Lite DePalma Greenberg & Afanador, LLC (“LDGA,” “we,” “our,” or “us”) provides this Privacy Policy (“Policy”) to describe how we collect, use, store, share and transfer personal data in the course of our business.

In using our website at https://www.litedepalma.com/ (the “Site”) or otherwise corresponding with us, you consent to our collection, use, disclosure and international transfer of personal data in accordance with the terms of this Policy. Where you engage us to provide legal services, we will provide you separately with a copy of our client privacy policy which will apply to data obtained in the course of that relationship. 

Where we hold personal data, LDGA will act as a data controller and will be responsible for determining the permitted purpose, extent and means of any processing of that data.

You have the right at any time to obtain confirmation of personal data we hold about you, verify its contents or request that such data be updated, restricted or erased as explained in the Your Choices & Rights In Personal Data section below.

This Policy sets out our practices related to:

1. Personal Data Collection & Purposes
2. Grounds for Processing Personal Data
3. Personal Data Sharing
4. Digital Analytics
5. Third Party Links & Tools
6. Transfers of Personal Data
7. Retention of Personal Data
8. Your Choices & Rights In Personal Data
9. California Privacy Rights
10. Changes to This Policy
11. Contact Us

1. Personal Data Collection & Purposes

• Data you provide to us: You may choose to provide us with personal data when you are introduced to us, in person, by phone, email, or via social media or our Site. This may include data that can be used to identify you or that we can link to you, including your name, contact information, job title and any associated organization and any other information which LDGA may use to identify you in relation to our services. This data may fall into the following categories: 
  • Correspondence, events and updates – we may process data contained in or relating to any communication which you send or otherwise provide to us including for the purposes of subscription to our newsletters and other publications; registration for seminars and other events; recruitment; maintaining our list of contacts; and other purposes.
  • Enquiries relating to our services - we may process data contained in any enquiry that you submit to us indicating your interest in our services or any position with the firm, including the contents of your enquiry and any contact details. We process such data for the purposes of responding to your enquiry and updating you in relation to our services where appropriate, unless you indicate to us that you no longer wish to hear from us.
  • Contract information – where we enter into a contract to provide legal services to you or for the provision of third-party services to the firm, we may process personal data for the purposes of that contract and our related business services. This may include personal data contained within contract-related correspondence, data provided for the purposes of the contract and/or transactional data and bank account information for the purposes of supplying and receiving services, making payments and record-keeping.  
  • Data we collect automatically: Certain data may automatically be collected when you use our Site via cookies or similar technologies. This may include your computer's browser type, operating system and IP address, as well as the date and time of your visit, geographic location and information about your navigation and use of the Site, including the pattern and length of your use and referral source. We use this data to evaluate Site use, assess and improve Site performance, provide information we think will be of interest to you, and improve our services. 
  • Data we collect from third-party sources: We may obtain information about you from public sources or from third parties which we may use to help us update and analyze our records, identify potential new clients, and for compliance and regulatory checks.

2. Grounds for Processing Personal Data

We rely on the following legal grounds to process personal data depending on the purpose for which it has been obtained:

• Performance of a contract – where processing is necessary to perform our obligations under a contract with you or your organization or to take steps at your request prior to entering into a contract with you. This may involve processing of personal data provided in correspondence, enquiries and for the purposes of contracts and transactions. 
• Consent – where you have expressly consented to use of data for a specific purpose, including subscription to our newsletters, updates or invitations to our events.
• Legitimate interests – where processing is necessary for the purposes of our legitimate interests or those of any third-party recipients that receive personal data from us, provided that such interests are not overridden by your own interests or fundamental rights and freedoms. This basis may be relied on for the purposes of:
  
  • responding to correspondence and enquiries and developing our business with interested parties by keeping in touch; 
  • use of transactional data for the purposes of making and receiving payments and pursuing recovery of debts as necessary;
  • business data analysis to assess the effectiveness of our services;
  • detecting, preventing and responding to actual or potential fraud or other illegal activities or intellectual property infringement;
  • operation of our IT and data security systems, including backups to ensure the resilience of our IT systems and the integrity and recoverability of our data; and
  • protecting and asserting our legal rights and those of others in relation to legal claims.
• Compliance with legal obligations or protection of vital interests - we may process any personal data we hold where reasonably necessary or appropriate for compliance with our legal obligations, including record keeping and regulatory requirements, or to protect the vital interests of a data subject or other individual.

3. Personal Data Sharing

We may share your personal data with our employees, partners and consultants on a confidential basis where required for the provision of our legal services, internal administration, billing, compliance and reporting, promoting our events and services, and other business purposes.

In addition, we may share your personal data with the following types of third parties for these business and commercial purposes:

• with third-party service providers for the purposes of our litigation services;
• with third party service providers, including data hosting providers, IT and marketing consultants, payment processing providers, and other suppliers of business and administrative services, including debt recovery;
• with third party service providers for fraud and crime prevention purposes, including to prevent money laundering and conduct compliance and reference checks;
• with our insurers and professional advisors as is necessary for the purposes of obtaining and maintaining insurance coverage, obtaining professional advice, managing legal disputes, maintaining account records and conducting financial audits; and
• with any third party to whom we assign or novate any of our rights or obligations in the event that any part of our business is sold or transferred to or integrated with another organization.  

We share information with third-party service providers pursuant to contractual arrangements which require that the information be processed in accordance with our instructions for specified purposes and in compliance with applicable law.

LDGA reserves the right to disclose any personal data it holds where necessary: a) to appropriate courts, law enforcement authorities, governmental or regulatory authorities, if required to do so by law or regulation or by any governmental or law enforcement agency; and b) in order to protect the vital interests of the data subject or of any other individual. 

4. Digital Analytics

We may work with third parties that collect data about your use of the Site and other sites over time for non-advertising purposes. We use Google Analytics and other third-party services to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

5. Third-Party Links & Tools

We use reasonable administrative, technical and physical measures to keep your personal data confidential and secure, in accordance with our internal procedures to protect it from being accidentally lost, altered, used, accessed or disclosed in an unauthorized way. Personal data may be held on our data technology systems, those of our third-party contractors and/or in paper files. Where we share information with third parties, we will obtain written confirmation that they will similarly protect the data with appropriate safeguards.

Although we do our best to ensure the security of your personal data and to use only reputable service providers, unfortunately no information system can be 100% secure and we cannot guarantee the absolute security of your information. In particular, we will not be responsible for the security of any information which you transmit to us over networks that we do not control including the internet and wireless networks. We have 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. If you follow any link from our Site to a third-party website or interact with any third-party entity referenced on our Site, please be aware that these third-party websites and entities are not governed by this Policy and will have their own privacy terms. We are not responsible for the data practices of other websites and entities or their use of any personal data you share with them. We encourage you to read and understand the policies of every website that you visit.

This Site also includes integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Site, these companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. LDGA is not responsible for the information practices of the companies that provide these features. We encourage you to carefully read the policies related to any online accounts you create and use.

6. Personal Data Transfers

As LDGA operates globally, we may transfer your personal data abroad for storage or processing where required for any of the purposes set out above, including to any of the countries in which LDGA and its affiliates, agents or contractors have offices. When doing so, we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal data. Where we use third-party service providers, we will put in place confidentiality agreements, including appropriate data protection obligations. 

Users of this Site who are based in the UK or the European Economic Area (“UK/EEA”) should be aware that personal data you provide to LDGA may be transferred to countries outside of the UK/EEA (including the United States). These countries may not have the same standard of data protection as those inside the UK/EEA. For the purposes of processing personal data related to you, we will ensure a data protection level equivalent to the minimum level within the UK/EEA, including by entering into the EU Standard Contractual Clauses (“SCCs”), or by similar protective measures.

7. Retention of Personal Data

We delete personal data when it is no longer reasonably required for the permitted purposes for which it is held or when you withdraw your consent (where applicable), so long as we are not legally required or otherwise permitted to continue storing the data. Where necessary, we will retain personal data where it may be required for LDGA to assert or defend any legal claims or otherwise assert our rights or those of third parties until the end of the relevant retention period or until any claims have been resolved. We will also retain personal data where necessary to comply with our legal obligations, regulatory requirements and reporting obligations. We may also hold data in backup systems put in place to maintain the integrity of our IT systems for the minimum retention periods. 

8. Your Choices & Rights In Personal Data

If you no longer wish to receive updates and communications from us, you can let us know by sending us an email using the contact details provided in the Contact Us section below. To opt out of our email marketing, you can use the link provided at the bottom of each marketing message. If you opt out of our email marketing, we will still send you messages related to our transactions and relationship with you.

You may request to exercise the following rights in regards to personal data we collect and maintain about you, subject to limitations and exceptions under applicable law:

• The right to know the categories of personal data which we hold about you, the purposes for which we process the data and any third parties with whom it is shared.
• The right to request a copy of personal data we maintain about you, provided the rights and freedoms of others are not affected by our compliance with such a request.
• The right to request an update or correction to any personal data we hold about you, and to object to or ask us to restrict the processing of that personal data for particular purposes. You may object to the processing of personal data for direct marketing purposes and withdraw consent you have previously given to us stage by emailing epalomino@litedepalma.com or using the other contact details provided below. We may not comply with an objection or request to restrict processing of personal data if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, including our compliance with legal obligations and for the purposes of legal claims.
• Where the personal data is no longer necessary for the purposes for which it was collected, you may have the right to request that it be erased. Note that we may not comply with such requests where the relevant data is necessary for other purposes, including compliance with a legal obligation or in connection with potential legal claims.
• Where we hold personal data with your consent or for the performance of a contract with you and processing is carried out by automated means, you may have the right to receive personal data we maintain about you in a portable format so that it can be transferred to an alternative third-party provider, provided doing so would not adversely affect the rights and freedoms of others.
• The right to lodge a complaint related to our personal data practices with the appropriate supervisory authority. Details for the relevant authority in relation to the LDGA entity in your jurisdiction is provided in the Contact Us section below.

If you wish to exercise any of these rights in relation to personal data we hold about you, please contact us by email or post using the contact details below. 

9. California Privacy Rights

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.

Personal Information We Collect. In the preceding 12 months, we collected and disclosed the following categories of personal information about California consumers.

Categories of Personal Information	Disclosed for business purposes to the following categories of third parties:
Personal and online identifiers (such as first and last name, email address, or unique online identifiers)	All categories listed below.
Categories of information described in Section 1798.80(e) of the California Civil Code (such as bank account number, credit card number, debit card number, or any other financial information)	All categories listed below.
Commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered)	All categories listed below.
Internet or other electronic network activity information (such as search history and interactions with our website)	All categories listed below.
Geolocation information (such as IP address)	All categories listed below.
Professional or employment-related information	All categories listed below.
Inferences drawn from the above information about your predicted characteristics and preferences	All categories listed below.
Other information about you that is linked to the personal information above	All categories listed below.

Some of the categories of personal information listed above are considered sensitive personal information under the CCPA. We do not use or disclose sensitive personal information, as defined by the CCPA, for purposes other than those specified in the CCPA.

Categories of Sources. We collect personal information from the following categories of sources:

• Consumers;
• Our clients;
• Advertising networks;
• Internet service providers;
• Data analytics providers;
• Social networks;
• Operating systems and platforms;
• Data brokers;
• Other service providers;
• Affiliates not under the LDGA brand;
• Nonprofit organizations; and
• Government entities.

Why We Collect, Use, and Disclose California Information.  We use and disclose the personal information we collect for our commercial and business purposes, as further described in the Personal Data Collection & Purposes and Personal Data Sharing sections above.

Recipients of California Personal Information.  We do not “sell” or "share" personal information we collect.

We disclose the categories of personal information designated above to the categories of recipients listed below for business purposes:

• Affiliates and business partners;
• Service providers;
• Government entities;
• Internet service providers;
• Data analytics providers;
• Operating systems and platforms; and
• Social networks.

Retention of California Personal Information. We retain the personal information we collect for as long as reasonably necessary to accomplish our purposes for collection, described further in the Retention of Personal Data section above.

Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding personal information we have collected or maintain about you, subject to certain exceptions and limitations:

• The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you; the categories of sources from which we collected personal information about you; our purposes for collecting or selling personal information about you; the categories of personal information about you that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
• The right to request that we delete the personal information we have collected from you.
• The right to request correction of inaccurate personal information we maintain about you.
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

• by email to epalomino@litedepalma.com or
• by post to Lite DePalma Greenberg & Afanador, LLC, 570 Broad Street, Suite 1200, Newark, New Jersey 07102

Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. Generally, we verify your identity by matching the information provided in your request with the information we maintain in our records. We will require you to provide, at a minimum, your name and email address.

Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by designating such an agent in writing or through a power of attorney. We will require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.

Minors’ Rights. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

10. Changes to This Policy

We may revise and update this Policy from time to time to reflect any changes in our personal data processing practices, or changes in applicable legal requirements or regulatory guidance. We will publish the updated Policy on this page. You should review this page periodically to ensure that you are aware of any change to its terms.

From time to time, LDGA may offer additional services via additional web pages or through separate websites linked to this website. In some cases, such additional services may be subject to alternative terms of use, including the use of personal data. If you choose to use any such services and provide personal data in doing so, we will ask you to consent to such alternative terms of use and the specified processing purpose. Unless otherwise stated, such alternative terms of use shall supplement this Policy.

11. Contact Us

If you require any further information or would like to contact us with any queries or comments, please contact the appropriate LDGA entity using the contact details below. 

• by email to epalomino@litedepalma.com or
• by post to Lite DePalma Greenberg & Afanador, LLC, 570 Broad Street, Suite 1200, Newark, New Jersey 07102