PRIVACY POLICY

 

Talis Partners, LLP (“Talis”, “we”, “us,” or “our”) is committed to protecting the privacy and integrity of your information. This Privacy Policy describes how we collect, use, and share personal information through our website, blogs, newsletters, and other publications, as well as communications and events (collectively, the “Services”). This Privacy Policy does not apply to, and we are not responsible for the privacy practices of, any third-party websites to which any of the Services may reference or link.

 

PERSONAL INFORMATION WE COLLECT

 

We may collect personal information directly from you, as well as automatically or from third parties. Our primary goal in collecting personal information is to provide and improve the Services.

 

1. Information You Provide to Us

 

Clients. If you are a client, we collect your name, contact information, payment information and any other information you provide to us. The type of information we collect from clients varies depending on the client matter and may include information about our clients’ businesses, finances, operations, owners, employees, customers, partners, and any other information that may be relevant for the matter.

 

Subscriptions. When you subscribe to receive newsletters or other publications, we collect your name, email address, and other contact details. We may also collect information about your interests and preferences.

 

Events. We may collect personal information about you if you choose to register for an event we sponsor. This personal information may include your name, contact information, professional details, and other information relevant to the particular event.

 

Business Partners. We may receive contact details and payment information from business partners and their employees or agents in furtherance of the relevant partner relationship.

 

Communications. We collect personal information from you such as your name, contact information, and the content, date and time of your message, as well as our reply and any follow up action we take in relation to such communications.

 

Social Media Content. We may offer forums, blogs, or links to social media pages. Any content you provide on these channels will be considered public, and we may use this information to tailor our communications with you.

 

2. Information Collected Automatically or from Third Parties

 

Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your device IP address, unique device ID, hardware and software type, Internet service provider, serving domain, geographical area, location data, browser type and settings data, operating system, referring URLs, search history, information on actions taken or interaction with our digital assets, dates and times of actions, and other information about how you use the Services, such as the types of content you interact with and the frequency and duration of your activities.

 

Cookies, Pixel Tags/Web Beacons, and Analytics Information. We, as well as third parties that provide analytics services to us, may use cookies, pixel tags, local storage, and other technologies (“Web Technologies”) to automatically collect information through the Services. Web Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

 

  • Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly. Most web browsers allow you to manage cookies through the browser settings. Be aware that, if you opt out from and do not agree to certain cookies, your experience on our Services may be diminished and some features may not work as intended depending on the cookie. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org.

  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel tag allows us to track certain information (e.g., that a user has visited a particular web page or clicked on a particular link).

  • Analytics. We may also use Google Analytics and other service providers to collect information regarding visit, or behavior and visitor demographics on our Services. For more information about Google Analytics, visit https://policies.google.com/technologies/partner-sites. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

 

Information from Other Sources. We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application or site, such as a website or social networking service, we may collect information about you from that third-party website or service that you have made public via your privacy settings. We may also obtain information about you through publicly available sources (such as government databases or publicly accessible websites), private marketing or business agencies (such as industry or marketing reports), or persons that you authorize to communicate with us (such as your representatives, partners, or opposing parties). Such information may include details relevant to the Services or a client matter.

 

HOW WE USE YOUR INFORMATION

 

1. General Use of Your Personal Information

 

We use your personal information for a variety of business purposes, including to:

 

  • communicate with you and respond to your inquiries;

  • provide services to you, including advising or representing you, managing your information, and allowing you to access publications or register for/attend events;

  • analyze and improve our Services, including measuring interest in our Services, researching and developing the Services, developing new content and Services, and debugging to identify and repair errors;

  • conduct marketing activities, including send newsletters and other communications.

  • manage our business relationships with customers, clients, vendors, business partners, cooperating law firms and other contractors;

  • detect, prevent, and respond to security incidents, including actual or potential fraud and malicious, deceptive, fraudulent, or illegal activity; and

  • perform other business purposes, including data analyses, defending our legal rights, and complying with our legal obligations and internal policies.

 

2. Legal Grounds for Using Personal Information

 

Where European Union data protection laws apply, such as the General Data Protection Regulation, we only process your personal information when we can rely on a valid legal ground such as:

 

  • where we need to perform a contract we are about to enter into or have entered into with you;

  • where it is necessary for our legitimate interests (or those of a third party), including to conduct business analytics, marketing, or to improve the safety, security, and performance of our Services;

  • where we need to comply with a legal or regulatory obligation; or

  • where you have given your consent.

 

3. Use of De-identified and Aggregated Information

 

We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

 

4. Automatic Collection Technologies

 

We, as well as third parties that provide content, advertising, or other functionality on the Services, may use Web Technologies to automatically collect information through the Services. Our uses of these Web Technologies fall into the following general categories:

 

  • Required. This includes Web Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security, or that allow you to make use of our functionality.

  • Functional. We may use Web Technologies to assess the performance and offer you enhanced functionality of our Services, including as part of our analytic practices to help us understand how our visitors use the Services or identify you when you access or sign into our Services.

  • Advertising. We may use first party or third-party Web Technologies to deliver content, including advertisements for us on third-party sites.

 

5. Notice regarding Third-Party Websites and Social Media Platforms

 

The Services may contain links to other websites, and other websites may reference or link to our website or the Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

 

Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. As such information will be public, the personal information provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Facebook, LinkedIn, Instagram and Twitter (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.

 

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

 

Except as provided below, we do not disclose or sell your personal information.

 

1. Service Providers

 

We may share any personal information we collect about you with our third-party service providers. The categories of service providers (processors) to whom we entrust personal information include IT and related services, Wix.com (the platform on which we host our website), payment processors, customer service providers, and vendors to support the provision of the Services and client matters.

 

2. Business Partners

 

We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.

 

3. Affiliates

 

We may share personal information with our affiliated companies.

 

4. Disclosures to Protect Us or Others

 

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

 

5. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

 

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law or contract.

 

6. International Data Transfers

 

Information processed by us may be transferred, processed, and stored anywhere in the world, including the United States or other countries, which may have data protection laws that are different from the laws where you live. Where required by applicable law, we will ensure that appropriate safeguards are in place to protect your personal information. If we engage a third party to process personal information on our behalf, we will also contractually require them to handle your personal information appropriately. Further details can be provided upon request.

 

YOUR RIGHTS AND CHOICES

 

1. General

 

You have certain rights and choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.

 

2. Marketing

 

We allow you to opt out of marketing communications at any time by following the opt-out instructions contained in such communications. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our terms or this Privacy Policy). We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.

 

3. “Do Not Track”

 

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

 

4. Cookies and Interest-Based Advertising

 

You may stop or restrict the placement of Web Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.aboutads.info/choices/, https://youradchoices.ca/choices/, www.networkadvertising.org/managing/opt_out.asp, and http://www.youronlinechoices.eu/. Alternatively, for some devices you may use your device's platform controls in your settings to exercise choice. Please note you must separately opt out in each browser and on each device.

 

5. European Privacy Rights

 

If you are located in the European Economic Area, you may have the following rights to the extent provided by law:

 

  • Request access to and receive information about the personal information we maintain about you, update and correct inaccuracies in your personal information, restrict or object to the processing of your personal information, have the information deleted, or exercise your right to data portability to easily transfer your personal information to another company.

  • Lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

  • Withdraw any consent you previously provided to us regarding the processing of your personal information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

 

6. California Privacy Rights

 

If you are a Consumer receiving products or services for which we are a Business, as those terms and any other capitalized terms in this section are defined under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (the “CCPA”), California law may permit you to request information regarding the:

  • categories of Personal Information (as defined by applicable California law) Collected, Sold or Disclosed by us;

  • purposes for which categories of Personal Information Collected by us are used;

  • sources of information from which we Collect Personal Information; and

  • specific pieces of Personal Information we have Collected about you.

 

In addition, if you are a Consumer you may:

  • opt-out of the Sale or Disclosure of your Personal Information, in some circumstances;

  • opt-out of receiving marketing communications from us; however, you may still receive administrative communications regarding the Services; and

  • request deletion of your Personal Information by us and our Service Providers, in some circumstances.

 

The CCPA also provides Consumers with the right not to receive discriminatory treatment by a Business for the exercise of these rights regarding Personal Information.

 

DATA RETENTION

 

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

 

SECURITY OF YOUR INFORMATION

 

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

 

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail, or by sending an e-mail to you.

 

CHILDREN’S INFORMATION

 

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information.

 

SUPERVISORY AUTHORITY

 

If you are located in the European Economic Area or the UK and required by applicable law, you may have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

 

CHANGES TO OUR PRIVACY POLICY

 

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

 

CONTACT US

 

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

 

Talis Partners, LLP

Attn: Privacy Questions

416 Portofino Drive

San Carlos, CA 94070

info@talispartners.com

 

Updated July 7, 2020

Talis Partners, LLP

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