Last Updated: December 12, 2019
Rogers Joseph O’Donnell (“we,” “us,” “our” or “RJO”) is committed to protecting your privacy. This Privacy Policy describes our online and offline data practices, including the rights that you have relating to your personal information. If you have any questions about the Privacy Policy or would like to submit requests relating to your personal information, please contact us at privacylaw@rjo.com, or as otherwise provided in the CONTACT US section below. We may revise this Privacy Policy from time to time and in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law.
Collection of Personal Information
Personal Information is information that can directly or indirectly identify you as an individual. We collect your Personal Information when you voluntarily choose to disclose such information to us, such as when you sign up for RJO sponsored events, elect to receive our newsletters, or submit job applications. We may also obtain Personal Information from other sources, such as your online professional profile or personal references. The categories of Personal Information we collect include:
- Name (first and last)
- E-mail address
- Postal address
- Telephone and facsimile numbers
- Employment history
- Educational background
Cookie Policy
Cookies are small text files placed on your device by your web browser and enable websites to remember your actions, preferences, and other session information related to your visits. We use cookies and other tracking technologies to collect certain information about you through automatic means, such as when you visit our website (www.rjo.com), social media page, or other linked sites (collectively, the Websites). We also utilize tools provided by Google, including Analytics and Search Console, to assess traffic and use patterns on our Websites. If you sign up for our e-mail newsletter, we use an embedded image to track whether you open our e-mail.
We use cookies on our Websites to collect the following categories of information:
- IP address
- Browser type
- Operating system
- Referring URL
- Content viewed
We collect the information above to help deliver basic functions on our Websites, such as page navigation, as well as to understand user traffic on our Websites. We collect and retain this information in de-identified and aggregate form. You can control what cookies you allow on our Websites by selecting your preferences in your web browser settings. Be advised that if you change your settings to block certain cookies, some features on our Websites may not operate as intended. We do not support the Do Not Track browser option.
We also provide links to content hosted on external sites, such as our profile on the LinkedIn platform or articles posted on news organization sites. When you click on links that direct you to external content, the providers of that content may place their own cookies on your device, access existing cookies that you previously set for other websites, or otherwise gather information about you. Please refer to the privacy policies and notices on those providers’ respective websites to learn more their data practices. RJO does not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications.
How We Use Your Personal Information
We collect and use your Personal Information for various legal and legitimate interests, including the following purposes:
- Provide legal services to our clients;
- Respond to your questions, comments, and requests, including delivery of newsletters and client alerts you sign up for;
- Send you information related to the services you request, including confirmations, receipts, updates, and reminders;
- Manage our business relationships with our clients, business partners, vendors, cooperating law firms, or other contractors, such as to process invoices;
- Assess job applications and make hiring decisions;
- Operate and improve our Websites;
- Monitor and analyze user traffic, trends, and activities across our Websites;
- Ensure internal quality control;
- Detect, prevent, and respond to security risks;
- Comply with applicable laws, regulations, guidelines, and internal RJO policies.
Sharing of Personal Information
We do not sell your Personal Information. In limited circumstances, as described below, we may share your Personal Information as needed to run our business and provide services, and where required for legal compliance purposes:
- Service Providers. We may share Personal Information with our third-party service providers, including payment processors, event management hosts, database and other IT consultants, and vendors that support RJO’s Websites and related marketing services. We do not use or share Personal Information for direct marketing purposes without your permission.
- Affiliates and Business Partners. We may provide Personal Information to affiliated companies and business partners with whom we jointly offer products or services. In such cases, our affiliate’s or business partner’s name will appear along with RJO’s.
- Merger, Sale, or Other Asset Transfers. If RJO is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then we may sell or otherwise transfer your Personal Information as part of the transaction, as permitted by law and/or contract.
- Legal Purposes. We will disclose your Personal Information outside of RJO when required by law, subpoena, or other legal process. In such circumstances, we may, and you authorize us to, share information with the requesting government agency or investigatory body, including law enforcement or regulatory authorities.
Your Rights
We will collect and use your information as described in this Privacy Policy, which includes your rights to control the collection, use, and sharing of your data, as provided below:
- Delete your data. You can request erasure or deletion of all or some of your Personal Information, subject to certain exceptions prescribed by law.
- Change your data. You may request that we change, update, or fix your Personal Information in certain cases, including correcting inaccuracies. In some cases, we may provide self-service tools that enable you to directly update your Personal Information.
- Object to, limit or restrict use of your data. You can ask us to stop using your Personal Information in certain cases, in which case RJO will cease processing some or all of your Personal Information in accordance with applicable laws.
- Right to access your data. Consistent with legal requirement, you may request access to a copy of the Personal Information we have on file for you. In some cases, you may have the right to receive or have your Personal Information electronically transferred to another party.
- Supervisory authority. If you are located in the European Economic Area or the UK, you may have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.
To exercise your rights of access and control, please contact us as provided in the CONTACT US section below. We strive to respond to all legitimate requests promptly and will contact you if we need additional information. Please be advised that we will take steps to verify your identify in response to each request.
Data Security
We use appropriate and reasonable security measures as required by relevant law and security best practices. We also regularly monitor our systems for possible vulnerabilities and attacks. However, no system is 100% secure. We cannot warrant the security of any information that you send to us, and we cannot guarantee that your Personal Information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
By using our Websites or providing Personal Information to us, you agree that we may communicate with you electronically regarding any security, privacy, and administrative issues. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Websites, or contact you by mail or e-mail.
Data Retention
We retain your Personal Information over the course of your use of our Websites and services, and as further needed to fulfill the purpose(s) for which it was collected. We also store your Personal Information for as long as we have a lawful basis for the continued retention or processing, including legitimate interests where the processing of Personal Information is not overridden by your interests or fundamental rights. These include resolution of disputes, enforcement of our agreements, and compliance with applicable laws. These bases are subject to your rights to access and control your data, as described in this Privacy Policy.
Children’s Information
Our Websites and services are not directed to children under 18 (or other age as required by local law). We do not knowingly collect Personal Information from children. If we learn that we have collected any Personal Information from children in violation of applicable laws, we will promptly take steps to delete such information.
Contact us
If you have any questions about the Privacy Policy or would like to submit requests relating to your Personal Information, please contact us as:
Rogers Joseph O’Donnell, PC
311 California Street, 10th Floor
San Francisco, CA 94104-2695
privacylaw@rjo.com
415.956.2828