CALBAR CONNECT PRIVACY POLICY
Effective Date: September 1, 2023
1. Our Commitment to Privacy.
This policy describes CalBar Connect’s privacy principles and procedures. Our Privacy Policy is designed to advise you about how we collect, use, disclose, store, and protect your personal information.
2. Definition of Personal Information.
Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly, with you or your household. Personal information does not include publicly available information, information that is anonymized, aggregated or information that cannot be reasonably used to infer information or otherwise be linked to you.
3. What Personal Information is Collected.
We collect the following categories and specific types of consumer personal information:
a. Identifiers, such as your name, postal address, phone number, email address, unique personal identifier, online identifier, IP address, or other similar identifiers.
b. Commercial information, such as the products or services purchased, used, or considered.
c. Internet or Network Information, such as your browser or device information, browsing history and information regarding your interaction with our website.
d. Geolocation, such as information about your physical location collected from geolocation features on your device.
e. Professional or employment-related information, such as your job title, and employer.
f. Inferences drawn from any of the information identified above to create a profile about you as a consumer, including your preferences and characteristics.
4. How Your Personal Information is Collected.
We collect personal information from the following categories of sources:
a. Directly from You: We collect any information you voluntarily provide us by corresponding with us by phone or email, and through our website, surveys, marketing efforts or other means.
b. Government Entities: As permitted by applicable law, we obtain publicly available information about California licensed attorneys from the State Bar of California. The information we obtain from the State Bar of California may include personally identifiable information, such as your name, admission date, address, telephone number, email address, and employer.
c. Third Parties you direct to share information with us: We receive personal information from our affiliate partners, which may include your name, contact information, and the services or products you purchased through our affinity program. Our affiliate partners may also disclose the total amount charged for products or services rendered. They will not, however, share your credit card information or other payment methods you use to complete the transactions.
d. Cookies and Online Tracking Technologies. We and third parties we work with use online tracking technologies, such as cookies, pixels, and tags to track details of your visits to our website. This information may include, but is not limited to, setting preferences, traffic data, location data, web server logs and other communication data, and the resources you use, as well as information about your computer and internet connection, including your IP address or online identifier, the web page from which you arrived at our website, and the pages you viewed on our website. The information we collect automatically may also include performance and statistical information that will be used by us in an aggregated and anonymized manner. Online tracking and marketing tools we use include Google Analytics, Meta Pixel, LinkedIn Ads.
For more information about Google Analytics, please visit http://www.google.com/policies/privacy/partners. You can opt-out of Google Analytics’ collection and use of data generated by your use of the website by going to https://tools.google.com/dlpage/gaoptout.
To opt out of Facebook ad tracking and analytics, please visit https://www.facebook.com/help/568137493302217
You can learn more about our use of cookies by visiting our Cookie Policy [link]. Click here to manage your cookie preferences.
e. Contractors or Service Providers. In the course of performing our services or marketing activities, our contractors or service providers may conduct activities resulting in the collection of your personal information.
5. How and Why Your Personal Information is Used.
Through our affinity program, we offer California attorneys access to savings, services and resources for their life and legal practice. We leverage their collective buying power to obtain special discounts and benefits from our affiliate partners. The information we collect is used to conduct our business activities and comply with our legal and regulatory obligations. The information we collect may also be used for analysis to better understand the demographics of California attorneys and to develop and improve our services.
Personal information provided to us by our affiliate partners, such as your name and products or services purchased, may be used to confirm eligibility of benefits, royalty payments or otherwise enforce our contractual rights and obligations.
Your personal information may be used to contact you via postal mail or email with information about special benefits, products and services available through our affiliate partners, or other opportunities that we believe may be of interest to you. For example, we may send you newsletters, MCLE announcements, or surveys. For some marketing campaigns, we may use the personal information we collect about you to help us determine the most relevant information to send you.
6. Who We Share Your Personal Information With.
In accordance with how your personal information is used, we share your personal information with the following:
a. Contractors and Service Providers. We disclose personal information to with contractors and service providers who help us run our business, such as email marketing agencies or marketing consultants. We allow our contractors and service providers to handle your personal information only if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on our contractors and service providers to ensure they can only use your personal information to provide services to us and to you.
b. Third Parties for Business Purposes. We disclose personal information with the California Lawyers Association, a partner of CalBar Connect, for business purposes, only to the extent necessary to comply with applicable law or legal obligations, verify eligibility of member benefits, or to enforce our legal or contractual rights. We may also disclose personal information to the California State Bar or our affiliate partners in case of an audit or to resolve a complaint.
c. Entities who provide advertising, marketing or audience measurement. We disclose personal information to advertising and marketing networks, social networks, and other businesses we work with on marketing activities.
d. We may also be required to disclose personal information we collect for other purposes as permitted by law, such as complying with federal, state or local laws, a legal investigation, or fulfilling any other purpose with your consent.
7. Categories of Personal Information We Sold or Shared for Cross-Context Behavioral Advertising
In the preceding 12 months, we have shared the following categories of personal information for the purpose of engaging in targeted advertising and other marketing activities, including efforts to expand the reach and effectiveness of our marketing campaigns. Under certain state laws, including the California Consumer Privacy Act, these disclosures are considered “sales” or “sharing for cross-context behavioral advertising.”
a. Identifiers, such as your name, email address, unique personal identifier, online identifier, IP address, or other similar identifiers.
b. Commercial information, such as the products or services purchased, used, or considered.
c. Internet or Network Information, such as your IP address, browser or device information, browsing history and information regarding your interaction with our website.
We have disclosed these categories of personal information to advertising and marketing networks, social networks, and other businesses we work with on marketing activities.
8. Categories of Personal Information Disclosed for Business Purposes.
In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
a. Identifiers, such as your name, address, phone number, email address, or other similar identifiers.
b. Commercial information, such as the products or services purchased through our affinity program.
c. Internet or Network Information, such as your IP address, browser or device information, browsing history and information regarding your interaction with our website.
d. Professional or employment-related information, such as your job title and employer.
Where applicable, we disclose identifiers, commercial information and professional or employment-related information to California Lawyers Association to verify eligibility of member benefits, provide them notice of the transactions completed through our affinity program and to confirm royalty payments or otherwise enforce our contractual rights or obligations.
We also disclose the categories listed above to service providers and contractors that perform services for us, on our behalf, which may include providing mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting and providing analytic services.
9. Sensitive Personal Information.
Sensitive Personal Information means personal information that reveals a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data, and biometric information. We do not collect, sell or share Sensitive Personal Information.
10. How Long Your Personal Information Will Be Kept.
We will keep your personal information while we are offering or providing products and services to you, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, responding to any questions or complaints, and enforcing our agreements.
Different retention periods apply for different types of personal information. We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymize it. If deletion or anonymization of your personal information is not possible, for example because it has been stored in backup archives, we will securely store your personal information until deletion is possible.
11. Methods We Use to Protect Your Information.
We have implemented reasonable security measures and practices to protect your personal information from unauthorized access or accidental loss. We use security software, secured files and buildings to protect the confidentiality of your personal information. We limit access to your personal information to those who have a genuine business need to access it. In addition, our business practices are reviewed periodically for compliance with policies and procedures governing the security and confidentiality of our information.
12. Your Rights with Regards to Your Personal Information.
California consumers, you have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise the rights detailed below free of charge.
a. Right to Disclosure of Personal Information we collect about you. You have the right to know, and request disclosure of, the categories and specific pieces of personal information (including sensitive personal information) we have collected about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling or sharing personal information, and the categories of third parties with whom we disclose personal information.
Please note that we are not required to retain any personal information about you that was collected for a single one-time transaction, if, in the ordinary course of business, that information about you is not retained; reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information.
b. Right to Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose. In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know, the categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared and the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.
c. Right to Access. Upon receipt of a verifiable request from you, you have the right to obtain access to your personal information in a portable and readily usable format that allows you to transmit this information to another entity without hindrance. Please note that we are not required to provide the personal information to you more than twice in a 12-month period.
d. Right to Deletion. You have the right to request deletion of your personal information from our records. Your request for deletion may be limited in certain circumstances, such as where the personal information is necessary to comply with a legal obligation, complete the transaction for which the personal information was collected, or otherwise use the personal information in a lawful manner that is compatible with the context in which you provided the information.
e. Right to Correction. If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercial reasonable efforts to correct the inaccurate personal information.
f. Right to No Retaliation. You have the right to not be retaliated against by us because you exercised your rights under this policy. This means we cannot deny you goods or services, or provide a different level or quality of goods or services. Note, however, that we are not prohibited from offering financial incentives for the collection of personal information.
g. Right to Opt-Out. You have the right, at any time, to direct CalBar Connect to not sell or share your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.
If you would like to opt out of the sale or sharing of your personal information, you may click the “Do Not Sell or Share My Personal Information” link located in our website footer. You may choose to enable online, where available, a universal tool that automatically communicates your opt-out preference, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt-out. Note that your opt-out choice is specific to the device and browser you are using.
You may also submit a broader request to limit the sale or sharing of your personal information at California Consumer Request Form.
If you do not want to receive communications directly from us, you may also unsubscribe from our marketing and other email communications by sending an email to info@calbaraffinity.org or by using the unsubscribe link in our emails.
13. How You Can Exercise Your Rights.
If you wish to exercise any of the rights described in this Privacy Policy, please contact us via email at info@calbaraffinity.org. You can also submit a request for information HERE.
If you choose to contact us directly by website or email, you will need to provide us with enough information to identify you, proof of your identity and address, and a description of the rights you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
14. Children’s Information.
This website does not provide services or sell products to children under the age of 16. We do not collect, sell or share personally identifiable information of any person we actually know is a child under the age of 16.
15. Consent.
By using our website, you consent to the collection and use of your personal information as described in this Privacy Policy.
16. Changes to Privacy Policy.
We may update this Privacy Policy from time to time. If our Privacy Policy or procedures change, we will immediately post those changes to our website. Any such changes will be effective immediately upon being posted, unless otherwise stated in the change.
17. Links to Third Party Websites.
For the convenience of our visitors, this website contains links to a number of sites that we believe may offer useful information or services. The policies and procedures described in this Privacy Policy do not apply to those sites or features. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies.
18. Do You Need Extra Help?
If you would like this notice in another format (for example, audio, large print, braille), please contact us at info@calbaraffinity.org or here (link to https://www.calbarconnect.com/contact/) .