Privacy Policy

1. Scope

This Privacy Policy applies to the personal information we collect related to our:

• websites, including https://start.law/ and our other websites that display this Privacy Policy, and the services available through our websites (together, our "Sites").
• mobile apps (“Apps”) and social media properties
• events, marketing and business development activities
• business communications and other online and offline business interactions
• legal and professional services

Collectively, we refer to the above as our “Services.” Additional or different privacy notices may apply to certain of our Services. If a different or supplemental privacy notice applies, this will be clearly disclosed to you. This Privacy Policy does not apply to the personal information that we collect about employees and other personnel, contractors, or applicants and candidates.

California Consumer Privacy Act.

If you are a California resident, please review the Additional Privacy Information for California Residents section below, for important information about how we collect, use and disclose personal information about California residents and your rights under the California Consumer Privacy Act.

GDPR.

If you are a EU resident, please review our GDPR Privacy Notice below, for additional information about how Start.law processes personal information that is subject to EU data protection laws (including those implementing the EU General Data Protection Regulation, or "GDPR").

2. Information we collect

We may collect information directly a, as well as from third parties or automatically related to the use of our Sites and Services.

• Information collected directly

We may collect personal information about you—such as your name, address, telephone number, fax number, e-mail address, etc.—directly from you. For example, personal information may be collected when you fill out a 'Contact Us' form, sign up for our mailing lists, register for events we host or sponsor, submit information as part of certain online services post comments on our blogs, or otherwise provide us personal information through the Sites and Services

. Generally, the information we collect includes your:

• Name, company name and title/position.
• Email address, phone number, mailing address and contact details.
• Contact preferences and interests.
• Business affiliations.
• For events, it may include dietary restrictions, requested accommodations and other event-related preferences.
• Information provided in conjunction with our Client Services.
• Other information related to your request or inquiry, or that you provide when you communicate, engage or otherwise interact with us or the Services.

• Automatically-collected information We use cookies, log files, pixel tags, local storage objects and other tracking technologies to automatically collect information when users access or use the services or visit our Site, such as an IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider ("ISP"), referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information. For more information, see the Cookies and similar devices section below.

• Information received from third parties We may collect or receive information about individuals from service providers, and other third parties, such as our clients, representatives and professional advisers, content providers, government authorities and public sources and records.

3. Use of personal information

We use the personal information we collect in order to respond to your request or inquiry and in the ordinary course of conducting our business. Generally, we use the personal information that we collect as follows:

• Providing support and services To operate our Sites, provide our Services, communicate with you about your use of the Sites or Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.
• Responding to your requests To respond to your inquiries, fulfill your orders and requests, and otherwise consider or process your request.
• Personalization To tailor content we may send or display to you, including to offer location customization and personalized help and instructions on our Sites and Apps, and to otherwise personalize your experiences.
• Newsletters, mailing lists and direct marketing For direct marketing purposes, including to send you newsletters, client alerts and information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them.
• Analytics and improvement To better understand how users access and use our Sites and other Services, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations and to develop services and features.
• Protect legal rights and prevent misuse To protect the Sites, Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of us or any person or third party, or violations of our Terms of Use or other agreements; and to respond to actual or potential legal claims against us.
• Comply with legal and ethical obligations In order to respond to legal process (eg, court orders, subpoenas or warrants) or regulator investigations and inquiries, or where otherwise required by law or our legal, regulatory or ethical obligations.
• General business operations Where necessary, for the administration of our general business, accounting, recordkeeping, audit, compliance and legal functions.
• Anonymous and de-identified information We create and use anonymous and de-identified information to assess, improve and develop our business, products and services, and for similar research and analytics purposes.

4. Disclosure of personal information

The Services provided by Start.law are provided by the New York law firm, Start.law, PC, and Start.law Relationship firms. Start.law Relationship firms are independently operated law firms who work together and with Start.law, PC to provide a comprehensive and coordinated legal service to clients, nationwide. Any information that we collect or that you provide to us may be shared and processed by any Start.law practicing entity. We will not rent or sell your personal information, nor will we share it with third parties, outside of Start.law, for their own marketing purposes.

We may share personal information with the following categories of third parties:

• Third party service providers that provide services to us or to whom we outsource certain services, such as data hosting or software or technology services.
• Content providers that we partner with to make available training and other content or resources. We do not share your information with them for their own independent use; however, if you register for an account with one of these third parties they will use the information you provide to them subject to their own privacy policy and terms.
• Our professional advisers, such as lawyers and accountants.
• Government and/or regulatory authorities.
• Professional indemnity insurers.
• Regulators, tax authorities and/or corporate registries.

In addition, we may disclose personal information to other third parties under the following circumstances:

• Business transfers As part of any actual or potential merger, sale and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law.

• Comply with law, legal process and ethical obligations To comply with the law and our ethical obligations, or respond to legal process or regulator investigations and inquiries, or where otherwise required by law or our ethical obligations. For example, we may disclose information in response to subpoenas, court orders and/or other lawful requests by regulators and/or law enforcement, including responding to national security or law enforcement disclosure requirements.

• **Performance of legal services **To the extent required or necessary for our provision of legal services. For example, to our clients, with respect to the relevant legal services we provide to them, or to respond to other parties in legal matters for which we have been engaged as legal counsel.

• Protect and defend rights Where we believe it necessary to respond to claims asserted against us, enforce or administer our agreements and terms, or for fraud prevention, risk assessment and investigation, and to protect and defend the rights, property or safety of Start.law, our clients and customers, or others.

We may also share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

5. Cookies and similar devices

We and our service providers use cookies, pixels, log files and other mechanisms to gather information about your use of our Sites and Apps.

• Cookies Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

• Clear GIFs, pixel tags and other technologies Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our services to, among other things, track the activities of users of our services, help us manage content, and compile statistics about usage of our services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, to identify when our emails are viewed, and to track whether our emails are forwarded.

• Log files Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.

• Third party analytics We also use automated devices and applications, such as Google Analytics to evaluate the use of our Sites and Services. We use these tools to gather non-personal data about users to help us improve our services and user experiences. These analytics providers may use cookies and other technologies to perform their services and may combine the information they collect about you on our Sites with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties.

• Do-not-track signals Our Site does not respond to do-not-track signals. You may, however, disable certain tracking as discussed above (eg, by disabling cookies) and as set out in our Cookie Policy.

6. Direct marketing

As noted, we may send periodic promotional emails to you, and where required by law, we will obtain your consent to do so. You may opt out of such communications at any time by following the opt-out instructions contained in the email or email us at office@start.law. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

7. International transfers

When you submit personal information to us, or when others provide personal information to us, we will receive it and process it in the United States

8. Access and correction

If you would like to review the personal information we have collected about you via the Sites, or request that we update or delete it, please contact us at office@start.law

9. Third-party websites and links

Our Sites may contain links to other sites whose information practices may be different than ours. Visitors should consult the other sites' privacy notices as we have no control over information that is submitted to, or collected by, these third parties.

10. Co-sponsored events

Start.law posts information about programs and events that are sponsored by or co-sponsored by other firms or organizations. Should you choose to register electronically for any of these events or submit your information to these third parties, Start.law will have no control over the third-party sponsors' use of this information, and this Privacy Policy will not apply.

11. Our commitment to security

We employ security measures to prevent unauthorized access to information that we collect online. However, we cannot guarantee the security of your personal information.

12. How to contact us

If you have any questions or concerns about the Privacy Policy for Start.law or its implementation, you may contact us at office@start.law. If at any time you decide that we should no longer hold any of your personal information, or you wish to change the use to which any such information can be put, please let us know by emailing us at office@start.law.

13. Revisions to our Privacy Policy

We reserve the right to revise this Policy or any part of it from time to time. Please review the Policy periodically for changes. If we make material changes, we will endeavor to provide notice ahead of such changes, such as by email or through a notice on https://start.law/

14. Additional Privacy Information for California Residents

In this section, we provide additional information to California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”). This section does not apply to publicly available information lawfully made available by state or federal government records, deidentified information, aggregate consumer information, or other personal information that is exempt under the CCPA (such as information covered by the Health Insurance Portability and Accountability Act).

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about California residents in the prior 12 months (from the Last Updated date above), and the rights California residents have under the CCPA regarding this personal information.

• Categories of personal information that we collect and disclose

The table below identifies the categories of personal information (as defined by the CCPA) that we have collected about consumers in the prior 12 months, as well as how we have disclosed such information for a business purpose (subject to our applicable legal and ethical obligations). For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the Use of personal information and the Disclosure of personal information sections above.

Personal information collected	Disclosed for business purposes
Category	Description	Yes/No	Categories of third parties*
Identifiers	Includes direct identifiers such as a name, alias, address, email address, user ID, IP address and other online identifiers and other similar identifiers.	Yes	Service providersJudicial and quasi-judicial bodiesRegulatory and government entitiesAffiliatesLegal support firmsClients Parties and related parties in legal matters
Customer records	Customer records: includes personal information, such as name, account name, billing and payment information, signatures, government identifiers and other information that individuals provide us in order to use our Services.	Yes	Service providersJudicial and quasi-judicial bodiesRegulatory and government entitiesAffiliatesLegal support firmsClients Parties and related parties in legal matters
Protected classifications	Characteristics of protected classifications, such as age, gender, marital status, disability and health information that individuals provide to us.	Yes	Service providersJudicial and quasi-judicial bodiesRegulatory and government entitiesAffiliatesLegal support firmsClients Parties and related parties in legal matters
Commercial information	Such as records of purchases and use of the Services and other products and services.	Yes	Service providersJudicial and quasi-judicial bodiesRegulatory and government entitiesAffiliatesLegal support firmsClients
Usage data	Internet or other electronic network activity information: including browsing history, search history, access logs and usage data, and other information regarding a person’s interaction with our Sites, Apps and Services.	Yes	Service providers Judicial and quasi-judicial bodies Regulatory and government entities Affiliates
Geolocation data	Such as location information from your device or IP address.	Yes	Service providers Judicial and quasi-judicial bodies Regulatory and government entities Affiliates
Audio, Video and Electronic Data	Includes audio, electronic, visual, thermal, olfactory, or similar information, such as thermal screenings and CCTV footage (e.g., collected from visitors to our offices for health and safety purposes), photographs and images (eg, that you provide us) and records of calls, webinars and video conferences (eg, when you participate in one of our webinars).	Yes	Service providersJudicial and quasi-judicial bodiesRegulatory and government entitiesAffiliates
Professional information	Includes professional and employment-related information such as your employer name, title, the nature of your responsibilities, and your practice area, specialties, qualifications and areas of focus.	Yes	Service providersJudicial and quasi-judicial bodiesRegulatory and government entitiesAffiliatesLegal support firmsClients Parties and related parties in legal matters
Education information	Education information: information that is not publicly available personally identifiable information as defined in the Federal Education Rights and Privacy Act.	Yes	Service providersJudicial and quasi-judicial bodiesRegulatory and government entitiesAffiliatesLegal support firmsClients Parties and related parties in legal matters
Inferences	Includes inferences drawn from any of the information identified above to create a profile about you, such as reflecting your preferences and other characteristics.	Yes	Service providersAffiliates

In addition to the above, we may disclose the personal information that we collect to others, as necessary to comply with applicable laws or our legal and ethical obligations. We do not sell personal information about California residents, including those we have actual knowledge are younger than 16.

Categories of sources of the personal information that we may collect

As further described in the Information we collect section above, we may collect personal information directly from individuals, as well as from third parties* and other sources:

• Service providers*
• Judicial and quasi-judicial bodies*
• Regulatory and government entities*
• Affiliates*
• Legal support firms*
• Clients*
• Parties and related parties in legal matters*
• Public sources and records
• Social networks

*Additional information about the categories of third parties listed above:

• Service providers: includes vendors, service providers, and content providers, as well as our professional advisors (such as lawyers and accountants) and our professional indemnity insurers.

• Judicial and quasi-judicial bodies: such as courts, arbitral bodies and tribunals.

• Regulatory and government entities: government, administrative, law enforcement and regulatory agencies; tax authorities; corporate registries; and other public agencies or authorities.

• Affiliates: our affiliates and subsidiaries, as well as other Start.law member and relationship firms.

• Legal support firms: other law firms, consultants and professional advisors that we work with to provide our legal services to a particular client.

• Clients: our clients, with respect to, the relevant legal services we provide to them.

• Parties and related parties in legal matters: other parties in legal matters for which we have been engaged as legal counsel, to the extent required or necessary for our provision of legal services.

CCPA Rights

In general, California residents have the following rights with respect to their personal information:

• Do-not-sell (opt-out): to opt-out of our sale of their personal information. We do not sell personal information about California consumers, including those we have actual knowledge are younger than 16.
• Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.

• Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):

• categories of personal information collected
• categories of sources of personal information
• categories of personal information about them we have disclosed for a business purpose or sold
• categories of third parties to whom we have sold or disclosed for a business purpose their personal information
• the business or commercial purposes for collecting or selling their personal information

• a copy of the specific pieces of personal information we have collected about them

• Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests

California residents may submit CCPA requests to know (access) and requests to delete their personal information through one of the following methods:

• Online by emailing office@start.law
• By phone at 332-217-1471

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must provide your name and contact information to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us by email at the above link; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

15. GDPR

In this section, we provide additional information about how we handle personal information that is subject to the GDPR when we are the controller of that information. In this GDPR section, we use the term "GDPR" to include the EU General Data Protection Regulation, as well as associated national laws.You have the following rights in relation to the personal information we hold about you:

• Your right of access If you ask us, we will confirm whether we are processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Your right to correction (rectification) If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it corrected. If you are entitled to have information corrected and if we have shared your personal information with others, we will let them know about the rectification where possible. If you ask us, we will also tell you, where possible and lawful to do so, with whom we have shared your personal information so that you can contact them directly.
• Your right to erasure You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, we will also tell you, where it is possible and lawful for us to do so, with whom we have shared your personal information with so that you can contact them directly.
• Your right to restrict (block) processing You can ask us to restrict the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, we will also tell you, where it is possible and lawful for us to do so, with whom we have shared your personal information so that you can contact them directly.
• Your right to data portability You have the right, in certain circumstances, to receive a copy of personal information we've obtain from you in a structured, commonly used and machine readable format, and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
• Your rights in relation to automated decision-making and profiling You have the right not to be subject to a decision when it's based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
• Your right to withdraw 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.
• Your right to lodge a complaint with the supervisory authority If you have a concern about any aspect of our privacy practices, including the way we've handled your personal information, you can report it to the relevant supervisory authority.

Please note that some of these rights may be limited where we have an overriding legitimate interest or legal obligation to continue to process the personal information, or where the personal information may be exempt from disclosure due to applicable law, the applicable rules of professional conduct, attorney-client privilege, legal professional privilege, other applicable privileges or protections, or professional secrecy obligations.

For more information about our privacy practices, you may contact us as set forth in the How to contact us section above.