Last Updated: November 5, 2024
Edge 365, PLLC (“Edge 365”, “we”, “us”, and “our”) provides comprehensive legal services to small, medium and large private and publicly-traded companies. This privacy policy (“Privacy Policy”) describes how we collect, use, and share personal information through our website, our Edge 365 mobile applications (“Apps”), and in connection with blogs, alerts, newsletters and other communications and events we offer (collectively, the “Services”). This Privacy Policy explains the kinds of information we may collect and how we intend to use and share that information. This Privacy Policy does not address our processing of personal information in connection with our attorney-client relationships, which are addressed in our engagement agreements with our clients.
NOTICE AT COLLECTION
At or before the time of collection, California residents may have a right to receive notice of our privacy practices, including the categories of personal information to be collected, the purposes for which such information is collected or used, whether such information is “sold” or “shared” and how to opt-out of such uses, and how long such information is retained. You can find those details in the section titled “SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS” as set forth below in this Privacy Policy.
PERSONAL INFORMATION WE COLLECT
Our primary goals in collecting personal information are to provide and improve the Services, to administer your use of the Services, and to provide you with information that you request from us via your use of the Services, including, but not limited to, the provision of information about Edge 365 hosted events, the delivery of our email “legal updates” to subscription groups and responding to queries about, or applications for, job listings. If you are a job applicant, please review our “JOB APPLICANT PRIVACY POLICY” as set forth below in this Privacy Policy, which is incorporated herein by reference.
Information You Provide to Us
Subscriptions and Other Content. When you subscribe to receive alerts, newsletters, surveys or event announcements or register to receive certain content and/or templates we may make available, we collect your name, title, email address, company name, company office address, work phone number, and other business card information.
Account Creation. Clients may gain online access to certain client records hosted by Edge 365 or certain content and/or templates we may make available. To access these online records, we will collect the username and password from the client.
Your Communications with Us. We collect personal information from you such as your email address, phone number, or mailing address when you request information about our legal services and expertise, subscribe to our client alerts, register to attend a webinar or event, request customer or technical support, apply for a job or otherwise communicate with us.
Interactive Features. Our Services may include publicly accessible blogs, forums, social media page, commenting functionalities, and messaging and chat features, (“Interactive Features”). Any information you provide using the Interactive Features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. In addition, social media buttons such as Facebook, LinkedIn, Instagram, and X (that might include widgets such as the “share this” button or other interactive mini programs) may be on our website. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our website. Your interactions with these features apart from your visit to our website are governed by the privacy policy of the company providing it.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Social Media Content. We may offer forums, blogs, or links to social media pages such as X, LinkedIn, Facebook and Instagram. Any content you provide on these channels will be considered public, and we may use this information to tailor our engagements with you, for example, providing you with details of events or legal updates we think may be relevant to you.
Conferences, Trade Shows, and Other Events. We may collect personal information from you when you attend or we host conferences, recruiting events, and other events.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Information Collected Automatically or From Others
Automatic Data Collection. We may collect certain information automatically when you use the Services including information collected when you search for an Edge 365 professional, open a client alert, view a video, publication or blog and use our Services. This information may include your internet protocol (IP) address and inferred information such as company, area code, postal code and country; user settings; cookie identifiers and similar technology; mobile carrier; mobile advertising and other unique identifiers; details about your browser, operating system or device information; location information and inferred metro area and city); and internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using the Services including information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your information with information that other people provide when they use our Services.
Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising. We, as well as third parties that provide advertising and analytics services to us, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.
Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application or site, such as an app store or a social networking site, we may collect information about you from that third-party site that you have made public via your privacy settings. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, and Services.
HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to:
Provide you with our Services, such as:
Analyze and improve our Services pursuant to our legitimate interest, such as:
Provide you with additional content and Services, such as:
Where European Union data protection laws apply, such as the General Data Protection Regulation, we will process your personal information for the purposes described above and for marketing, described below, where we have a lawful basis to do so. For example, for processing necessary to provide you with the Services, the lawful basis will generally be that it is necessary for the purposes of performing our contract with you. For marketing, described below, we may send you marketing based on it being in our ‘legitimate interests’ to do so (where you are a corporate customer) or based on consent where you are acting in an individual capacity. Other processing that we do, such as that for service development and improvement, may not be ‘necessary’ to provide the Services but may still be necessary for our ‘legitimate interests’ of running a business and offering the Services.
If you have any questions about our marketing practices, you may contact us at any time as set forth in our “CONTACT US” section below.
Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.
Process Information on Behalf of Our Clients. Our clients may choose to use our Services to process certain data of their own, which may contain personal information. The data that we process through our Services is processed by us on behalf of our client, and our privacy practices will be governed by the engagement letters or other arrangements that we have in place with our clients, not this Privacy Policy.
If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity, who has contracted with us to use the Service to process this data. Our clients control the personal information in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to our clients to address any concerns you may have, in accordance with the terms of our contract with them. If you are a client and wish to receive a list of our sub-processors, contact us as described below.
Automatic Collection Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:
See “YOUR PRIVACY CHOICES AND RIGHTS” below to understand your choices regarding these Technologies.
Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.
Notice regarding Third Party Websites and Social Media Platforms. The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. As such information will be public, the personal information provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Facebook, LinkedIn, Instagram and X (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.
DISCLOSING YOUR INFORMATION TO THIRD PARTIES
Except as provided below, we do not disclose or sell your personal information with the following categories of third parties.
Service Providers. We may share any personal information we collect about you with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, data hosting, website development and operation, and related services; payment processing, customer service, and related services.
Business Partners. We may provide personal information to business partners to provide you with the products or services you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
Affiliates. We may share personal information with our affiliated corporate entities.
Advertising Partners. Through our Services, we may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements for Edge 365 to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below under “YOUR PRIVACY CHOICES AND RIGHTS” or, if you are a California resident, by following the opt-out instructions described under the “SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS”section.
Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
International Data Transfers. All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
For more information about the safeguards, we use for international transfers of your personal information, please contact us as set forth below.
YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.
Email and Telephone Communications. If you receive an unwanted promotional email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding our Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our terms or this Privacy Policy).
We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, contact us as set forth below. We will process such requests in accordance with applicable law. To protect your privacy, we will take steps to verify your identity before fulfilling your request. If applicable laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.
DATA RETENTION
We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents supplements our Privacy Notice and only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information we have collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider), whether we “sold” that personal information, and whether we “shared” that personal information for “cross-context behavioral advertising” in the preceding 12 months. California residents can find this information below:
Categories of personal information disclosed Categories of third parties to whom this
for our business purposes information was disclosed
- Identifiers - Service providers and business affiliates
- Financial information - Service providers and business affiliates
- Commercial information - Service providers and business affiliates
- Internet or other electronic network activity - Service providers and business affiliates
information
- Professional or employment-related information - Service providers and business affiliates
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “PERSONAL INFORMATION WE COLLECT”, “HOW WE USE YOUR INFORMATION”, and “DISCLOSING YOUR INFORMATION TO THIRD PARTIES” above, respectively. We will retain personal information in accordance with the time periods set forth in “DATA RETENTION”.
Additional Privacy Rights for California Residents
Opting Out of “Sales” of Personal Information and/or “Sharing” for Cross-Context Behavioral Advertising under the CCPA. California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.” California residents may exercise these rights by emailing privacy@edge365.ai.
Disclosure Regarding Individuals Under the Age of 16. Edge 365 does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Edge 365 does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”
Disclosure Regarding Sensitive Personal Information. Edge 365 only uses and discloses sensitive personal information for the following purposes as permitted under the CCPA:
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To authorize an agent, please contact us as set forth in the “CONTACT US” section below, provide written authorization signed by you and your designated agent and ask us for additional instructions.
Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling request submitted under the CCPA. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to provide the first name, last name, email address, company name and country. We’ll also ask for your phone number and job title if applicable to the contact information we have on file.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in the “CONTACT US”section below. We will process such requests in accordance with applicable laws.
Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this Privacy Policy, please do so from your web browser or by saving the pages as a PDF.
SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us at privacy@edge365.ai.
CHILDREN’S INFORMATION
The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information in violation of applicable law, we will delete any personal information.
SUPERVISORY AUTHORITY
If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
CHANGES TO OUR PRIVACY POLICY
We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.
CONTACT US
If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at privacy@edge365.ai.
EDGE 365, PLLC
California Consumer Privacy Act (“CCPA”) Applicant Privacy Notice
This CCPA Privacy Notice applies to personal information of employees and job applicants that Edge 365, PLLC (“Edge 365”, “we”, “us”, and “our”) collects and processes in the course of our human resources operations, from submission of an application, throughout the course of an individual’s employment, and following employment (collectively, “Human Resources Operations”). This CCPA Privacy Notice explains the kinds of information we may collect and how we intend to use and share that information.
PERSONAL INFORMATION WE COLLECT
The personal information we collect may include (a) identification and contact information, such as name, address, phone number, email address, date of birth, passport number, driver’s license number, social security number or other government‐issued identification number; (b) employment history; and (c) education and professional qualifications, employee compensation, financial information related to credit checks, bank details for payroll, information that may be recorded on a resume/CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy.
We may also collect sensitive personal information such as details of health and disability, including medical information, health insurance information, mental health, medical leave, and maternity leave; information about national origin, immigration status, and other characteristics of protected classifications under California or federal law; and optional demographic information such as race or veteran status, which helps us achieve our diversity goals.
We may collect or receive information about you from other sources, including through third party services and organizations, to supplement information provided by you. For example, where permitted by law, we may utilize consumer reporting agencies to conduct background checks on you prior to your employment with Edge 365. Personal information provided to us by a consumer reporting agency allows us to verify information that you have provided to Edge 365.
Use of Edge 365 Information Technology Systems and Networks. Edge 365 may collect certain information automatically through the course of your employment, such as your internet protocol (IP) address, inferred location based on your IP address or activities, device identifiers associated with your computer or device, mobile carrier and related information, activity logs, and other information about activities you engage in through the use of Edge 365 property, equipment, accounts, systems and/or networks.
Edge 365 may monitor and review, and there is no expectation or right of privacy in connection with, employee use of Edge 365 equipment, accounts, information technology systems and networks, including its phone networks, computer networks, including those used to access the internet, videoconferencing systems and other Edge 365-provided electronic communications tools. Edge 365 may access and review electronic files, messages, and emails sent or stored on its information technology systems, including accounts, computers and devices provided to employees.
HOW EDGE 365 USES YOUR INFORMATION
We collect and utilize personal information, and share it with third parties, only for legitimate business purposes, including in connection with the following:
· To collect information from your managers, peers, professional staff or other employees regarding your interactions with them (e.g., performance reviews and surveys);
· To communicate with you about the application process and/or your application;
· To assess your suitability, aptitude, skills, qualifications, and interests for employment with Edge 365;
· To take steps at your request prior to entering into an employment contract with you (for example, after we have sent you an offer, we need to process certain personal information in order to enter into and then perform the contract of employment);
· Workflow management, including assigning, managing and administering projects;
· Personnel administration and communication;
· Payroll and the provision of benefits;
· Compensation, including bonuses and long‐term incentive administration, compensation analysis, including monitoring overtime and compliance with labor laws, and Edge 365 recognition programs;
· To protect our legitimate interests (for example, fraud prevention, network and information security);
· Job grading activities;
· Performance and employee development management;
· Organizational development and succession planning;
· Benefits and personnel administration;
· Absence management;
· Helpdesk and IT support services;
· Internal and/or external or governmental compliance investigations;
· Internal or external audits;
· Where it is necessary for the establishment, exercise, or defense of legal claims;
· Diversity and inclusion initiatives;
· Restructuring and relocation;
· Emergency contacts and services;
· Employee safety;
· To comply with our legal obligations;
· Processing of employee expenses and travel charges;
· Acquisitions, divestitures, and integrations; and
· As you otherwise agree or consent.
POTENTIAL DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust personal information include service providers for: (i) provision of IT and related services; and (ii) processing to maintain our Human Resources Operations.
Affiliates and Subsidiaries. Edge 365 may share personal information with our affiliates and subsidiaries and successors for legitimate business purposes.
Displaying to Other Individuals. If you post personal information on Edge 365’s intranet hosted sites, such information will be accessible to other Edge 365 personnel.
Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) to enforce Edge 365 policies and contracts; (iv) to collect amounts owed to us; (v) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
DATA RETENTION
Edge 365 retains the personal information we receive as described in this CCPA Privacy Notice for as long as necessary to fulfill the purpose(s) for which it was collected, carry out our Human Resources Operations, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
CHANGES TO OUR CCPA PRIVACY NOTICE AND PRACTICES
We may modify this CCPA Privacy Notice from time to time in our sole discretion, and we will notify you in the event we implement material changes. If we would like to use your previously collected personal information for different purposes than those that we notified you about at the time of collection, we will provide you with a new notice and, where required by law, seek your consent, before using your personal information for a new or unrelated purpose. You understand and agree that you will be deemed to have accepted the updated CCPA Privacy Notice if you continue your employment with Edge 365 after the new CCPA Privacy Notice takes effect. If at any point you do not agree to any portion of the Privacy Notice in effect, you must immediately contact Edge 365’s human resources department at hr@edge365.ai.
CONTACT US
If you have any questions about our privacy practices or this CCPA Privacy Notice, or if you wish to submit a request to exercise your rights as detailed in the Privacy Policy or this CCPA Privacy Notice, please contact us at privacy@edge365.ai.
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