Redline Privacy Policy

REDLINE PRIVACY POLICY
v.1.9
Effective Date: 1 January 2011
Last Revised: 24 May 2018

IN THIS PRIVACY POLICY, "WE," "US," "ITS" AND "OUR" REFER TO JURIDIKO CORPORATION ("JURIDIKO"), AND "YOU" AND "YOUR" REFER TO YOU. Before using the Redline.net website(s) containing the link to this policy (the "Site"), please read carefully this Privacy Policy ("Policy") relating to your use of the Site.

By using the Site, you consent to:
  • the collection and use of personal information and data as set forth in this Policy;
  • the use of cookies (per section F below);
  • emails sent to you for Redline account management purposes; and
  • emails (of which you may opt-out at any time) sent to notify you of Redline activity.
We are self-certified as compliant with the EU-US and Swiss-US Privacy Shield Frameworks, as set forth in the Redline EU-US Privacy Policy set forth below. In the event of any conflict or inconsistency with the terms of this Privacy Policy and the terms of EU-US Privacy Policy, the terms of the EU-US Privacy Policy will control. We are compliant with the EU's General Data Protection Regulation 2016/679 (GDPR).

A. Introduction

This Policy tells you how we use and protect personal information and non-personal information and data collected through use of the Site. This Policy covers only information and data that is collected through this Site and no other web sites that may be linked to or from this Site; nor does this Policy apply to practices of companies that we do not control or to people we do not employ or manage.

By accepting the Policy during registration, you expressly consent to our collection, storage, use and disclosure of your personal information and non-personal information as described in this Policy and to all other terms herein.

It may be possible for you to browse certain parts of the Site without telling us who you are or revealing any information that enables us to directly identify you as an individual. However, you may lose anonymity once you give us personal information about you, and by doing so, you agree to the collection, transfer and storage of that information to our servers and to the terms of this Privacy Policy.

B. Information Collected

This section details the personal and other information about you or arising from your activities on the Site as may be collected and stored by us (which will be in addition to the information we collect as described in the Terms of Membership).

We collect information about you in various ways when you use the Site. Some of this information may be Personal Data about you. As used in this Policy, "Personal Data" means any information (either alone or in combination with other information we hold) that specifically identifies you as an individual, such as your name, address and physical location, email addresses, and telephone numbers.
 
As well as Personal Data, we also collect some information that is not personally identifying, including aggregate or anonymized information, which is data we collect about use of the Site or about a group or category of users from which it has never been, or is no longer, possible to identify you (“Nonpersonal Data”; together with Personal Data, collectively "Information").
 
Personal Data
 
When you request an invitation to join the membership, or when you are invited to join by us or another member, we collect the following Personal Data:
  • first and last name
  • email address
  • country and (if applicable) state of residence
  • date of first admission or certification to practice law
  • optional bar association number (if you choose to submit it)
  • optional biographical content in aid of evaluating eligibility (if you choose to submit it) 
Upon and after registration to join the membership, we collect the following Personal Data:
  • login credentials (username and password)
  • type of practice (law firm, in-house, government, academic or other)
  • location*
  • area(s) of law practice*
  • optional employer (if you choose to provide it)*
  • optional biographical information (if you choose to provide it)*
  • optional guilds of interest (if you choose to designate guilds)
  • to the extent you provide any personally identifying information about you in any Content (as that term is defined in the Terms of Membership) you choose to submit
  • to the extent you provide any personally identifying information about you in any communications you have with us 
*You may elect not to display the asterisked items on your profile page (visible to other members).
 
Nonpersonal Data
 
When you use the Site, we automatically collect Nonpersonal Data, such as a device ID or unique identifier, device type, model and brand, geo-location information, computer, network and connection information, access times, operating system and browser version, and device identifiers, type and language, and other technical information or data collected from Site traffic, including standard web log information and information gathered from cookies, beacons and other mechanisms. We also collect Nonpersonal Data generated from your usage and activity on the Site, including statistics and data relating to upvotes, downvotes, bounty awarded and given, mojo awarded, best reply/bounty, guilds, content postings, followers and subscriptions. This Policy does not restrict or limit our collection, disclosure and use of Nonpersonal Data.
 
Excluded Data
 
We do not solicit and do not knowingly collect data from you related to: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sexuality; or genetic or biometric data; or data related to criminal convictions or offenses.
 
Legal Bases for Collection
 
We collect and use Personal Data only if supported by a lawful basis. Lawful bases include: (i) consent (if given by you including by your choice to submit such data in the Redline milieu, which you are free to withdraw at any time); (ii) contract (including the offering and purchase, for a fee or otherwise, of membership in Redline); and (iii) our legitimate interests, including for direct marketing purposes (of which you may opt-out or object), to perform, maintain and improve the Site, and as further set forth in section C, below.
 
Retention

We retain Personal Data from closed accounts, if, for as long as, and to the fullest extent permitted by applicable law, including in order to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our agreements and policies, and take other actions otherwise permitted by law or as specified elsewhere in this Policy.

C. Our Use of Information

We may combine your information with information we collect from other sources to improve the Site and the functionality and depth and breadth of offerings provided by us and our third party affiliates, customers and partners. We may provide, sell or rent anonymized information to non-affiliated third parties arising from your use of the Site, not connected to your identity, for marketing or other commercial purposes (such as without limitation information regarding preferences, practice areas, Site activity, locations, and working habits). Such use of your information collected per this Policy is used to better the Redline membership experience for all, and to facilitate the creation of a vibrant platform catering to the needs of legal professionals worldwide.

We provide data to our advertising partners or customers after we have removed your name and any other personally identifying information from it, or have combined it with other people's data in a way that it is no longer associated with you. Similarly, when we receive data about you from our partners or customers, we keep the data and subsequently combine it with other people's data in a way that it is no longer associated with you. Further, you agree that we may use your Personal Data as specified in the Terms of Membership, and to:

(i) fulfill the purposes disclosed when you provided your information to us;

(ii) provide, deliver, and collect payment for the services, products, and customer support you request;

(iii) review and process applications for employment;

(iv) resolve disputes, collect fees, and troubleshoot problems;

(v) prevent potentially prohibited or illegal activities, and enforce our Site-related agreements;

(vi) provide, customize, measure, and improve our services, membership benefits and the Site's functionality, content and layout;

(vii) provide you with personalized content and offerings;

(viii) tell you about targeted marketing, service updates, and promotional offers including based on your communication preferences; and

(ix) compare information for accuracy, and verify it with third parties.

Content (as that term is defined in the Terms of Membership) and related data, including anonymous postings, may be exposed to public search engines and publicly available search results, or other legal research services, for purposes of inviting broader engagement within the legal and business community. Nothing in this Privacy Policy or Terms of Membership should be construed to prevent us from charging a fee to access Redline or Redline Content.

You have the option of submitting specified and individualized content anonymously. While we endeavor to ensure that such postings remain anonymous, we cannot guarantee absolute anonymity and make no warranty that other users will never be able to determine your identity, such as (without limitation) by observations of your activity on the Site, the manner in which you express yourself, and other patterns of conduct or behavior. Further, it may be possible for other members to ascertain the fact that a member has posted anonymous content.

Further, we may disclose Personal Data to respond to legal requirements, enforce Terms of Membership or Site policies, in connection with a merger, sale of assets, or other similar corporate transactions, respond to claims that a listing or other content violates the rights of others, or protect the rights, property, or safety or any person.

If you reside in the European Union, Switzerland, Norway, Lichtenstein or Iceland, and are protected by European data protection requirements, we will treat your Personal Data in compliance with the EU-US Privacy Policy (below) and the GDPR.

D. Sharing Information

We may also share your Personal Data with other members per the Site's settings (over which you have control):

(i) members of our corporate family to help detect and prevent potentially illegal acts and provide joint services to requesting users;

(ii) service providers, consultants or similar contractors or agents to support or enhance the Site or our business operations, or with whom we contract in order to carry out transactions initiated by you, such as credit card processing organizations, and companies providing services available on the Site (including authentication and/or spellcheck services);

(iii) other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and solicited consent when using a specific service);

(iv) law enforcement or other governmental officials, in response to a verified request relating to a criminal investigation or alleged illegal activity, or to respond to any legal process;

(v) persons as we in our sole discretion believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity;

(vi) in an aggregated and/or anonymized form which cannot reasonably be used to identify you; and

(vii) other business entities, should we plan to merge with, or be acquired by such entities.

Third Party Recipients
 
We share Personal Data with the following third parties:

Mailchimp (email marketing)
https://mailchimp.com/legal/privacy/

Webspellchecker (spellchecker service)
https://docs.webspellchecker.net/display/Legal/Privacy+Policy

Clarion Technology (Site developers and administrators)
https://www.clariontech.com/


E. Your Use of the Site

In order to offer the services for which you will use the Site, your username will necessarily be displayed throughout the Site and to the public. All of your activities on the Site will be traceable to your username, from which your actual identity may be known. Notices are sent to other community members regarding suspicious activity and policy violations on the Site and refer to usernames and specific items. Please understand that because you link your name with your username, others will be able to personally identify your activities.

F. Cookie Policy

The Site may utilize "cookies", which are small text files placed on your computer or device. We also use pixel tags, web beacons and other similar technologies. Such devices are used to help analyze our web page flow, customize our services, optimize our user interfaces, measure promotional effectiveness, and promote trust and safety. With these devices, we collect data such as the identity of the applicable internet service provider, the user's IP address of his or her terminal device, the type of browser software and operating system in use, the date and time of site access, the website address, if any, from which the user linked to the Site, and other similar traffic-related information. We may also aggregate such information with similar data collected from other users and disclose such aggregate information to third parties. Certain features are only available through the use of cookies, and generally we need to use cookies to help identify you and maintain your signed-in status. You are always free to decline Site cookies via your browser settings, although doing so may interfere with your use of the Site. You may encounter cookies from non-affiliated third parties on certain pages of the Site. To learn more about cookies, please visit allaboutcookies.org.

The following is an illustrative list of the cookies that may be used and installed on your computer or device by the Site:
 
Name Purpose Duration Source Type
SESS[*] Fix user's session Session-only Redline Functional
has_jp Javascript check Session-only Redline Functional
__utma Site visits 2 years Google Analytical
__utmb Site duration 30 minutes Google Analytical
__utmc Site duration Session-only Google Analytical
__utmz Usability 6 months Google Analytical
osp Spellcheck function Until 2038 Webspellchecker.net Functional

Explanation:
Functional - these cookies are necessary for the Site to function properly.
Analytical - these cookies allow us to understand how visitors use our Site, so we can measure and improve how the Site works.
Duration - cookies may be session-only, in which they expire at the end of each browser session, or may expire at a certain date.

G. California Do Not Track Disclosures

We do not engage in the collection of personally identifiable information from users across third party sites or applications. We do not knowingly enable other parties to collect personally identifiable information about our user's activities over time and across different sites or services.

H. Password

Your password deserves careful thought and protection. Use unique numbers, letters, and special characters and do not disclose your password to anyone. If you do share your password or your personal information with others, you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. If your password has been compromised for any reason, you should immediately access your profile on the Site to change your password and notify us immediately at help@redline.net.

I. Your Rights & Choices

You can see, review and change most of your Personal Data by logging into the Site and navigating to the Settings page or by editing Content via Site controls for that purpose. You have the right to request that we not process your Personal Data for marketing or promotional purposes. You may also opt-out of receiving promotional emails from us by following the instructions in the emails or via email sent to webmaster@redline.net. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
 
Rights to Review, Rectify, Erasure, and Portability
 
You can review and change your Personal Data at any time via the Settings page or by contacting us.  If at any time you choose to opt out from allowing us to share with or disclose to non-agent third parties your personal information in the future, or if you wish to request access to, or deletion or modification of, any Personal Data that we have about you that we don't already make available to you for your review and deletion or modification, contact us directly via email to webmaster@redline.net. We endeavor to provide such data in a portable, structured, commonly-used, and machine-readable format.
 
Upon receipt and process of a reasonable request, we will, within a commercially reasonable period of time, comply with such request to the extent technically and commercially feasible. Note that requests to terminate disclosure to third parties may frustrate or render impossible our ability to provide the Site or conduct transactions initiated by you.

We advise you to promptly update your Personal Data if it changes or is inaccurate. Once you make a public (to the members or otherwise) Content posting, you may not be able to change or remove it. If you deactivate your membership, your profile page (with a notice that your membership has been deactivated) will still be visible and all your Content will still be accessible.

Right to Object

You may exercise your right to object, if no opt-out mechanism is otherwise made available to you (including objecting to the basis of use for the purpose of our legitimate interest), by sending an email to webmaster@redline.net.

J. Applicability

Except as otherwise expressly included in this Policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others, whether they are users on the Site or other sites throughout the internet, different rules may apply.

K. Children

The Site is not directed to children under sixteen years of age, and we do not knowingly collect personal information from such children. If you are younger than sixteen, please do not provide any personal information to us. If a person 13 years of age or younger has provided personal information to us, a parent or guardian of such person should contact us at webmaster@redline.net so that we can remove such personal information from our database.

L. Jurisdiction

Redline is located in the United States, as are the servers that make the Site available. All matters relating to privacy issues are governed by the laws of the United States and the State of California. Nothing in this Policy will be construed as an admission or implication that we are subject to the laws or jurisdictions of any national or international jurisdiction or governmental entity, or to non-US law.

M. Data Security

We take appropriate technical and organizational measures to maintain the security of your personal information on the Site. However please remember that any messages you send over the internet are not secure unless they are appropriately encrypted. Despite our efforts, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your personal information that they collect from the Site.

N. Policy Changes

We may amend this Policy from time to time. If we make any changes to this Policy, we will post the amended terms here and change the "Last Revised" date above.

O. Questions or Complaints
 
If you have any questions about this Policy, please contact us at webmaster@redline.net.
 
You have the right to lodge complaints with your applicable local data protection authority, but we hope that you will try to work things out with us first.

EU-US PRIVACY POLICY
 
This EU-US Privacy Policy explains how we adhere to the privacy principles of the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework with respect to transfers of personal information from the European Union, as well as Norway, Lichtenstein and Iceland (collectively, "EU"), and from Switzerland, to the United States. We are subject to the investigatory and enforcement powers of the FTC.
 
The United States Department of Commerce and the European Commission have agreed on a set of Privacy Principles and Supplemental Principles to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States (the "EU-US Privacy Shield"). The EU also has recognized the EU-US Privacy Shield as providing adequate data protection. The United States Department of Commerce and the government of Switzerland have agreed on a similar set of principles to enable U.S. companies to satisfy the requirement under applicable Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “Swiss-US Privacy Shield”). Consistent with its commitment to protect personal privacy, we adhere to the principles of the EU-US Privacy Shield and the Swiss-US Privacy Shield in effect as of the last revised date above (the “Privacy Shield Principles”) as documented in this policy.

We comply with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles.
 
A. Scope
 
This EU-US Privacy Policy applies to all personal information received by us in the United States from the EU and from Switzerland, in any format, including electronic, paper or verbal.
 
B. Definitions
 
For purposes of this Policy, the following definitions will apply:
  • “agent” means any third party that collects or uses personal information under our instructions and for us, or to which we disclose personal information for use on our behalf.
  • “personal information” and "personal data" means any data, information or data/information set(s) that identifies or could be used by or on behalf of us to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
  • “sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, we will treat as sensitive personal information any information received from a third party where that third party treats and explicitly identifies the information as sensitive within the same meaning as used here.
C.  Privacy Shield Principles
 
The privacy principles in this EU-US Privacy Policy have been developed based on the Privacy Shield Principles and Supplemental Principles. For purposes of these principles and this section C, the term "EU" includes Switzerland.
 
(i) Notice. Where we collect personal information directly from individuals in the EU, we will inform such individuals about the purposes for which we collect and use personal information about them, the types of non–agent third parties to which we disclose that information, the choices and means, if any, we offer individuals for limiting the use and disclosure of personal information about them, and how to contact us. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information, or as soon as practicable thereafter, and in any event before we use or disclose the information for a purpose other than that for which it was originally collected.
 
Where we receive personal information from our subsidiaries, affiliates or other entities in the EU, we will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
 
(ii) Choice. We will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose that is materially different than the purpose for which it was originally collected or subsequently authorized by the individual.
 
For sensitive personal information, we don't solicit such information and there's no need to disclose such information in order to use the Site. If we elect in the future to solicit such information, we will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of such solicited information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
 
We will provide individuals with reasonable mechanisms to exercise their choices.
 
(iii) Data Integrity. We will use personal information only in ways that are compatible with and relevant to the purposes for which it was collected or subsequently authorized by the individual. We will take reasonable steps to ensure that personal information is reliable to its intended use, accurate, complete, and current. We will remain compliant for as long as we retain personal information. Personal information will be retained in a form identifying or making identifiable an individual only for so long as necessary to process such information, subject to our right to retain such information for longer periods for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research, and statistical analysis.
 
(iv) Accountability for Onward Transfer. To transfer personal data to an agent, we will: (a) transfer such data only for limited and specified purposes; (b) ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Privacy Shield Principles; (c) take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with our obligations under the Privacy Shield Principles; (d) require the agent to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles; (e) upon notice, including under (d), take reasonable and appropriate steps to stop and remediate unauthorized processing; (f) provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department of Commerce upon request; and (g) enter into enforceable contracts with agents consistent with this Policy.

We will undertake to obtain assurances from our agents that they will safeguard personal information consistent with this Policy. Examples of appropriate assurances that may be provided by agents include: (g) a contract obligating the agent to provide at least the same or substantially similar level of protection as is required by the relevant Privacy Shield Principles, (h) such agent being certified as Privacy Shield Principles-compliant, (i) such agent being subject to the EU Data Protection Directive, or (j) such agent being subject to another EU or Swiss adequacy finding (e.g., companies located in Canada). Where we have knowledge that an agent is using or disclosing personal information in a manner contrary to this policy, we will take reasonable steps to prevent or stop such use or disclosure.
 
(v) Access and Correction. Upon request, we will grant individuals reasonable access to personal information that it holds about them. In addition, we will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete, or that has been processed in violation of the Privacy Shield Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.
 
(vi) Security. We will take reasonable and appropriate measures to protect personal information in our possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and nature of the personal data.
 
(vii) Enforcement. We will conduct compliance reviews of our relevant privacy practices to verify adherence to this EU-US Privacy Policy and appropriate employee and agent training as necessary. Any employee or agent of ours that we determine is in violation of this policy will be subject to disciplinary action up to and including termination of employment or service. We will be responsible if our agent processes personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
 
(viii) Dispute Resolution. Any questions or concerns regarding the use or disclosure of personal information should be directed to the Redline Privacy Office at the address given below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the Redline Privacy Policy and this EU-US Privacy Policy in an expeditious manner, and at no cost to the individual.

We have further committed to refer unresolved Privacy Shield complaints to JAMS (jamsadr.com), an alternative dispute resolution provider located in the United States, which serves as our third-party dispute resolution provider for Privacy Shield Principles-related disputes. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit JAMS for more information or to file a complaint. The services of JAMS are provided at no cost to you. 

Individuals may submit complaints on an individualized basis (and not purporting to be acting in a representative capacity or on behalf of a class) to JAMS. No damages, fees, or other remedies are available. Arbitrators will have the authority only to award individual-specific non-monetary equitable relief (such as access, correction, deletion, or return of the individual data's in question). Each party will bear its own attorneys fees, subject to the rules of JAMS.

In addition, individuals may submit disputes to binding arbitration who first comply with pre-arbitration requirements. This arbitration may not be invoked and is not available if the individual’s same claimed violation of the Privacy Shield Principles: (a) has previously been subject to binding arbitration; (b) was the subject of a final judgment entered in a court action to which the individual was a party; or (c) was previously settled by the parties. In addition, arbitration is not available if an EU Data Protection Authority: (d) has authority under Sections III.5 or III.9 of the Privacy Shield Principles; or (e) has the authority to resolve the claimed violation directly with us.
 
D. Limitation
 
Adherence to this EU-US Privacy Policy is limited to the extent (i) required to respond to a legal or ethical obligation; (ii) necessary to meet national security, public interest or law enforcement obligations; and (iii) expressly permitted by an applicable law, rule or regulation.
 
E. Privacy Policy
 
We recognize the importance of maintaining the privacy of information collected online and via applications, and have created the Redline Privacy Policy (of which this EU-US Privacy Policy is a part) governing the treatment of personal information collected through web sites and applications that we operate. The Redline Privacy Policy reflects additional legal requirements and evolving standards with respect to privacy, and in fact, we utilize this Redline Privacy Policy in facilitating adherence to the Privacy Shield Principles. As such, this EU-US Privacy Policy and the Redline Privacy Policy should be construed harmoniously wherever possible; however, with respect to personal information that is transferred from the EU or Switzerland to the US, the Redline Privacy Policy is subordinate to this EU-US Privacy Policy.
 
F. Contact Information
 
Questions or comments regarding this policy should be submitted to the Redline Privacy Office
, 1320 San Anselmo Ave., San Anselmo, California, 94960 USA, or via e-mail to webmaster@redline.net.
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