February 16, 2018
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY IDENTIFYING INFORMATION
Users of the Website Generally
“Non-Personally Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, we gather from users of the Website Non-Personally Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally Identifying Information, it may be possible for us to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. We analyze Non-Personally Identifying Information gathered from users of the Website to help us better understand how the Website is being used. By identifying patterns and trends in usage, we are able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, we may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. We may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally Identifying Information. They are a technique we may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Cookies or modifying your browser setting to notify you each time a Cookie is tendered, permitting you to accept or decline Cookies on an individual basis.
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Website, including Google Analytics. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/). We may partner with selected third parties to allow tracking technology on the Website, which will enable them to collect data about how you interact with the Website and our services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.
Aggregated and Non-Personally Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances, including, without limitation, sharing it with third parties and our affiliate companies. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties for the purpose of conducting general business analysis. This information does not contain any Personally Identifying Information, and may be used to develop website content and services that we hope you and other users will find of interest and to target content.
Mobile Device Additional Terms
- Mobile Device. If you use a mobile device to access the Website or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
- Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for us to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.
- Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally Identifying Information you submit within the mobile application.
We may use hyperlinks on the Website, which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. These third-party services may collect and share information about a user. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. For example, when you click on Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION
As defined above, Personally Identifying Information is information that can be directly associated with a specific person. We may collect a range of Personally Identifying Information from and about Website users. Much of the Personally Identifying Information collected by us about users is information provided by users themselves when: (1) registering for our services; (2) participating in polls, surveys or responding to offers; (3) communicating with us; (4) creating a public profile; or (5) signing up to receive newsletters. That information may include each user’s name, address, email address and telephone number. Users of the Website are under no obligation to provide us with Personally Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.
BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION” SECTION.
We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt-out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt-out of all voluntary email notifications.
Since DRRT is a global organization, we may share users’ information with our offices throughout the world. Additionally, we will disclose Personally Identifying Information under the following circumstances:
- Communications If you wish to opt-out of receiving communications from us, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable) or contacting us using the contact information below.
Changing Personally Identifying Information; Account Termination
INFORMATION BY THIRD PARTIES
Thank you for visiting our website. We created this site so you could learn more about the legal services offered by our firm. The website is intended for informational purposes only. None of the information contained in this website is intended to constitute, nor does it constitute legal advice.
Our website does not create an attorney-client relationship between you and DRRT. An attorney-client relationship cannot be formed by reading the information on this website. The only way the attorney-client relationship is formed is to become our client by specific and explicit agreement with an individual attorney at DRRT. By providing information about our firm on this website, we are not soliciting clients nor do we propose any type of transaction. You should not act or rely on any information contained on this website without seeking the advice of an attorney. The determination and need for legal services as well as the choice of a lawyer is an extremely important decision and should not be based solely upon advertisements or self-proclaimed expertise.
We take the security of your Personally Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.
We are dedicated to protect all information on the Website. However, you are responsible for maintaining the confidentiality of your Personally Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.
DRRT Privacy & Data Protection Policy
DRRT is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). DRRT may be required to disclose personal information to law enforcement, regulatory or other government agencies, or to other third parties, in each case to comply with legal, regulatory, or national security obligations or requests.
In compliance with the Privacy Shield Principles, DRRT commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact DRRT at:
Diana Oliveira, Data Protection Specialist
Phone: +1 (305) 760-8002
DRRT has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association’s International Center of Dispute Resolution (“ICDR”), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.icdr.org for more information or to file a complaint. Under certain conditions, individuals may have the possibility to engage in binding arbitration through the Privacy Shield Panel.
DRRT is committed to protecting the privacy of our clients. DRRT will use personal information or data we collect or receive only in a lawful manner and will not contact any individual without prior consent.
DRRT will never collect sensitive information about any individuals without their explicit consent and hold any personal information received or collected securely in accordance with the DRRT Privacy & Data Protection Policy as well as the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield.
DRRT does not sell or transfer any information to any third party and are not liable in case of onward transfers to third parties. While we may use technology to track patterns or behavior of visitors to our site, it is not our current policy to do so. This could include using a “cookie” which would be stored on a visitor’s browser to allow a future identification of such visitor, but any visitor can “disable cookies” to prevent this.
The Children’s Online Privacy Protection Act (COPPA) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally Identifying Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to delete the information. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred Personally Identifying Information to the Website, please contact us using our contact information below to have that child’s account terminated and information deleted.
Most web browsers and some mobile operating systems include a Do-Not-Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. The Website currently does respond to DNT browser signals or mechanisms.
LIMITATION OF LIABILITY
We are not responsible for any damages or injury, including but not limited to special, indirect, incidental or consequential damages, that result from your use of (or inability to use) this site, including any damages or injury caused by any failure of performance, error, omission, interruption, defect, delay in operation, computer virus, line failure, or other computer malfunction. You understand and agree that your use of this site is predicated upon your waiver of any right to sue us or its affiliates directly or to participate in a suit for any losses or damages resulting from your use of this site.
You agree that your use of this site and any disputes relating to any of them shall be governed in all respects by the laws of the State of Florida, United States. Any dispute relating to the above shall be resolved by arbitration, as the sole and exclusive legal recourse. The arbitration site shall be Miami, Florida, USA and the arbitration site’s procedural rules shall apply. The arbitration proceeding shall be conducted in the English language. All parties agree that the resulting arbitral award shall be the sole and exclusive remedy. The arbitral award may, in the arbitrator’s sole discretion, include reasonable attorney’s fees incurred in the proceeding.
Attn: Privacy Officer
340 West Flagler Street, 2nd Floor
Miami, Florida 33130
Phone: +1 (305) 760-8002