California Privacy Statement
Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us at:
Fennemore
Attn: Chief Privacy Officer
2394 E Camelback Rd, Suite 600
Phoenix, AZ 85016
Email: privacyofficer@fennemorelaw.com
Phone: 1-833-522-0655
Introduction
This California Privacy Notice is for California Residents and supplements Fennemore Craig, P.C. and Fennemore LLP’s Privacy Policy. This statement describes how we collect, use, disclose, share, and retain personal information, and outlines your rights under the California Consumer Privacy Act (CCPA), the California “Shine the Light” law, and other California privacy laws. It also explains how California residents (“you” or “consumers”) can exercise those rights regarding their personal information.
What Is Personal Information
Personal information is information that identifies, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Personal information does not include publicly available information, such as information lawfully made available from government records, or de-identified or aggregated consumer information.
Certain personal information is exempt from the CCPA, including:
- Information covered by specific federal or state privacy laws (e.g., HIPAA, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act).
- Personal information collected in the course of your role as an employee, contractor, or job applicant with Fennemore.
Personal Information We Collect, Use, and Share
In general, in the past 12 months, we may have collected the following categories of personal information for business purposes:
- Identifiers: Name, postal address, email address, IP address, account name, and other similar identifiers.
- Personal Information (California Customer Records Statute): Name, address, phone number, credit card information, or other financial or health information.
- Characteristics of Protected Classification: Age (40 years or older), gender, marital status, physical or mental disability, sexual orientation, veteran or military status, genetic information.
- Commercial Information: Records of personal property, services or products purchased, obtained, or considered.
- Biometric Information: Fingerprints, faceprints, voiceprints, and other biological or physical data.
- Internet or Other Network Activity: Browsing history, search history, and interactions with our website, applications, or advertisements.
- Geolocation Data: Physical location or movements.
- Professional or Employment-Related Information: Current or past job history, performance evaluations.
- Non-Public Education Information: Grades, transcripts, student records.
- Inferences: Profiles reflecting preferences, behavior, and characteristics.
We collect this information from:
- You, as a consumer.
- Service providers, data analytics services, and lead generation services.
Purpose Of Collection
We do not sell or share your personal information, including your sensitive personal information. We use the personal information we collect for the following purposes:
- Account Services: To manage your account and provide services, products, or information you request and to communicate with you.
- Security and Fraud Detection: To detect and prevent fraud, malicious activities, or illegal activities.
- Marketing and Advertising: To send you promotional materials and marketing communications.
- Legal Obligations: To comply with legal obligations, to enforce our agreements and our terms of use.
- Product and Service Improvement: To maintain, service, and improve our services and offerings.
- Business Interests: For the administration and protection of our business and to fulfill business purposes such as auditing, transactions, and mergers.
Disclosing Your Personal Information for Business Purposes
We may disclose your personal information to third parties for business purposes, such as:
- Service providers who assist with web hosting, analytics, collections, or customer service.
- For security, fraud detection, or legal compliance purposes.
- During mergers, acquisitions, or other business transactions.
- In compliance with legal obligations, including court orders or subpoenas.
Your Rights Under the CCPA
As a California resident, you have the following rights under the CCPA:
- Right to Know: You can request the categories of information and the specific pieces of personal information we’ve collected about you.
- Right to Deletion: You can request that we delete the personal information we’ve collected about you, subject to certain exceptions.
- Right to Correct: You can request correction of inaccurate personal information.
- Right to Opt-Out: You can request to opt-out of the sale of your personal information (Fennemore does not sell personal information).
- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
To exercise any of these rights, please submit a verifiable consumer request to us by either:
- Contacting us via the Contact Us section of this Privacy Policy.
- Using the Right to Know or Right to Delete forms.
Shine the Light Law
Under California’s Shine the Light Law (California Civil Code Section 1798.83), you may request information about how your personal information has been shared with third parties for their direct marketing purposes. To make such a request, please contact us as provided in the Contact Us section of this Privacy Policy.
Exercising Your Rights Under the CCPA
To exercise your rights to know, delete, correct, or opt-out, please submit your request through the following:
- Contact Us section.
- Right to Know or Right to Delete forms.
We will respond to your request within 45 days. If necessary, we may extend the response period for up to 45 additional days with notice to you. In order to verify your request, we may require you to submit personal information (such as an email address or telephone number) that will allow us to confirm that you are the consumer about whom we have collected information, or you are an agent authorized by the consumer to act on their behalf.
Retention
Unless otherwise stated above, we will retain categories of your personal information only for as long as necessary. We make this determination based on our relationship with you, applicable laws, and our data retention policies. We will retain each category of your personal information for as long as we have a relationship with you (e.g. for as long as you are a client and for a reasonable period thereafter).
When determining how long to retain each category of personal information after we no longer have a relationship with you, we take into account how long our clients usually want to continue hearing from us, our legal obligations and the expectations of regulators, as well as the length of time information is needed for internal audit purposes and to exercise or defend our legal rights.
We also consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We review our retention periods for each category of personal information on a regular basis, and all data is retained in compliance with applicable data protection laws.