Privacy and Cookie Policies
As of April 11, 2022
PRIVACY POLICY
This privacy policy (this “Privacy Policy”) applies to information collected by Sirkin Tarnow LLP (“ST”, “we” or “us”) on this website, its subdomains, and through any other online or mobile website, application, product, event, or service operated by ST on behalf of itself and/or its partners (each, a “Site”), as well as any personal information provided to ST by any means. Your privacy is important to us. As such, we provide this Privacy Policy explaining our online information practices. We encourage you to read this Privacy Policy in its entirety before using the Site or submitting any Personal Information (defined below) to us. If you choose to provide us with your Personal Information, you are telling us that you understand and accept the privacy practices detailed in this Privacy Policy and you authorize us to take actions consistent with this Privacy Policy.
We are required by law to tell you what information we collect from you, how we use it, under what circumstances we may share it with third parties, how we protect that information and how you may opt out of the sale of that information. If you have questions about this Privacy Policy, contact us at office@sirkintarnow.com.
This Privacy Policy does not apply to any products, services, websites or content that are offered by third parties, which are governed by their respective privacy policies.
I. The Information We Collect
We receive both information that is directly provided to us, such as personal information you provide when you visit the Site, and information that is passively or automatically collected from you, such as information collected from your browser or device. In this Privacy Policy, any information that could reasonably be used to identify you personally or identify your household or device is referred to as “Personal Information”.
In addition to information that you choose to submit to us, we may use automated means to collect various types of Information about you, your computer, or other devices used to access the Site (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include:
· Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
· Your Device functionality (including browser (e.g., Chrome, Safari, Firefox, Internet Explorer), browser language, operating system (e.g., Microsoft Windows or Mac OS), hardware, mobile network information);
· The name of your Internet service provider (e.g., Spectrum, Verizon or AT&T) and domains used by such providers;
· Referring and exit web pages and URLs;
· The areas within our Site that you visit and your activities there, including remembering you and your preferences or the content and advertisements you have accessed, seen, forwarded and/or clicked on;
· Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Services;
· Your Device characteristics; and
· Certain other Device data, including the time of day you visit our Site(s).
For location information, we may use this information to provide customized Services, content, promotional offers, and other information that may be of interest to you. If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your Device or through the settings in the applicable mobile application. Consult your Device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, Content, promotions, or products on our Site may be limited to disabled.
Use of Cookies and Other Tracking Technologies
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):
· Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage.
· Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.
· Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.
· ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
· Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
· Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
We may use Tracking Technologies for a variety of purposes, including:
· To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality or to allow you to make use of cart or payment functionality;
· To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
· To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
· To deliver content relevant to your interests on our Site and third‑party sites based on how you interact with our advertisements and/or content.
You can get more information about Cookies and Tracking Technologies, and instructions on how to opt out of cookies and certain tracking technologies, in our “Ads and Information About You” section below and in our Cookie Policy.
II. How We Use the Information
We may use your Personal Information to:
· Provide information and communicate with you;
· Respond to your inquiries;
· Communicate with you;
· Enforce the legal terms (including, without limitation, our policies), and/or for the purposes for which you provided the Information;
· Provide technical support for, address problems with, and improve the Site;
· Verify your identity and/or prevent fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through the Site;
· Comply with applicable law and protect the safety, rights, property, or security of TL, the Services and our Users;
· Protect the security and integrity of our Site, including understanding and resolving any technical and security issues reported on the Site;
· Facilitate our internal business purposes and purposes disclosed at the time you provide your information or as otherwise set forth in the Privacy Policy.
We may use “cookies” or similar technologies to associate certain of the Information with a unique identifier that then associates the Information with your device or browser. Sometimes, we may associate cookies with the Information, including de-identified, “hashed,” or anonymous versions of Information you have provided. Please see our Cookie Policy for more information.
III. Information Sharing and Disclosure
We may disclose the Information as follows:
1. To service providers or Partners that we have engaged to perform business-related functions on our behalf. This may include service providers that: (a) conduct research and analytics; (b) provide customer, technical or operational support; and/or (c) otherwise support the Site.
2. In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency's request or similar request.
3. With third parties in order to investigate, prevent, or take action (in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the Site, or violations of our policies, the law, to verify or enforce compliance with the policies governing the Site.
IV. Other Important Information About Your Privacy
1. How We Respond to Do Not Track Signals
Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed these signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services, but at this time there is no universally-agreed upon standard for what a company should do when it detects a DNT signal. As a result, the Site currently does not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.
2. Linked Sites
For your convenience, the Site may contain links to or integrations with other services (such as Facebook, Twitter, or LinkedIn), and other media services and platforms. ST is not responsible for the privacy practices, advertising, products, services, or the content of such other sites, and their information practices may be different than ours. Users should be aware when they leave our Site and should review these other services’ privacy notices if they are asked to give any personal information. None of the links on our Site to other services should be deemed to imply that ST endorses or has any affiliation with the third-party link. This Privacy Policy applies solely to information collected by ST, and not by any other sites or third parties.
3. Visitors to the Site Outside of the United States
Our Site is not intended for visitors outside of the United States. If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. Our Services are governed by and operated in accordance with U.S. law. The data protection laws in the U.S. may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the U.S. If you are located outside of the US, you use this Site and the Services at your own risk. By using the Site or providing us with any information, you consent to your Personal Information being collected, processed, used, stored, and transferred in the U.S. as set forth in this Privacy Policy.
4. Data Security
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information, including physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the Personal Information we collect. These safeguards vary based on the sensitivity of the Personal Information that we collect and store. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic information can be guaranteed 100% secure. As a result, although we take appropriate measures to safeguard against unauthorized disclosures of Information, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you provide us with your information at your own risk.
5. California Residents – Your California Privacy Rights
ST collects certain types of personal information about you as a visitor, user, or consumer. Under California law, if you are a resident of California, you have the right to request certain information that we collect about you, including:
(1) The categories of Personal Information we have collected from you;
(2) The categories of sources from which we collected the Personal Information;
(3) The business purpose we have for collecting or selling that Personal Information;
(4) The categories of third parties with whom we share such Personal Information; and
(5) The specific pieces of Personal Information we have collected about you.
In addition, if we sold or disclosed your personal information for a business purpose, you may request that we provide you with:
(1) The categories of Personal Information that we sold about you, and the categories of third parties to whom the personal information was sold, by category or categories of Personal Information for each category of third parties to whom the information was sold; or if we have not sold consumers’ Personal Information; and
(2) The categories of Personal Information that we have disclosed about you for a business purpose, and the categories of third parties to whom the personal information was disclosed, by category or categories of Personal Information for each category of third parties to whom the information was disclosed; or if we have not disclosed consumers’ Personal Information for a business purpose.
As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information or “Do Not Sell.” You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
· Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
· Debug products to identify and repair errors that impair existing intended functionality;
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
· Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
· Comply with a legal obligation; or
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.
To exercise the access, data portability, Do Not Sell, and deletion rights described in this section, please submit a verifiable consumer request to us by emailing office@sirkintarnow.com, or mailing or writing us with your request at the contact information below. Please include “California Privacy Rights” as the subject line. Only you may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You must include your full name, email address, and attest to the fact that you are a California resident by including a California postal address in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in California in order to obtain the information, and you are only entitled to make this request twice a year. We will respond to your request within 45 days or let you know if we need additional time. If you have an account with st, we may require you to log into that account to make this request.
Email Address:
We may be unable to respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Please note that certain of your Personal Information may remain in our database even after a deletion request in order to maintain the integrity and historical record of our database and systems.
6. Your Data Protection Rights Under the General Data Protection Regulation (GDPR)
If you are a resident of or located within the European Economic Area (“EEA”), you have certain additional data protection rights. These rights include:
· The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
· The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
· The right to object. You have the right to object to our processing of your Personal Information.
· The right of restriction. You have the right to request that we restrict the processing of your personal information.
· The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
· The right to withdraw consent. You also have the right to withdraw your consent at any time where ST relied on your consent to process your personal information.
Legal Basis for Processing Personal Information Under GDPR
ST’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.
ST may process your Personal Information because:
· We need to perform a contract with you;
· You have given us permission to do so;
· The processing is in our legitimate interests and it is not overridden by your rights; or
· To comply with the law.
Retention of Information
ST will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
ST will also retain Usage Data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.
Disclosure of Personal Information
Disclosure for Law Enforcement - Under certain circumstances, ST may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
ST may disclose your Personal Information in the good faith belief that such action is necessary to:
· To comply with a legal obligation
· To protect and defend the rights or property of T
· To prevent or investigate possible wrongdoing in connection with the Service
· To protect the personal safety of users of the Service or the public
· To protect against legal liability
Security of Information
Please note that we may ask you to verify your identity before responding to any data subject access requests.
Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first.
We can be contacted at office@sirkintarnow.com, or:
For more information, please contact your local data protection authority in the EEA.
V. Updates to this Privacy Policy
From time to time, we may update this Privacy Policy. In such event, we will post the policy changes in our Privacy Policy on the Site, and they will become effective on the date posted. We encourage you to periodically check back and review this policy so that you always will know what information we collect, how we use it, and with whom we share it.
COOKIE POLICY
Effective Date: April 11, 2022
Our Cookie Policy
Sirkin Tarnow LLP (“ST,” “us,” “we,” or “our”) uses cookies on www.sirkintarnow.com website and associated web pages (the “Site”). By using the Site, you consent to our use of cookies. Our Cookie Policy explains what cookies are, how we use them, how third parties we may partner with may use cookies on the Site, your choices regarding cookies, and how you can manage them.
What are cookies?
A “cookie” is a small piece of information stored on your device when you visit a website. The cookie means that the Site will remember you and how you’ve used the Site every time you come back. A cookie can be a “persistent” or “session” cookie. A “persistent” cookie will remain for a period of time set for that cookie. A “session-based” cookie is allocated only for the duration of your visit to our website and automatically expires when you close down your browser.
If you want to know more about cookies, head to aboutcookies.org or allaboutcookies.org (please note: these links are not operated by us, and may open a new window or browser tab).
How we use cookies
We use cookies to do several things. For example, cookies are used to enable certain functions of the Site, enhance security, improve functionality of the Site, remember your preferences, or count the number of people looking at a website. We also use them to keep track of what you’ve done on the Site, and to make online advertising more relevant to you.
We receive data from you as part of the communication connection itself through the standard electronic greeting between your computer and our servers. This information often consists of network routing (where you came from), equipment information (browser type), Internet protocol address, date and time. Other parts of the Site use cookies (including signup forms) to collect information about your use of the site and to facilitate return visits. Cookies on the Site may collect the following information: a unique identifier, user preferences and profile information used to personalize the content that is shown.
Cookies themselves don’t hold personally identifiable information (“PII”). They only have a unique alphanumeric identifier that sits on your browser. And in many cases, we won’t be able to link the information we collect by using a cookie back to you. They can, however, enable us to link that information back to you and your personal information, for example, when you log in, or choose to register for a service, white paper, or newsletter.
We may also engage third parties to track and analyze non-personally and personally identifiable website data and to serve advertisements. To do so, we may permit third parties to place cookies on devices of users of our Site, where permitted by law, and subject to your right to opt out through the Site. We use the data collected to help us administer and improve the quality of the Site and to analyze Site usage. Such third parties may combine the information that we provide about you with other information that they have collected. These third parties are required to use your information in accordance with this Cookie Policy and our Privacy Policy. We will record all such disclosures and will use reasonable efforts to ensure that such third parties do not use your PII for any purpose that is not expressly provided for herein.
We’ve put our cookies into the following categories or “types”, to make it easier for you to understand why we need them:
· (1) Strictly necessary – these are used to help make our Site work efficiently.
· (2) Performance – these are used to analyze the way our Site works and how we can improve it.
· (3) Functionality – these help to enhance your experience by doing things like remembering products you’ve added to your basket.
· (4) Targeting/advertising – these are used to share some information with third parties who we advertise with, so we know how you’ve reached our Site. We can also use cookies to identify the parts of the Site that you are interested in. We then use this information to show you advertisements and pages we think may also be of interest to you, to tailor how we communicate with you, or to tailor the contents of the communications we send to you. If you prefer, you can opt out of these. Tailoring of content means it includes information reflecting the interest you’ve shown in the content of our web pages or offers or promotions that we think may interest you, and to improve how we respond to your needs.
In addition to the cookies we use on our Site, we also use cookies and similar technologies in some emails and notifications we send to you. These help us to understand whether you have opened the email and how you have interacted with it. If you have enabled images, cookies may be set on your computer or mobile device. Cookies will also be set if you click on any link within the email.
Cookies and You
Some of the more popular browsers (and links to manage your cookies on each) are:
If you choose not to enable cookies, you will still be able to browse our Site, but it will restrict some of the functionality of our Site and what you can do.
Controlling your cookies
You can set your web browser to alert you when a cookie is being used. You can also get information on the duration of the cookie and what server your data is being returned to. You then can accept or reject the cookie. Additionally, you can set your browser to refuse all cookies or accept only cookies returned to the originating servers.
You can opt in or out of cookies at any time – except strictly necessary cookies (these are used to help make our website work efficiently).
You can enable or disable cookies in your browser. If you wish to restrict or block the cookies set by any website – including the exeter.edu website – you can do this through the web browser settings for each web browser you use, on each device you use to access the internet.
Information on controlling and deleting cookies, including on a wide variety of browsers, is also available at allaboutcookies.org.
In our cookie policy under the heading ‘Cookies and you’, we’ve also provided a few links for some of the more popular browsers – but check your particular browser and device for correct and up-to-date information.
Some services may not function or may have more limited functionality if your web browser does not accept cookies. However, you can allow cookies from specific websites by making them ‘trusted websites’ in your web browser.
If you want to opt-out of cookies across different advertising networks, the Network Advertising Initiative website – www.networkadvertising.org – has more information and guidance.
If you don't wish to accept cookies from one of our emails, you can choose not to download any images or click on any links. You can also set your browser to restrict cookies or to reject them entirely. These settings will apply to all cookies, whether included on websites or in emails. Depending on your email or browser settings, cookies in an email may sometimes be automatically accepted (for example, when you’ve added an email address to your address book or safe senders list). For more information, refer to your email browser or device instructions.
First-Party Cookies
First-party cookies originate from the same domain as the website you’re currently visiting (in this case www.sirkintarnow.com).
Third-Party Cookies
Third-party cookies originate from a domain that’s different from the website being visited. For example, when you visit our website, we may link to another company’s website. We don’t control how these third parties use their cookies, so we suggest you check their website to see how they’re using them and how you can manage them.