1. Objective & Scope
For the purposes of this Policy, “Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from the information. This policy does not cover any information, recorded in any form, about more than one individual where the identity of the individuals is not known and cannot be inferred from the information (“Aggregated Information”). Garfin Zeidenberg retains the right to use Aggregated Information in any way that it determines appropriate.
2. Collection of Personal Information
Garfin Zeidenberg collects only such information from individuals or organizations as is required for the purposes of providing services or information to them. Garfin Zeidenberg collects e-mail and mailing addresses from clients and individuals who subscribe to Garfin Zeidenberg’s publications. Garfin Zeidenberg uses information collected through such subscriptions to send subscribers the publication they have requested, and to provide information that may be of possible interest.
Unless permitted by law, no Personal Information is collected about an individual, without first obtaining the consent of the individual to the collection, use and dissemination of that information.
Personal Information will be collected, to the extent possible, directly from the individual concerned.
Unless in the context of providing legal or other services, Garfin Zeidenberg does not knowingly collect Personal Information from anyone under the age of 18 and does not use such information if it discovers that it is has been provided by a minor.
3. Use and Disclosure of Personal Information
Garfin Zeidenberg’s professionals and support staff use Personal Information of clients for the purposes of client work, such as providing legal and related services to individuals and corporations, for precedents usage, to administer client accounts, including time, billing and contact information databases, to perform conflict searches, to enhance our relationship with clients and to provide legal updates which we believe to be of relevance to our clients. In addition, we may send you holiday cards and other greetings from firm lawyers whom you know. If an individual is already a client of Garfin Zeidenberg, or has been in the past, we maintain their client information to facilitate the provision of ongoing services, or anticipated future service. An individual may request that they not receive information about our services or about new developments in the law, and we will adjust our mailing lists accordingly. The firm does not disclose Personal Information to any third party to enable them to market their products or services, but it may disclose Personal Information in certain circumstances, as set out below.
Subject to our professional obligations to keep client information confidential, under certain circumstances Garfin Zeidenberg will disclose Personal Information to a third party without express client consent, including, where required, or authorized, by law or where the legal services you have retained us to provide requires us to give Personal Information to a third party (e.g. to a lender in a real estate mortgage transaction, to a government agency for permit applications, consents etc., and any other organization or enterprise when required for services to and for clients).
Where Garfin Zeidenberg is required to disclose Personal Information of clients to third parties for data processing (e.g. for contracted services such as photocopying, computer backup services or archival storage services) or other third party services related to services rendered to and for clients, we will ensure that those third parties agree to only use the Personal Information for the specified administrative purposes and agree to provide a level of protection to the information comparable to that adopted by Garfin Zeidenberg. Garfin Zeidenberg does not sell, trade, barter or exchange for consideration any Personal Information it has obtained.
Garfin Zeidenberg endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which Garfin Zeidenberg uses that information.
Garfin Zeidenberg keeps Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of a person’s relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. When your Personal Information is no longer required for Garfin Zeidenberg’s purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.
Garfin Zeidenberg endeavours to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information.
Garfin Zeidenberg further protects Personal Information by restricting access to it to those employees that the management of Garfin Zeidenberg has determined need to know that information in order that Garfin Zeidenberg may provide its services.
In terms of communicating Personal Information to Garfin Zeidenberg, you may wish to note that there is no method of transmitting or storing data that is completely secure. While the physical characteristics of each are different, mail, telephone calls, faxes and transmissions over the Internet are all susceptible to possible loss, misrouting, interception and misuse of the information being communicated or transmitted.
As do many organizations, Garfin Zeidenberg attempts to strike a reasonable balance between security and convenience. In communicating with clients and others, Garfin Zeidenberg often requests the right to use a method of communication that is less secure than some of its less convenient alternatives. An example of this is e-mail. At this time, when we use e-mail, it may be sent as unencrypted plain text. We do this because Garfin Zeidenberg believes that many of our clients and others cannot readily process encrypted e-mail. This is done for their convenience but has the security concern that, if misrouted or intercepted, it could be read more easily than encrypted e-mail.
7. Garfin Zeidenberg Web Site
Garfin Zeidenberg may provide clients and others with general access to public web sites and restricted access to extranets. Our web servers may track general information about visitors such as their domain name and time of visit. Garfin Zeidenberg’s web servers may also collect and aggregate information regarding which pages are being accessed as well as information volunteered by visitors through online surveys or subscriptions to electronic newsletters. This information may be used internally, only in aggregate form, to better serve visitors by helping us manage our sites, diagnose any technical problems, and improve the content of our web site.
8. Amendment of Garfin Zeidenberg Practices and This Policy