III. Types of Data
We Collect Personal Data We collect information (whether online, by phone, or by paper) that enables the RLF to identify or contact you (“Personal Data”) to carry out its business purposes. RLF Sites collect this information for a variety of business reasons, including but not limited to, engaging with you in relation our representation of you or of providing services offered by the RLF, or otherwise interacting with the RLF.
The types of Personal Data we collect include, but are not limited to:
• General data (e.g., names, dates of birth, home and business addresses, email addresses, Internet protocol addresses and mobile/landline business/personal telephone numbers that are provided by our clients)
• Government-issued identification numbers (e.g., social security numbers, and tax identification numbers, and the like) • Other information (e.g., photographs, documents, and the like related to a representation)
• Financial information (e.g., credit and debit card numbers, credit reports, passwords and PIN numbers), as needed for a representation
• Sensitive Personal Data (e.g., racial or ethnic origin, sexual orientation and disability data), as needed for a representation The RLF may also receive Personal Data from third parties for the RLF’s use in marketing or for other purposes.
We may collect information (whether online, by phone, or by paper) that does not directly identify you as you interact with our Sites (“Non-Personal Data”). The types of Non-Personal Data we may collect includes, but is not limited to:
• Site usage (e.g., browsing history, search terms, number of clicks, referring/exit pages, date/time stamp, time on Site)
• Products and services viewed
• Computer type, operating system and platform type
• Internet service provider
IV. How We Use Your Data
In addition to the uses described above, we use your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the following, in order to:
• Identify you when you visit our Sites
• Provide service communications such as bill reminders • Provide products, information and services you request or that we think you may be interested in
• Respond to your emails or online requests for products, services, or information
• Personalize and improve the usability of the Sites
• Fulfill and/or deliver RLF products and services
We use Non-Personal Data to improve the usability of our Sites and for other business reasons. We or other third-party companies may also use the Non-Personal Data to provide advertisements and targeted advertisements to you (ads based on the Non-Personal Data). We do not provide Personal Data to third parties with whom we share your Non-Personal Data. Please note that, when you select an advertising link or other link that takes you to sites not operated by the RLF, you may be subject to the privacy policies of these third-party sites.
V. How We Share Your Data
We share your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to:
• Share data with third parties to fulfill service requests and to perform business functions (e.g., the RLF contracts with third parties to provide services on our behalf such as data hosting services).
• Share data with third parties as required by law or to protect the RLF in the good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on the RLF; (b) protect and defend the RLF’s rights or property; or (c) protect the personal safety of RLF personnel or members of the public in appropriate circumstances.
• Share data with third parties if the RLF and/or its assets (or a portion of its assets) are sold, assigned, transferred, or merged, or if the RLF undergoes some other change including a change to its corporate form as part of a bankruptcy proceeding or otherwise; information may be transferred as part of that transaction or change.
• Share data with social media sites such as Facebook, LinkedIn, Twitter and others who may contact you with “targeted ads” relating to legal and other services.
• Share data with third parties in other situations, with your consent.
• Share your email address, but only as permitted by the RLF Email Policy, as follows:
Your email address will be used only by the RLF for business purposes. RLF does not sell or rent email addresses to anyone outside the RLF, nor does the RLF share email addresses with unrelated third-parties.
VI. How You Can Manage the Processing of Your Data
You can manage your email preferences, including “opting out” of email by contacting us using the information in the “Contact Information” section below. If you prefer to receive hard copy mailings only from the RLF, you can contact us and request to have your name and address removed from the list we provide to third parties. For California residents, please consult the “California Privacy Rights” section for additional considerations.
Our processing of your data is based upon your consent, contract performance, legitimate business interest (e.g., direct marketing of goods and services), or compliance with law. You have the right to object to our processing of your data or to restrict our processing of your data. In addition, if you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time.
VII. California Privacy Rights
VIII. Canada Anti-Spam Law
The RLF complies with the Canada Anti-Spam Law. Clients who provide us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as defined under the Canada Anti-Spam Law) unless these individuals have “opted-in” to receive Commercial Electronic Messages.
We do not knowingly collect Personal Data from or market to children under the age of 13.
X. How We Protect Personal Data
XI. Linking to Other Internet Sites
XII. How You Can Access, Change and Delete Your Personal Data
XIII. Cookies and Other Web Devices
XIV. Transmission of Data to Other Countries
Your Personal Data is processed in the United States, where privacy laws may be less stringent than the laws in your country and where the government, courts, or law enforcement may be able to access your data. By submitting your Personal Data to us, you agree to the transfer, storage and processing of your Personal Data in the United States.
XV. Right to Complain to Supervisory Authority
You, as the data subject, have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of your personal data does not comply with legal requirements.
XVI. Breach Notification
In the event we determine the occurrence of a data security incident, we will notify you by email, US mail, telephone, or other means as permitted by law
XVII. Contact Information
If you have questions, comments, or complaints concerning our privacy practices or if you wish to change, access, or remove your Personal Data, please contact us as indicated below. We will attempt, where practical, to respond to your requests and to provide you with additional privacy related information.
Effective Date: September 22, 2022