Introduction
Brooks Kushman (“BK”) respects the privacy of its clients and others who provide us with their personal data. Brooks Kushman is transparent about the limited personal information it collects, why that information is collected, and how that information is managed and shared.
BROOKS KUSHMAN, PC
BK is a global law firm, providing intellectual property and technology related services to domestic and international clients. Information that we collect on our website, and elsewhere, from overseas, including personal information, may be transferred to the US to permit us to comply with our legal and contractual obligations, to provide information and services to prospective and current clients, and to perform related business activities. In addition, we may work with third-party service providers in the U.S. and in other countries to support our business activities. Thus, personal information may be transferred to, stored on servers in, and accessed from the United States and countries other than the country in which the information was initially collected. In all such instances, we use, transfer, and disclose personal information solely for the purposes described in this Privacy Policy.
This policy is intended to be consistent with (and supplement) our obligations under applicable laws and the EU General Data Protection Regulation (“GDPR”).
Communications regarding this policy should be directed to our Data Protection Officer (“DPO”):
Attention: BK Data Protection Officer
1000 Town Center, 22nd Floor
Southfield, Michigan 48075
DPO@brookskushman.com
WHAT PERSONAL DATA DO WE COLLECT?
“Personal Data” means any information from or about a person that either identifies that person directly or that makes that person identifiable when it is combined with other information from or about that person from any source. Personal Data stops being personal information when it has been aggregated, de-identified, or otherwise anonymized sufficiently that the individual is no longer identified or identifiable using reasonable efforts, resources, and technology.
Examples of personal data that Brooks Kushman collects are:
- contact information, including name, physical and mailing address, email address, phone number, fax number;
- professional information, including company or firm, job title or position, employment history, academic record, awards, and membership in professional organizations;
- financial data, such as bank account or credit card information, accounts receivable or payable balance information, income information;
- services information, including business information necessary for us to perform services requested by clients;
- marketing data, including information provided by you about your preferences for marketing material and updates on legal developments;
- user data and usage information collected by our website or provided by you when using our electronic services;
We do not collect personal data about you on our website at brookskushman.com – such as your name, address, phone number, etc. – unless you choose to fill out a form, found on many of the pages of the site or to email us directly.
We do automatically collect certain non-personal data when you visit our site – such as the type of browser you are using, the type of operating system you are using, and the domain name of your Internet service provider.
HOW DO WE USE YOUR PERSONAL DATA?
BK uses your personal data in a limited fashion, only to:
- establish and maintain contractual relationships with our clients
- evaluate prospective clients in accordance with our professional and legal obligations;
- manage our business relationships with our clients and service providers;
- analyze and improve the BK website and our marketing services and communications;
- evaluate and interview job applicants, service providers, or other third parties;
- comply with legal and regulatory obligations
- protect and manage our business, including analyzing and improving data security, acquiring insurance and managing liability, assessing compliance with our policies, and defending our legal rights
- fulfill our other legitimate interests to the extent that they are not overridden by individual interests, fundamental rights, or freedoms.
CONSENT TO COLLECTION AND USE OF YOUR PERSONAL DATA
When you provide your personal data on our website or otherwise, you consent to the collection, use, processing, transfer, and disclosure of your personal and non-personal data globally in accordance with this Privacy Policy.
When you provide us the personal data of other people, you must ensure that you are entitled to share that data with us and that we can collect, use, and disclose that personal information without taking further action in a way that is consistent with our privacy policy.
You may request a copy of the Personal Data we have collected about you, or withdraw your consent and request deletion of your Personal Data, by sending a request to the DPO at the contact information provided above.
WHERE IS YOUR INFORMATION SHARED?
Your information is only shared to the extent necessary to fulfill our business obligations, to accomplish one of the lawful purposes described in this Privacy Policy, or in response to your express instructions.
California Civil Code Section 1798.83 permits website users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not sell, transfer, or otherwise disclose Personal Data that we collect from or about you. BK does not use automated decision-making services using your personal data and does not otherwise share personal information with third-parties for their direct marketing purposes.
We may share Personal Data that has been aggregated, de-identified, or otherwise anonymized and thus does not directly or indirectly identify you and that cannot, with reasonable efforts, resources, and technologies, be used to re-identify you. Such aggregated, anonymized, de-identified, or otherwise not re-identifiable information is not Personal Data within the scope of this Privacy Policy.
ACCESS TO AND CONTROL OVER YOUR INFORMATION.
You may contact the BK DPO to request a copy of your information, to make updates or request restriction or deletion of your personal information.
BK retains data obtained during the course of client representations for a period of time that is consistent with our professional responsibilities and that is reasonably necessary for the purpose for which the data was collected and to protect and defend against legal claims. For other personal data, we retain the data until no longer reasonably necessary for the purpose for which is was collected or until consent to hold the data is revoked, and there is no other basis for use to hold the information consistent with legal obligations and professional responsibility
YOUR INFORMATION IS SECURE.
To protect your personal data, BK maintains reasonable administrative, technical and physical safeguards, including security system monitoring and encryption. Unfortunately, despite such measures, no data transmission over the Internet and no database or other depository of information can be one hundred percent secure. As a result, while we will strive to protect your Personal Data, we cannot and do not guarantee or warrant the security of any of your Personal Data. We will not be and are not liable for disclosures of your personal information due to errors in transmission, networks that we do not control, or unauthorized acts of third parties.
CHILDREN (UNDER 16 YEARS OF AGE).
BK does not knowingly collect personal data from children under 16 years of age. If a child has provided us with personal data, a parent or guardian of that child may contact our DPO to have this information deleted from our records.
WHAT NON-PERSONAL DATA DO WE COLLECT?
Cookies. To enhance the performance and functionality of our site, we may use session or persistent “cookies” that store a small text file on your computer and collect certain information about your visit to our site.
A “session” cookie is stored only in your computer’s working memory (RAM) and only lasts for your browsing session. When you close all your browser’s windows, or when you shut down your computer, the session cookie disappears forever.
A “persistent” cookie is stored on your computer’s hard drive until a specified date, which could be tomorrow, next week, or 10 years from now. Persistent cookies stay on your computer until either a) they expire, b) they are overwritten with newer cookies, or c) you manually remove them.
We use cookies for the following purposes:
- authentication – we use cookies to identify you when you visit our website and as you navigate our website;
- security – we use cookies as an element of the security measures used to protect our website and services;
- cookie consent – we use cookies to store your preferences in relation to the use of cookies.
Most browsers can be configured not to accept cookies and delete cookies. However, this will impact the usability of our site and may prevent you from having access to some site functions or features.
Aggregate Data. We may collect non-personal data on an individual and aggregate (or anonymous) basis that includes all site visitors. Non-Personal aggregate data collected on BK may be used to:
- Compile aggregate and statistical data to improve our website and the user experience
- Perform analytics on the user’s experience while visiting this site on an aggregate level that does not identify you or your information personally
We may use third-party click tracking analytics tools such as Google Analytics, to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at:
https://www.google.com/policies/privacy/.
Third-party vendors with which BK has entered into contracts to perform site analytics and which are provided aggregate information are to use that information only to perform those services, and they may not share or resell this information.
MODIFICATIONS TO THIS POLICY.
Occasionally we may update the BK Privacy Policy in order to reflect any changes to our website or privacy practices, or to comply with new laws and regulations. BK may modify, add or remove portions of this Privacy Policy at any time. Where such changes are material in nature, BK will provide additional notice via email or notification on its website.
This Privacy Policy is effective November 8, 2018.
