Privacy Policy

Effective Date: August 1, 2021

This Privacy Policy describes how Nielsen Merksamer Parrinello Gross & Leoni llp (“Nielsen Merksamer”), collects, uses, and discloses Personal Information when we provide legal and compliance services to clients, manage our business and other relationships, or when you use our websites, receive our updates, or otherwise communicate with us (collectively, the “Services”).  We are committed to ensuring the privacy and integrity of the Personal Information you share with us or we otherwise collect as we provide these Services.

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

Personal Information We Collect

In most cases, we collect Personal Information directly from you. However, we may also obtain Personal Information about you from third parties or automatically when you interact with our Services.

Below is a description of the different types of Personal Information we may process and the sources from which we obtain them:

  • Clients. If you are a client of our firm, we collect your name, contact details, payment information, and any other information you provide to us or we otherwise obtain from third parties (e.g., from government entities, from the opposing party etc.) when providing legal and compliance services to you. The type of information we collect from our clients varies depending on the matter and may include information about our clients’ employees, customers, and vendors (e.g., name, contact details), communications with our client, information provided by our client, sensitive Personal Information (including social security numbers and drivers’ license numbers) and any other information that may be relevant for the matter.
  • Website Visitors. If you are a visitor to our website, through the use of cookies and similar technologies, we may collect your device IP address, unique device ID, hardware and software type, Internet service provider, serving domain, geographical area, location data, browser type and settings data (such as screen resolution, color depth, time zone settings, browser extension and plugins) operating system, referring URLs, search history, information on actions taken or interaction with our digital assets (e.g., page views) and dates and times of actions.
  • Nielsen Merksamer business partners and vendors. We may receive contact details and payment information from business partners’ and vendors’ employees in furtherance of the relevant partner or vendor relationship.
  • Events. We collect Personal Information about you if you choose to register for an event sponsored by our firm, such as an in-person or virtual Essential Ethics briefing. This Personal Information may include your first and last name, address, title, company, phone number, and email address, as well as specific information relevant to the event for which you are registering. If we are offering CLE credit, we may also request your bar membership number and signature.
  • Essential Ethics and Other Updates. We are pleased to provide weekly Essential Ethics updates as well as other updates, including upcoming reporting deadlines, to our clients and others. If you sign up to receive our updates focusing on key legal, regulatory, and industry trends, we will ask you to provide your first and last name, company, city, email address and the practice areas and updates that you are interested in.
  • Nielsen Merksamer Client Portal: We are also pleased to provide clients with access to our Client Portal, where you will find propriety, jurisdiction-specific materials. If your representation includes access to our Client Portal, we will provide you with a username and password. To set up your account, you will also be asked for your first and last name, email address, title, and company.
  • Communications. If you choose to contact us for any purpose, we will collect your contact details, your name, and the content, date and time of your message, as well as our reply and any follow up action we take in relation to your inquiry.
  • Questionnaires. If your representation includes compliance services, you will be asked to provide Personal Information through a third party vendor, Qualtrics. Personal Information we collect through questionnaires will be used only to perform compliance services specifically agreed upon. Personal Information collected through questionnaires may include your first and last name, email address, telephone number, title, company, and salary information. We encourage you to review Qualtrics’ privacy policy.
  • Job applicants. If you apply for a job with us via our website, you may be asked to enter or upload your first and last name, resume and transcripts, phone, email address, law school, graduation year, application office, department, and position. You may also provide your middle name, address, country, reference(s), a cover letter, writing sample, and additional transcripts.
  • Other sources. We may receive Personal Information about you from other sources, including third parties that help us update, expand, and analyze our records, identify new clients, or prevent or detect fraud. We may also receive information about you from social media platforms, for example when you interact with us on those platforms or access our social media content. The information we may receive is governed by the privacy settings, policies, and/or procedures of the relevant social media platform, and we encourage you to review them.

Cookies and Similar Technologies

Through the use of cookies and similar technologies, we may collect your device IP address, unique device ID, hardware and software type, Internet service provider, serving domain, geographical area, location data, browser type and settings data (such as screen resolution, color depth, time zone settings, browser extension and plugins) operating system, referring URLs, search history, information on actions taken or interaction with our digital assets (e.g., page views) and dates and times of actions.

The types of cookies we use include:

  • Google Analytics to collect information about how you use our Services. We use this information to create reports and improve our Services. The cookies help us understand the number of visitors to our website and where visitors come from. To learn more about how Google uses data when you use our Services, visit https://policies.google.com/technologies/partner-sites. To opt-out from these cookies across all websites, visit http://tools.google.com/dlpage/gaoptout.

Most web browsers allow you to manage cookies through the browser settings. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org.

Use of Personal Information

We may use your Personal Information for the following purposes:

  • To provide legal and compliance services to our clients, such as to advise clients on legal and compliance matters, represent them in the context of legal proceedings such as court proceedings, arbitration and settlement, and dealings with regulatory authorities; to file lobby and campaign registrations and reports; to file nonprofit applications and tax filings; to manage and collect information for potential or actual litigation proceedings, including e-Discovery; and to process payments and advance payments on behalf of our clients.
  • To provide relevant updates, including to send Essential Ethics updates and other communications to our clients and business contacts. We will send you communications that are relevant to you, based for example on the practice areas and industries you select when you subscribe to receive our communications.
  • To provide event information, including to register you for, and confirm your attendance at, events; furnish biographical details to other attendees; and assess the effectiveness of our events and publications.
  • To manage our business relationships with customers, clients, vendors and suppliers, business partners, cooperating law firms and other contractors, including processing invoices and sending service-related communications.
  • For recruitment purposes, including to evaluate job applications and invite you for a job interview.
  • To communicate with you and respond to your inquiries.
  • For other business purposes, such as to provide, operate and improve our products and services, perform data analyses, detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement, defend our legal rights, and comply with our legal obligations and internal policies.

Disclosure of Personal Information

We may disclose Personal Information about you as described below:

  • With third party contractors engaged by Nielsen Merksamer in the course of business (e.g., accountants, insurance companies, banks, auditors, and advisors and/or consultants engaged by Nielsen Merksamer).
  • With government agencies, regulators or courts, as required by applicable law and/or in the context of legal or compliance proceedings.
  • As necessary to provide legal services to our clients, including opposing counsel.
  • With event partners or co-sponsors.
  • With vendors and service providers who perform services on our behalf with whom Nielsen Merksamer has a direct contractual relationship.
  • If you gave us your permission, or if doing so is required or appropriate to (i) comply with laws, law enforcement requests, and legal process, such as a court order or subpoena; (ii) respond to your requests; or (iii) protect your, our or others’ rights, property, or safety.

California Privacy Rights

If you are a Consumer receiving products or services for which we are a Business, as those terms and any other capitalized terms in this section are defined under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (collectively referred to as the “CCPA”), you have various rights relating to the use and disclosure of your Personal Information, subject to certain limitations by law and contingent upon receipt of verifiable consumer requests where applicable. These rights generally include:

  • The right to request that we disclose the categories and specific pieces of Personal Information that we have collected.
  • The right to request that we delete any Personal Information about you which we have collected from you.
  • The right to request, that if we collect Personal Information about you, we disclose the following to you:
  • the categories of Personal Information we have collected about you;
  • the categories of sources from which the Personal Information is collected;
  • the Business or Commercial Purpose for collecting or selling your Personal Information;
  • the categories of third parties with whom we disclose your Personal Information; and
  • the specific pieces of Personal Information we have collected about you.
  • The right to be informed in our Privacy Policy of the following, if we collect Personal Information about you: a list of the categories of Personal Information we have collected about you in the preceding 12 months by reference to the enumerated category or categories that most closely describe the Personal Information collected (e.g., geolocation data; professional or employment-related information; etc.).
  • The right to request, that if we sell your Personal Information, that we disclose the following to you:
  • the categories of Personal Information that we collected about you;
  • the categories of Personal Information that we sold or shared about you and the categories of third parties to whom the Personal Information was sold or shared, by category or categories of Personal Information for each category of third parties to whom the Personal Information was sold or shared; and
  • The categories of Personal Information that we disclosed about the you for a Business Purpose.
  • The right to be informed in our Privacy Policy of the following, if we sell your Personal Information or disclose it for a Business Purpose:
    • The category or categories of your Personal Information we have sold. Alternatively, if we have not sold Consumers’ Personal Information, we must disclose that fact; and
    • The category or categories of Personal Information we have disclosed for a Business Purpose. Alternatively, if we have not disclosed Consumers’ Personal Information for a Business Purpose, we must disclose that fact.
  • If we sell your Personal Information, you have the right to opt-in or opt-out of the sale of your Personal Information, depending on your age. Specifically, you have the right to opt-out of the sale of your Personal Information if you are at least 16 years of age or older. If we have actual knowledge that you are under the age of 16, but at least 13 years of age, we may not sell your information unless you have exercised your right to opt-in to the sale of your information. If you are under the age of 13, only a parent or guardian may opt-in to the sale of your information. You, or a person authorized by you, may opt-out of the sale of your Personal Information.
  • You have the right to not be discriminated against when exercising any of your rights under the CCPA. For example, this means we cannot deny you goods or services or provide you a different quality or level of goods or services, simply because you requested that we inform you of your right to know what information we collected or sold.

Sale of Personal Information/ Financial Incentives

We have not sold Consumers’ Personal Information in the preceding 12 months. We do not offer financial incentives to Consumers based upon the retention or sale of a Consumer’s Personal Information.

Personal Information Collection and Disclosure in the Preceding 12 Months

Categories of Personal Information Collected

 

Categories of Sources of Collection of Personal Information

 

Business Purpose for Collecting Personal Information  Categories of Third Parties (If Any) With Whom Personal Information May be Disclosed
Identifiers
Examples: Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Directly from you, e.g., via email correspondence, questionnaires, or forms you complete or products and services you purchase.

Indirectly from you, e.g., from observing your actions on our Website or from your Devices.

Directly or indirectly from others including our third party vendors and business partners.

Public records from government entities.

Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Short-term, transient use, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about a Consumer or otherwise alter an individual Consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

Performing services on behalf of the Business or Service Provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Business or Service Provider.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

Internet service providers.

Data analytics providers.

Parties to business transactions.

Government entities.

Operating systems and platform.

Social networks.

Vendors and Service Providers.

Third parties integrated into our services.

Third parties as required by law and similar disclosures.

Other third parties for whom we have obtained your permission to disclose your Personal Information.

Categories of Personal Information in Cal. Civ. Code Section 1798.80

Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.

Directly from you, e.g., via email correspondence, questionnaires, or forms you complete or products and services you purchase.

Indirectly from you, e.g., from observing your actions on our Website or from your Devices.

Directly or indirectly from others including our third party vendors and business partners.

Public records from government entities.

Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Short-term, transient use, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about a Consumer or otherwise alter an individual Consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

Performing services on behalf of the Business or Service Provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Business or Service Provider.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

Internet service providers.

Data analytics providers.

Parties to business transactions.

Government entities.

Operating systems and platform.

Social networks.

Vendors and Service Providers.

Third parties integrated into our services.

Third parties as required by law and similar disclosures.

Other third parties for whom we have obtained your permission to disclose your Personal Information.

Commercial Information

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Directly from you, e.g., via email correspondence, questionnaires, or forms you complete or products and services you purchase.

Indirectly from you, e.g., from observing your actions on our Website or from your Devices.

Directly or indirectly from others including our third party vendors and business partners.

Public records from government entities.

Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Short-term, transient use, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about a Consumer or otherwise alter an individual Consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

Performing services on behalf of the Business or Service Provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Business or Service Provider.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

Internet service providers.

Data analytics providers.

Parties to business transactions.

Government entities.

Operating systems and platform.

Social networks.

Vendors and Service Providers.

Third parties integrated into our services.

Third parties as required by law and similar disclosures.

Other third parties for whom we have obtained your permission to disclose your Personal Information.

Internet or Other Electronic Network Activity Information

Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.

Directly from you, e.g., via email correspondence, questionnaires, or forms you complete or products and services you purchase.

Indirectly from you, e.g., from observing your actions on our Website or from your Devices.

Directly or indirectly from others including our third party vendors and business partners.

Public records from government entities.

Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Short-term, transient use, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about a Consumer or otherwise alter an individual Consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

Performing services on behalf of the Business or Service Provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Business or Service Provider.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

Internet service providers.

Data analytics providers.

Parties to business transactions.

Government entities.

Operating systems and platform.

Social networks.

Vendors and Service Providers.

Third parties integrated into our services.

Third parties as required by law and similar disclosures.

Other third parties for whom we have obtained your permission to disclose your Personal Information.

Geolocation Data

Example: Precise physical location.

Directly from you, e.g., via email correspondence, questionnaires, or forms you complete or products and services you purchase.

Indirectly from you, e.g., from observing your actions on our Website or from your Devices.

Directly or indirectly from others including our third party vendors and business partners.

Public records from government entities.

Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Short-term, transient use, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about a Consumer or otherwise alter an individual Consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

Performing services on behalf of the Business or Service Provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Business or Service Provider.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

Internet service providers.

Data analytics providers.

Parties to business transactions.

Government entities.

Operating systems and platform.

Social networks.

Vendors and Service Providers.

Third parties integrated into our services.

Third parties as required by law and similar disclosures.

Other third parties for whom we have obtained your permission to disclose your Personal Information.

Sensory Information

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Directly from you, e.g., via email correspondence, questionnaires, or forms you complete or products and services you purchase.

Indirectly from you, e.g., from observing your actions on our Website or from your Devices.

Directly or indirectly from others including our third party vendors and business partners.

Public records from government entities.

Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Short-term, transient use, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about a Consumer or otherwise alter an individual Consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

Performing services on behalf of the Business or Service Provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Business or Service Provider.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

Internet service providers.

Data analytics providers.

Parties to business transactions.

Government entities.

Operating systems and platform.

Social networks.

Vendors and Service Providers.

Third parties integrated into our services.

Third parties as required by law and similar disclosures.

Other third parties for whom we have obtained your permission to disclose your Personal Information.

Professional or employment- related information

Examples: Job application or resume information, past and current job history, and job performance information, unless exempt.

Directly from you, e.g., via email correspondence, questionnaires, or forms you complete or products and services you purchase.

Indirectly from you, e.g., from observing your actions on our Website or from your Devices.

Directly or indirectly from others including our third party vendors and business partners.

Public records from government entities.

Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Short-term, transient use, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about a Consumer or otherwise alter an individual Consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

Performing services on behalf of the Business or Service Provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Business or Service Provider.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

Internet service providers.

Data analytics providers.

Parties to business transactions.

Government entities.

Operating systems and platform.

Social networks.

Vendors and Service Providers.

Third parties integrated into our services.

Third parties as required by law and similar disclosures.

Other third parties for whom we have obtained your permission to disclose your Personal Information.

Inferences Drawn from Personal Information

Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Directly from you, e.g., via email correspondence, questionnaires, or forms you complete or products and services you purchase.

Indirectly from you, e.g., from observing your actions on our Website or from your Devices.

Directly or indirectly from others including our third party vendors and business partners.

Public records from government entities.

Auditing related to a current interaction with the Consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Short-term, transient use, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about a Consumer or otherwise alter an individual Consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

Performing services on behalf of the Business or Service Provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Business or Service Provider.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Business.

Internet service providers.

Data analytics providers.

Parties to business transactions.

Government entities.

Operating systems and platform.

Social networks.

Vendors and Service Providers.

Third parties integrated into our services.

Third parties as required by law and similar disclosures.

Other third parties for whom we have obtained your permission to disclose your Personal Information.

 

 

Requests under California Privacy Laws

Such information may be used for the purposes for which it was collected or as otherwise permitted or required by applicable law.

You can make requests related to your California privacy rights by calling 877-389-6800 or by email to privacy@nmgovlaw.com or in writing to Nielsen Merksamer, 2350 Kerner Blvd. #250, San Rafael, CA 94901. Please be aware that we do not accept or process requests through other means (e.g., via fax or social media).

We will review the information provided and may request additional information to ensure we are interacting with the correct individual. If you have an online account with us, you may be required to log-in to your account for identity verification. If you do not have an account with us, additional information to verify your identity may be required by law before we may take action upon such a request. This additional information may vary depending on the nature of your request and/or the nature of the information about which your request relates. In some cases, we may also be required by law to obtain a signed declaration under penalty of perjury from you that you are the subject of the request being made. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic.

By law, we are not required to collect Personal Information that we otherwise would not collect in the ordinary course of our business, retain Personal Information for longer than we would otherwise retain such information in the ordinary course of our business, or reidentify or otherwise link information that is not maintained in a manner that would be considered Personal Information. If we have not requested specific additional information from you to verify your request, please do not send such information.

If your request is regarding household information, the same verification steps above are required before we can provide you with aggregate household information. For us to process a request for access to or deletion of specific pieces of information regarding your household, all members of the household must make the request, and we must be able to verify each household member.

In some cases, we may not have sufficient information about you or your household to be able to verify your identity or sufficiently differentiate you from another consumer or household to the degree of certainty required by law, in which case, we will not be able to act upon your request. In such cases, it may be unlikely that we would be able to identify you or your household in the future without collecting significantly more information or seeking to reidentify deidentified information. At this time, we do not intend to take such steps in response to a request made pursuant to this Privacy Policy and applicable law does not require that we do so. If, in the future, we determine a reasonable method to identify you or your household absent such steps, we will provide an update to you through this Privacy Policy and in response to any such request at that time.

Information that you submit for the purpose of allowing us to verify your identity in furtherance of a consumer-related or household-related request pursuant to California law will only be used by us, and our service providers if any, for that purpose and no other. Except where we are required by law to maintain such information for record-keeping purposes, we will take steps to delete any new Personal Information collected for the purpose of verification as soon as practical after processing your request.

Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of Personal Information or content you may have posted, and there may be circumstances in which the law does not require or allow us to fulfill your request, including, for example, where fulfilling your request may infringe upon the rights and freedoms of other consumers.

We reserve the right to take appropriate action in response to requests from a consumer or household that are manifestly unfounded or excessive, in particular because of their repetitive character.

You may designate an authorized agent to make a request on your behalf pursuant to applicable law. We accept documentation of your designation in the form of a valid power of attorney and/or a notarized statement. You must submit evidence of your designation of an authorized agent in writing to: Nielsen Merksamer, 2350 Kerner Blvd #250, San Rafael, CA 94901. We may require verification of your authorized agent in addition to the information for verification above for consumers and households.

Links to Other Websites

This website may link to websites maintained by outside organizations, including third-party social networks (such as Facebook, Twitter, LinkedIn). Please be aware that these third-party websites are governed by their own privacy policies. Our firm is not responsible for the content or policies maintained by these websites. Please familiarize yourself with the privacy policy of any third-party website you visit, as it will govern any information you submit through that website.

Security

While no system can be guaranteed to be 100% secure, we maintain administrative, technical, and physical safeguards that are intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession.

Data Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the nature and length of our relationship with you, mandatory retention periods provided by law and the statute of limitations, the type of Services requested by or provided to you, the possible re-enrolment with our Services, and the impact on our Services if we delete some information from or about you.

Changes to This Policy

We may make changes to this Privacy Policy. The “Effective Date” date at the top of this page indicates when this Privacy Policy was last revised. If we make material changes, we may notify you via a notice posted on our website or other method. We encourage you to read this Privacy Policy periodically to stay up-to-date about our privacy practices.

Contact Us

If you have any questions about this Privacy Policy, you may contact us at:

Nielsen Merksamer Parrinello Gross & Leoni llp
2350 Kerner Boulevard #250
San Rafael, California, 94901
privacy@nmgovlaw.com
877-389-6800