DarrowEverett LLP Privacy Policy

Last updated May 30, 2023

This privacy policy (“Privacy Policy”) describes how and why DarrowEverett LLP (“Company,” “we,” “us,” or “our“) might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you (i) visit our website at https://www.darroweverett.com (the “Website”) and/or (ii) engage with us in other related ways, including any sales, marketing, or events.

PLEASE REVIEW THIS PRIVACY POLICY AND THE TERMS & CONDITIONS FOR THE WEBSITE CAREFULLY. YOUR USE OF THIS WEBSITE SIGNIFIES YOUR AGREEMENT TO THIS Privacy Policy AND THE TERMS & Conditions.

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at corpnotice@darroweverett.com.

1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us or is collected automatically when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personally Identifiable Information (“PII”) you disclose to us.

The personally identifiable information (“PII”), which may specifically identify an individual or business, that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• mailing addresses
• debt, credit, banking and/or financial information
• job titles
• contact preferences
• contact or authentication data
• any other identifiers which you may be prompted to provide in connection with accessing or using the Website and/or Service

Non-Personally Identifying Information (“Non-PII”) automatically collected.

We automatically collect certain information when you visit, use, or navigate the Services. This non-personally identifying information (“Non-PII”) does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. DO WE USE COOKIES OR OTHER TRACKING TECHNOLOGIES?

Like many businesses, we also collect information through cookies and similar technologies. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

“Cookies” (or browser cookies), which are small files placed on the hard drive of your computer by the Website and/or Services to deliver content specific to your interest, save passwords, and for other purposes. Most web browsers maintain a “help” section on the toolbar that provides more information about cookies. Please refer to this “help” section for information on how to receive notifications when you are receiving a new cookie and how to turn cookies off. Acceptance of cookies is not a requirement to browse the Website; however certain areas and features of the Website and/or Services may require cookies to function properly.

Visitors may opt out of Google’s use of cookies by visiting the Ads Preferences Manager. Visitors may opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

“Web beacons” (or clear gifs, pixel tags or web bugs), which are tiny graphics with a unique identifier, similar in function to cookies, are placed in the code of a webpage. Web beacons monitor the traffic patterns of users from one page within our sites to another, deliver or communicate with cookies, understand whether you have come to the Website from an online advertisement displayed on a third-party website, and improve Website and/or Services performance.

Some content, including advertisements, on the Website and/or Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

3. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the Services, including but not limited to, answering inquires as to the availability of an attorney or attorneys with regard to legal services, providing access to educational and/or informational newsletters, articles, or publications, receiving client payments or deposits, and/or holding client funds in escrow.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our services, changes to our terms and policies, and other similar information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see section WHAT ARE YOUR PRIVACY RIGHTS? below.
• To send you education and information communications. We may process your personal information to send you educational and/or informational newsletters, articles, or publications that provide insight, updates and/or general information about current industry events.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To comply with our legal obligations and rights. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
• To fulfill other purposes. We may process your information to fulfill any other purpose as otherwise described to you at the point of collection.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with are as follows:

• Ad Networks
• Communication & Collaboration Tools
• Sales & Marketing Tools
• Social Networks
• Retargeting Platforms
• Merchant and Payment Processors (i.e., credit/debit card, ACH and other payment processing service providers)

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link. We obtain and store on your device (“cache”) your location. You may revoke your consent anytime by contacting us as described in section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below.
• Google Analytics. We will not (and will not allow any third party to) use statistical analytics tool to track or to collect your PII. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a user. We will not associate any data gathered from this site with any PII from any source, unless you explicitly submit that information via a fill-in form on the Website.

Information to opt out of Google Analytics by visiting the Google Analytics Opt-out Browser Add-on webpage.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Legal Obligations. We may disclose information you provide, including your PII, if required to do so by law or if we believe, in our sole discretion, that disclosure is reasonably necessary to: (a) comply with federal, state, or local law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law); (b) protect or defend us or a third party’s rights or property; (c) protect someone’s health or safety, such as when harm or violence against any person (including you) is threatened; and/or (d) prevent fraud.
• Aggregate Information. We may share aggregate information that does not include PII, and we may otherwise disclose Non-PII with third parties for industry analysis, demographic profiling and other purposes. Any aggregate information shared in these contexts will not contain your PII or NPI.

5. THIRD PARTY WEBSITES

The Website and/or Services may contain links to third party owned and/or operated websites. We are not responsible for the privacy practices or the content of such websites. We suggest that you contact these third parties directly for information regarding their privacy, security and data collection and distribution policies prior to providing them with any information.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website and/or Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website and/or Services.

All PII and NPI that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

8. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 13 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 13 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 13, please contact us at corpnotice@darroweverett.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

If you do not want us to share your information with nonaffiliated or non-agent third parties for promotional purposes, by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE? below.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

10. YOUR STATE PRIVACY RIGHTS

Residents of certain states, such as California, Colorado, Nevada, Utah, and Virginia, may have additional rights and choices regarding their personal information that we have collected, including the right to:

• Request to know what information we collect, use, disclose or sell (including to third parties for direct marketing purposes);
• Request we delete some or all of their personal information;
• Request access to their personal information;
• Correct inaccuracies in their personal information;
• Direct us not to sell or share their personal information, or use certain sensitive information; and
• Opt-out of the use, sale, disclosure, or sharing of their personal information.

If you have questions or comments about your privacy rights, or would like to exercise any rights you may have, including any rights to opt-out, please contact us as provided in section HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? below.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Under applicable law, you or someone legally authorized to act on your behalf (your “authorized agent”), may make a request to access, correct or delete your PII. You may, under applicable law, also make a request to know or delete PII on behalf of your child. Requests or exercise of your right(s) can be made by:

• emailing us at corpnotice@darroweverett.com
• calling us at (401) 453-1200
• sending us a written request by mail to:

DarrowEverett LLP
Attn: Legal
One Turks Head Place, Suite 1200
Providence, RI 02903

A request or exercise of your right(s) must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent, and should include: (i) the state of which you are a resident; (ii) a description of your request/exercise of your right, with sufficient detail that allows us to properly understand, evaluate, and respond; and (iii) identifying personal information.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm your information.

We will only use your information provided in the request to verify the requestor’s identity or authority to make said request. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We will only use your information provided in the request to verify the requestor’s identity or authority to make said request. Please note that we cannot delete your personal information except by also deleting your Account, if any. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

13. APPLICABLE LAW

We control and operate the Website and provide the Services from the United States. The Website is not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. We do not represent or warrant that the Website or Services is appropriate for use in any particular jurisdiction. Those who choose to access the Website and/or Services do so at their own initiative and are responsible for complying with all applicable international, federal, state, and local laws, rules, and regulations.

14. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “last updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you contact us at:

DarrowEverett LLP
One Turks Head Place, Suite 1200
Providence, RI 02903
(401) 453-1200
corpnotice@darroweverett.com