Privacy Policy

Green, Waters Ogle and McCarter (GWO, PLLC) is committed to ensuring that your privacy is protected. This Privacy Policy (“Privacy Policy”) sets out how GWO, PLLC uses and protects any information that you give our firm when you use this website.

By using this website and providing us with your information, you agree to this Privacy Policy. When the term “you” is used below, we refer to “you” as an individual, and you along with your end-users if you are a business entity.

In this Privacy Policy, “personal information” means information that (either in isolation or in combination with other information held by the Firm) enables you to be identified or recognized. With respect to California residents, references to “personal information” in this Privacy Policy mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, subject to certain exceptions set forth in the California Consumer Privacy Act (the “CCPA”). The Firm will not sell or disclose personally identifiable information about you to unaffiliated third parties except in accordance with this Privacy Policy.

Collection of Information

Although you are not required to provide any personal information on the public areas of our website, you may choose to do so by completing certain contact or marketing forms. Should you do so, we may, for example, keep a record of your name, email address, and any other information you voluntarily provide to us.

Additionally, we may collect the following categories of personal information from you in the course of business, including through your use of the Website, when you contact or request information from us, when we provide services to you, or when we receive services from you. If you choose not to provide such information, you may not be permitted to access certain Firm Website features, content or services.

• Identification data, such as name, gender, title, job title, or address.• Contact information, including your phone number(s), your email address, and your social media account or handle where appropriate.• Financial data, such as bank account information and invoicing details.• Event registration or mailing list data, such as dietary requirements (which may reveal information about your health or religious beliefs), preferences and interests, subscriptions, downloads, and username/passwords.• Job applicant data, such as identification data and contact information, resumé and other data provided by you or third parties (e.g., recruiters) on our website, online recruitment portal (where applicable) or offline in connection with job openings, which may be subject to additional local requirements.• Legal and regulatory compliance data as required for purposes such as know your client, anti-money laundering, and market abuse regulations requirements, or as part of our client onboarding process, which may include passport or other identification data, date of birth, home address, and other due diligence data.• Other service data, such as personal information relevant to the provision or receipt of services, in relation to any of your employees, customers or vendors, and client feedback.• Cookie and device data, such as information about your visit to our website, IP address, the URLs of the websites and pages you visit (before, during and after your visit to the Firm Website) and the times and dates of such visits, information about the computer hardware and software you use, device identifier, location and time zone setting, even when you are not logged in. Also, the Firm may place “cookies” on your computer to recognize you on return visits to enable the Firm to enhance your browsing experience, as well as to collect additional information about you. As further described below, you may adjust your browser settings or use other means to prevent cookies from being placed on your computer, but doing so may result in reduced functionality and a less personalized browsing experience.• We may supplement the information that you provide to us with information that we receive or obtain from other sources, such as from our staff or personnel, clients, professional advisers, partners, and agents of the Firm, third parties with whom we interact, and publicly available sources.

Use of Information

We may use your personal information for the following purposes:We may use that Personal Information where in our legitimate interest to do so for the following purposes:• to contact you and respond to your requests and enquiries• to personalize your visit and use of our Internet Services and to assist you while you use those services• to carry out, monitor and analyze our business or website operations• to conduct our recruiting and selection process• to provide you with legal services, if you are or become a client of the firm, and otherwise deal with you, and administer the matters you instruct us on• to contact you (unless you tell us that you prefer us not to) regarding legal or law firm developments that may be of interest to you. If you do not want to receive publications or details of events or seminars that we consider may be of interest to you, you may do so by clicking on the unsubscribe link in electronic marketing communications• to enter into or carry out contracts of various kinds• to comply with applicable laws, regulations, guidance or professional obligations that we may be subject to, including anti-money laundering requirements.• Where Personal Information is necessary for the firm to carry out its anti-money laundering checks failure to provide such information may result in the firm not being able to provide the representation.• Provision of legal services – We use personal information that you voluntarily submit to us on the website or during the course of our engagement, regardless of the media used, such as identification data, contact details, and other service data that we may process in connection with the provision of services. The Firm’s work for you may also involve providing such information to third parties, such as expert witnesses and other professional advisers in order to represent your interests most effectively. This is necessary for us to perform our contract with you.• Administration of client and vendor relationships – We use identification data, contact details, financial data, and other service data, including for the processing of invoices, the updating of client records, and the management of our vendor relationships. This is necessary to perform our contract with you.• Addressing client inquiries/feedback – We use identification data, contact details, and other service data for this purpose. This process is necessary to perform our contract with you. It may also be necessary for our legitimate interests to establish or maintain a relationship with you; it is also in your interest to receive a response from us when you contact us.• Sending relevant marketing messages and inviting you to events/seminars – We use identification data, contact details, cookie and device data, and mailing list data to communicate with you by way of email alerts and post to provide you with information about our events, seminars, or services that may be of interest to you. This processing is necessary for our legitimate interest to send you tailored marketing messages, client newsletters, and invitations to relevant events and seminars.• Improving our website – We use cookie and device data to improve the functionality and user-friendliness of our website. This is necessary for our legitimate interests to constantly monitor and improve our online presence and services to you.• Keeping our website and IT systems and processes safe – We use identification data, contact details, financial data, cookie and device data, and other service data. This is necessary to perform our contract with you and to ensure the security and confidentiality of your data. It is also necessary for our legitimate interests to prevent illegal activities, including fraud, which could harm you and us.• Complying with legal or regulatory inquiries/requests – We use identification data, contact details, financial data, cookie and device data, and legal and regulatory compliance data (including for anti-money laundering or fraud detection purposes, statutory returns and fulfillment of the Firm’s ethical obligations). This is necessary for the purpose of complying with legal requirements that apply to the Firm.• Recruitment – Personal information about job applicants is collected and processed for purposes of screening, identifying, and evaluating candidates for positions; record-keeping related to hiring processes; analyzing the hiring process and outcomes; and conducting background checks, where and to the extent permitted by applicable law, which may also be subject to relevant local recruitment privacy policy. If you are hired by the Firm, this data will be transferred to our employee record files for the purpose of your employment. This is necessary in order to take steps at the request of the job applicant in the context of recruitment prior to entering into a contract. In addition, job applicant data and legal and regulatory compliance data may be used as necessary to comply with legal, regulatory, and corporate governance requirements.

Information Sharing

We may share your personal information with the following categories of recipients:• Other entities within the Firm to provide legal services to you and to administer any service provided to you that the Firm agrees to undertake;• Professional advisers, partners, and agents of the Firm to provide you with local legal services, as required, and to administer our relationship with you;• Vendors that will process your personal information on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, financial institutions, customer relationship management databases and other cloud-based solutions, third-party companies providing us with business analytics and statistics to assist with our marketing campaigns, and third-party venues in which we may host events and seminars. We contract with such vendors to ensure that they only process your personal information under our instructions and ensure the security and confidentiality of your personal information by implementing the appropriate technical and organizational measures for such processing;

• Any law enforcement, regulatory, or government agency requesting personal information in connection with any inquiry, subpoena, court order, or other legal or regulatory procedures, with which we would need to comply. We may also share personal information to establish or protect the Firm’s legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims;• Any third party connected with business transfers; we may transfer your personal information to third parties in connection with a reorganization, restructuring, merger, acquisition, or transfer of assets of the Firm, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Policy.• We are not responsible for the data policies or procedures or content of any linked websites. We recommend that you check the privacy and security policies of each website you visit.

Transfers of Information

Your personal information may be transferred to or shared across our integrated computer networks with one or more Firm offices and our affiliated offices in the United States, or carefully selected service providers that the Firm may engage to host the Firm Website or to provide other services that may not be subject to data protection laws similar to those prevailing in the jurisdiction in which such information is provided to or received by us. All of our offices adhere to the same procedures with respect to your personal information, including this Privacy Policy, and the Firm will require all such service providers to use the information solely to provide the specified services, and otherwise to conform to the requirements of this Privacy Policy.

Your Rights

If you are a California resident, you have the following rights, subject to certain exceptions as set forth in the CCPA:• Right to access personal information. You have the right to receive the specific pieces of your personal information we have collected about you in the 12 months preceding your request.• Right to data portability. You have the right to receive a copy of your electronic personal information in a readily-usable format.• Right to know. You have the right to receive information from us regarding the categories of personal information we collected, the sources from which we collect personal information, the purposes for which we collected and shared personal information, the categories of any personal information we sold as well as the categories of third parties to whom such personal information was sold, and the categories of personal information that we disclosed for a business purpose in the 12 months preceding your “right to know” request.• Right to request deletion. You have the right to request the deletion of the personal information that you provided to us. Please note that in certain instances we may not be able to process your request, such as (i) due to the existence of a legal obligation, (ii) to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, or (iii) in order to complete a transaction for which your personal information was collected.• Right to non-discrimination. You have the right to be free from discrimination by us as a result of you exercising your rights under the CCPA.

If you wish to exercise these rights, you must submit a request by emailing info@gwofirm.com. The CCPA requires us to verify requests we receive when one is seeking to exercise certain of the rights listed above. We may ask you to provide certain information in order for us to verify your request. Note that certain of the rights set forth above do not apply until January 1, 2021 for job applicants, employees, partners, and contractors, and when personal information is transmitted in business-to-business written or verbal communications or transactions relating to due diligence, or providing or receiving a product or service to or from another business, and the personal information concerns an employee, owner, director, officer or contractor of that business.

The Firm has collected the following types of personal information about California residents in the last 12 months:

Network Advertising Initiative opt-out page. You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.com.

We will only retain your personal information for as long as necessary for the purposes for which that information was collected as set out in this Privacy Policy or for longer as required under any applicable legal, regulatory, accounting, or reporting requirements. Should you opt out or no longer wish to receive marketing messages from us, we will securely delete your personal information from the relevant mailing list(s).

Additional Services

From time to time, the Firm may offer additional services through the Firm Website. In some cases, additional services may be subject to alternative terms of use (as identified by the Firm), and your use of any such services will constitute your acceptance of such alternative terms of use. Unless otherwise stated, such alternative terms of use shall apply to supplement this Agreement and in the context of any conflicting terms, this Agreement shall govern with respect to the Firm Website, content and services, excepting only those services which are expressly covered, and then only to the extent so expressly covered, by such alternative terms.

Sending Information Does Not Form an Attorney-Client Relationship

Transmission of information from this Website does not create an attorney-client relationship between you and the Firm, nor is it intended to do so. The transmission of the Website, in part or in whole, and/or any communication with us via Internet e-mail through this site does not constitute or create an attorney-client relationship between us and any recipients.