Effective: August 3, 2019
Introduction and Coverage
We reserve the right to amend this Policy from time to time without notice by updating the effective date. Your use of our Website constitutes acceptance of these terms or any amended terms.
What is Personal Data?
Personal Data means any information relating to a living person who is identified or identifiable. A person is an identifiable if they can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We Are a Data Controller
Because we determine the purposes and means of processing your Personal Data, we are considered a “Data Controller” under European Union law.
Purposes of Processing – Why We Process Your Personal Data
We process your Personal Data for one or more of the following purposes:
- providing you with our services
- answering your questions
- marketing our services to you
Types of Personal Data We Collect
We generally only collect the following types of Personal Data:
- biographical information, including, but not limited to: name, date and location of birth, occupation, title, employer information, income and net worth, spousal and familial information
- contact information, including, but not limited to: email address, telephone number, and mailing and residential address
If you engage us for certain services (such as estate planning), we may collect additional Personal Data, including “Special Categories” of Personal Data.
Special Categories of Personal Data include the following: religious or philosophical beliefs, or trade union membership, data concerning health or data concerning a natural person’s sex life or sexual orientation.
In the spirit of data minimization and protecting your privacy, we will collect the minimal amount of Personal Data required for the purposes of processing.
How We Receive Your Personal Data
We receive your Personal Data in one or more of the following ways:
- you provide us the Personal Data when you contact us
- you provide it to us in the course of our provision of services
- our clients provide it to us
- you are referred to us by a business partner, friend, or family member
Legal Basis of Processing
We generally process your Personal Data on one of more of the following bases:
- your consent
- performance of a contract with you
- steps required before entering into a contract with you
- our legitimate interests or another party, namely marketing our services to you;
- compliance with law
- any other legal basis
If we collect “Special Categories” of Personal Data, as outlined further below under the heading “Types of Personal Data We Collect”, we will process this data under one or more of the following bases:
- your explicit consent
- protecting the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent
- the processing relates to Personal Data made public by the data subject
- for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity
- for reasons of substantial public interest, and subject to further conditions under applicable law
Regarding the legal basis of processing, please keep in mind the following:
If consent is the legal basis by which we process your Personal Data, you can withdraw your consent at any time. Please be advised, however, that this will not affect the legality of any processing that occurred prior to the withdrawal of your consent, or processing based on another legal basis.
If we process your Personal Data in connection with providing you with services, this information is required in order to perform the contract. Without it, we would be unable to provide our services.
Sharing Your Personal Data
We may share your Personal Data with companies with which we are affiliated – to the extent it is necessary for our legitimate business purposes. We may also share your Personal Data with our vendors so that they may process the Personal Data for us. These third parties may only use the Personal Data to help us achieve purposes of processing discussed above or as required by law. Our vendors provide us with services such as email hosting, cloud storage, and other software applications.
It is important to know that some of the third parties with whom we share Personal Data are located outside of the European Union and the wider European Economic Area. And because the countries in which these third parties operate may not be deemed to provide adequate levels of data protection, according to the European Commission. As such, we only transfer your Personal Data to third parties in these countries subject to appropriate safeguards, which may include standard contractual clauses (aka “model clauses”).
We may also disclose your Personal Data if doing so is required by law. In the event we are required to disclose your Personal Data to law enforcement or government agencies, we cannot guarantee that the recipients will provide the same level of privacy and security as outlined in this Policy.
Finally, if we sell our business, undergo a change of corporate control, or restructure our company, we may also share your Personal Data with the acquirer, affiliate, or controlling entity, fiduciaries, or their agents, as applicable, so long as they agreed to abide by the terms of this Policy or as is then in effect.
The terms above do not impact any attorney-client privilege, which may apply to communications we received in the scope of providing you with legal services.
How Long We Store Your Personal Data
When we no longer need your Personal Data, we will delete it within six months.
You also have the option of setting your browser to send a “do not track” signal (also called a “DNT” signal). You can read more about this at https://allaboutdnt.com/.
Filing a Complaint with an EU Supervisory Authority
If we process your Personal Data, you may have the right to lodge a complaint with an EU supervisory authority.
Data Subject Rights
Subject to certain conditions and qualifications, you may have the right to request one or more of the following:
- to access, correct, or delete your Personal Data
- to request a copy of your Personal Data
- to restrict the processing of your Personal Data
- to object to the processing of your Personal Data
You can make a request by contacting us as outlined below.
If you have questions related to this Policy or how we use your Personal Data, you may contact us as follows:
Red Dog Legal
Attn: Data Protection Officer
609 Foreside Road
Topsham, Maine 04086 USA