Effective Date: May 23, 2018
2. INFORMATION WE MAY COLLECT
When you use the Services, we may collect two types of information: Personal Information and Usage Data.
Personal Information does not include either (i) aggregated information to the extent that an individual’s identity cannot reasonably be derived from it, or (ii) publicly available information that has not been combined with non-public Personal Information.
We define “Usage Data” as information about an individual’s activity on or through the Services that, by itself, does not reasonably identify the individual, such as the following:
•Browser and operating system information
•Computer or device type
•Time spent navigating certain webpages or connected via mobile applications
•Information collected through Data Collection Technologies (as defined below)
Generally, we do not consider Usage Data as Personal Information, because Usage Data by itself usually does not identify an individual. However, in some jurisdictions, Usage Data may be considered Personal Information because it can be used to make inferences about you.
3. COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
We collect, use and disclose Personal Information for all lawful purposes in the operation and conduct of our business.
How We May Collect Personal Information
We and our service providers may collect Personal Information through your use of the Services, such as when you register with us, participate in surveys and questionnaires, apply for employment, or subscribe to newsletters and blog updates. We also may collect the Personal Information that you publish or display on public areas of the Services, such as one of PKF O’Connor Davies’s blogs (collectively, “User Contributions”). Your User Contributions are made publicly available at your own risk. We do not control the actions of third parties that access your User Contributions.
Through Mobile Applications: We may offer mobile applications (“Apps”) as part of the Services or at certain PKF O’Connor Davies events that we host. When we offer Apps, we may collect information about your use of and interaction with the Apps, such as operating system type, browser type, domain and other system settings, search queries, the country and time zone in which the mobile device or tablet is located, metadata and other information associated with other files stored on your device. We also may collect information about the location of the mobile device or tablet used to access the Services (“Location Data”). Location Data includes: (i) the location of the mobile device or tablet derived from GPS or WiFi use, (ii) the IP address of the mobile device or tablet or internet service used to access the Services, and (iii) other information made available by a user or others that indicates the current or prior location of the user, such as geotag information in photographs. If you do not want us to collect Location Data from your device, please delete the App or disable the location settings on your device or tablet. Note, however, that disabling the location setting may affect your ability to access and use an App.
How We May Use Personal Information
•To confirm registrations, respond to your inquiries or fulfill your requests, such as to register you for a seminar or to email you materials you requested
•To send you information, such as legal updates and event announcements, that we think may interest you
•To allow you to send Services-related content through the Services
•If you contact us through the services, to keep a record of your contact information and correspondence to use when responding to you
•To notify you about important information regarding changes to our terms, conditions and policies
•To analyze use of the Services to help us detect problems, prevent fraud, identify usage trends and improve user experience
•If you apply for employment with us, to process your employment application and other related activities only
How We May Disclose Personal Information
We may disclosure your Personal Information as follows:
•With your consent. We may disclose your Personal Information to any party for whom your consent has been provided. For example, we may disclose your Personal Information to anyone to whom you send messages through the Services.
•To our service providers. We may disclose information with third-party service providers that support our operations, through services such as registering and hosting webcast and live events, and employee recruitment.
•In relation to a corporate transaction. We may disclose and transfer Personal Information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control (whether in whole or in part).
4. COLLECTION, USE AND DISCLOSURE OF USAGE DATA
We collect, use and disclose Usage Data for all lawful purposes in the operation and conduct of our businesses.
How We May Collect Usage Data
When you use the Services, including Apps, we and our service providers may collect the Usage Data that is collected by most browsers or automatically through your device. When you download and use an App, we and our service providers may track and collect App data, including when you accessed our servers and what information and file have been downloaded. We also collect Usage Data through our use of Data Collection Technology. For more information about how we use Data Collection Technology, including cookies, please review Section 5 below.
How We May Use and Disclose Usage Data
We may use and disclose Usage Data for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat certain types of Usage Data as Personal Information under applicable law, we use and disclose it as described in Section 3 above.
In some instances, we may combine Usage Data with Personal Information (such as your device ID with your name). If we combine any Usage Data with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined and can be used to identify you.
5. COOKIES AND OTHER DATA COLLECTION TECHNOLOGY
We refer to cookies, web beacons (also known as pixel tags and clear GIFs) and other similar technology as “Data Collection Technology.”
A cookie is a small text file that is sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (when it expires), and a randomly generated unique number or other similar identifier. A cookie may also contain information about your computer, such as user settings, browsing history and activities conducted while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org.
How We Use Data Collection Technology: Data Collection Technology helps us improve your experience of the Services. In particular, we use analytics cookies to compile statistics about the use of the Services, help us analyze technical and navigational information about the services, and detect and prevent fraud. We also may use Data Collection Technology to collect information from the computer or device that you use to access the Services, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.
Your Control of Cookies: Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or alert you when a cookie is placed on your computer or device. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.
Our Policy on Do Not Track Signals: Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain Personal Information about the browser’s user. We follow the DNT signals we receive from your browsers.
6. CHOICES AND ACCESS
Marketing Emails: If you do not wish to receive marketing-related emails from us, please click the unsubscribe link at the bottom of a marketing email, or email us at email@example.com.
Access Requests: You may request access to any of your Personal Information that you have previously provided to us through the Services. You may also request that we update, modify or delete your Personal Information that we have collected. Please contact us by email at firstname.lastname@example.org to exercise these rights.
Please note that we cannot remove or modify your Personal Information from the databases of third parties to which we have disclosed your information prior to your opt-out or access request. Please contact those third parties directly.
7. SPECIAL NOTICE TO CALIFORNIA RESIDENTS
California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us at email@example.com. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this Section.
8. LINKS TO OTHER WEBSITES AND SERVICES
9. NOTICE TO INTERNATIONAL VISITORS
The Services are controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.
We take reasonable precautions intended to help protect the Personal Information that we collect and store; however, no system or online transmission of data is completely secure. We cannot guarantee the security of information transmitted to or through the Services. Any transmission is at your own risk. Please use security measures to protect your Personal Information.
11. CHILDREN’S PRIVACY
The Services are not directed to or intended for use by minors. Consistent with the requirements of the US Children’s Online Privacy Protection Act, if we learn that we have received information directly from a child under age 13 without his or her parent or legal guardian’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. Subsequently, we will make commercially reasonable efforts to delete such information.
12. QUESTIONS OR COMMENTS
PKF O’Connor Davies LLP
500 Mamaroneck Ave
Harrison, NY 10528
By Phone: +1 914 381 8900
By Email: firstname.lastname@example.org
By Fax: +1 914 381 8910