Website Privacy Notice
May 18, 2018
Barnes & Thornburg LLP (“Barnes & Thornburg” or “we”) is committed to protecting your information. We act in accordance with applicable data protection and privacy laws when we collect and use information about you and strive to protect this information for you.
This Website Privacy Notice (the “Privacy Notice”) applies to your use of Barnes & Thornburg’s websites (collectively the “Websites”) and describes how Barnes & Thornburg collects, uses, and shares your information when you visit our Websites.
Barnes & Thornburg LLP has offices throughout the United States, including at 11 South Meridian Street Indianapolis, Indiana 46204. Should you have any comments or questions about how we collect and use your personal information, communication can be directed to Barnes & Thornburg’s postal address, via email to email@example.com, or by telephone to (317) 236-1313 to the attention of the Office of the General Counsel.
Applicability & Eligibility
This Privacy Notice applies to the Websites, and Barnes & Thornburg’s collection, use, disclosure, and protection of your data. It does not apply to third party websites, applications, or services. Before accessing, using, or interacting with the Websites you should carefully review the terms and conditions of this Privacy Notice.
By accepting our Privacy Notice, you are confirming that you have read and understand these policies, including how and why we use your information. If you don’t want us to collect or process your personal information in the ways described in this Privacy Notice, you should not use the Websites.
The Websites are not directed to children under the age of 18. You may not use the Websites if you are under the age of 18. If you are under the age of 18, you should not provide any information on our Websites.
Information Collection & Use
Barnes & Thornburg collects information about you and your use of the Websites through various means, including when you provide information to us and when we automatically collect information about you when you access, use, or interact with the Websites. Such processing is utilized to provide the Websites to our visitors. By accepting our Privacy Notice, you are confirming you have read and understand our policies including how and why we use your information.
Where we process your information on the basis of consent, we will clearly obtain your opt-in consent. Where given, you may withdraw your consent at any time by contacting us at firstname.lastname@example.org. Where we process your information on the basis of legitimate interests, we do so to pursue the legitimate interests of providing the function or service you requested.
The types of information Barnes & Thornburg may collect about you include:
Information You Provide To Us:
We generally process information you provide to us on the legal basis of Barnes & Thornburg’s legitimate interests in performing the function or service you requested. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing.
Marketing Communications: When you sign-up for or subscribe to our marketing communications, we ,collect your name, email address, and postal address. We use your information to send you updates that may be relevant to you regarding legal and regulatory developments, firm-related events, activities, and news. We process your information on the basis of legitimate interests, or where we obtain your affirmative consent, on the basis of that consent.
We do not share or sell any personal information to other organizations for commercial purposes.
If you do not want to receive communications from us in the future, please let us know by sending us an email requesting the same to email@example.com or by following the unsubscribe instructions found in any email we send. Please note requests to remove your email address from our lists may take some time to fulfil. We may also still contact you as needed to provide important announcements or notifications regarding the Websites.
If you supply us with your postal address on-line, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by contacting us at firstname.lastname@example.org or by calling our phone number provided above.
Support Information: You may provide information to us via a support request submitted through the Websites. We will use this information to assist you with your support request and may maintain this information to assist you or other users with support requests. Please do not submit any information to us via a support submission, including confidential or sensitive information that you do not wish for Barnes & Thornburg or our service providers to have access to or use in the future. We process your information in this instance on the basis of legitimate interests to provide the support requested.
Form Information: We may use forms to request certain information from you on the Websites, such as your contact information to assist with contacts or service requests. This information may include personal data. We process your information in this instance on the basis of legitimate interests to process the information you provide.
Information We Collect Automatically:
We use automatic data collection and analytics technologies to collect aggregate and user-specific information about your equipment, domain name, patterns of use, communication data and the resources that you access and use on the Websites, including your IP address, browsing and navigation patterns. This information is used to improve our Websites. We generally process information collected automatically on the basis of Barnes & Thornburg’s legitimate interests in assessing the use of its Websites. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing.
Unique Identifiers: When you use or access the Websites, we may access, collect, monitor, store on your device, and/or remotely store one or more "Unique Identifiers," such as a universally unique identifier (“UUID”). A Unique Identifier may remain on your device persistently, to help you log in faster and enhance your navigation through the Websites. Some features of the Websites may not function properly if use or availability of Unique Identifiers is impaired or disabled.
Analytics Information: We use data analytics to ensure site functionality and improve the Websites. We use mobile analytics software to allow us to understand the functionality of the Websites on your mobile device. This software may record information such as how often you use the Websites, what happens within the Websites, aggregated usage, performance data, app errors and debugging information, and where the Websites were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.
Log File Information: When you use our Websites, we may receive log file information such as your IP address, browser type, access times, domain names operating system, the referring web page(s), pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We receive log file data when you interact with our Websites, for example, when you visit our websites, sign into our Websites, or interact with our email notifications. Barnes & Thornburg uses log file data to provide, understand, and improve our Websites, and to customize the content we show you. Barnes & Thornburg may link this log file to other information Barnes & Thornburg collects about you via the Websites.
Public Information: Barnes & Thornburg may also collect information about you from publicly available sources. Information you make publicly available in any public or open forum, such as on a social network, may be considered public information for the purposes of this Privacy Notice, and may be accessed and collected by Barnes & Thornburg. Please be aware that any content or information you share with or provide to third parties using or related to your use of the Websites is neither private, nor confidential. Barnes & Thornburg is not responsible for any content or information you post or share with third parties. If you do not wish for certain information to be public, please do not share it.
Barnes & Thornburg uses the information we receive about you for the purposes described in this Privacy Notice. We process personal data received about you through our Websites on the basis of Barnes & Thornburg’s legitimate interests in providing the Websites and their functionality to you. Such processing is necessary for the purposes of the legitimate interests pursued by Barnes & Thornburg or by our Service Providers related to the Websites. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing.
When you access or use the Websites, we collect, use, share, and otherwise process your personal information as described in this Privacy Notice. Barnes & Thornburg will not share, sell, rent, or otherwise disclose your private personal information to third parties without your consent or another valid legal basis permitted by law.
Barnes & Thornburg will share your information in the following circumstances on the legal basis of the legitimate interests of providing the requested Websites:
Aggregated Non-Personal Data: We may disclose aggregated, non-personal data received from providing the Websites, including information that does not identify any individual, without restriction. Barnes & Thornburg may share demographic information with business partners, but it will be aggregated and de-personalized, so that personal information is not revealed.
Within Barnes & Thornburg: We may share and process information internally within Barnes & Thornburg and with our subsidiaries and affiliates. Barnes & Thornburg’s personnel may have access to your information as needed to provide and operate the Websites in the normal course of business. This includes information regarding your use and interaction with the Websites.
Service Providers: Barnes & Thornburg works with various organizations and individuals to help provide the Websites to you ("Service Providers"), such as website and data hosting companies and companies providing analytics information. Barnes & Thornburg needs to engage such third-party Service Providers to help us operate, provide, and market the Websites. These third parties have only limited access to your information and may use your information only to perform these tasks on our behalf. Information we share to our Service Providers may include both information you provide to us and information we collect about you, including personal data and information from data collection tools like cookies, web beacons, and log files.
Barnes & Thornburg takes reasonable steps to ensure that our Service Providers are obligated to reasonably protect your information on Barnes & Thornburg’s behalf. If Barnes & Thornburg becomes aware that a Service Provider is using or disclosing information improperly, we will take commercially reasonable steps to end or correct such improper use or disclosure.
We share personal information with our Service Providers on the basis of Barnes & Thornburg’s legitimate interests in providing you with the Websites. Our engagement of Service Providers is often necessary for us to provide the Websites to you, particularly where such companies play important roles like helping us keep our Websites operating and secure. In some other cases, these Service Providers aren’t strictly necessary for us to provide the Websites, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with Service Providers to make our Websites better.
Business Transactions: Barnes & Thornburg may purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets (a “Business Transaction”). Your information, including personal data, may be among assets sold or transferred as part of a Business Transaction.
Safety and Lawful Requests: We may be required to disclose Websites user information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. We may share your information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Websites or using the Barnes & Thornburg name, or to protect the safety of any person. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Privacy Notice is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
Your Rights and Choices Regarding Your Information
Barnes & Thornburg seeks to ensure all individuals are provided with the rights mandated by their governing jurisdiction. Not all of the rights discussed herein will apply to each individual data subject and may not apply to you depending upon your jurisdiction.
You may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. If you would like to manage, change, limit, or delete your personal information, you can do so by contacting us. Upon request, Barnes & Thornburg will provide you with information about whether we hold any of your personal information. In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your personal information. In certain circumstances, you also have the right to request the deletion of your personal information, and to obtain a copy of your personal information in an easily accessible format.
To the extent that such rights are mandated by the laws applicable to the individual data subject, such as all data subjects residing in the European Union (“EU”), the following rights may apply: the right to access (GDPR, Article 15); the right to rectification (GDPR, Article16); the right to erasure (GDPR, Article 17); the right to restrict processing (GDPR, Articles 18); the right of object (GDPR, Article 21); and if applicable, the right to data portability (GDPR, Article 20). You may also have a right to lodge a complaint with an appropriate data privacy regulatory authority (GDPR, Article 77)
If we process your information based on our legitimate interests as explained in this Privacy Notice, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or changing your account settings.
Where you have provided consent to certain data processing, you have the right to withdraw that consent at any time by contacting Barnes & Thornburg at email@example.com. A withdrawal of consent will not affect the validity of our use of your personal data up until the point you have withdrawn your consent.
Access To The Information Barnes & Thornburg Has Collected About You
Barnes & Thornburg welcomes you to contact us regarding the information we have collected about you, including regarding the nature and accuracy of the data that has been collected about you, to request an update, modification, or deletion of your information, to opt-out of certain Websites uses of your information, or to withdraw any consent you may have granted to Barnes & Thornburg.
Please note requests to delete or remove your information do not necessarily ensure complete or comprehensive removal of the content or information posted, and removed information may persist in backup copies indefinitely. Please note that if you choose to delete your information or opt-out of the collection and use of your information, you understand that certain features, including but not limited to access to the Websites, may no longer be available to you.
We may retain the information we receive about you for as long as necessary to fulfil our contractual and legal obligations, or indefinitely, but information generally will be retained only for as long as necessary to fulfill the purposes for which the information was collected, or as otherwise required by law. In addition, we may delete your personal data from our systems as part of a data retention plan. Following termination or deactivation of a Websites Account, Barnes & Thornburg may retain your information and content for a commercially reasonable time for backup, archival, and audit purposes.
Opting-Out Of Communications From Barnes & Thornburg
Users may opt-out of receiving certain communications from Barnes & Thornburg by following the unsubscribe process described in an email communication, or by contacting us using the contact information provided above.
Do Not Track
Barnes & Thornburg does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including personal data, about your online activities over time and across different websites or online services when you use Websites. You may opt out of online behavioral ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser.
Security Of Your Information
Barnes & Thornburg takes reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect it from loss, misuse, unauthorized access, disclosure, alteration and destruction. Barnes & Thornburg implements security measures as we deem appropriate and consistent with industry standards. As no data security protocol is impenetrable, Barnes & Thornburg cannot guarantee the security of our systems or databases, nor can we guarantee that personal information we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information you transfer to or from Websites is provided at your own risk.
Additional Provisions Regarding The Websites & Your Information
Transfer And Storage Of Your Information
Please note information Barnes & Thornburg collects about you may be transferred, processed and/or accessed by us in the United States, or another country where we, or our Service Providers operate. Please be aware your personal data may be transferred to, and maintained on, computers located outside of your state or country where privacy laws may differ from and may not be as protective as those where you live. If you are located outside the United States and choose to allow us to collect information about you, please be aware that Barnes & Thornburg may transfer your personal data to the United States and process and store it there.
If you are located in the European Economic Area ("EEA") or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction, as disclosed in this Privacy Notice. It may also be processed by staff operating outside the EEA who work for us or for one of Service Providers, also as disclosed.
Safely Using Barnes & Thornburg’s Websites
Despite Barnes & Thornburg’s safety and privacy controls, we cannot guarantee the Websites are entirely free of illegal, offensive, or otherwise inappropriate material, or that you will not encounter inappropriate or illegal conduct from other users when using the Websites. You can help Barnes & Thornburg by notifying us of any unwelcome contact by contacting us using the information below.
Your California Privacy Rights
Under California Civil Code Section 1798.83 (known as the "Shine the Light" law), Barnes & Thornburg clients and customers who are residents of California may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below or at firstname.lastname@example.org with "Request for California Privacy Information" on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
Changes to Our Privacy Notice
Barnes & Thornburg may modify this Privacy Notice from time to time. The most current version of this Privacy Notice will govern our use of your information and will be located at www.btlaw.com. You may contact us to obtain prior versions. We will notify you of material changes to this policy by posting a notice at the Websites or by emailing you, if applicable, and provide an “at a glance” overview of any changes.