flexible technology-focused legal counsel
Last updated and effective date:
September 1, 2024
United States Regional Privacy Notice
Questions About Our Policies?
This United States Regional Privacy Notice (this “U.S. Privacy Notice”) is for individuals residing in the United States and supplements our Privacy Policy, available at: https://www.rightarrowlegal.com/privacy-policy. This U.S. Privacy Notice explains how Right Arrow Legal, LLC and its subsidiaries and affiliated companies (“Right Arrow Legal,” “we,” “our,” or “us”) collect, use, and disclose your personal information. It also makes disclosures required, and describes rights that you may have, under the California Consumer Privacy Act (the “CCPA”), and other U.S. state laws applicable to individuals in their jurisdiction (collectively, “U.S. Privacy Laws”). We strongly encourage you to read this U.S. Privacy Notice in its entirety. This U.S. Privacy Notice supplements our Privacy Policy. In the event of any inconsistency between this U.S. Privacy Notice and our Privacy Policy, this U.S. Privacy Notice shall govern, as to our processing of personal information of data subjects located in the United States. Capitalized terms used, but not otherwise defined herein, shall have the meanings given to them in our Privacy Policy.
For purposes of this U.S. Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household in the states subject to U.S. Privacy Laws. This U.S. Privacy Notice does not apply to publicly available information lawfully made available by state or federal government records, de-identified information, aggregate consumer information, or other personal information that is exempt under applicable U.S. Privacy Laws. U.S. Privacy Laws may not apply in some jurisdictions to personal information of individuals acting in a commercial or employment context, such as a job applicant.
While our collection, use, and disclosure of personal information varies based upon our relationship and interactions with you, this U.S. Privacy Notice describes, generally, the categories of personal information we collected and disclosed about California residents in the prior 12 months (from the Last updated and effective date above), and the rights California residents have under the CCPA regarding this personal information.
Updates
to this U.S. Privacy Notice
We may update this U.S. Privacy Notice from time to time. Any updated U.S. Privacy Notice will be effective when posted. If we decide to update this U.S. Privacy Notice, we will post the updated U.S. Privacy Notice on our website and update the “Last updated and effective date.” Please check back regularly to review any changes to this U.S. Privacy Notice.
Categories of personal information that we collect, use, and disclose
The table below identifies the categories of personal information (as defined in the CCPA) that we have collected or used about California consumers in the 12 months prior to the ‘Last updated and effective date’ of this U.S. Privacy Notice, and how we have disclosed such information for a business purpose (subject to our applicable legal and ethical obligations).
Personal Information collected or used
Category:
Identifiers
Description:
Direct identifiers, such as name, alias, physical address, email address, user ID, IP address and other online identifiers, or other similar identifiers
Disclosed for business purposes
( Yes/No )?
Yes
If Yes, Categories of Third Parties:
- Affiliates and subsidiaries
Service providers
Consultants
Judicial and quasi-judicial bodies
Regulatory and government entities
Recipients for legal, security, and safety purposes
Personal Information collected or used
Category:
Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e))
Description:
A name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
Disclosed for business purposes
( Yes/No )?
Yes
If Yes, Categories of Third Parties:
- Affiliates and subsidiaries
Service providers
Consultants
Judicial and quasi-judicial bodies
Regulatory and government entities
Recipients for legal, security, and safety purposes
Personal Information collected or used
Category:
Protected classification characteristics under California or Federal law
Description:
Age, ethnicity, citizenship, religion or creed, marital status, physical illness, mental illness or disability, gender, or veteran status
Disclosed for business purposes
( Yes/No )?
Yes
If Yes, Categories of Third Parties:
- Affiliates and subsidiaries
Service providers
Consultants
Judicial and quasi-judicial bodies
Regulatory and government entities
Recipients for legal, security, and safety purposes
Personal Information collected or used
Category:
Customer records
Description:
Name, account name, billing and payment information, signatures, government identifiers, or other information that individuals provide to us in order to use our business products and services
Disclosed for business purposes
( Yes/No )?
Yes
If Yes, Categories of Third Parties:
- Affiliates and subsidiaries
Service providers
Consultants
Judicial and quasi-judicial bodies
Regulatory and government entities
Recipients for legal, security, and safety purposes
Personal Information collected or used
Category:
Commercial information
Description:
Records of purchases and use of our business products and services
Disclosed for business purposes
( Yes/No )?
Yes
If Yes, Categories of Third Parties:
- Affiliates and subsidiaries
Service providers
Judicial and quasi-judicial bodies
Regulatory and government entities
Personal Information collected or used
Category:
Internet and other Electronic Usage data
Description:
Internet or other electronic network activity information, including browsing history, search history, access logs and usage data, or other information regarding a person’s interaction with our business products and services
Disclosed for business purposes
( Yes/No )?
Yes
If Yes, Categories of Third Parties:
- Affiliates and subsidiaries
Service providers
Judicial and quasi-judicial bodies
Regulatory and government entities
Personal Information collected or used
Category:
Geolocation data
Description:
Location information from your device, such as IP address
Disclosed for business purposes
( Yes/No )?
Yes
If Yes, Categories of Third Parties:
- Service providers
Judicial and quasi-judicial bodies
Regulatory and government entities
Affiliates and subsidiaries
Personal Information collected or used
Category:
Audio, visual, and electronic data
Description:
Audio, electronic, visual, thermal, olfactory, or similar information, such as thermal screenings and CCTV footage (e.g., collected from visitors to our offices for health and safety purposes), photographs and images (e.g., that you provide us) and records of calls, webinars, and video conferences (e.g., when you participate in one of our webinars)
Disclosed for business purposes
( Yes/No )?
Yes
If Yes, Categories of Third Parties:
- Service providers
Judicial and quasi-judicial bodies
Regulatory and government entities
Affiliates and subsidiaries
Personal Information collected or used
Category:
Professional information
Description:
Professional and employment-related information such as your title, employer’s name, the nature of your responsibilities and your practice area, specialties, qualifications, and areas of focus
Disclosed for business purposes
( Yes/No )?
Yes
If Yes, Categories of Third Parties:
- Service providers
Judicial and quasi-judicial bodies
Regulatory and government entities
Affiliates and subsidiaries
Personal Information collected or used
Category:
Education information
Description:
Information that is not available publicly and personally-identifiable information, as defined in the Federal Education Rights and Privacy Act
Disclosed for business purposes
( Yes/No )?
Yes
If Yes, Categories of Third Parties:
- Service providers
Judicial and quasi-judicial bodies
Regulatory and government entities
Affiliates and subsidiaries
Personal Information collected or used
Category:
Inferences
Description:
Includes inferences drawn from any of the information identified above to create a profile about you, such as reflecting your preferences and other characteristics
Disclosed for business purposes
( Yes/No )?
Yes
If Yes, Categories of Third Parties:
- Service providers
Affiliates and subsidiaries
In addition to the above, we may disclose the personal information that we collect to others, as necessary to comply with applicable law and/or for our legal and ethical obligations. We do not knowingly share personal information, including sensitive personal information, of minors under 16 years of age within the scope of the U.S. Privacy Laws.
Rights concerning personal information
Depending on where you live and subject to certain exceptions, you may have the following rights concerning collection, use, sharing, and deletion of your personal information:
Right to Know.
The right to request information about the categories of personal information we have collected about you, the categories of sources from which we collected the personal information, the purposes for collecting, selling, or sharing the personal information, and the categories of third parties with which we have shared, sold, or disclosed your personal information, as well as the specific pieces of your personal information we have collected, used, or shared.
Right to Delete.
The right to request that we delete your personal information.
Right to Opt Out of Sale or Sharing.
The right to request that we stop selling or sharing your personal information (“opt-out”). We do not sell your personal information.
Right to Non-Discrimination.
We will not discriminate against those California residents who choose to exercise their CCPA rights.
Right to Correct.
The right to request that we correct inaccurate personal information that we have about you.
Right to Limit.
The right to limit the use and disclosure of your sensitive personal information (e.g., your social security number, financial account information, or your genetic data).
You may exercise these rights by contacting us at privacy@rightarrowlegal.com.
Verification
In order to process rights requests, we may need to obtain information to locate you in our records or to verify your identity depending on the nature of the request. In most cases, we will collect some or all of the following data elements: first and last name, email address, and telephone number. In some cases, we may request different or additional information, including a signed declaration that you are who you say you are. We will inform you if we need such information.
Authorized Agents
Authorized agents may exercise rights on your behalf by submitting a request to privacy@rightarrowlegal.com. Any person acting as an authorized agent on behalf of another person must indicate so when submitting a request. We may require the authorized agent to demonstrate authority to act on your behalf by providing signed permission from you. We may also require you to verify your own identity directly with us or to confirm directly with us that you provided the authorized agent permission to submit the request.
Timing:
To the extent not prohibited by applicable U.S. Privacy Laws, we will respond to requests within 45 days unless we need more time, in which case we will notify you and may take up to 90 days total to respond to your request.
How to Contact Us
You may submit a request to exercise your rights described above by contacting us at privacy@rightarrowlegal.com.