Privacy Policy

Last Updated: January 1, 2020

Credit Chronometer is operated by Davis+Gilbert LLP (“we” or “us”). We have created this privacy policy ("Privacy Policy") in order to demonstrate our firm commitment to your privacy. The following discloses our information collection and use practices for this Web site ("Web site"). This Privacy Policy does not apply to any other website or service provided by us, our affiliates or clients, unless it appears on such website or service.

By using or accessing this Web site, you signify your agreement to our Privacy Policy. We reserve the right, at our discretion, to change, modify, add or remove portions from this Privacy Policy at any time by posting such changes here. Your continued use of our Web site following the posting of any changes to this Privacy Policy indicates your acceptance of such changes. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY YOU ARE NOT AUTHORIZED TO ACCESS OR OTHERWISE USE THE WEB SITE.

IF YOU ARE SITUATED IN THE EU OR A RESIDENT OF CALIFORNIA OR NEVADA, PLEASE SEE THE SECTIONS “ADDITIONAL EU DISCLOSURES”, “CALIFORNIA CONSUMER RIGHTS” OR “NEVADA PRIVACY RIGHTS” FOR SPECIFIC DISCLOSURES WITH RESPECT TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

OVERVIEW

• We collect Personal Information from you directly that identifies you as an individual when it is voluntarily provided by you, such as your name and email address.
• We automatically collect browsing information and other information from you that does not directly identify you as an individual, but may identify your device, such as information about your browsing activities and information about the devices you use to access our Web site.
• You can access, delete and control certain uses of your information as set forth in the “California Consumer Rights” and “Additional EU Disclosures” sections below.
• Information about our data collection during the prior 12 months is further described below. We intended to collect the same data going forward.

Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified (“Personal Information”).

Information We Collect From You:

When using the Web site, in order to utilize some of the services that may be available, such as, registering for or subscribing to the blog, newsletter, submitting a comment to a blogpost or other forms or information you provide when you contact us, you may be asked to provide, or may choose to provide, certain Personal Information about you, such as your name, address and email address. Your provision of such information to us is completely voluntary; it is not a statutory or contractual requirement. In addition, we may also collect information from you automatically, such as IP host addresses, web pages viewed, browser type, referring pages, usage and browsing habits and similar data.

We may aggregate or deidentify Personal Information we collect in a manner which does not identify any individual ("Aggregate Information"). We reserve the right to use and disclose Aggregate Information in any manner permitted by law except as otherwise provided in this Privacy Policy.

Information Usage:

We will only use your Personal Information as described herein, unless you have specifically consented to another type of use, either at the time the Personal Information is collected from you or through some other form of consent from you or notification to you:

• We may use your Personal Information to respond to your inquiries or requests.
• We may use your Personal Information to send you emails from time to time about our services and to manage our events, but we will not provide your Personal Information to third parties for them to contact you directly unless otherwise permitted by this Privacy Policy or you provide your consent.
• We may permit our vendors and subcontractors to access and process your Personal Information, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.
• We may disclose Personal Information as required by law or legal process.
• We may disclose Personal Information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the terms or policies for our services.
• We may transfer your Personal Information in connection with the sale, merger, reorganization or change of control of Davis+Gilbert or as part of a bankruptcy proceeding.
• We may use and disclose Aggregate Information for any number of reasons.

Cookies and Similar Technologies:

When you visit our Web site, we may track information about your visit and store that information in web server logs, which are records of the activities on our Web site. The servers automatically capture and save the information electronically. Examples of the information we may collect include: your unique Internet protocol address; the name of your Internet service provider; the town/city, county/state and country from which you access our Web site; the kind of browser or computer you use; the number of links you click within the Web site; the date and time of your visit; the web page from which you arrived to our Web site; the pages you viewed on the Web site; and certain searches/queries that you conducted via our Web site. The information we collect in web server logs helps us administer the Web site, analyze its usage, protect the Web site and its content from inappropriate use and improve the user experience.

In order to offer and provide a customized and personal service, we and/or third-party contractors may use cookies, web beacons, clear gifs and similar technologies to store and help track information about you, customize your use of the Web site and for other purposes to make your access more convenient or to enable us to enhance and monitor the Web site. An example of such third party is Google Analytics, which we use to collect and analyze demographic and other information, and through which Google will collect certain information to be used according to Google’s privacy practices. You may opt-out of data collection by Google Analytics as set forth in the "Your Choices, Rights and the Opt-Out Process" section below.

Sharing of Personal Information:

The chart above lists the categories of third parties with which we may share your Personal Information for a business or commercial purpose. We do not share your Personal Information in a manner that constitutes a “sale,” as defined by the CCPA.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for business purposes:

• Personal identifiers
• Personal information covered by the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Internet or other similar network activity

Social Media:

This Web site contains links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Web site. These social media platforms collect information pursuant to their own policies. We do not control their practices, so you should read their policies on their sites. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services, you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

Your Choices, Rights and the Opt-Out Process:

You may opt-out of receiving commercial emails from us at any time by contacting us at privacy@dglaw.com. Please note that there might be a brief delay between when you submit your request to opt-out of such emails and when it is processed and reflected in our systems; accordingly you may continue to receive communications from us for a limited time after you unsubscribe.

To opt-out of the use of Google Analytics, click here.

You can set your browser to notify you when you receive a cookie, flush any cookies that may already be on your computer and/or device or refuse to accept cookies. You should understand that some features of many sites may not function properly if you don’t accept cookies. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Web site or some of its functionality may be affected.

Subject to local law, you may also have certain rights regarding information that we have collected and that is related to you. See “Additional EU Disclosures”, “California Consumer Rights” and “Nevada Privacy Rights” below for more information on your additional rights over the collection, use and disclosure of your information under those jurisdictions.

California Consumer Rights
If you are a California resident (“California Consumer”), under CCPA, you have specific rights regarding your Personal Information. This section describes the rights that you have under CCPA or similar laws under your jurisdiction (if any) and explains how to exercise those rights.

Right to Know About Personal Information Collected, Disclosed or Sold
As a California Consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure or sale of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Access and Deletion Rights”), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:

• The categories of Personal Information we collected about you.
• The categories of sources from which the Personal Information is collected.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).

Deletion Request Rights
You 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 (see “Exercising Access, Data Portability, and Deletion Rights”), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. However, we maybe retain Personal Information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions in accordance with applicable laws, set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.

Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a request to us by emailing us at privacy@dglaw.com.

Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above.

The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the Personal Information or an authorized representative of that person.

For more information about verification, see “Response Timing and Format” immediately below.

Response Timing and Format
We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing. In order to protect the security of your Personal Information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. The method used to verify your identity will depend on the type, sensitivity and value of the information, including the risk of harm to you posed by any authorized access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the Personal Information that we already have.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with a request, or cannot fully comply with a request, the response we provide will also explain the reasons we cannot comply.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.

Nevada Privacy Rights
If you are a Nevada resident, you have the right to request that we do not sell (as defined by N.R.S. 603A) certain personal information that we have collected, or may collect, from you. We do not “sell” your personal information as defined by N.R.S. 603A, however, if you would like to make such a request you may do so by contacting us at privacy@dglaw.com.

Additional EU Disclosures
Grounds for Using Your Personal Data:
We rely on the following legal basis to process your Personal Information:

• It may be necessary for us to use and disclose your Personal Information for the performance and fulfillment of the contract between us and to provide you with our services;
• We may use and disclose your Personal Information where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests;
• If you specifically consent to certain uses of your Personal Information, we may use your Personal Information in a manner consistent with that consent and
• We will also process, transfer, disclose and preserve Personal Information when we have a good faith belief that doing so is necessary.

Data Subject Rights
If you are located in the European Union with rights under the General Data Protection Regulation ("GDPR"), you have the right to withdraw previously provided consent for our processing of your Personal Information by contacting us at privacy@dglaw.com. Such individuals also have the following rights:

• Right to access – This right allows individuals to obtain confirmation that his or her Personal Information is being process and allows individuals to request details of the processing of his or her Personal Information, including, without limitation, categories of recipients to whom the Personal Information have been or will be disclosed and purposes of processing.
• Right to rectify – This right allows individuals to rectify any inaccurate Personal Information about him or her.
• Right to restrict processing – This right allows individuals to block or suppress processing of Personal Information under certain circumstances.
• Right to be forgotten – This right is also known as the "right to erasure." It is an individual’s right to have Personal Information erased or to prevent processing in specific circumstances.
• Right of data portability – This right allows individuals to move, copy or transfer Personal Information from one place to another in a secure manner without interrupting the integrity and usability of the information.
• Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.

Security:

We have put in place reasonable physical, electronic and managerial procedures to safeguard the information we collect; however, due to the inherent open nature of the Internet, we cannot guarantee that all information will be free from unauthorized access by third parties, such as hackers, and your use of the Web site demonstrates your assumption of this risk.

Record Retention:

If you provide us with Personal Information through the Web site, we retain your information for as long as necessary for our business purposes. This may include, but is not limited to, retaining such information to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Information, we may continue to retain and use Aggregate Information previously collected. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

Links to Other Web sites:

This Web site may contain links to other web sites. Please be aware that we are not responsible for the privacy practices of other web sites and by linking to such web sites we are not endorsing their content or practices. We encourage you to be aware when you access any such third-party links and to read the privacy policies of each web site that you access.

Cross Border Transfers:

Our servers are maintained in the United States of America ("USA"). By using the Web site, you freely and specifically give us your consent to export and store your Personal Information in the USA. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA. We may transfer Personal Information from the European Economic Area and Switzerland to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. Personal Information of European Union residents will be transferred in compliance with the requirements of the GDPR.

Web Site Terms and Conditions:

Use of this Web site is governed by the provisions contained in the Terms and Conditions. Your use, or access, of the Web site constitutes your agreement to be bound by those provisions. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS YOU MAY NOT ACCESS OR OTHERWISE USE THE WEB SITE.

Contact:

For questions or concerns relating to privacy, we can be contacted at: privacy@dglaw.com. If you are located in the European Union with rights under the GDPR and have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority.