Last Modified February 26, 2021
For the purposes of this Policy, “personal information” is data which identifies, describes, is associated with, or could be linked to an individual, such as a name, birth date, postal address, email address, telephone number, driver’s license, SSN, or government issued identification number, credit card number or the like.
Personal information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data. Also, some of our clients are businesses, companies, institutions, or other entities rather than individuals. We do not consider business information such as an individual’s title, employer, work email, work phone number or work address to be personal information.
What Information Do We Collect?
Information Collected Directly from You
We may collect personal information directly from you through the System or our attorneys and staff. For example, you may voluntarily provide us with personal information when you interact with us as a current, prospective, or former client, sign up for a newsletter or mailing list, register an account, send us an email, fill out a form, register for an event, apply for a job, or interact with us on social media.
Information we collect may include:
- Email address, phone number, mailing address, and other contact information;
- Username and password;
- Employment application information, including education and employment history;
- Payment information;
- Business affiliations and contact information;
- Social media username;
- Demographic information;
- Preferences and interests; and
- Other information related to your requests or inquiries.
Information Collected Automatically
- Your Internet Protocol address (“IP address”) to measure our website traffic and to help provide a more personalized experience;
- Information regarding your browser, internet service provider, operating system, and other technical specifications;
- Mobile device information when you access our System, including hardware model, operating system and version, unique device identifiers, and network information;
- Your transaction history relating to the use of our Services; and
- Information about your navigation to, from, and on our Site, including computer data files such as “cookies,” “clear GIFs” and “web beacons.” For more information, see the “Cookies and Similar Technologies” section below.
Collecting Information from Children Under the Age of 16
Our Site and System are not designed for children, and we do not knowingly collect information from any person under the age of 16.
How Do We Use Your Information?
We use your personal information for our legitimate business interests, including but not limited to:
- Providing our Services to you and responding to your inquiries.
- Maintaining and improving the operation, content and functionality of our System.
- Informing you of services, information or opportunities that may interest you.
- Personalizing content based on your location and preferences.
- Assessing job applicants and making employment decisions.
How Do We Protect Your Information?
We maintain reasonable and appropriate administrative, physical, and technical safeguards for all user information collected in our System. Unfortunately, no transmission or data storage measure can be assured to be completely secure. While we strive to protect your personal information, by your continued use of our System you acknowledge and accept that the security, privacy, and integrity of your data cannot always be guaranteed.
With Whom Do We Share Your Information?
We share your personal information between our offices for purposes of administration, billing, promotion of our events and Services, and to provide you with our Services.
We may share your Personal Information with affiliates and third parties who may help us operate the Site, assist us in providing you with our Services, or help us assess your interest or satisfaction with the Site or our Services. Examples of these third-party services include web hosting, credit card verification, data tracking, marketing initiatives, employment recruiting, document production, delivery services, and maintaining and improving the System or our Services. In providing our Services, we may disclose personal information to other parties involved in legal matters, including other law firms, attorneys, courts and regulatory bodies.
We may share aggregated and anonymized forms of your information and browsing preferences to evaluate our products or allow the third parties we work with to better serve our users.
As Required by Law
We may share your personal information in response to investigations, subpoenas, court orders, law enforcement requests or legal processes, to establish or exercise our legal rights or defend against legal claims, or as otherwise required by law.
As Part of a Business Sale, Merger or Acquisition
We may also disclose your information to a third party as part of reorganization, sale, or a prospective sale of substantially all of the assets or equity interest of Rinke Noonan, Ltd., its subsidiaries or divisions. Any third party to which Rinke Noonan, Ltd. transfers or sells the System or related assets or equity interest will have the right to continue to use the personal and other information that you provide to us.
Where Do We Store and Process your Personal Information?
Cookies and Similar Technologies
Cookies are small data files that enable the System to remember user preferences and settings, as well as track and analyze user behavior to improve our System. You can find the following types of cookies employed on our System.
Essential Cookies make it possible for the System to function and we cannot switch them off. They are typically set in response to some action on your part, like providing us with your email or other information online. You can set your browser to block or alert you about these cookies, but some parts of the System may not work.
Analytics Cookies allow us to count visits and traffic sources, so we can measure and improve our System. They show us which pages are popular and how visitors navigate on them. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our System.
Functional Cookies make it possible for us to enhance the functionality of our system and personalize it. We may set them or have third-party service providers set them. If you do not allow these cookies then some or all of these services may not function properly.
Targeting Cookies record your visits to our System, the pages you have visited and the links you have followed. They are persistent cookies, meaning they remain on your device after your session is over. They will recognize you as a previous visitor and to track your activity on the Sites and other websites you visit. You can delete these cookies via your browser settings. See “Your Cookie Options” section below for how you can control these cookies.
Your Cookie Options
Most browsers allow you to control and/or delete cookies as you wish – for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. Some browsers will allow you to block all cookies, while others will allow you to set up rules about which cookies to accept from which site, depending on your preferences. If you do block cookies, however, you may experience some functionality issues and some services within the system may not work for you.
Clear GIFs (also called pixel tags or web beacons) are small files embedded in websites that are often used in combination with cookies. These often-transparent images allow us to count users who have visited certain pages, to generate statistics about System use, and to make the System more intuitive and user friendly. They are not used to access personal information.
Third-Party Websites and Social Networking Sites
You may be able to post content to third-party Social Networking Sites (such as Facebook, LinkedIn, Twitter, Instagram) on which we maintain a presence. We are not responsible for the availability, accuracy, content, products or services of Social Networking Sites. We will provide information to the Social Networking Site(s), and receive information from them, in accordance with your elections.
We may also use third-party vendors, such as Google Analytics, to advertise to our users online. These third-party vendors may display Rinke Noonan, Ltd. advertisements on other websites based on your internet usage. More specifically, these vendors use first-party cookies (such as the Google Analytic cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to the Site or another site affiliated with Rinke Noonan, Ltd. products or services. You can opt-out of Google Analytics for Display Advertising by using Google’s Ads Settings.
We retain data collected from you only for as long as necessary to complete the purpose for which it was collected, or as required by law.
Your Access and Consent to Use of Your Information
You control access to and use of your personal information. Please contact us at firstname.lastname@example.org, with “Privacy Rights” in the subject line, for the following:
- To request the review, correction, change or deletion of your personal information.
- To withdraw your consent for us to collect, use, or disclose your personal information as described in this Policy. Please specify the activity you wish to stop. Denying or withdrawing consent may not allow us to provide you with some or all of the products, services, or information you request.
- To opt-out of our marketing communications. You can also opt-out by clicking the “unsubscribe” link at the bottom of any email.
- To stop receiving promotional text messages from us. You can also opt-out by following the cancellation instructions contained in the last text message.
If you opt-out from receiving marketing emails or text messages, we may still need to send you communications about our Services, your account, orders, customer service inquiries, and other matters.
- As explained in the “Cookie and Similar Technologies” section, you may limit the collection of cookies through your browser settings, but it may affect your ability to use or navigate the System.
- You may limit the ability of Google Analytics to track your online activity, as outlined in the “Behavioral Advertising” section.
- Your browser may have a “Do Not Track” option, but our System operates no differently if these “Do Not Track” signals are enabled.
Your California Privacy Rights
If you are a California resident, you have certain rights under California Consumer Privacy Act and other data protection laws, including:
- The right to know the sources of your personal information we have collected in the last twelve months, what we use that information for, whether it is being disclosed or sold, and to whom it is being disclosed or sold.
- The right to “opt-out” of Rinke Noonan, Ltd.’s sale of your personal information to any third parties.
- The right, with some exceptions, to have your personal information deleted from Rinke Noonan, Ltd.’s possession or control.
- The right to receive equal service and pricing from Rinke Noonan, Ltd. even if you exercise any of your privacy rights.
You may submit requests for access or erasure of your personal information by emailing email@example.com or by calling toll-free (within the U.S. only) 1.888.899.6700 (and asking for the Marketing Manager).
If you submit a request for access or erasure of personal information, you will be required to verify your identity by answering certain questions. We will not disclose or delete any information until your identity is verified.
If you are making a request for erasure, we will ask you to confirm again that you want us to delete your personal information before processing your deletion request.
If you are making a request for access, we may not be able to provide specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your personal information, your account with us, our network or the System.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.
Agents making requests on behalf of California residents must verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.
Our response to a request is at no cost to you. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
Under the California “Shine the Light” law, California residents may request information about our disclosures of certain categories of personal data to third parties (i.e., our affiliates) for such third parties’ direct marketing purpose, by emailing firstname.lastname@example.org or writing to: Rinke Noonan, Ltd. (California Privacy Rights), Attn: Marketing Manager, P.O. Box 1497, St. Cloud, MN 56302-1497.
If you are under 18 years old, a California resident, and a registered user of any Site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to email@example.com. Your request does not ensure complete or comprehensive removal of what you have posted and the law may not require or allow removal even if requested.
European Privacy Rights
If you are an EU resident, you are afforded certain rights regarding your personal information, including:
- The right to be informed about what happens with your Personal Data (information relating to an identified or identifiable natural person), including how it is collected from you, how it is used as well as the right to access that Personal Data, to modify it when it is incomplete or incorrect, and the right to withdraw consent for its use;
- The right to access Personal Data held by organizations about an individual;
- The right to rectification allowing individuals to correct inaccurate information or complete incomplete information;
- The right to erasure (or the right to be forgotten) allowing, with some exceptions, an individual to have their Personal Data deleted upon request;
- The right to restriction and withdraw consent for data processing;
- The right to data portability allowing individuals to ask for the transfer of their Personal Data or to obtain and use their Personal Data for their own purposes;
- The right to object, with some exceptions, to the processing of an individual’s Personal Data;
- The right to prevent automated decision making or profiling and to require that those decisions be made by natural persons.
Rinke Noonan, Ltd. (European Privacy Rights)
Attn: Marketing Manager
P.O. Box 1497
St. Cloud, MN 56302-1497
Individuals may also have a right to lodge a complaint about the processing of their personal information with their local data protection authority.
Rinke Noonan, Ltd.
Attn: Marketing Manager
P.O. Box 1497
St. Cloud, MN 56302-1497