Thompson Legal Advisory Services (“We” “Us” “Our”, or “TLAS”) is a trading name of Thompson Legal Advisory Services P.C. We are committed to your privacy.
For the purpose of the European Union General Data Protection Regulations (the “GDPR”), if and to the extent GDPR applies, the data controller is Thompson Legal Advisory Services P.C. at One Sansome Street, Suite 3500, San Francisco, CA 94104.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO, Jeffrey Smith, via e-mail at: email@example.com or via mail at: Attention: Jeff Smith/DPO, Thompson Legal Advisory Services P.C. at One Sansome Street, Suite 3500, San Francisco, CA 94104.
1. INFORMATION WE MAY COLLECT FROM OR ABOUT YOU
We may collect, use, store, process or transfer personal data about you. Personal data or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, process or transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title and gender.
- Contact Data includes email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this site.
- Profile Data includes your username and password, your interests, preferences and feedback.
- Usage Data includes information about how you use our site, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us and we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity and contact data by filling in forms or providing other information via our site, e-mail or requesting services or information. This includes personal data you provide when you:
- request our services;
- subscribe to our publications;
- request marketing materials and information to be sent to you; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our site, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookies policy for further details below.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google based outside the UK and EU
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site. TLAS’s website sets cookies which remain on your computer for differing times. Some expire at the end of each session and some remain for longer so that when you return to our site, you will have a better user experience.
Cookie Consent. Web browsers allow you to exercise some control of cookies through the browser settings. Most browsers enable you to block cookies or to block cookies from particular sites. Browsers can also help you to delete cookies when you close your browser. You should note however, that this may mean that any opt-outs or preferences you set on the site will be lost.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit, allaboutcookies.org.
3. USES MADE OF PERSONAL INFORMATION
We use personal information collected, stored or processed about you in the following ways. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org:
Personal Information you give to us. We will use this information for the following legitimate interest and purpose:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- where applicable, to send statements and invoices to you, and collect payments from you;
- to send you general (non-marketing) commercial communications;
- to send you email or text notifications which you have specifically requested;
- to deal with enquiries and complaints made by or about you relating to our site; and
- from time to time, if applicable, to send to you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you by post or, where you have specifically agreed to this, by email, text or similar technology. You can opt-out by informing us at any time if you no longer desire to receive marketing communications by sending an email to email@example.com.
Personal Information we collect about you. We will use this information for the following legitimate interest and purpose:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site and your browsing experience by ensuring that the content is presented in the most effective manner for you and for your computer;
- to enable your use of our services and other resources available on our site;
- as part of our efforts to keep our site safe and secure; and
- to provide third parties with statistical information about our users. This information will not be used to identify any individual user.
4. DISCLOSURE OF YOUR INFORMATION
We may share your personal information with selected third parties including:
- our business partners, group companies, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
- analytics and search engine providers that assist us in the support, maintenance, improvement and optimization of our site.
We do not sell your personal information or any client data for any purposes, including marketing purposes, but may share it with other professional organizations with which we work in order to provide you services or arrange marketing or other promotional events.
We may disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if TLAS or substantially all of its assets or voting interests are transferred or otherwise acquired by a third party, then personal data held by it about its clients will be one of the transferred assets; or
You further acknowledge that any emails sent to a TLAS email address may be subject to monitoring, either by us, or by a third party service provider engaged by us to provide email services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law
5. WHERE AND HOW WE STORE YOUR PERSONAL DATA
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and if and to the extent they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data when it is under our control, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access such as through the use of network access controls, passwords and access logging.
6. YOUR RIGHTS
Under the federal and state privacy laws in the US and GDPR, to the extent each apply, you have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
7. THIRD PARTY LINKS AND WEBSITES
Our site may, from time to time, contain links to and from the websites, plug-ins and applications of our partner networks, advertisers and affiliates or third party websites. Clicking on those links or enabling those connections may allow third parties to access or collect personal data about you. We do not control these third-party websites and connections and are not responsible or liable for these third parties, accessing them is at your own risk. When you leave our site, we encourage you to read the privacy notice of every website you visit.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure above for further information.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. ACCESS TO INFORMATION
Your right of access can be exercised in accordance with the US federal and state laws and GDPR, in each case, where applicable. You will not have to pay a fee to access your personal data (or to exercise any of the other rights listed above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Please contact email@example.com should you wish to request access to such information or if you have any queries or concerns about our use of any personal data relating to you. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. US STATE CONSUMER PRIVACY LAWS
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, visit https://oag.ca.gov/privacy/ccpa.
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
- Confirm whether we process their personal information.
- Access and delete certain personal information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales.
- Colorado, Connecticut, and Virginia also provide their state residents with rights to:
- Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
- Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise any of these rights or submit an appeal regarding a consumer’s rights request, please contact us at firstname.lastname@example.org.