Privacy Policy Disclosure

Maslon LLP (“we,” “us,” or “our”) is committed to safeguarding the privacy of visitors to our website (“you”). We appreciate that you may have questions about our privacy policy. The following provides information on how we collect, use, and otherwise process your personal information during your visit of this website, as well as the rights that you have in relation to our processing of that information (the “Privacy Policy”).

Please note that if you are a Maslon client, this Privacy Policy is not applicable to you. Please refer to the engagement letter you signed with us.

In this Privacy Policy, “personal information” means any information that (either in isolation or in combination with other information held by us) enables you to be identified or recognized.

If you are a California resident, please click on the California Privacy Notice section for more information.

If you are a European Union citizen, please click on the European Economic Area Rights & General Data Protection Regulation section for more information.

If you have any comments or questions in connection with this Privacy Policy, or for further information on our processing activities and your rights in relation to your personal information, please contact us via email at info@maslon.com. You may also call us at 612.672.8200.

Quick-References Links

• Information Collection
• Information Usage
• Information Sharing
• Marketing Choices
• Security
• Links
• Cookies
• Do Not Track
• Information Retention
• Notification of Changes
• European Economic Area Rights & General Data Protection Regulation
• California Privacy Notice

Information Collection

You are not required to provide any personal information to view our website. If you choose to send us personal information by email, mail, or some other form, we may keep a record of that information. [Discussion point: If we plan on expanding the functionality of the website, such as adding a text input field that contains personal information, we will need to expand this section.]

Additionally, we may collect the following categories of personal information from you in the course of business, including through your use of the website, when you contact or request information from us:

• Identification data, such as name, title, job title, or address.
• Contact information, including your phone number(s), your email address, and social media account or handle where appropriate.
• Event registration or mailing list data, such as dietary requirements (which may reveal information about your health or religious beliefs), preferences and interests, subscriptions, downloads, and username/passwords.
• Job applicant data, such as identification data and contact information, resumé and other data provided by you or third parties (e.g. recruiters) on our website, online recruitment portal (where applicable) or offline in connection with job openings, which may be subject to additional local requirements based on the country for which the position is advertised.
• Cookie and device data, such as information about your visit of our website, IP address, device identifier, browser type and version, operating system and network, location, and time zone setting.
• We may supplement the information that you provide to us with information that we receive or obtain from other sources, such as from our staff or personnel, clients, professional advisers, partners, and agents of Maslon, third parties with whom we interact, and publicly available sources.

Information Usage

We may use your personal information for the following purposes and, for each purpose, based on the following legal grounds:

• Administration of client and vendor relationships.
• Addressing client inquiries/feedback. It may also be necessary for our legitimate interests to establish or maintain a relationship with you; it is also in your interest to receive a response from us when you contact us.
• Sending relevant marketing messages and inviting you to events/seminars – we use identification data, contact details, cookie and device data, and mailing list data to communicate with you by way of email alerts and post to provide you with information about our events, seminars, or services that may be of interest to you.
• Improving our website – we use cookie and device data to improve the functionality and user-friendliness of our website.
• Keeping our website and IT systems and processes safe.
• Complying with legal or regulatory inquiries/requests.
• Recruitment – personal information about job applicants is collected and processed for purposes of screening, identifying, and evaluating candidates for positions; record-keeping related to hiring processes; analyzing the hiring process and outcomes; and conducting background checks, where and to the extent permitted by applicable law, which may also be subject to relevant local recruitment privacy policy. If you are hired by us, this data will be transferred to our employee record files for the purpose of your employment. This processing is necessary in order to take steps at the request of the job applicant in the context of recruitment prior to entering into a contract.

Information Sharing

We may share your personal information with the following categories of recipients:

• Vendors that will process your personal information on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, customer relationship management databases and other cloud-based solutions, third party companies providing us with business analytics and statistics to assist with our marketing campaigns, and third-party venues in which we may host events and seminars.
• Law enforcement, regulatory, or government agency requesting personal information in connection with any inquiry, subpoena, court order, or other legal or regulatory procedures, with which we would need to comply. We may also share personal information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
• Any third party connected with business transfers; we may transfer your personal information to third parties in connection with a reorganization, restructuring, merger, acquisition, or transfer of assets of our firm, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Policy.
• We are not responsible for the data policies or procedures or content of any linked websites. We recommend that you check the privacy and security policies of each website you visit.

Marketing Choices

We may send you direct marketing messages including by way of email alerts and mail provided that we have a lawful ground to do so. If you no longer wish to receive our email alerts, to be part of a mailing list, or to receive any marketing communications, you can opt-out of such communications at any time by clicking on the unsubscribe link in the relevant communication or contacting us at info@maslon.com.

Security

We have implemented technical and organizational security measures in an effort to safeguard the personal information in our custody and control. Such measures include, for example, limiting access to personal information only to staff and authorized service providers on a need-to-know basis for the purposes described in this Privacy Policy, as well as other administrative, technical, and physical safeguards.

We endeavor to take reasonable steps to protect your personal information, but cannot guarantee the security of any data you disclose online. Please note that email is not a secure medium and should not be used to send confidential or sensitive information. By providing information online, you accept the inherent security risks of providing information over the Internet and will not hold us responsible for any breach of security, unless it is due to our negligence or willful default.

Links

Links to websites that are not operated by or for Maslon (“Third Party Sites”) are provided solely as a convenience to you. This Privacy Policy does not apply to Third Party Sites. We have not reviewed the Third-Party sites, do not control and are not responsible for any of their content or their privacy policies, if any. We do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third-Party Sites listed on or linked to from our website, you should understand that you do so at your own risk.

Cookies

“Cookies” are small pieces of information that are stored by your web browser on your computer’s hard drive or temporarily in your computer’s memory. The use of cookies is now an industry standard and you will find them on most major web sites.

We may place and store Internet cookies on your hard drive. The use of cookies provides benefits to you by saving your name, information supplied at registration, and other information that may make the use of our services easier. Although most web browsers are initially set up to accept cookies, if you prefer, you can decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to block or delete the cookie. Please note, however, that certain areas on a web site may not function properly if your web browser does not accept cookies. When you visit our Website, or open an email you have received from us, we may place or recognize a unique cookie on your browser. These cookies, which do not contain PII, enable us, customize our services and gather insight analytics.

Additionally, emails we send to you may contain a bit of code known as a “web beacon” or “pixel.” This code helps us understand the time and date that you opened an email and when you used a link within the email to visit a website, allowing us to collect analytics about our traffic, customize our services, and send you ads about our services and promotions. You can disable our web beacons by turning images “off” in your email client (e.g., Outlook, Outlook Express).

Strictly Necessary Cookies

Cookie Subgroup	Cookie File Name	Use	Lifespan	Purpose
.maslon.com	ARRAffinitySameSite	Third Party	Session	Azure Load Balancing

Functional Cookies
 

Cookie Subgroup	Cookie File Name	Use	Lifespan	Purpose
.maslon.com	lastFeaturedld	First Party	Session	Prevents seeing the same featured item two-page loads in a row

Targeting Cookies
 

Cookie Name	Default Expiration Time	Description
_ga	2 years	Used to distinguish users
_gid	24 hours	Used to distinguish users
_gat	1 minute	Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property- id>
AMP_TOKEN	30 seconds to 1 year	Contains a token that can be used to retrieve a client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
_gac_<property-id>	90 days	Contains campaign related information for the user. If you had linked your Google Analytics and Google Ads accounts, Google Ads website conversation tags will read this cookie unless you opt out.

Do Not Track

Please note that we do not support "Do Not Track" browser settings at this time.

Information Retention

We will only retain your personal information for as long as necessary for the purposes for which that information was collected as set out in this Privacy Policy or for longer as required under any applicable legal, regulatory, accounting, or reporting requirements. Should you opt out or no longer wish to receive marketing messages from us, we will securely delete your personal information from the relevant mailing list(s).

Notification of Changes

We reserve the right to change this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will post the revised version to https://www.maslon.com/legal-notices and update the “Effective Date” at the top of this Privacy Policy. Except as otherwise indicated, any changes will become effective when we post the revised Privacy Policy on our website.

European Economic Area Rights & General Data Protection Regulation (“GDPR”)

If you are in the European Economic Area (the “EEA”), you have the following rights:

• Access. You have the right to request a copy of the personal information that we are processing about you. If you require additional copies, we may need to charge a reasonable fee.
• Rectification. You have the right to require the correction of any mistake in the personal information that we hold about you.
• Deletion. You have the right to require the erasure of personal information concerning you in certain situations, such as where we no longer need it or if you withdraw your consent (where applicable).
• Portability. You have the right to receive the personal information concerning you that you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit that data to a third party in certain situations.
• Objection. You have the right to: (i) object at any time to the processing of your personal information for direct marketing purposes and (ii) object to our processing of your personal information where the legal ground of such processing is necessary for legitimate interests pursued by us or by a third party. Upon confirmation of your identity, as reasonably necessary, we will comply with your request unless we can demonstrate compelling legal grounds for the processing.
• Restriction. You have the right to request that we restrict our processing of your personal information in certain circumstances, such as when you contest the accuracy of that personal information.
• Withdrawal of consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. "Explicit consent" would be required if we rely on consent as the condition to lawfully process "special categories of personal data," as defined in the GDPR.

You also have the right to lodge a complaint with the local data protection authority, if you believe that we have not complied with applicable data protection laws, including the GDPR. Please click here for a list of local data protection authorities in the EEA countries.

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the personal information or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.

If you are in the EEA and would like to exercise any of those rights, please:

• Email us at info@maslon.com;
• Provide enough information to identify yourself (e.g., name, email address, etc.);
• Provide proof of your identity and address (a copy of your driver’s license or passport and a recent utility or credit card bill); and
• Provide the information to which your request relates.

As it relates to the GDPR, Maslon is the data controller in relation to any personal information that we process about you and is responsible for ensuring that such processing complies with the GDPR.

California Privacy Notice

Effective Date: January 1, 2020

Introduction

This section (the “California Notice”) describes how we collect, use, and share personal information about California residents in and their rights with respect to that information.

Scope

This California Privacy Notice applies only to “personal information”, as defined in the CCPA, that we collect as a “business” as defined in the CCPA but does not apply to personal information excluded from the scope of the CCPA. This California Notice does not apply to you if you are not a California resident or you or are otherwise not entitled to a notice under Section 1798.100 of the CCPA (e.g., because we collect your personal information while interacting with you in your capacity as an employee, controlling owner, director, officer, or contractor of an organization while providing or receiving products or services to or from, or performing due diligence on, that organization).

Personal information we collect

1. 1. 1. Categories. Below is a summary for the preceding 12 months of the Personal Information categories (as identified and defined by the CCPA) that we collected in the course of providing our clients with promotions and services:

Category	Examples	Identify if Processed
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	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.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary codes.	No
K. Inferences drawn from other personal information.	Profile a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

1. 1. 2. Categories Shared. We may use or disclose Personal Information in the following categories in the course of providing our clients with promotions and services (the “Business Purpose Disclosures” in the table below).
          

Category	Business Purpose Disclosures
A. Identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute	Yes
C. Protected classification characteristics under California or federal law.	Yes
D. Commercial information.	Yes
E. Biometric information.	No
F. Internet or similar network activity.	Yes
G. Geolocation data.	Yes
H. Sensory data.	Yes
I. Professional or employment-related information.	No
J. Non-public education information	No
K. Inferences drawn from other personal information.	Yes

1. 1. 3. No Sale. In the 12 months prior to the effective date of this Disclosure, Maslon has not sold (as the term “sell” is defined in the CCPA) your Personal Information.
2. 1. 4. Requests Regarding Personal Information. You may have the right to request information about our collection of your Personal Information, to access it, or instruct us to delete it (subject to the exceptions below). To do so, please contact us using the information provided in Section 6. Note that we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity based on the Personal Information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. If we cannot comply with your request, we will provide you with an explanation.
3. 1. 5. Timing. We will use reasonable efforts to respond to your request within 45 days of receipt. If we require additional time, we will inform you of the reason and the extension period in writing.
4. 1. 6. Exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us to:

• • • • • Complete the transaction for which we collected the Personal Information;
• • • • • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• • • • • Identify and/or repair errors that impair the functionality of our services;
• • • • • Make other lawful uses of the Personal Information that are compatible with the context in which you provided it; and
• • • • • Comply with a legal obligation.

1. 1. 7. Content. Any Personal Information we provide you with will only cover the 12-month period preceding our receipt of your request. Once we receive your request, validate your identity (and unless one of the exceptions above apply) we will disclose to you:

• • • • • The categories of Personal Information we collected about you;
• • • • • The categories of sources for the Personal Information we collected about you;
• • • • • Our business purpose for collecting that Personal Information and whether it was sold;
• • • • • The categories of third parties with whom we shared the Personal Information;
• • • • • If we sold or disclosed your Personal Information for a business purpose, we will provide you with information about those sales and disclosures along with the Personal Information categories that were provided and each recipients category.
• • • • • The specific pieces of Personal Information we collected about you (also called a data portability request, as detailed below).

1. 1. 8. Data Portability. For data portability requests, we will select a data format that is readily useable and should allow you to transfer the Personal Information to another entity without difficulty.
2. 1. 1. No Charge. We do not charge a fee to process or respond to your Personal Information request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
3. 1. 10. No Discrimination. Maslon will not discriminate against any consumer for exercising their rights under the CCPA.
           
4. Changes to this Privacy Policy

This Notice was last updated on October 14, 2021.  However, this Notice will change over time, for example to comply with legal requirements or to meet changing our business needs.  The most up to date version can be found on the Website.  In case there is a change that we want to highlight to you, we will also inform you in another appropriate way (for example, via a pop-up notice or statement of changes on our Website).