Last modified November 2020.
Nothing in this Policy supersedes or changes our ethical obligations to clients and our duties of confidentiality under the applicable state bar rules governing attorneys. Our terms of professional engagement with clients may set forth more specific details with respect how we handle a client’s data and Personal Information. Sequel’s engagement letter with clients supersedes this Policy to the extent there is any conflict.
A. HOW WE COLLECT PERSONAL INFORMATION
We may collect Personal Information from you in the following ways:
1. Your submissions. We collect Personal Information when you voluntarily submit information directly to us. This can include information you provide to us when you complete a web-based form; sign up for a webinar or course; correspond with us; subscribe to our mailing lists, newsletters, or other forms of marketing communications; use some feature of our Website; request to be added to a professional or social media network (such as LinkedIn, Facebook, or Twitter) or accept an invitation from one of our media platforms; or when you interact with us by telephone or in person. If you are an employee, agent, contractor or vendor of Sequel (“Sequel Personnel”) then we collect Personal Information consistent with, and as is usual in, a business or employment relationship.
2. Your visit to our Website. We collect some information when you access the Website, including information about the browser and device you have used to access the website, your location (country and city), and what pages you have looked at on our Website (“Browsing Behavior”). This information may be matched to other available information to identify you.
3. Via Cookies. Our Website uses Google Analytics and plug-in called Fastbase. These applications deposit cookies on your browser to collect and store Browsing Behavior when you access our Website and potentially to identify you. You may prevent cookies from being placed by accessing your web browser’s settings. You may also opt out of providing Browsing Behavior to Google Analytics by using the Google Analytics Opt-out Browser Add-on, which is available at https://tools.google.com/dlpage/gaoptout.
4. From a client. We may collect Personal Information when, in the course of representing a client, we gather material relating to the representation that contains Personal Information.
5. From a third party. We may collect Personal Information from other third-party providers, such as through credit reporting services, referrals, mailing lists or information gathered from Internet communication or media providers, such as Constant Contact, Vimeo, or Skype, or gathered from parties to a transaction or adversarial proceeding.
B. TYPES OF PERSONAL INFORMATION COLLECTED
The list below sets out the categories of Personal Information we may collect:
1. Contact Details. We may collect contact information such as your name, your email address, your organization, your role, telephone number, and your addresses.
2. Payment, Transaction, and Financial Information. We keep records of the services we have provided to you, including your billing information and payment history. If you are Sequel Personnel, we collect and store financial information as well as Personal Information for HR, insurance, and other administrative purposes.
3. Browsing Behavior. We collect information about how visitors use our Website. In some cases, this information may be linked to other personal information.
C. HOW WE USE YOUR PERSONAL INFORMATION
We use your Personal Information in the following ways:
1. To provide you (or someone else) with legal services, or as requested. We may use your Personal Information in the course of providing legal services to you or to another one of our clients. You may voluntarily provide Personal Information in response to a request for Personal Information on our Website, such as a web-based form. We will use this Personal Information for the purposes provided in the request.
2. For Decision-Making & Recordkeeping. We use your Personal Information in the course of determining whether to accept you as a client or enter into a business relationship with you. If we have a relationship with you, we will use your Personal Information to identify you internally in connection with any matters relating to you.
3. To comply with our legal, professional, and ethical obligations. We will keep Personal Information as may be required by applicable laws, regulations, or professional rules.
4. To provide you with information about our services. We may use your Personal Information to communicate with you about products or services we are offering and to provide you with our newsletter.
5. To provide you with information about other’s services and to act on your behalf. We may use your Personal Information to engage with other businesses who may be able to help you, such as, but not limited to, when we engage an advisor, consultant, witness, investigator, docketing service, document service, e-Discovery provider, research service, information technology provider, or other service provider that may act on our behalf or yours, or when purchasing or subscribing to products or services that are necessary to support your interests, such as docketing, document management, hosted IT environments, or data compliance tools.
6. For Sequel Administration. If you are Sequel Personnel, we use your Personal Information to identify you internally for HR purposes and to administer your payment and benefits, as well as for insurance, safety, and other administrative purposes consistent with Sequel’s legitimate business interests and our personnel policies.
7. To improve our Website. We may use Personal Information you indirectly submit to us by visiting our Website to make changes that improve the functionality of our Website on your browser or device.
8. For storage and backup. We store all Personal Information we collect as detailed in the Where and How Your Personal Information Is Stored section below.
9. For marketing and lead generation purposes. When you visit our website, we use personal information obtained from you to provide you with information about our products and services. You may unsubscribe from these communications at any time.
D. WHO SEES YOUR PERSONAL INFORMATION
Your Personal Information may be accessed by the following people or entities:
1. Sequel Personnel, affiliates and any subsidiaries. Sequel Personnel, Sequel’s affiliated companies, licensees, and our subsidiaries (i.e. any organization Sequel may own, or which is under common control with Sequel) may have access to any Personal Information that is necessary to perform Sequel’s or their professional duties. Sequel is affiliated with Sequel Services, LLC (doing business as Achieved Compliance Solutions) and Sequel Health Law PLLC.
2. Our service providers. Your Personal Information may be accessed by third parties who provide a service to us, including server providers, document management contractors, and e-discovery contractors, and any of the providers listed above in Section C (5), and/or affiliated companies. These third parties will only be allowed to use your Personal Information in accordance with our instructions and will be required to keep your information secure pursuant to an agreement that we reasonably determine is appropriate to the circumstances.
3. Purchasers of our business. Personal Information may be disclosed or transferred to buyers or prospective buyers of our business or any part of our assets as part of any such proposed sale, including to their professional advisors, lawyers, or accountants.
4. Law enforcement, regulators, and other parties for legal reasons. We may disclose your Personal Information to a court, regulatory authority, law enforcement agency, or other third party when we are legally required to do so by law or when we must disclose your Personal Information to protect our rights, property, or safety or to protect the rights, property, or safety of others. We may also disclose Personal Information to third parties to help detect or investigate illegal activities and breaches of any agreement we have with you.
5. Opponents and counterparties. If you are involved in an adversarial matter on which we are providing representation, we may provide your Personal Information to an opponent or its affiliated entities in furtherance of your representation or consistent with a court order.
E. USING YOUR PERSONAL INFORMATION FOR MARKETING.
From time to time we may contact you with information about our products and services or those offered by an affiliate. If you do not want to receive marketing messages from us, you are able to unsubscribe at any time by directly contacting us or by using the unsubscribe function on the communication. You can also change your marketing preference by following the instructions on the communication.
F. WHERE AND HOW YOUR PERSONAL INFORMATION IS STORED
We store your Personal Information in the following ways:
1. Physically. We may keep physical copies of your Personal Information at our offices or otherwise in our possession.
2. On a secured server. All Personal Information is stored on a secured server. We outsource all our systems to a professional IT solutions provider commonly used by law firms to host, manage, maintain and support our remote network and remotely accessed desktops (“Managed Systems”).
3. On Sequel personnel’s devices. Sequel Personnel may access your Personal Information via their own computers, tablets, or mobile devices. However, it is our firm policy that all Personal Information or confidential information must only be stored on the Managed Systems or on a password-protected device.
4. On your device. We may store information (which may include Personal Information) locally on your device using cookies and other browser and application storage methods. For further information please see the section above on “How We Collect Personal Information.”
5. Personal Information may be stored in, or transferred to, countries outside of the jurisdiction in which you reside – Specifically in the US. We are a US-based law firm. The laws of the US may offer less protection to your Personal Information than the jurisdiction in which you reside. If you are submitting personal information to us, then you are granting us permission to process and store your information in the US. For more information, see How Your Personal Information Is Handled Internationally, below.
G. HOW YOUR PERSONAL INFORMATION IS SECURED
We take the following steps to secure your Personal Information:
1. Technical Safeguards. We keep your electronically stored Personal Information in secure online and offline facilities and implement appropriate measures to protect your Personal Information against accidental or unlawful destruction, loss, change, damage, or unauthorized access. See Sections F (3&4).
2. Organizational Safeguards. We maintain security policies that govern all Personal Information. All Sequel Personnel are made aware of these policies, and we have procedures in place to train Sequel Personnel on implementing these policies. Failure to properly secure confidential and/or Personal Information results in discipline. Sequel periodically assesses compliance with these policies.
H. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
We provide you with access to the information we collect and store about you – however, this is subject to and limited by our ethical obligations, including the attorney/client privilege and attorney work product limitations (“Legal Privileges”). Nothing herein shall provide you with any right that would interfere with or compromise our clients’ Legal Privileges. If none of these Legal Privileges apply then you may contact our office manager about:
1. how your Personal Information is being used;
2. accessing your Personal Information;
3. correcting inaccurate Personal Information or any request to block or delete your Personal Information where the processing does not comply with local data protection laws;
4. opting out of providing your Personal Information to third parties (other than those acting on our behalf or on behalf of a client); and
5. limiting Sequel’s use of your Personal Information for any purposes other than those listed in this policy.
We will not disclose any sensitive Personal Information to a third party or use your sensitive Personal Information for any purposes other than those listed in this policy without first obtaining your consent, subject to the exceptions in the EU-U.S. Privacy Shield. For more information, see How Your Personal Information is Handled Internationally, below.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us as set out in the Contacting Us section below. Please provide as much information as you can about the Personal Information you are looking for and we will attempt to help you find it.
I. HOW YOUR PERSONAL INFORMATION IS HANDLED INTERNATIONALLY
Sequel has clients and personnel in various parts of the world, including the United States and the European Union. It may be necessary at times to transfer your Personal Information between the United States and the European Union. Sequel will obtain your consent to do so when appropriate. Sequel also has in place the contractual arrangements necessary to facilitate the legal cross-border transfer of information. Please contact our Article 27 Representative in the EU or the UK (see below) if you have any questions about how we process your personal data under the General Data Protection Regulation (“GDPR”).
J. CONTACTING US
If you have any questions regarding this policy, or need to contact us for any other reason, you may contact our office manager, Deanna McVeigh. Her contact details are listed in her biography under the Bios tab, or you can use the “Contact” page. If you are located in the European Union, you may contact our representative in the European Union by email at email@example.com.
K. HOW TO RESOLVE YOUR PRIVACY-RELATED COMPLAINTS
If you have a privacy-related concern or complaint, please contact us using the information above and we will attempt to address your concerns. You may contact the Data Protection Authority in your country if we do not resolve your complaint.
L. CHANGES TO THIS POLICY
M. NOTICE TO YOU