Effective Date: 1 January 2011
Last Revised: 11 November 2016
By using the Site, you consent to:
- the collection and use of personal information and data as set forth in this Policy;
- 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.
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.
B. Information Collected
The following personal and other information about you or arising from your activities on the Site may be collected and stored by us (which will be in addition to the information we collect as described in the Terms of Membership):
(i) name and identity, email address, physical and virtual contact information (including home and/or office address), biographical and professional information, association affiliation, licensing and bar registration information, demographic data, and financial information, including credit card and/or bank account numbers;
(ii) information responsive to Redline or member polls or surveys or applications for employment, disclosed in resumes, or requested in order to provide information about our business, employment, products or services;
(iii) transactional information based on your activities on the Site;
(iv) shipping, ordering, billing and other similar information you provide to purchase or ship an item or service;
(v) community discussions, chats, dispute resolution, correspondence through the Site, and correspondence sent to us;
(vi) computer sign-on data, time and date data, statistics on page views, your IP address, your GPS location, the type of computing environment you use, and traffic to and from the Site (including data about you whenever you interact with the Site, such as when you search, click on links, send messages, make comments, replies or queries, and select best replies);
(vii) other technical information or data collected from Site traffic, including IP address and standard web log information and information gathered from cookies, beacons and other mechanisms;
(viii) supplemental or additional information we may request from you in the event previous information you've provided cannot be verified;
(ix) Your Content (as that term is defined in the Terms of Membership) and any other information that you choose to make available via the Site or that other members share about you; and
(x) information that you voluntarily provide to us.
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 or 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 information 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) customize, measure, and improve our services, membership benefits and the Site's 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.
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 information 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.
D. Sharing Information
We may also share your personal information with:
(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;
(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; and
(vi) other business entities, should we plan to merge with, or be acquired by that business entity.
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.
The following is an illustrative list of the cookies that may be used and installed on your computer or device by the Site:
|SESS[*]||Fix user's session||Session-only||Redline||Functional|
|__utma||Site visits||2 years||Analytical|
|__utmb||Site duration||30 minutes||Analytical|
|osp||Spellcheck function||Until 2038||Webspellchecker.net||Functional|
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.
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, remember that 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 email@example.com.
I. Your Rights
You can see, review and change most of your personal information by logging into the Site. You must promptly update your personal information if it changes or is inaccurate. Once you make a public 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 posted content will still be accessible. In addition to the foregoing, we retain personal information from closed accounts, if 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 Site-related agreements, and take other actions otherwise permitted by law or as specified elsewhere in this Policy.
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 information 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 firstname.lastname@example.org. Upon receipt and process of a reasonable opt-out request, we will, within a commercially reasonable period of time, comply with such request to the extent reasonable. 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.
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.
The Site is not directed to children under thirteen (13) years of age, and we do not knowingly collect personal information from such children. If you are younger than thirteen, 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 email@example.com so that we can remove such personal information from our database.
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.
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.
The United States Department of Commerce and the European Commission have agreed on a set of privacy shield principles and frequently asked questions 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 "US-EU Privacy Shield"). The EU also has recognized the US-EU Privacy Shield as providing adequate data protection. The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions 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 “US-Swiss Safe Harbor”). Our certification under the US-Swiss Safe Harbor is here. Consistent with its commitment to protect personal privacy, we adhere to the principles of the US-EU Privacy Shield and the US-Swiss Safe Harbor in effect as of the effective date below (the “Privacy Shield Principles”) as documented in this policy.
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.
(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 Swiss Federal Act on Data Protection, or (j) such agent being subject to another European Commission or Swiss FDPIC 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.
F. Contact Information
Questions or comments regarding this policy should be submitted to the Redline Privacy Office , 1000 4th Street, Suite 875, San Rafael, CA 94901 USA, or via e-mail to firstname.lastname@example.org.