Anderson Leavitt LLC Terms Of Use & Privacy Policy

Table Of Contents

1. Terms of Use
2. Privacy Policy
3. US State Supplemental Privacy Policy
4. CA Business Privacy Policy
5. Online Cookie Notice
6. DO NOT SELL MY PERSONAL INFORMATION

TERMS OF USE

ANDERSON LEAVITT LLC

Effective  January 1, 2023

Andersonleavitt.com (this “Site”) is owned and operated by Anderson Leavitt LLC (“Anderson Leavitt,” “we,” “our” or “us”).

Consent to These Terms of Use

The use of this Site is subject to these Terms of Use (“Terms of Use”). By using this Site, you agree to these Terms of Use. If you do not agree with these Terms of Use, you cannot use this Site.

Content of this Site is Not Legal Advice

The information offered on this Site does neither constitutes legal advice nor does it form an attorney-client relationship.  We urge you to seek the specific advice of counsel who is familiar with your specific situation before acting on any issue discussed on this Site.

Sending us an Email Does Not Make You a Client of this Firm

Sending us an email does not make you a client. Anderson Leavitt must agree to represent you in writing.  Nothing you send will be confidential or privileged prior to the firm agreeing to represent you. Do not send us any confidential information by email except at the specific request of a lawyer of this firm. Unsolicited emails are not binding on this firm and do not impose valid deadlines.

Changes to Terms of Use and Modification or Discontinuation of Site

Anderson Leavitt reserves the right to update or revise these Terms of Use at any time without prior notice by posting the revised version on this Site. The date these changes will be effective will be stated at the top of this page. By using this Site following any such change, you agree to be bound by the revised Terms of Use. For this reason, it is important for you to periodically review our Terms of Use.

We may at any time modify, edit, delete, suspend or discontinue, temporarily or permanently, the Site (or any portion thereof) with or without notice. You agree that we will not be liable to you or to any third party for any such modification, editing, deletion, suspension, or discontinuance of the Site. Any of the material on the Site may be out of date at any given time, and we are under no obligation to update such material.

Privacy Notice

The Anderson Leavitt Privacy Notice (“Privacy Notice”) describes how we protect your personal information when you use this Site.

Ownership of Site and Content

As used in these Terms of Use, the term “Content” means all of the code and software that comprise and operate this Site, and all of the text, photographs, images, illustrations, graphics, designs, audio, video and audio-video clips, and other materials provided through this Site. Anderson Leavitt and its licensors own all right, title and interest in the Content, including all copyrights. In addition, the entire Content of this Site is protected as a compilation under U.S. and international copyright laws and treaties and Anderson Leavitt owns the copyright in the compilation, including the collection, assembly, selection, coordination, and arrangement of the Content of this Site.

We grant you a limited, revocable license to download and print copies of any portion of the Content of this Site for your own personal, non-commercial use, and only if you do not remove, modify or obscure any copyright, trademark, or other proprietary notices. The foregoing license is subject to these Terms of Use and does not include the right to use any data mining, robots or similar data gathering or extraction methods nor the right to “harvest” email addresses. This license is revocable at any time without notice and with or without cause. If you wish to copy, distribute, disseminate, perform or display publicly, prepare derivative works based on, broadcast, exploit or use any part of the Content on this Site other than as set forth above please contact [email protected] for written authorization to do so. Other than the limited license set forth herein, nothing in these Terms of Use shall be interpreted as transferring any right, title or interest in this Site or its Content to you or anyone else.

Trademarks

Anderson Leavitt LLC, the Anderson Leavitt logo and all related names, logos, product and service names, designs, and slogans are trademarks of Anderson Leavitt LLC or its affiliates or licensors. You must not use such marks without our prior written permission. of the Company. All other names, logos, product and service names, designs, and slogans on this Site are the trademarks of their respective owners.  Reference to any third party company by trade mark or otherwise does not constitute or imply endorsement, sponsorship or recommendation thereof by Anderson Leavitt and we do not represent or guaranty that any third party materials are accurate or reliable.  These materials are provided for your convenience and should be used at your sole risk.

User Contributions

The Site may contain message boards, chat rooms, personal web pages or profiles, forums, bulletin boards and other interactive features (collectively, “Interactive Services”) that allow users to post, submit, publish, display, or transmit to other users or other persons (hereinafter, “post”) content or materials (collectively, “User Contributions”) on or through the Site.

All User Contributions must comply with these Terms of Use.

Any User Contribution you post to the Site will be considered non-confidential and non-proprietary. By providing any User Contribution on the Site, you grant us and our service providers, and each of their and our respective licensees, successors, and assigns the right to use, reproduce, modify, perform, display, distribute, and otherwise disclose to third parties any such material.

You represent and warrant that:

• You own or control all rights in and to the User Contributions and have the right to grant the license granted above to us and our service providers, and each of their and our respective licensees, successors, and assigns.
• All of your User Contributions do and will comply with these Terms of Use.

You understand and acknowledge that you are responsible for any User Contributions you submit or contribute, and you, not Anderson Leavitt, have full responsibility for such content, including its legality, reliability, accuracy, and appropriateness.

We are not responsible or liable to any third party for the content or accuracy of any User Contributions posted by you or any other user of the Site.  We disclaim all liability and responsibility arising from any reliance placed on such materials by you or any other visitor to the Website, or by anyone who may be informed of any of its contents.

Content Standards

These content standards apply to any and all user Contributions and use of Interactive Services. User Contributions must in their entirety comply with all applicable federal, state, local, and international laws and regulations. Without limiting the foregoing, user Contributions must not:

• Contain any material that is defamatory, obscene, indecent, abusive, offensive, harassing, violent, hateful, inflammatory, or otherwise objectionable.
• Promote sexually explicit or pornographic material, violence, or discrimination based on race, sex, religion, nationality, disability, sexual orientation, or age.
• Infringe any patent, trademark, trade secret, copyright, or other intellectual property or other rights of any other person.
• Violate the legal rights (including the rights of publicity and privacy) of others or contain any material that could give rise to any civil or criminal liability under applicable laws or regulations or that otherwise may be in conflict with these Terms of Use and our Privacy Policy.
• Be likely to deceive any person.
• Promote any illegal activity, or advocate, promote, or assist any unlawful act.
• Cause annoyance, inconvenience, or needless anxiety or be likely to upset, embarrass, alarm, or annoy any other person.
• Impersonate any person, or misrepresent your identity or affiliation with any person or organization.
• Involve commercial activities or sales, such as contests, sweepstakes, and other sales promotions, barter, or advertising.
• Give the impression that they emanate from or are endorsed by us or any other person or entity, if this is not the case.

Your Obligations

If you wish to register on the Site, you will be required to provide certain personal information to us. You agree to (a) provide true, accurate, current and complete information about yourself as prompted in the applicable page, (b) maintain and promptly update your information to keep it true, accurate, current and complete and (c) comply with the terms of our Privacy Notice.

You agree to use the Site in a manner consistent with any and all applicable laws, rules and regulations. You agree not to upload or transmit to or through this Site any computer viruses, trojan horses, worms or anything else designed to interfere with, interrupt or disrupt the normal operating procedures of a computer. Any unauthorized modification to, tampering with or change to any information, or any interference with the availability of or access to our Site is strictly prohibited. We reserve all rights and remedies available to us including reporting any breach to the relevant law enforcement authorities and working with those authorities by disclosing your identity to them.

Indemnification

You agree to defend, indemnify and hold harmless Anderson Leavitt, its independent contractors, service providers and consultants, and their respective directors, members, employees and agents, from and against any claims, damages, costs, liabilities and expenses (including, but not limited to, reasonable attorneys’ fees) arising out of or related to any User Content/Contributions you post, store or otherwise transmit on or through the Site, including without limitation any actual or threatened suit, demand or claim made against Anderson Leavitt and/or its independent contractors, service providers, employees, directors or consultants, arising out of or relating to your conduct, your violation of these Site Terms of Use or your violation of the rights of any third party.

DISCLAIMER OF WARRANTIES

You understand that we cannot and do not guarantee or warrant that files available for downloading from the internet or the Site will be free of viruses or other destructive code. You are responsible for implementing sufficient procedures and checkpoints to satisfy your particular requirement for anti-virus protection and accuracy of data input and output, and for maintaining a means external to our site for any reconstruction of any lost data. TO THE FULLEST EXTENT PROVIDED BY LAW, WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY A DISTRIBUTED DENIAL-OF-SERVICE ATTACK, VIRUSES, OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, DATA, OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE SITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE SITE OR TO YOUR DOWNLOADING OF ANY MATERIAL POSTED ON IT, OR ON ANY WEBSITE LINKED TO IT.

YOUR USE OF THE SITE, ITS CONTENT, AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE SITE IS AT YOUR OWN RISK. THE SITE, ITS CONTENT, AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE SITE ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. NEITHER THE ANDERSON LEAVITT NOR ANY PERSON ASSOCIATED WITH THE ANDERSON LEAVITT MAKES ANY WARRANTY OR REPRESENTATION WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, QUALITY, ACCURACY, OR AVAILABILITY OF THE SITE. WITHOUT LIMITING THE FOREGOING, NEITHER THE ANDERSON LEAVITT NOR ANYONE ASSOCIATED WITH ANDERSON LEAVITT REPRESENTS OR WARRANTS THAT THE WEBSITE, ITS CONTENT, OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL BE ACCURATE, RELIABLE, ERROR-FREE, OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED, THAT OUR SITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR THAT THE SITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE SITE WILL OTHERWISE MEET YOUR NEEDS OR EXPECTATIONS.

TO THE FULLEST EXTENT PROVIDED BY LAW, ANDERSON LEAVITT HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY, OR OTHERWISE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT, AND FITNESS FOR PARTICULAR PURPOSE.

THE FOREGOING DOES NOT AFFECT ANY WARRANTIES THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

LIMITATION OF LIABILITY

THIS IS A COMPREHENSIVE LIMITATION OF LIABILITY THAT APPLIES TO ALL LOSSES AND DAMAGES OF ANY KIND (WHETHER DIRECT, INDIRECT, GENERAL, SPECIAL, CONSEQUENTIAL, INCIDENTAL, EXEMPLARY OR OTHERWISE, INCLUDING LOSS OF DATA, INCOME OR PROFITS), WHETHER THE CLAIM IS BASED ON CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY OR ANY OTHER LEGAL THEORY, EVEN IF AN AUTHORIZED REPRESENTATIVE OF ANDERSON LEAVITT HAS BEEN ADVISED OF OR SHOULD HAVE KNOWN OF THE POSSIBILITY OF SUCH DAMAGES, AND WITHOUT REGARD TO THE EFFECTIVENESS OF OTHER REMEDIES.

IF ANY PART OF THIS LIMITATION ON LIABILITY IS FOUND TO BE INVALID OR UNENFORCEABLE FOR ANY REASON, THEN YOU AGREE THE AGGREGATE LIABILITY OF ANDERSON LEAVITT FOR LIABILITIES THAT OTHERWISE WOULD HAVE BEEN LIMITED SHALL NOT EXCEED $100.00.

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF LIABILITY FOR CERTAIN TYPES OF DAMAGES. ACCORDINGLY, SOME OF THE FOREGOING LIMITATIONS OF LIABILITY MAY NOT APPLY TO YOU.

Links to this Site

You may link to our home page so long as it does not damage our reputation or suggest any form of approval or endorsement.

You must not establish a link to this Site from any website that is not owned by you.

You agree to cooperate with us in causing any unauthorized framing or linking immediately to stop. We reserve the right to withdraw linking permission without notice. The website from which you are linking must comply in all respects with the content standards set out in these Terms of Use.

Links from this Site

If the Site contains links to other sites and resources provided by third parties, these links are provided for your convenience only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third-party websites linked to this Website, you do so entirely at your own risk and subject to the terms and conditions of use for such websites.

Interpretation

As used in these Terms of Use, the term “including” means “including, but not limited to.”

Waiver and Severability

No waiver by Anderson Leavitt of any term or condition set out in these Terms of Use shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition, and any failure of Anderson Leavitt to assert a right or provision under these Terms of Use shall not constitute a waiver of such right or provision.

If any provision of these Terms of Use is held by a court or other tribunal of competent jurisdiction to be invalid, illegal, or unenforceable for any reason, such provision shall be eliminated or limited to the minimum extent such that the remaining provisions of the Terms of Use will continue in full force and effect.

Termination

Notwithstanding any provision within these Terms of Use, Anderson Leavitt reserves the right, without notice and in its sole discretion, to terminate your license to use the Site, and to block or prevent your use of and future access to the Site.

Governing Law, Jurisdiction and Venue

These Terms of Use shall be governed by the laws of the Commonwealth of Pennsylvania without regard to its conflicts of law provisions. Venue for all actions or proceedings arising out of or relating to these Terms of Use shall be exclusively in the state or federal court of Pennsylvania and by using this Site you irrevocably consent and submit to the personal jurisdiction of such courts for all purposes.

Entire Agreement

These Terms of Use contain the entire understanding and agreement between you and us with respect to this Site (including the use of the Content) and supersede all prior communications, negotiations and agreements, whether oral, written, or electronic between you and us with respect to this Site.

Questions and Contact Information

Questions or comments about the Site may be directed to [email protected].

Privacy Notice

ANDERSON LEAVITT LLC

Effective Date: January 1, 2023

Your privacy is important.  Please read this privacy notice to understand the online information practices of Anderson Leavitt and your related choices.

This Privacy Policy Notice (the “Privacy Notice”) sets forth how Anderson Leavitt LLC (“Anderson Leavitt,” “we” or “us”) collects, uses and discloses information about you when you use www.andersonleavitt.com (the “Site”), and other online services (collectively, the “Services”). This Privacy Notice also applies when you attend our events or when you otherwise interact with us as described below, unless we state that a different Privacy Notice applies.

The effective date of this Privacy Notice is posted above. We may update this Privacy Notice from time to time. If we make updates, we will notify you by revising the date at the top of this Privacy Notice, and if required by law, we may provide you with additional notice (such as by adding a statement to our Site homepage or by sending you an email).  We encourage you to review this Privacy Notice whenever you access these Services to stay updated about our information practices and your choices.

For individuals located in the European Economic Area (“EEA”) review the “European Data Protection Law” section which, in addition to the general information in this Privacy Notice, contains further information required by the European data protection laws about how Anderson Leavitt processes your personal data.

INFORMATION WE COLLECT

Information You Provide to Us
We collect information you provide directly to us. Examples include when you send us an email, fill out a form, apply for a job, interact with us on social media, or otherwise communicate with us.  The types of information we may collect include your name, username and password, postal address, email address, phone number, current occupation and business contact information, social security number, employment application information (including education and work history), social media username or handle, demographic information, and any other information you choose to provide.

Information We Collect Automatically
When you access or use the Services, we collect certain information about you that is sent to us automatically by your web browser, including:

• Log Information. Information about your use of the Services, including your internet protocol address (“IP address”), the identity of your Internet Service Provider, usage details from your Site visit, the name and version of your operating system and web browser. Although it does not identify you by name, we treat your IP address as your personal information.

When you access the Services by clicking on a link in an electronic communication you receive from us, your browser tells us that someone has clicked on a particular link in that particular electronic communication. We use this information to improve our marketing efforts. In addition, we review our server logs — which contain visitors’ IP addresses — for security and fraud prevention purposes. If criminal activity is suspected, we may share our server logs and the personal information we have collected through the Services with the appropriate investigative authorities who could use that information to trace and identify individuals.

• Information Collected by Cookies and Other Tracking Technologies. Information collected by us or our third-party providers using various technologies, including cookies and web beacons (or pixel tags).  Cookies are small data files stored on your hard drive or in device memory that help us to, among other things, improve the Services and your experience, see which areas and features of the Services are popular and count visits. Web beacons are clear, electronic images that may be used on the Services or in our emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine if an email has been opened and acted upon. For more information, please refer to our Online Cookie Notice.
• Device Information. Information about the mobile device you use to access our mobile applications, including the hardware model, operating system and version, unique device identifiers and mobile network information.

Information from Other Sources

We may also obtain information from other sources and combine that with information we collect through the Services. For example, we may use information from LinkedIn to update information about you in our contact database.

 HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Site and its contents to you.
• To provide you with information, products, or services that you request from us.
• To provide you with legal services.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Site or legal services we offer.
• To allow you to participate in interactive features on our Site.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

HOW WE DISCLOSE YOUR INFORMATION

We may share information about you as set forth below or as otherwise set forth in this Privacy Notice.

To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Anderson Leavitt’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Anderson Leavitt’s Site users is among the assets transferred.· To fulfill the purpose for which you provide it. · For any other purpose disclosed by us when you provide the information.· With your consent. We may also disclose your personal information: · To comply with any court order, law, or legal process, including to respond to any government or regulatory request.· To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Anderson Leavitt, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

YOUR CHOICES

In General

We respect your right to make choices about the ways we collect, disclose and use your personal information.

Direct Marketing

We will not without your consent use your personal information for direct marketing purposes. We obtain your opt-in consent  to our marketing communications via the Site. We include an “opt-out” link  in electronic newsletters and promotional emails we send you, so that you can inform us that you do not wish to receive such communications from us in the future. If at any time you wish to be removed from our mailing lists, please contact us using the contact information provided at the end of this Privacy Notice. Please provide your full name, company name, postal address and email address so that we can locate you on our mailing lists. We will honor your request within a reasonable period of time and, in any event, within the time limits established by law.

Account Information

If you wish to access, modify or correct or delete your personal information, please contact us by email at anderson@andersonleavitt or postal mail at Anderson Leavitt LLC, 620 West Germantown Pike, Suite 260, Plymouth Meeting, PA 19462 USA, Attn: David Anderson. We will respond to you within a reasonable time period and, in any case, within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if it would violate any law or legal requirement or cause the information to be incorrect or if we are unable to verify your identity. To the extent authorized by law, we reserve the right to charge a reasonable fee to meet our costs in providing you with details of the personal information we hold about you. Please know that we may retain certain information for our legitimate business purposes (for example – we may need to retain your contact information to comply with our obligation to maintain and return your records in accordance with the rules of Professional Responsibility

Links to Third Party Content and Other Websites

This Privacy Notice does not apply to third-party services that are not operated or controlled by Anderson Leavitt, and accordingly, we cannot take responsibility for the content, privacy policies, or practices of third-party services. Care should be taken to review the privacy policies of any third-party service (LinkedIn for example) before providing any information to or through them.

DATA RETENTION AND STORAGE  

Data Retention

Information collected about you is stored for as long as necessary for the purpose(s) for which we collected it and in accordance with applicable law and legitimate business interests.

When determining the appropriate data retention period, we take into account the amount, nature, and sensitivity of the information, the risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the data and whether we can achieve those purposes through alternative means all the while complying with applicable law.

Security of Information

Appropriate and reasonable security precautions are in place to protect against the misuse, alteration or loss of any personal information we have received/collected.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information and data may be viewed or compromised by a third party and is entirely at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site

Accuracy of Information

We try to maintain accurate records and will make appropriate corrections when you notify us. Please tell us if there is incorrect information in any statements or other communications that you receive from us. If you would like to correct or update your personal information, please contact us at [email protected]

Children Under the Age of Thirteen

Our Site is not intended for children or minors under the age of thirteen years without the permission of a parent or guardian. If you believe that a child has submitted personal information on or through our Site without the consent and supervision of a parent or guardian, contact us using the information provided below (or at [email protected]) so that we can take appropriate action.

CALIFORNIA PRIVACY RIGHTS

Shine the Light

California Civil Code Section 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to [email protected] with the subject “Shine the Light Request.”

California Consumer Privacy Act

If you are a California resident, we encourage you to review our California Privacy Policy for  information about the additional rights you have under the California Consumer Privacy Act, California Civil Code Sections 1798.100–.199.

EUROPEAN DATA PROTECTION LAW 

This section applies only to individuals who are located in the European Economic Area. Nothing is this section is intended to bind Anderson Leavitt in respect of the personal information of any other individual.

For the purpose of applicable data protection laws in the European Union (including the General Data Protection Regulation (2016/679)), Anderson Leavitt LLC is the data controller of your personal information.  For queries, contact us at [email protected].

Our Legal Grounds for Using Your Personal Information

We will only use your personal information when allowed by law and in most instances as follows:

• When we need to perform the contract we are about to enter into or have entered into with you (“Contract performance”);
• When it is necessary for our legitimate interests (i.e. we have a business or commercial reason for using your information) and your interests and your fundamental rights do not override those interests (“Our legitimate interests”);
• Whenwe need to comply with a legal or regulatory obligation (“Compliance with our legal obligations”); or
• When you consent (“Consent”).

Personal information may be processed for more than one legal ground depending on the specific purpose. Please contact us if you would like details about the specific legal ground we are relying on to process your personal information.

 

Purpose	Legal Ground(s)	Legitimate Interest(s) (if applicable)
To comply with our legal and regulatory obligations under applicable law	Compliance with our legal obligations	N/A
Operate the Services and improve the content, functionality and usability of the Services	Contract performance	Efficiently fulfilling our legal and contractual duties; providing high quality client service
To customize our Sites’ content and layout	Consent (where this involves the use of cookies; please see our .	Providing high quality client service
Respond to your questions, comments and requests you have made through the Services (including our digital marketing tools)	Our legitimate interests	Providing high quality client service
Contact you about products, services, offers, and events offered by Anderson Leavitt or our partners that we believe will be of interest to you (unless you have chosen not to receive these communications)	Our legitimate interests   Your consent	Providing high quality client service; keeping our services relevant, effective and of high quality; defining types of clients New services or offerings; marketing our services
Contact you with information and notices related to your use of the Services	Your consent   Our legitimate interests	Providing high quality client service; marketing our services; fulfilling our legal and/or contractual obligations
Invite you to participate in surveys and provide feedback to us (unless you have chosen not to receive such invitations)	Our legitimate interests   Your consent	Providing high quality client service; keeping our services relevant, effective and of high quality; defining types of clients for new services or offerings; marketing our services
Ensure our mailing lists are accurate, current and do not contain multiple entries for the same individual	Our legitimate interests   Compliance with our legal obligations	Providing high quality client service; keeping our services relevant, effective and of high quality; fulfilling our legal and/or contractual obligations
Monitor and analyze usage, trends and activities related to the Services to better understand your needs and interests	Our legitimate interests	Providing high quality client service
Assess job applicants and make hiring decisions	Compliance with our legal obligations   Our legitimate interests	Making hiring decisions; ensuring the quality and good character of our personnel
Provide legal services	Contract performance   Compliance with our legal obligations	N/A
To perform any agreement and/or contract we have with you	Contract performance	N/A
To administer and protect the security of our business and IT infrastructure, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data	Our legitimate interests   Compliance with our legal obligations	Efficiently fulfilling our legal and contractual duties; complying with regulations that apply to us; developing and improving the network security, efficiency and technical specification of our IT systems and infrastructure
As part of any proposed mergers and acquisitions involving Faegre Drinker	Our legitimate interests	Expanding and developing our business; ensuring the future success of our business
To assert our rights in contracts to which we are a party and to establish, exercise or defend legal claims in which we are involved	Our legitimate interests   Contract performance   Compliance with our legal obligations	Efficiently fulfilling our legal and contractual duties; complying with regulations that apply to us; to establish, exercise or defend legal claims

We will only use your personal information for the purposes it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal ground which allows us to do so.

Your Rights

Subject to any local or national law exceptions, if you are a resident of the European Economic Area (“EEA”) you the following rights:

• Access. Subject to certain exceptions, you have the right to confirm and request a copy of the personal information being processing about you.
• Rectification. You have the right to require that any incomplete or inaccurate personal information that we process about you is updated.
• Erasure/Deletion. In certain circumstances, you have the right to request that we delete personal information that we process about you-the right to be forgotten.
• Restriction. You have the right to request that we restrict our processing of your personal information where: (a) you believe such information is not accurate, (b) our processing is unlawful but you oppose the deletion of your personal information, (c) we no longer need to process such information for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because we require the information in connection with legal claims, or (d) you object to the processing of your personal information.
• Portability. You have the right to request that we transmit the personal information we hold in respect of you to another data controller, where this is (a) personal information which you have provided to us, (b) the processing is by automated means, and (c) we are processing that information on the basis of your consent or in order to perform our obligations under a contract to you.
• Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your specific situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
• Withdrawing Consent. If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. This includes cases where you wish to opt out from marketing messages that you receive from us.
• Making a Complaint. You may make a complaint at any time with the national data protection authority in the EU country where you are based. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us at [email protected].

 

You may contact us at [email protected] at any time to exercise any of the rights which apply to you. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights).

Cross-Border Data Transfers

We transfer personal information to jurisdictions as necessary for the purposes described above. In particular, our Site is hosted on servers located in the United States. To the extent permitted by law, such submission also constitutes your consent for the cross-border transfer.

With respect to transfers from the EEA to the United States and other non-EEA jurisdictions, we implement standard contractual clauses as approved by the European Commission, and other appropriate solutions to address cross-border transfers as required or permitted by Articles 46 and 49 of the General Data Protection Regulation.  Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us.

Privacy Rights in Other Jurisdictions

You may have rights in relation to your personal information under applicable data privacy laws in other jurisdictions. If you wish to exercise any such rights, please contact us using the contact information below.

Contact Information

If you have any questions about this Privacy Notice or our data practices, please contact us:

For the USA.

Anderson Leavitt LLC Attn: Compliance Support 620 West Germantown Pike, Suite 260 Plymouth Meeting, PA 19426 USA [email protected]

(484) 535-7080

Supplemental Website Privacy Notice for California, Colorado, Virginia, Utah, & Connecticut Consumers

Last Updated: January 2023

This Supplemental Website Privacy Notice (“Supplemental Notice”) applies only to information collected about California, Colorado, Virginia, Utah, and Connecticut consumers. It provides information required under the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 and their implementing regulations (collectively, the “CCPA”), the Colorado Privacy Act of 2021 (the “CPA”), the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”), the Utah Consumer Privacy Act of 2022 (the “UCPA”), and the Connecticut Data Privacy Act of 2022 (“CDPA”). We also provide a brief paragraph regarding information collected about Nevada consumers under the heading “Privacy Notice for Nevada Residents” at the end of this Supplemental Notice. The other portions of this Supplemental Notice do not apply to Nevada consumers.

This Supplemental Notice describes Anderson Leavitt LLC’s (“Anderson Leavitt,” “we,” “us,” “our”) practices regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests. This Supplemental Notice is parallel in scope to our  Privacy Notice and applies to information collected through both online and offline interactions with consumers.

Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, we have indicated that such language applies only to those consumers.

Please also note that this Supplemental Notice does not address our Collection and processing of Personal Information from employees, job applicants, other individuals with whom we interact in an employment-related context, or business contacts. California residents who are business contacts may access our California business privacy disclosures.

1. Definitions

• “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information includes “personal data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA. Personal Information also includes “Sensitive Personal Information,” as defined below, except where otherwise noted.
• “Sensitive Personal Information” means Personal Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; and genetic data. Sensitive Personal Information also includes processing of biometric information for the purpose of uniquely identifying a consumer and Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Sensitive Personal Information also includes “sensitive data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA.
• “Third Party” has the meanings afforded to it in the CCPA, CPA, VCDPA, UCPA, and CDPA.
• “Vendor” means a service provider, contractor, or processor as those terms are defined in the CCPA, CPA, VCDPA, UCPA, and CDPA.

To the extent other terms used in this Supplemental Notice are defined terms under the CCPA, CPA, VCDPA, UCPA, or CDPA they shall have the meanings afforded to them in those statutes, whether or not capitalized herein. As there are some variations between such definitions in each of the five statutes, the definitions applicable to you are those provided in the statute for the state in which you are a consumer. For example, if you are a Virginia consumer, terms used in this Supplemental Notice that are defined terms in the VCDPA shall have the meanings afforded to them in the VCDPA as this Supplemental Notice applies to you.

1. Collection & Processing of Personal Information

We, and our Vendors, collect the following categories of Personal Information about consumers. We also have collected and processed the following categories of Personal Information about consumers in the preceding 12 months:

1. Identifiers, such as name or social security number;
2. Contact and financial information, including phone number, address, email address, bank account number, credit card number, debit card number, or any other financial information;
3. Characteristics of protected classifications under state or federal law, such as gender;
4. Internet or other electronic network activity information, such as browsing history and interactions with our websites or advertisements;
5. Geolocation data, such as device location; and
6. Professional or employment-related information, such as work history and prior employer.

Retention of Personal Information. We retain each of the categories of Personal Information listed in Section B for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes listed in Section E.

When assessing the data retention period, we take into account the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements.

1. Categories of Personal Information We Disclose to Vendors & Third Parties

In the past twelve months, we have disclosed the following categories of Personal Information to Vendors and Third Parties for a business purpose:

1. Identifiers, such as name or social security number;
2. Contact and financial information, including phone number, address, email address, bank account number, credit card number, debit card number, or any other financial information;
3. Characteristics of protected classifications under state or federal law, such as gender;
4. Internet or other electronic network activity information, such as browsing history and interactions with our websites or advertisements;
5. Geolocation data, such as device location; and
6. Professional or employment-related information, such as work history and prior employer.

Disclosure for California Consumers: We do not sell or share any of the categories of Personal Information we collect about you, and we have not sold or shared Personal Information about California consumers in the past twelve months. Relatedly, we do not have actual knowledge that we sell or share Personal Information of California consumers under 16 years of age. For purposes of the CCPA, a “sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

Disclosure for Colorado, Virginia, Utah, and Connecticut Consumers: We do not sell or share Personal Information to Third Parties or process Personal Information for purposes of targeted advertising, as the terms “sell,” “share,” “process,” and “targeted advertising” are defined in the CPA, VCDPA, UCPA, and CDPA.

1. Sources from Which We Collect Personal Information

We collect Personal Information directly from California, Colorado, Virginia, Utah, and Connecticut consumers, as well as from joint marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, people with whom you are connected on social media platforms, and Vendors and Third Parties when they share the information with us.

1. Purposes for Processing & Disclosing Personal Information

We, and our Vendors, collect, process, and disclose the Personal Information (excluding Sensitive Personal Information) described in this Supplemental Notice to:

• Operate, manage, and maintain our business;
• Confirm consumer identities;
• Manage client relationships;
• Provide client services;
• Provide, develop, improve, and maintain our services;
• Record and maintain client instructions;
• Process payment transactions;
• Promote client or business-development events and programming;
• Direct marketing, including newsletters and client alerts;
• Better understand the market for our existing services, and potential new services, and adjust our research, development, and marketing strategies accordingly;
• Conduct research, analytics, and data analysis;
• Monitor and improve website functionality;
• Maintain our facilities and infrastructure;
• Protect against security threats and misuse of the Anderson Leavitt website;
• Conduct risk and security controls and monitoring;
• Detect and prevent fraud;
• Perform accounting, audit, and other internal functions, such as internal investigations;
• Process payment transactions;
• Maintain records;
• Otherwise accomplish our business purposes and objectives.

In addition to the purposes identified above, Anderson Leavitt may use and disclose any and all Applicant Personal Information that we Collect as necessary or appropriate to:

• Comply with laws and regulations, including, without limitation, applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws;
• Monitor, investigate, and enforce compliance with and potential breaches of Anderson Leavitt policies and procedures and legal and regulatory requirements;
• Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and
• Exercise or defend the legal rights of Anderson Leavitt and its employees, affiliates, customers, contractors, and agents.

We, and our Vendors, collect and process the Sensitive Personal Information described in this Supplemental Notice only for the below purposes that are authorized by the CCPA and its implementing regulations:

• Performing the services or providing the goods reasonably expected by an average consumer who requests those goods or services;
• Ensuring security and integrity to the extent the use of the consumer’s Personal Information is reasonably necessary and proportionate for these purposes;
• Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted Personal Information;
• Resisting malicious, deceptive, fraudulent, or illegal actions directed at the business and prosecuting those responsible for those actions;
• Ensuring the physical safety of natural persons;
• Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with us; provided that we will not disclose the consumer’s Personal Information to a Third Party and or build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business;
• Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us; and
• Collecting or processing Sensitive Personal Information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

1. Categories of Entities to Whom We Disclose Personal Information

• Affiliates & Vendors. We may disclose your Personal Information to our affiliates and Vendors for the purposes described in Section E of this Supplemental Notice. Our Vendors provide us with services for our websites, as well as other products and services, such as web hosting, data analysis, payment processing, customer service, infrastructure provision, technology services, email delivery services, credit card processing, legal services, and other similar services. We grant our Vendors access to Personal Information only to the extent needed for them to perform their functions, and require them to protect the confidentiality and security of such information.
• Third Parties. For each category of Personal Information identified in Section C, we disclose such Personal Information to the following categories of Third Parties:
• At Your Direction.We may disclose your Personal Information to any Third Party with your consent or at your direction.
• Business Transfers or Assignments. We may disclose your Personal Information to other entities as reasonably necessary to facilitate a merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
• Legal and Regulatory.We may disclose your Personal Information to government authorities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.

1. Data Subject Rights

• Exercising Data Subject Rights. California, Colorado, Virginia, Utah, and Connecticut consumers have certain rights with respect to the collection and use of their Personal Information. Those rights vary by state. As required by the CCPA, we provide detailed information below regarding the data subject rights available to California consumers. Colorado, Virginia, Utah, and Connecticut consumers have similar rights and can find more detail by referencing the CPA, VCDPA, UCPA, or CDPA, as applicable.

You may exercise the data subject rights applicable to you under the CCPA, CPA, VCDPA, UCPA, or CDPA by contacting us at [email protected] or by calling 484-535-7080​. Consumers in some states may also authorize an agent to make data subject requests on their behalf via the above-listed methods.

• Verification of Data Subject Requests. We may ask you to provide information that will enable us to verify your identity in order to comply with your data subject request. In particular, when a California consumer authorizes an agent to make a request on their behalf, we may require the agent to provide proof of signed permission from the consumer to submit the request, or we may require the consumer to verify their own identity to us or confirm with us that they provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.
• Non-Discrimination. We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.
• Appeals for Virginia, Colorado, and Connecticut Consumers. Virginia, Colorado, and Connecticut consumers have the right to appeal our decisions on their data subject requests. This section does not apply to California or Utah consumers. To appeal our decision on your data subject requests, you may contact our Privacy Office at [email protected] or by calling 484-535-7080​. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.
• Data Subject Rights Disclosure for California Consumers: California consumers have the following rights regarding our collection and use of their Personal Information, subject to certain exceptions.
  • Right to Receive Information on Privacy Practices: You have the right to receive the following information at or before the point of collection:
    • The categories of Personal Information to be collected;
    • The purposes for which the categories of Personal Information are collected or used;
    • Whether or not that Personal Information is sold or shared;
    • If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and
    • The length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.
    • We have provided such information in this Supplemental Notice, and you may request further information about our privacy practices by contacting us as at the contact information provided above.
    • Right to Deletion: You may request that we delete any Personal Information about you we that we collected from you.
    • Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.
    • Right to Know: You may request that we provide you with the following information about how we have handled your Personal Information:
    • The categories of Personal Information we collected about you;
    • The categories of sources from which we collected such Personal Information;
    • The business or commercial purpose for collecting, selling, or sharing Personal Information about you;

• The categories of Third Parties to whom we disclose such Personal Information; and
• The specific pieces of Personal Information we have collected about you.

• Right to Receive Information About Onward Disclosures: You may request that we disclose to you:

• The categories of Personal Information that we have collected about you;
• The categories of Personal Information that we have sold or shared about you and the categories of Third Parties to whom the Personal Information was sold or shared; and
• The categories of Personal Information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

• Right to Non-Discrimination: You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights.
• Rights to Opt-Out of the Sale and Sharing of Your Personal Information and to Limit the Use of Your Sensitive Personal Information: You have the right to opt-out of the sale and sharing of your Personal Information. You also have the right to limit the use of your Sensitive Personal Information to the purposes authorized by the CCPA. We will not sell or share any of the categories of Personal Information we Collect about you, and we have not sold or shared Personal Information in the past twelve months. Further, we do not use or disclose Sensitive Personal Information for purposes beyond those authorized by the CCPA.

• Opt-Out Preference Signals. We do not sell or share Personal Information, or use or disclose Sensitive Personal Information for purposes other than those authorized by the CCPA and its implementing regulations, as listed in Section E. Accordingly, we do not process opt-out preference signals. If we process opt-out preference signals in the future, we will update this policy to provide details about how we do so.

1. Other Disclosures

• California Residents Under Age 18. If you are a resident of California under the age of 18 and a registered user of our website, you may ask us to remove content or data that you have posted to the website by writing to [email protected].  Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.
• Disclosure About Direct Marketing for California Residents. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. We do not distribute your Personal Information to other entities for their own direct marketing purposes.
• Financial Incentives for California Consumers. Under California law, we do not provide financial incentives to California consumers who allow us to collect, retain, sell, or share their Personal Information. We will describe such programs to you if and when we offer them to you.
• Privacy Notice for Nevada Residents. We do not sell Covered Information as defined under Nevada law, and we generally do not disclose or share personal information as defined under Nevada law for commercial purposes. Under Nevada law, you have the right to direct us to not sell or license your personal information to third parties. To exercise this right, if applicable, you or your authorized representative may contact our Privacy Office at [email protected].
• Changes to our Supplemental Notice. We reserve the right to amend this Supplemental Notice at our discretion and at any time. When we make material changes to this Supplemental Notice, we will notify you by posting an updated Supplemental Notice on our website and listing the effective date of such updates.
• Contacting Us. If you have any questions, comments, requests, or concerns related to this Supplemental Notice, Anderson Leavitt’s information practices, or how to access this policy in another format, please contact us at Anderson Leavitt LLC, 620 West Germantown Pike, Suite 260, Plymouth Meeting PA 19462 or at [email protected] for assistance.

CALIFORNIA BUSINESS CONTACT PRIVACY POLICY

Last Updated: January 2023

The California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (collectively, the “CCPA”), gives California residents certain rights and requires businesses to make certain disclosures regarding their Collection, use, and disclosure of Personal Information. This CCPA Business Contact Privacy Policy (the “Policy”) provides such notice to California residents who interact with Anderson Leavitt LLC (“Anderson Leavitt,” “we,” “us,” “our”) in a business-related capacity (“Business Contacts”).

Please note that this Policy only addresses Anderson Leavitt’s Collection, use, and disclosure of Personal Information from consumers with whom we interact in a business-related capacity and only applies to residents of California. This Policy does not apply to individuals who are residents of other U.S. states or other countries and/or who do not interact with Anderson Leavitt in a business-related capacity. For further details about our privacy practices pertaining to non-Business Contact Personal Information, please see our  California Privacy Policy.

As a Business Contact, you have the right to know what categories of Personal Information Anderson Leavitt Collects, uses, discloses, Sells, and Shares about you. This Policy provides that information and other disclosures required by California law.

1. DEFINITIONS

• Personal Information: As used in this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information includes Sensitive Personal Information, but does not include protected health information covered by the Health Information Portability and Accountability Act (“HIPAA”), nonpublic personal information under the Gramm-Leach-Bliley Act (“GLBA”), Publicly Available Information, or any other information that is exempt from the CCPA.
• Publicly Available Information: As used in this Policy, “Publicly Available Information” means information that is lawfully made available from federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public by the Consumer or from widely distributed media, or information made available by a person to whom the Consumer has disclosed the information if the Consumer has not restricted the information to a specific audience. “Publicly Available Information” does not mean biometric information collected by a business about a Consumer without the Consumer’s knowledge.
• Sensitive Personal Information: As used in this Policy, “Sensitive Personal Information” includes Personal Information that reveals, among other things, social security number, driver’s license number, state identification card number, passport number, racial or ethnic origin, union membership, or the contents of a Consumer’s mail, email, and text messages, unless Anderson Leavitt is the intended recipient of the communication. Sensitive Personal Information also includes information concerning the Business Contact’s health, sex life, or sexual orientation.
• Other CCPA Definitions: As used in this Policy, the terms “Collect,” “Processing,” “Service Provider,” “Third Party,” “Sale,” “Share,” “Consumer,” and other terms defined in the CCPA and their conjugates, have the meanings afforded to them in the CCPA, whether or not such terms are capitalized herein, unless contrary to the meaning thereof.

1. Collection & Processing of Business Contact Personal Information

We, and our Service Providers, Collect the following categories of Personal Information about Business Contacts. We also have Collected and Processed the following categories of Personal Information about Business Contacts in the preceding 12 months:

• 1. Identifiers, such as name, alias, signature, online identifiers, account name, social security number, driver’s license or state identification card number, passport number, physical characteristics or description;
  2. Contact and financial information, including phone number, address, email address, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
  3. Characteristics of protected classifications under state or federal law, such as age, gender, race, physical or mental health conditions, and marital status;
  4. Commercial information, such as transaction information and purchase history;
  5. Internet or other electronic network activity information, such as browsing history and interactions with our websites or advertisements;
  6. Geolocation data, such as device location;
  7. Audio, electronic, visual and similar information, such as call and video recordings;
  8. Professional or employment-related information, such as work history and prior employer;
  9. Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information;
  10. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics; and
  11. Sensitive personal information, including:

1. Personal Information that reveals:
   1. Social security, driver’s license, state identification card, or passport number;
   2. Precise geolocation;

• Racial or ethnic origin, religious or philosophical beliefs, or union membership; and

1. Categories of Business Contact Personal Information We Disclose to Service Providers & Third Parties

In the past twelve months, we have disclosed the following categories of Business Contact Personal Information to Service Providers and Third Parties for a business purpose:

• 1. Identifiers, such as name, alias, signature, online identifiers, account name, social security number, driver’s license or state identification card number, passport number, physical characteristics or description;
  2. Contact and financial information, including phone number, address, email address, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
  3. Characteristics of protected classifications under state or federal law, such as age, gender, race, physical or mental health conditions, and marital status;
  4. Commercial information, such as transaction information and purchase history;
  5. Internet or other electronic network activity information, such as browsing history and interactions with our websites or advertisements;
  6. Geolocation data, such as device location;
  7. Audio, electronic, visual and similar information, such as call and video recordings;
  8. Professional or employment-related information, such as work history and prior employer;
  9. Education information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information;
  10. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics; and
  11. Sensitive personal information, including:

1. Personal Information that reveals:
   1. Social security, driver’s license, state identification card, or passport number;
   2. Precise geolocation;

• Racial or ethnic origin, religious or philosophical beliefs, or union membership; and

1. Purposes for Processing & Disclosing Business Contact Personal Information

We, and our Service Providers, Collect, Process, and disclose Business Contact Personal Information (excluding Sensitive Personal Information) described in this Policy to:

• Operate, manage, and maintain our business;
• Confirm Business Contact identities;
• Manage client relationships;
• Provide client services;
• Provide, develop, improve, and maintain our services;
• Record and maintain client instructions;
• Process payment transactions;
• Promote client or business-development events and programming, and communicate with Business Contacts regarding such events and programming;
• Respond to your requests for information about our services;
• Direct marketing, including newsletters and client alerts;
  • Better understand the market for our existing services, and potential new services, and adjust our research, development, and marketing strategies accordingly;
  • Conduct research, analytics, and data analysis;
  • Monitor and improve website functionality;
  • Maintain our facilities and infrastructure;
  • Meet our contractual obligations to you, if you provide us with services;
  • Process and manage contracts and other written agreements we may enter with you and the companies for which you work;
  • Protect against security threats and misuse of Anderson Leavitt websites;
  • Conduct risk and security controls and monitoring;
  • Detect and prevent fraud;
  • Perform accounting, audit, and other internal functions, such as internal investigations;
  • Process payment transactions;
  • Maintain records; and
  • Otherwise accomplish our business purposes and objectives.

In addition to the purposes identified above, Anderson Leavitt may use and disclose any and all Business Contact Personal Information that we Collect as necessary or appropriate to:

• Comply with laws and regulations, including, without limitation, applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws;
• Monitor, investigate, and enforce compliance with and potential breaches of Anderson Leavitt policies and procedures and legal and regulatory requirements;
• Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and
• Exercise or defend the legal rights of Anderson Leavitt and its employees, affiliates, customers, contractors, and agents.
• We, and our Service Providers, Collect, Process, and disclose the Sensitive Personal Information described in this Policy only for the below purposes that are authorized by the CCPA and its implementing regulations:
• Performing the services or providing the goods reasonably expected by an average Consumer who requests those goods or services;
• Ensuring security and integrity to the extent the use of the Consumer’s Personal Information is reasonably necessary and proportionate for these purposes;
• Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted Personal Information;
• Resisting malicious, deceptive, fraudulent, or illegal actions directed at the business and prosecuting those responsible for those actions;
• Ensuring the physical safety of natural persons;
• Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a Consumer’s current interaction with us; provided that we will not disclose the Consumer’s Personal Information to a Third Party and/or build a profile about the Consumer or otherwise alter the Consumer’s experience outside the current interaction with the business;
• Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured by, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us; and
• Collecting or Processing Sensitive Personal Information where such Collection or Processing is not for the purpose of inferring characteristics about a Consumer.

1. SOURCES FROM WHICH WE COLLECT BUSINESS CONTACT PERSONAL INFORMATION

We Collect Personal Information directly from Business Contacts. We also Collect Personal Information from joint marketing partners, public databases, providers of demographic data, publications, professional organizations, educational institutions, social media platforms, and Service Providers and Third Parties when they disclose information to us.

1. CATEGORIES OF ENTITIES TO WHOM WE DISCLOSE BUSINESS CONTACT PERSONAL INFORMATION

• Affiliates & Service Providers. We may disclose Business Contact Personal Information to our affiliates and Service Providers for the purposes described in Section D of this Policy. Our Service Providers provide us with website services, as well as other products and services, such as web hosting, data analysis, customer service, infrastructure services, technology services, email delivery services, legal services, and other similar services. We grant our Service Providers access to Personal Information only to the extent needed for them to perform their functions and require them to protect the confidentiality and security of such information.

• Third Parties. For each category of Personal Information identified in Section C, we disclose such Personal Information to the following categories of Third Parties:
  • At Your Direction. We may disclose your Personal Information to any Third Party with your consent or at your direction.
  • Business Transfers or Assignments. We may disclose your Personal Information to other entities as reasonably necessary to facilitate a merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
  • Legal and Regulatory. We may disclose your Personal Information to government authorities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.

1. DATA SUBJECT RIGHTS

• Data Subject Rights Available to You. As a Business Contact, you have the following rights regarding our Collection and use of your Personal Information, subject to certain exceptions:

• Right to Receive Information on Privacy Practices: You have the right to receive the following information at or before the point of Collection:

• • The categories of Personal Information to be Collected;
  • The purposes for which the categories of Personal Information are Collected or used;
  • Whether or not that Personal Information is Sold or Shared;
  • If the business Collects Sensitive Personal Information, the categories of Sensitive Personal Information to be Collected, the purposes for which it is Collected or used, and whether that information is Sold or Shared; and
  • We have provided such information in this Policy, and you may request further information about our privacy practices by contacting us as at the contact information provided below.

• Right to Deletion: You may request that we delete any Personal Information about you that we Collected from you.
• Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.
• Right to Know: You may request that we provide you with the following information about how we have handled your Personal Information:

• The categories of Personal Information we Collected about you;
• The categories of sources from which we Collected such Personal Information;
• The business or commercial purpose for Collecting, Selling, or Sharing Personal Information about you;
• The categories of Third Parties to whom we disclose such Personal Information; and

• Right to Receive Information About Onward Disclosures: You may request that we disclose to you:

• The categories of Personal Information that we have Collected about you;
• The categories of Personal Information that we have Sold or Shared about you and the categories of Third Parties to whom the Personal Information was Sold or Shared; and

• Right to Non-Discrimination: You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights. We also will not deny goods or services to you, charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.

• Rights to Opt-Out of the Sale and Sharing of Your Personal Information and to Limit the Use of Your Sensitive Personal Information: You have the right to opt-out of the Sale and Sharing of your Personal Information. You also have the right to limit the use of your Sensitive Personal Information to the purposes authorized by the CCPA. We will not Sell or Share any of the categories of Personal Information we Collect about you, and we have not Sold or Shared Personal Information in the past twelve months. Further, we do not use or disclose Sensitive Personal Information for purposes beyond those authorized by the CCPA. Relatedly, we do not have actual knowledge that we Sell or Share Personal Information of California Consumers under 16 years of age. For purposes of the CCPA, a “Sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “Share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

• Opt-Out Preference Signals. We do not Sell or Share Personal Information, or use or disclose Sensitive Personal Information for purposes other than those authorized by the CCPA, as listed in Section D. Accordingly, we do not process opt-out preference signals. If we process opt-out preference signals in the future, we will update this policy to provide details about how we do so.

• The length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.

• The specific pieces of Personal Information we have Collected about you.

• The categories of Personal Information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

• Exercising Data Subject Rights. Business Contacts may exercise your data subject rights by contacting us via email at [email protected] or via phone at (484) 535-7080. You may also authorize an agent to make a data subject request on your behalf, and the authorized agent may do so via the above-listed submission methods.
• Verification of Data Subject Requests. We may ask you to provide information that will enable us to verify your identity in order to comply with your data subject request. In particular, if you authorize an agent to make a request on your behalf, we may require the agent to provide proof of signed permission from you to submit the request, or we may require you to verify your own identity to us or confirm with us that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under the CCPA. We will respond to your request consistent with applicable law.

1. OTHER DISCLOSURES

• Protection & Retention of Personal Information: We retain each of the categories of Personal Information listed in Section B for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes listed in Section D.

When assessing the data retention period, we take into account the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements.

California Residents Under Age 18. If you are a resident of California under the age of 18 and a registered user of our webs

Online Cookies Notice

Anderson Leavitt LLC

Effective January 1, 2023

Cookies and Similar Technologies. We use cookies, web beacons, and similar tracking technologies (collectively, “cookies”) on www.andersonleavitt.com (our “Site”). Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a website. You can find more information about cookies and how they work at www.allaboutcookies.org and www.youronlinechoices.com.

Cookies on our Site are generally divided into the following categories:

• Essential Cookies: These cookies are essential in order to enable you to move around our Site and use its features, such as accessing secure areas of our Site
• Analytical / Performance Cookies: These cookies include Google Analytics and Siteimprove and they keep track of the pages you visit and content you access, so we can tailor our Site to our users’ needs and improve the performance of our Site.
• Functional Cookies: These cookies remember the choices you make, such as language options or the region you are in. These cookies personalize your experience when you use our Site.

Generally, the information we collect using these cookies does not identify you personally. If, however, you have created a user identity, for example, by subscribing to our publications or filling out forms, we may link the information we collect using cookies to other information that identifies you personally.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave our Site. Although you are not required to accept our cookies when you visit this Site, you will not be able to use all of the features and functionality of our Site if you set your browser to, or manually reject cookies.

The cookies used on our Site may include, but are not limited to, the following:

Essential
Cookie Name	Purpose	Expires
ASP.NET_SessionId	This cookie uniquely identifies each user session.	When you close your browser
Functional
Cookie Name	Purpose	Expires
SC_ANALYTICS_GLOBAL_COOKIE	This cookie establishes and continues a user’s session between visits on our Site.	After 10 years
Functional
Cookie Name	Purpose	Expires
HAS_ACKNOWLEDGED_COOKIE_PROMPT	This cookie tracks a visitor’s acknowledgement of our Site’s cookie notification prompt.	After 6 months
Functional
Cookie Name	Purpose	Expires
languageprompt	This cookie disables alerts to a visitor regarding content in a visitor’s preferred language.	When you close your browser
Functional
Cookie Name	Purpose	Expires
website#lang	This cookie is used to determine which language to use to present content to a visitor to our Site.	After 1 year
Analytical / Performance
Cookie Name	Purpose	Expires
__utma	This cookie tracks the number of times a visitor has been to our Site, when their first visit was, and when their last visit occurred. Google Analytics uses the information to calculate visitor statistics.	2 years after your last visit
Analytical / Performance
Cookie Name	Purpose	Expires
__utmb __utmc	These cookies work together to calculate how long a visit takes. _utmb takes a timestamp of the exact moment when a visitor enters our Site, while_utmc takes a timestamp of the exact moment when a visitor leaves our Site. _utmb expires at the end of the session. _utmc waits 30 minutes for another page view to happen, and if it doesn’t, it expires.	After 30 minutes
Analytical / Performance
Cookie Name	Purpose	Expires
__utmz	This cookie tracks where a visitor came from, what search engine was used, what links were clicked on, what keywords were used, and where in the world the visitor was located when the visitor accessed our Site.	6 months after your last visit
Analytical / Performance
Cookie Name	Purpose	Expires
__utmv	This cookie stores custom variables for each visitor to our Site and allows us to use segmentation to better understand our visitors.	2 years after your last visit
Analytical / Performance
Cookie Name	Purpose	Expires
__utmt	This cookie is used to throttle request rate.	After 10 minutes
Analytical / Performance
Cookie Name	Purpose	Expires
ARRAffinity	This cookie is used for functionality in conjunction with Microsoft Azure.	When you close your browser
Analytical / Performance
Cookie Name	Purpose	Expires
__hssc	This cookie is used to track analytics in conjunction with Hubspot.	After 30 minutes
Analytical / Performance
Cookie Name	Purpose	Expires
__hssrc	This cookie is used to track analytics in conjunction with Hubspot.	When you close your browser
Analytical / Performance
Cookie Name	Purpose	Expires
__hstc	This cookie is used to track analytics in conjunction with Hubspot.	After 2 years
Analytical / Performance
Cookie Name	Purpose	Expires
_ga	This cookie is used to identify unique users in conjunction with Google Analytics.	After 2 years
Analytical / Performance
Cookie Name	Purpose	Expires
_gat_UA-4032296-8	This cookie is used to track analytics in conjunction with Siteimprove.	After 1 minute
Analytical / Performance
Cookie Name	Purpose	Expires
_gid	This cookie is used to track analytics in conjunction with Siteimprove.	After 1 day
Analytical / Performance
Cookie Name	Purpose	Expires
hubspotutk	This cookie is used to recognize visitors to our Site in conjunction with Hubspot.	After 2 years
Analytical / Performance
Cookie Name	Purpose	Expires
nmstat	This cookie is used to track analytics in conjunction with Siteimprove.	After 33 months
Analytical
Cookie Name	Purpose	Expires
IPMeta	Obtains data for visitor network based on visitor IP address. IPMeta never stores any data of visitors, including the IP address. IPMeta converts visitor IP address into the network data (through a proprietary WHOIS database, making no use of third parties) and then immediately deletes the data.	N/A
Functional
Cookie Name	Purpose	Expires
siteimproveses	This cookie is used for functionality in conjunction with Siteimprove.	When you close your browser

 

DO NOT SELL MY PERSONAL INFORMATION

If you are a California resident and you would like to opt out of the sale of your personal information to third parties, please email  [email protected] and describe your request, or call 484-535-7080​. For more information about your privacy rights as a California resident, please refer to our California Privacy Policy.

We partner with Thomson Reuters, who might also collect data as part of our marketing efforts. To learn more about the Thomson Reuters privacy policy and the data that might be collected, please visit: Thomson Reuters Privacy Statement.