Disclaimer

The information on this website is presented as a service for our clients and Internet users and is not intended to be legal advice, nor should you consider it as such. Although we welcome your inquiries, please keep in mind that merely contacting us will not establish an attorney-client relationship between us. Consequently, you should not convey any confidential information to us until a formal attorney-client relationship has been established. Please remember that electronic correspondence on the internet is not secure and that you should not include sensitive or confidential information in messages. With that in mind, we look forward to hearing from you.

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California Privacy Policy

California Privacy Policy

Effective Date: January 1, 2023

Last Updated on: December 29, 2022

Privacy Policy for California residents applies solely to individuals who reside in the State of California (“CA Resident” or “CA Residents”). Carlton Fields adopts this Policy to comply with the California Privacy Rights Act (CPRA) and any terms defined in the CPRA have the same meaning when used in this Policy.

“Carlton Fields,” “we,” “us,” or “our” refers to Carlton Fields, LLP and Carlton Fields, PA.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual ("Personal Information"). Personal Information does not include:

  • Publicly available information from government records;
  • Deidentified or aggregated consumer information; or
  • Information excluded from the CPRA's scope, like:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, Carlton Fields has or may have collected the following categories of Personal Information from CA Residents within the last twelve (12) months:

What Personal Information We Collect?

Where We Get It?

Why We Collect It?

With Whom Do We Share It?

Identifiers such as a real name, alias, postal address, Internet Protocol address, email address.

The consumer directly and/or our attorneys.

To provide our services, to conduct data analysis, marketing, and market research.

Marketing providers and event partners.

Categories of personal information described in subdivision (e) of Section 1798.80.

The consumer directly and/or our attorneys.

To provide our services, to conduct data analysis, marketing, and market research.

Marketing providers and event partners.

Commercial information, including products or services purchased, obtained, or considered.

The consumer directly.

To provide our services, marketing and market research.

No one.

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement.

The consumer directly and from marketing and analytics providers.

To provide our services, to conduct data analysis, marketing, and market research.

Data analytics providers and marketing providers.

Geolocation data.

The consumer directly and from marketing and analytics providers.

To provide our services, to conduct data analysis, marketing, and market research.

Data analytics providers and marketing providers.

Inferences drawn from any of the information identified in this chart to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Marketing and analytics providers.

Marketing and market research.

No one.

 

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information.
  • To maintain security on Carlton Fields’ websites and Internet-connected assets, which includes hosting and maintenance of computer systems and infrastructure, management of Carlton Fields’ software and hardware computer assets, systems testing, such as development of new systems and end-user testing of computer systems, training, and monitoring email and Internet access.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
  • To comply with applicable legal or regulatory requirements, such as legal (state and federal) and internal company reporting obligations, including headcount, management information, demographic and health, safety, security, and environmental reporting.
  • As described to you when collecting your Personal Information or as otherwise set forth in the CPRA.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We may or may not have used Personal and Sensitive Personal Information about you for each of the above purposes.

Sharing Personal Information

Carlton Fields may share your Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

We do not sell your personal information.

In the preceding twelve (12) months, Company has disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below.

Personal Information Category

Business Purpose Disclosures

Identifiers

  • Public entities and institutions (e.g., regulatory, quasi-regulatory, tax or other authorities, law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies);
  • Professional advisors including law firms, accountants, auditors, insurers, and tax advisors;
  • Website hosting or information technology consulting service providers;
  • Data analysis service providers;
  • Administrative service providers;
  • Application service providers;
  • Insurance providers; and
  • Telecommunications and messaging services.

We may also disclose your Personal Information for other purposes permitted by law such as to:

  • Comply with applicable laws; or
  • Respond to governmental inquiries or requests.

Personal Information Categories Listed in the California Customer Records Statute

Protected Classification Characteristics under California or Federal Law

Internet or Other Similar Network Activity

Geolocation Data

Inferences Drawn from Other Personal Information

 

 

Your Rights and Choices

The CPRA provides California residents with specific rights regarding their Personal Information. This section describes your CPRA rights and explains how to exercise those rights.

In accordance with our policies and procedures, we will not discriminate or retaliate against you if you choose to exercise any of your rights under the CPRA.

Right to Access

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months (the "Right to Access"). Once we receive your request and confirm your identity, we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • If we disclosed your Personal Information for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
  • The specific pieces of Personal Information we collected about you.

Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the "Right to Delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Correct

You have the right to request that we correct any of your Personal Information that we collected from you and retained, subject to certain exceptions (the "Right to Correct"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your correction request if retaining the information is necessary for us or our service provider(s) to:

  • Take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will correct your Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Opt-Out of the Sharing of Personal Information

You have the right to request to opt-out of the sharing of Personal Information that may be collected and used, subject to certain exceptions (“Right to Opt-Out”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your opt-out request if retaining the information is necessary for us or our service provider(s) to:

  • Take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will opt you out of the sharing of your Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Limit the Disclosure of Sensitive Personal Information

You have the right to request that we limit the disclosure of certain sensitive Personal Information about our collection and use of your Personal Information over the past twelve (12) months pertaining to information that may be collected and used, subject to certain exceptions (“Right to Limit Disclosure”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your limitation request if retaining the information is necessary for us or our service provider(s) to:

  • Take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will opt you out from the disclosure of your sensitive Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Opt-Out of Automated Decision-Making

We do not engage in automated decision-making.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CPRA rights.

 

Exercising Your Rights and Choices

To Exercise

To exercise your rights as described above, please submit a request by either:

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. To designate an authorized agent, click here for the form and instructions.

You may only submit a request to know twice within a twelve (12) month period. Your request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the ten (10) day timeframe, please contact [email protected].

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically a .csv or .pdf file.

 

Retention of Personal Information

Personal information will not be kept for longer than is necessary for the business purpose for which it is collected and processed and will be retained in accordance with our internal document retention policies. In certain cases, laws or regulations require us to keep records for specific periods of time, including following termination of the employment relationship. In other cases, records are retained in order to administer the employment relationship or to resolve queries or disputes which arise from time to time.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Carlton Fields website and update the notice's effective date.

Contact Information

If you have any questions or comments about this notice, the ways in which Carlton Fields collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 844.316.3866

Website: https://carltonfields-web-stage-2023.bluemod.us/ccpa-request-form

Email: [email protected]

Postal Address:

4221 West Boy Scout Boulevard
Suite 1000
Tampa, FL 33607