Updated: January 26, 2019 v.2.
We (“SCLG” or “we” or “us” or “our”) are dedicated to respecting your privacy. This Privacy Notice (“Notice”) explains how we may collect, use, share and process information about you. It also describes how you can exercise your privacy rights. It applies to everyone who accesses our web pages, mobile apps, alerts, blogs, newsletters, advertising, social media sites or other communications transmitted over the Internet, and any data received by us.
Concerns or questions should be directed to us at SCLG, 1455 Pennsylvania Ave., N.W., Suite 400, Washington, D.C. 20004 or via email at firstname.lastname@example.org.
I. Notice Updates
We may update this Notice over time. Above, we note the effective date, and sometimes a version number, of the current Notice. We will notify you of any material change to our procedures or this Notice by posting, above, a notice that we have made changes. There are no material changes in v.2.
II. Information We May Collect
When you contact us, view our sites or materials, or otherwise interact with us we may collect personal information about your use of our sites or services, and information that you provide us. We use the term "personal information" to describe information that identifies you or makes you identifiable. Anonymized information that does not identify a specific individual is not “personal information.” Among the information or data that we may collect are the following:
A. Information Provided by You
We collect information that you voluntarily provide. This includes the time and method of communication, when and how you request information or materials, when you request employment information or submit an application for employment, when you sign up for any event or reply to a request for information from us, and when you request or engage legal services. Your information may include your name, telephone number, email address, title, your organization or other information you provide. Employment requests may include your background and history.
NOTE: Unless we specifically requested information, do not send us confidential, private or sensitive information, identifying numbers, license numbers, or financial information such as credit card or banking numbers. This information should only be sent via channels designated by us and upon our specific request.
B. Information Automatically Collected
We may automatically collect certain information when you access any of our media platforms or web sites. Such information includes the following:
1. Device Information. This includes information about your computer or other device, your IP address and other websites visited by you before contacting us.
2. Performance Data. This includes your IP address, browser type, operating system, command line information, diagnostic information, referring web page, crash reports, pages visited, location, mobile carrier, device and application IDs, search terms and similar information. We may collect information related to whether you received or opened our email, or took other action, and we may preserve your contact information and name.
3. Cookies. Please refer to our Cookie Notice for a discussion of this topic.
Due to the absence of a standard for the implementation and use of web browser “do not track” signals or other mechanisms that may permit opt outs of information collection across networks of websites, online services and similar media, we cannot currently accept such requests.
III. How and Why We Use Your Information
We use the personal information you provide to respond to your request or inquiry and in the ordinary course of conducting our business. Information we collect is or may be used for the following purposes:
A. Provide our Services and Support. Your personal information can help us better inform you about our services, new developments, information relevant to you, process your payments, and help us tailor our marketing events. It may also help us provide any website troubleshooting and technical support. Certain information is required in order to provide legal representation.
B. Inquiry Response. When you contact us, your personal information is necessary to respond to questions, concerns, feedback, disputes or issues.
C. Enforcement and Security. We require your personal information to monitor, investigate, prevent and mitigate alleged or actual prohibited, illicit or illegal activities while accessing our sites or media; investigate, prevent, or mitigate violations of our terms, agreements or policies; and enforce our agreements. We also use this information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity to thwart unauthorized users from using your account.
D. Providing a Personalized Experience. Our provision of Third-Party Services, plugins, and other options may require your personal information in order to tailor your experience to your preferences. For instance, we may be able to provide a better experience if we can use access your language selection, time zone, past preferences and similar data. Without processing your personal information for such purposes you may not be able to access or personalize part or all of our Services.
E. Research and Development. We may rely on information about the way you use and interact with our sites and media to improve our services. If we do so, we will take additional security measures, such as removing or masking your identifying information, limiting access to data, and employing other security measures.
F. For Potential Employment. Your personal information is required should you apply for employment.
G. Marketing. We may use your information to send you marketing communications, invite you to events or webinars, deliver targeted messages, or keep you updated on developments. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send such messages if you opt-in to receive them.
H. Business Operations. We may use your information, including your personal information, for the administration of our general business, accounting, legal and recordkeeping functions.
I. Legal Obligations. We may need to disclose information in response to subpoenas or court orders in order to comply with legal obligations and/or lawful requests by regulators or law enforcement, including responding to national security disclosure requirements.
Information Sharing and Disclosure
IV. We may sell, exchange, transfer, or give your personal information to another company or individual for only the following purposes:
A. Affiliates. We may share information with affiliates when relevant to information or services provided to you.
B. Service Providers. When we use affiliates, suppliers, subcontractors, and similar third parties to provide you service, we may share your information with them to the extent necessary to provide such service. We generally contractually prohibit their sharing of this information.
E. Consent. We will disclose your information to a person or organization you have given us your consent to disclose to.
V. Links to Third Party Services
Our web site or media may include links to third party services where you might be able to post comments, reviews, or view third party information. The use of these third party services may result in the collection and sharing of information about you by these third party services.
This Notice does not address the information practices of any third party, unless as specified otherwise. Please note, the inclusion of a link on our Service to a third party’s service does not imply endorsement of the third party’s data handling practices, and does not imply that the third party’s practices are covered by this Privacy Notice. We are not responsible for the privacy practices of these entities.
We encourage you to be aware when you leave our Service, and to read the privacy statements of each website or app on which you land after you click on a link or social networking button.
VI. Access to Your Information
You may access and update your personal information that we hold by contacting us directly at email@example.com. For your protection, we may need to verify your identity before implementing your request.
In your request, please make clear what information you would like to have changed, whether you would like to have your personal information suppressed from our database, or other limitations you would like to put on our use of your personal information. We may only implement requests with respect to personal information that is associated with the particular email address that you use to send your request.
We reserve the right to refuse to act on a request that is manifestly unfounded, excessive, abusive or repetitive, and to charge a fee, at our sole discretion for excessive or unreasonable requests, that takes into account the administrative costs for providing the information or taking the action requested.
VII. Information Security
We seek to use reasonable technical, organizational, and administrative measures to protect user information within our organization against unauthorized or unlawful access or processing, and against accidental loss, destruction, or damage. We believe that these measures are reasonably adapted to the nature of the information in our custody.
However, even though we make reasonable efforts to protect information in its custody, no data storage or transmission over the Internet and no security system is fully secure. Thus, we cannot guarantee the security of any information we may have collected or received from you or transmitted to you.
If you believe your information is not secure due to a problem in our systems, please immediately notify us of the problem at the address provided in the “How to Contact Us” section.
We retain information about users for as long as necessary to perform the activities described in this Notice, or where we have an ongoing legitimate business need to do so, such as for legal, regulatory, accounting or reporting requirements.
When our legitimate interest for retaining your personal information ceases to exist, we will either delete or anonymize your information so that it can no longer be attributed to a particular individual. To the extent residual information remains within our databases, back-ups or other records and we are unable to anonymize it we will isolate such information from further processing until deletion is possible.
IX. Children’s Information
We do not knowingly collect any personal information from children under 16. If we become aware that an individual under 16 is submitting information, we will delete the information as soon as possible from our database.