepare, and provide the Legal Services you requested;
- send Emails or other communications to you, including advertising, legal updates, information regarding changes to our policies, administrative notices, and other information we think may be of interest to you;
- verify your identity;
- personalize your use of the Services;
- consider your application for employment;
- issue invoices and collect and process payments;
- respond to your communications or to provide the information you requested, such as details about our Services;
- audit compliance with our policies;
- enforce our policies and contractual obligations;
- as permitted by, and to comply with, any legal or regulatory requirements or provisions; or
- for any other purpose to which you expressly consent.
We use your Anonymous Data to:
- analyze usage of the Website and identify usage trends;
- diagnose Website technical problems;
- enhance, modify, or expand our Services;
- analyze the security of the Website, prevent fraud, and monitor for intrusions;
- tailor or expand our marketing efforts; and
- and any other purposes authorized by law.
How We Share Your Information
We may occasionally share your Personal Information with third parties as described below. We only share your information to the extent necessary to accomplish the purpose for which the information was shared. We do not sell or rent your Personal Information, nor do we provide your Personal Information to third parties for their marketing purposes. We share your Personal Information with the following parties:
- Service Providers. We share your Personal Information with third parties that provide services to us or on our behalf, including but not limited to processing payments, sending Emails, delivering postal mail, creating and managing contact lists, analyzing data, tracking Website analytics, and providing customer service.
- Facilitating Requests. We will share your Personal Information with third parties at your request in connection with the Legal Services we perform for you, such as when we contact a government or regulatory agency on your behalf or when we contact a third-party to negotiate or resolve a legal issue on your behalf.
- Merger or Acquisition. In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of Neumann & Associates, we may have to disclose, transfer, sell, or assign your information obtained through the Site or Services. Whenever possible, you will be given notice of the transfer of your personal information.
You may be able to opt-out of some uses of your information, such as receiving our Emails by clicking the “unsubscribe” link at the bottom of the Email. However, you may not be able to opt-out of some communications, including important announcements or transactions.
How We Protect Your Information
Neumann & Associates takes the confidentiality of our clients’ information and the security of Personal Information very seriously. We adopt commercially reasonable physical, electronic, procedural, technical, and administrative data security measures and data collection and storage practices to protect the confidential information of our clients and prevent unauthorized access, use, disclosure, loss, or destruction of your Personal Information. We educate and communicate to our employees the need to protect all user Personal Information. Our service providers are prohibited from using your Personal Information for any purposes other than the service they provide on our behalf.
You need to know, however, that due to the open communication nature of the Internet, no transmission is 100% secure. We cannot guarantee that any confidential or Personal Information you send us, or we send to you at your request, will be free from delay, interruption, interception, or error.
Our Website and Services are not directed to anyone under the age of 18. We do not knowingly collect, store, use, or share any information from anyone under the age of 18, and will immediately delete any information that we know or reasonably believe to be Personal Information of a minor. If you believe your child may have provided us with Personal Information without your consent, please contact us at [email protected].
“Do Not Track” Requests
We do not generally track your activity on our Website, nor do we allow third parties to track your usage of the Website.
The following rights apply only to residents of California:
A. Shine the Light Disclosures: Under California Civil Code Section 1798.83 (the “Shine the Light” law), California residents who provide certain Personal Information in connection with obtaining products or services for personal, family, or household use are entitled to request and obtain from us: (a) a list of the categories of Personal Information, such as name, address, email address, and the type of services provided to the user, that we have disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (b) the names and addresses of all such third parties.
We do not share your Personal Information with third parties or affiliates for direct marketing purposes.
If you are a California resident and you have questions about our practices with respect to the “Shine the Light” law, please write to us at:
Neumann & Associates
591 Camino de la Reina
San Diego, CA 92108
Please note that we are only required to respond to each user once per calendar year. Not all information sharing is covered by the “Shine the Light” requirements, and only information on covered sharing will be included in our response.
B. California Consumer Privacy Act (CCPA) Disclosures. The California Consumer Privacy Act (CCPA) (Cal. Civ. Code §1798.100 et seq.) requires that we disclose, among other things, the categories of Personal Information we have collected from California residents in the previous twelve (12) month period and the source. This information is set forth in the table below:
Name, address, email address, IP address, account username
Client; Website user; Employee
California Customer Records Information
Education, employment history, bank account number, or other financial information.
Race, color, religion, gender, national origin, disability, familial status, or sexual orientation
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Fingerprints, DNA, etc.
Browsing history, search history, or other information about a consumer’s interaction with our Website
Third-Party Analytics Provider
Audio, electronic, or visual information
Employment-related information and history
Inferences that can be drawn from any of the foregoing information, such as the preferences, characteristics, psychological trends, behavior, attitude, intelligence, or abilities
We have used this information for the following purposes:
- To provide you with Legal Services;
- To consider your application for employment or provide employment to you;
- To deliver Emails or administrative communications to you;
- To improve our Website and Services;
- To respond to communications from you; and
- To manage our Website, diagnose technical problems, and improve content;
I. Personal Information Disclosure
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information, as defined in the table above, to third parties:
- California Customer Records Information
- Professional Information
- Internet Information
Such information was disclosed to:
- third parties at your request as part of the Legal Services, such as when you ask us to contact a government agency or engage in third-party negotiations on your behalf; and
- third party providers that provide services to us or to you on our behalf, such as providers that help us with processing payment, sending postal mail and email, analyzing data, providing search results and links, tracking website analytics, and providing customer service.
Neumann & Associates has not sold any Personal Information of any California residents within the past twelve (12) months.
II. Your Rights
Pursuant to the CCPA, California residents have the right to request from us, for the preceding twelve (12) month period: (1) the categories of Personal Information and the specific pieces of Personal Information that we have collected about the resident, (2) the categories of sources from whom the Personal Information was collected, (3) our purposes for collecting the Personal Information, and (4) the categories of third parties with whom we have shared the Personal Information.
You also have the right to request that we delete any Personal Information we have collected from you. Once we verify your request, we will delete any Personal Information from our records, unless retaining your Personal Information is necessary for us to:
- complete the purpose for which we have collected the Personal Information, provide you with the Services, or as reasonably anticipated in the context of our relationship;
- offer employment or provide employment benefits;
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
- identify and resolve errors in the Services or security threats; or
- comply with a legal obligation.
We will confirm receipt of right to know and deletion requests within ten (10) business days of receiving such requests and will provide information as to how we will process such requests. We will respond to verified requests within forty-five (45) days of receipt. Please note that we are only required to respond to each website visitor twice per twelve (12) month period.
We are not required to: (1) retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; or (2) reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information.
III. Where to Send Requests
If you are a California resident and you wish to make any of the above requests, please send a request to:
Mail: Neumann & Associates, Inc.
Attn: California Privacy Rights
591 Camino de la Reina
San Diego, CA 92108
Email: send request to [email protected] with “California Privacy Information Request” in the subject line.
When you contact us, you will need to provide us with enough information to identify you (e.g., your full name and address); proof of your identity and address (e.g., a copy of your driving license); and a description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf. Any Personal Information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
Upon verification, we will provide the requested information to you at your email address within the time period noted above. The information will be provided to you free of charge. We will not discriminate against you for exercising your rights under this section.
Update Your Information
You can review or correct the Personal Information we have collected from you by emailing Neumann & Associates at: [email protected] or writing to us at:
Neumann & Associates, Inc.
591 Camino de la Reina
San Diego, CA 92108
We may take steps to verify your identity before providing your Personal Information. You can help us maintain the accuracy of your Personal Information by notifying us of any change to your name, mailing address, telephone number, email address, or business name.
In some situations, we may not be able to provide you with access to your Personal Information, such as where the information is part of a file that is protected by the attorney/client privilege or contains confidential information. Where we are unable to provide you with access to your Personal Information, we will notify you in writing, document the reasons for refusal, and provide you with the information that is not subject to a confidentiality obligation or attorney/client privilege.
Questions About Our Privacy And Information Security Practices?
If you have any questions about our privacy practices or procedures, please feel free to contact us at: [email protected].
Or by mail, to:
Neumann & Associates, Inc.
591 Camino de la Reina
San Diego, CA 92108