Privacy Policy

UB GREENSFELDER LLP

WEBSITE PRIVACY POLICY

Last Revised: 10/30/2024

UB Greensfelder LLP (“UB Greensfelder” or “we”) values your privacy and is committed to protecting it.  Please read this Privacy Policy in its entirety, because by using or even visiting this website you agree to its terms as well as to any subsequent changes.  If you do not so agree, do not use this website.

The Information We Collect

Information You Provide to UB Greensfelder.  

We collect personal information that you provide to UB Greensfelder.  “Personal information” is information relating to an identified or identifiable natural person, and may include that person’s name, physical address, phone number, e-mail address, and any other information that will allow someone to identify or contact that person.  You are not required to provide any information to UB Greensfelder to use the UB Greensfelder website.  However, not providing certain information may result in certain UB Greensfelder website features not working, and in your not receiving UB Greensfelder publications or missing invitations to UB Greensfelder events.

Information We Collect Automatically When You Use the UB Greensfelder Website.  

When you access or use the UB Greensfelder website, we may automatically collect information about you, including:

  • Usage, System, and Log Data.  Your IP address, device identifier, location information, media access control or “MAC” address, browser, and activity on the UB Greensfelder website, including, but not limited to, date and times of use, clicks, page and profile views, and the amount of time you spend on each page.
  • Data Collected Through Cookies and Similar Technologies. Like many providers of online services, we use various technologies to collect usage data and to store preferences. One such technology is called a cookie. A cookie is a small data file that is transferred to your computer’s hard disk. We may use both session cookies and persistent cookies to help us understand how you interact with the UB Greensfelder website and to monitor aggregate usage by our users and web traffic routing on the UB Greensfelder website.  Also, we may create a unique device or user ID for you and store it in a cookie so we can recognize you and customize your experience based on your preferences.  Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie.  Please note that removal or rejection of browser cookies could affect the availability or functionality of the UB Greensfelder website.
  • Online Tracking.  Some web browsers have a “Do Not Track” feature.  That feature lets individuals tell the websites that they visit that they do not want to have their online activity tracked.  “Do Not Track” features are not uniform across all browsers and, at this time, the UB Greensfelder website does not respond to “Do Not Track” signals.

How and Why We Use Your Information

How We Use Your Information. 

We use your information to:

  • Provide, operate, maintain and improve the UB Greensfelder website;
  • Respond to your comments, questions, and requests and to provide customer service and support;
  • Send you promotional materials and information;
  • Monitor and analyze trends, usage, and activities in connection with the UB Greensfelder website and for marketing or advertising purposes; and
  • Provide you with legal services.

How We Share Your Information. 

We do not sell personal information and will not share your personal information with any third parties except as described in this Privacy Policy:

  • UB Greensfelder’s Service Providers.  We may share your personal information with third-party vendors that are performing work for UB Greensfelder in connection with our website and our services.
  • Compliance with Laws.  We may disclose your personal information to a third party if we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request.
  • Business Transfers.  We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of business assets, financing, or acquisition of all or a portion of our business to another entity.
  • Affiliates.  We may share your personal information with affiliates of UB Greensfelder for use as otherwise described in this Privacy Policy.

Why We Use Your Information. 

We use your personal information only when we are allowed by applicable law to do so and for the following lawful reasons:

  • Consent. When you share your personal information with UB Greensfelder to receive a response to an inquiry to UB Greensfelder, receive UB Greensfelder publications, receive invitations to UB Greensfelder events, or view UB Greensfelder webinars.
  • Legitimate Interest. To analyze and improve the UB Greensfelder website, to verify that the personal information have from you is current, and to keep a record of your communication preferences.
  • Legal Obligation. To comply with applicable statutes, regulations, and professional obligations.

Third Party Websites

Certain pages within the UB Greensfelder website contain “hyperlinks” to third-party websites.  Please note that UB Greensfelder is not responsible in any way for the privacy practices of other websites.  We suggest that you read the privacy policies of those third-party websites before using them.

Minors

We do not intend for children under the age of 18 to use our website.  Further, we do not knowingly collect personal information from children under the age of 18.  If you are a parent or guardian of a child under the age of 18 and believe that your child has disclosed personal information to us, please contact us at the e-mail address, physical address, or phone number set forth in this Privacy Policy and UB Greensfelder will delete such personal information.

Your Choices and Selecting Your Privacy Preferences 

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed.  Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

From time to time, we may send you email newsletters and marketing emails.  You may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing. Should you ever have questions about the accuracy or your Personal Information, please contact us at the email listed above.

California Residents

Each resident of California, thanks to section 1798.83 of the California Civil Code (the “Shine the Light” statute), may request, once per calendar year, from companies conducting business in California a list of all third parties to whom the company has disclosed certain personally identifiable information, as defined under California law, about that California resident during the preceding year for third-party direct-marketing purposes.  In your request, please attest to your being a California resident and provide a current California address for our response.

If you are a California resident and under the age of 18, and a user of this website, section 22581 of the California Business and Professions Code (the California Consumer Privacy Act) permits you to request companies to delete personal information that they have collected about you, and to remove content that you have publicly posted.  Certain exceptions may apply, such as the exception for business-to-business transactions.  Please note that your request will not ensure a complete removal of the content and that in some cases the statute may not require or allow removal even if requested.

California law treats disclosures of personal information in exchange for valuable consideration as “sales.”  California law gives consumers who reside in California the right to opt out of such sales, except in the case of personal data subject to the business-to-business exception, and to opt out of financial incentive programs that we might offer.  However, WE DO NOT SELL YOUR PERSONAL INFORMATION. If we ever decide to “sell” Personal Information, as those terms are defined under the CCPA, we will update you via this Privacy Policy and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Information.

Your State Consumer Rights

Some state laws in the United States provide consumers with additional rights with respect to their Personal Information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018 (the “CCPA”) as amended by the California Privacy Rights Act, the Colorado Privacy Act (“CPA”),the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”).  We seek to provide these rights regarding Personal Information to all visitors and users of our services, regardless of the state in which the visitor resides. Subject to our verification of your identity, the following rights may available to you under applicable law as a visitor to our website.

  1. Access.  You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
  2. Correction.  You can correct what personal data our Site database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us.
  3. Limit Use and Disclosure of Sensitive Personal Information. If we collect any sensitive personal information, you have the right to request that we limit the use of the sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
  4. Portability.  Upon request and when possible, we can provide you with copies of your Personal Information.  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy
  5. Deletion.  You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.  Where applicable, we will ensure such changes are shared with trusted third parties.
  6. Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.
  7. Non-Discrimination. If a consumer exercises his or her rights under applicable state law, including but not limited to the CCPA, CPA, UCPA, and VCDPA, we shall not discriminate against that data subject by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
  8. Exercising your rights. If you are a consumer that has rights under applicable state law, including but not limited to the CCPA, CPA, UCPA, and VCDPA, who chooses to exercise the rights listed above, you can submit a request via email at the address listed above.

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information.  If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Applicable state residents with questions about our handling of their personal information should email us at privacy@ubglaw.com and put “Your Privacy Rights” in the subject field of the email, or include that phrase in your letter if you write to us.  Be sure to include your name, street address, city, state, and zip code.

Notice about the European Union’s General Data Protection Regulation (“GDPR”)

You may have certain rights under the European Union’s GDPR 2016/679 if you are a data subject in the European Union protected by the GDPR  These rights are in addition to the commitments we are making elsewhere in this policy to safeguard your privacy.  The GDPR is a complex regulatory scheme and we do not intend to provide every detail here.  If you are interested you should read the GDPR and the relevant guidance provided by the applicable authorities for a fuller explanation.  The GDPR applies to businesses that market their products and services to people in the EU or that monitor the behavior of people in the EU.  We wish to assure visitors to our website that we have put in place processes and procedures to comply with GDPR.

The GDPR heightens the standards for disclosures prior to obtaining consent.  Consent must be “freely given, specific, informed and unambiguous.”  The consent must be in “clear and plain” language that users can pick out and distinguish from other matters.  If the GDPR applies to you, you must know exactly what you are consenting to when you consent and you must be informed in advanced of your right to withdraw that consent.

The GDPR builds in two new rights where applicable; namely, the “right to be forgotten” and the right to “data portability.”  More specifically, the GDPR provides the right, where applicable, (a) to access your Personal Data (as defined in the GDPR), (b) to restrict publication of your Personal Data, (c) to have your Personal Data rectified or erased, (d) to restrict the processing of your Personal Data, (e) to object to the processing of your Personal Data, (f) to data portability, meaning the right to obtain your Personal Data in a structured, commonly used and machine-readable format, so that you can transmit it to another data controller, (g) to complain to a supervisory authority, and (h) to withdraw your consent with respect to the processing of your Personal Data.  You do not have to give us reasons for exercising these rights.

Here are some further details about these rights:

  • Where applicable, the GDPR provides you with the right to confirm whether UB Greensfelder processes or has processed your Personal Data and to access that data, together with certain other information including the purposes of the processing, the categories of Personal Data concerned, and the recipients of the Personal Data. Where applicable, and providing that we do not affect the rights and freedoms of anyone else, we will supply you with one copy of your Personal Data.  The first copy is free.  We may charge a reasonable fee for additional copies.
  • Where applicable, the GDPR provides the right to rectify any inaccurate Personal Data about you and, taking into account the purposes of the processing, to complete any incomplete data about you.
  • In some circumstances the GDPR provides you the right to erase your Personal Data without undue delay, including (a) when we no longer need the Personal Data for the purposes for which we collected or processed the Personal Data, (b) if you withdraw your consent to consent-based processing, (c) if you object to the processing of the Personal Data under certain rules of the GDPR, (d) if the processing is for the purpose of direct marketing, and (e) if the Personal Data has been unlawfully processed. However, the GDPR provides exceptions or exclusions to the right to erase, including where the processing is necessary for the exercise of free expression and information, to comply with a legal obligation, or to establish, exercise, or defend a legal claim.
  • In some circumstances the GDPR provides you the right to restrict the processing of your Personal Data, such as to contest the accuracy of the Personal Data, where the processing is unlawful but you oppose erasure, or when we no longer need the Personal Data for the purpose of our processing but you require the Personal Data to establish, exercise, or defend a legal claim, and you have objected to the processing pending the verification of that objection. When processing has been restricted on this basis, we may continue to store your Personal Data.  We will process your Personal Data otherwise only with your consent to establish, exercise, or defend a legal claim, or to protect another natural or legal person’s rights, or for reasons of important public interest.
  • If applicable, the GDPR provides the right to object to our processing of your Personal Data on grounds relating to your situation, but only to the extent that the processing is necessary for a task carried out in the public interest or to exercise any official authority vested in UB Greensfelder, or for a legitimate interest pursued by UB Greensfelder or someone else. If you object, we shall stop processing the Personal Data unless we can demonstrate compelling legitimate grounds to process the information that override your interests, rights, and freedoms, or the purpose of the processing is to establish, exercise, or defend a legal claim.

You may object to our processing of your Personal Data for direct marketing purposes including profiling for direct marketing purposes.  If you notify us of such an objection, we will stop processing your Personal Data for direct marketing purposes.

You may object to our processing of your Personal Data for scientific or historical research or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for a task carried out in the public interest.

If the legal basis for our processing your Personal Data is consent or that the processing is necessary to perform a contract to which you are a party, or in order to take steps at your request before entering into a contract, and such processing is carried out by automatic means, you have the right to receive your Personal Data from us in a structured, commonly used, and machine-readable format. This right does not apply, however, when its application will affect the rights and freedoms of others adversely.

If you believe that our processing of your Personal Data infringes any data-protection statute, rule or regulation, you may lodge a complaint with the appropriate authorities responsible for data protection.  If applicable, you may lodge that complaint in the European Union member state of your habitual residence, your workplace, or the place of the alleged infringement.

To the extent that we base our processing of your Personal Data on your consent, you may withdraw that consent at any time, but your withdrawal of that consent will not affect the lawfulness of any processing we do before your withdrawal.

If you are an employee or former employee of, or an applicant for a job at UB Greensfelder or an affiliate of UB Greensfelder and you reside in the EU, please note that we have separate notices in line with applicable EU law, which inform you about the processing of your Personal Data and your rights.

If applicable, you may exercise any of your rights in relation to your Personal Data by emailing UB Greensfelder at privacy@ubglaw.com.

Safeguards

We use reasonable technical, administrative, and physical safeguards designed to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.  However, we can never promise 100% security. 

Accessing Your Personal Information Once Given

You and your authorized agent have the right to review, amend, or ask us to delete personal information that you have provided to UB Greensfelder by contacting UB Greensfelder at the e-mail address, physical address, or phone number set forth in this Privacy Policy.

Also, should you wish to restrict the types of promotional materials you receive from UB Greensfelder or opt out of receiving promotional materials altogether from UB Greensfelder, you may contact UB Greensfelder at the e-mail address, physical address, or phone number set forth in this Privacy Policy.

We will not discriminate against you or anyone else unlawfully for exercising any of these privacy rights, although deleting personal information and opting out of receiving certain promotional materials may prevent us from providing you content or invitations.

Retention of Personal Information

UB Greensfelder keeps data pursuant to its internal policies and procedures, for lengths of time that can vary based on a variety of factors.

Where We Maintain Personal Information

We maintain the data we collect, including personal information, within the United States.

Changes to This Policy

We may update this Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

Accountability and Compliance

You may address any question or complaints regarding how UB Greensfelder complies with this Privacy Policy to the e-mail address or phone number set forth in this Privacy Policy.

You may have the right to lodge a complaint with your local data protection authority about how we have processed your personal information, although we encourage you to contact us first using the e-mail address, physical address, or phone number set forth in this Privacy Policy so that we may try to address your concerns.

Contact Information

If you want to contact UB Greensfelder about anything related to this Privacy Policy, please:

  • Send an e-mail to privacy@ubglaw.com;
  • Send a letter to UB Greensfelder LLP, 1660 West 2nd Street, Suite 1100, Cleveland, Ohio 44113-1408, ATTN: Privacy Preferences; or
  • Call 216.583.7000.