Privacy Policy

What Information We Collect and How We Use It

We collect and store the information that you enter on this Website. In the last 12 months, we have collected the following categories of information about individuals using our Website:

• Name
• Postal / Shipping Address
• Billing Address
• Phone Number
• Email Address

The legal basis for processing this information

• The user has provided consent to the processing of their information;
• Processing is necessary to perform a contract with the user;
• Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation;
• Processing is necessary to protect the vital interests of the user or of another person;
• Processing is necessary for the purpose of a legitimate interest pursued by us or by a third party.

Where we get this information

• Information submitted by the consumer;
• Social networks;
• Surveys;
• Tracking pixels;
• The observation and recording of activities by the business, such as through the use of cookies;
• From co-counsel and other attorneys.

How we use this information

• Analytics;
• Auditing compliance and transactions the consumer has entered into;
• Creating new features;
• Enforcing our Terms of Service;
• Marketing and advertising;
• Participation in surveys and contests;
• Performing services;
• Processing or fulfilling orders or transactions, and processing payments;
• Protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible;
• Providing customer service and resolving disputes;
• Targeted advertising;
• Undertaking activities to verify or maintain the quality or safety of our services;
• Verifying customer information.

We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update or delete your testimonial, please contact us at requests@sirillp.com and be sure to include your name, testimonial location, and contact information.

If we do not have this information, our use of your data for the purposes above (analytics, auditing, creating new features, enforcing our Terms, marketing and advertising, surveys and contests, performing services, processing transactions and payments, fraud protection, customer service, dispute resolution, targeted advertising, quality and safety, and verifying customer information) will not be possible.

Note that we do not use your personal information for the purpose of profiling. Please see the “Your Rights” section below for more information about exercising your privacy rights related to profiling.

With Whom We Share Your Personal Information

In the last 12 months, we may have disclosed and shared the personal information above (Name, Postal / Shipping Address, Billing Address, Phone Number, and Email Address) with the following categories of third parties:

• Advertising networks;
• Content management systems;
• Customer management systems;
• Data analytics providers;
• Email marketing vendors;
• Financial transactions processors;
• Hosting providers;
• Internet service providers;
• Parties that need to operate the website;
• Shipping companies;
• Social networks;
• Subsidiaries.

Reasons for sharing and disclosing

• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements);
• To market to you via email;
• To manage our interactions with you;
• To prevent or investigate fraud;
• To process transactions;
• To analyze your interactions with us or our website;
• To enforce our Terms of Service;
• To provide you with advertisements.

How We Protect Your Information

We have implemented the following measures to protect and safeguard your personal information:

• Limiting the amount of personal information that we collect to strictly necessary only;
• Using SSL, TLS, or other secure connection technologies when receiving or sending personal information beyond internal networks;
• Performing regular risk assessments;
• Screening all employees with access to personal information;
• Training our employees and requiring them to sign confidentiality agreements;
• Implementing and monitoring intrusion prevention and detection systems;
• Maintaining up-to-date software and safeguards;
• Implementing physical security measures.

Sale of Your Information

We do not sell your personal information. Please see the “Your Rights” section below for more information about exercising your privacy rights regarding sales of your personal information.

Cookies

A cookie is a small piece of data sent from a website and stored on your device by your browser. This Website collects cookies. Please visit our Cookie Policy to learn more about what cookies we collect, why we collect them, and how to change your cookie settings.

Children’s Privacy

This Website is intended for use by a general audience and does not offer services to children. Should a child whom we know to be under 18 send personal information to us, we will use that information only to respond to that child to inform him or her that they cannot use this Website.

Analytics Programs

This Website uses analytics tools, including but not limited to Google Analytics, to collect information about you and your behaviors. If you would like to opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout/.

Information Retention

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law or applicable ethics rules. When we have no ongoing legitimate business need or ethical obligation to process or retain your personal information, we may either delete or anonymize it, or, if that is not possible (for example, because it has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

Direct Marketing

We use the information that we collect about you for direct marketing purposes. Direct marketing is the act of selling products or services directly to consumers rather than through retailers. You may, at any time, request that we cease to use your information for direct marketing purposes by emailing us at privacy@sirillp.com.

Your Rights

All visitors or users of this Website have the following rights with regard to their personal information:

• The right to opt out of the use of your personal information for the purposes of targeted advertising.
• The right to access the personal information that we have collected about you, and to know the categories of personal information, the sources, the business or commercial purpose for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it.
• The right to know whether your personal information is sold or disclosed and to whom, and the right to say no to the sale of your personal information.
• The right to opt out of the sharing of your personal information, and to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• The right to request that we delete all or some of the personal information that we have collected about you.
• The right not to be discriminated against based upon your exercise of your privacy rights, and the right to equal service and price even if you exercise your privacy rights.
• The right to ask us to transmit your personal information to another provider (where technically feasible), and to receive it in a portable and readily usable format.
• The right to request that we amend any of the information that we have collected about you.
• The right to withdraw your consent to the processing of your data, and to request that we restrict the processing of your data.
• The right to lodge a complaint regarding our collection, sharing, and processing of data with competent authorities in the proper jurisdiction.
• The right to stop receiving unwanted direct marketing.
• The right to limit the use and disclosure of your sensitive personal information.
• The right to confirm whether we are processing your personal information.

Exercising Your Rights

You may exercise the rights specified above by submitting a consumer request to Brad Linberg, Chief Technology Officer, requests@sirillp.com, 929-564-5875, 745 Fifth Ave, Suite 500, New York, NY 10151, United States, https://www.sirillp.com.

We will need to verify your identity prior to effectuating your request. To verify your identity, you will need to provide us with your name, postal / shipping address, billing address, phone number, and email address. Please note that we may be unable to process your request if you do not provide us with the above information.

You may also designate an authorized agent to exercise your rights on your behalf. We will ask the agent to submit a valid power of attorney, the requester’s valid government-issued ID, and the authorized agent’s valid government ID.

We will respond to most consumer requests within 30 to 45 days of receipt, depending upon where you reside; some requests may take longer, and we will notify you in writing if we need more time. We have the ability to deny your request if certain exceptions in the law apply, and if we do, we will provide you with the reasons. Normally, we do not charge a fee to process or respond to consumer requests; however, for residents of certain states or countries, we may charge a fee if the request is excessive, repetitive, or manifestly unfounded. You have the right to appeal a refusal to take action on a rights request by contacting us at the information above; we will respond to most appeals within 60 days of receipt.

Accountability

The person accountable and responsible for our privacy practices and procedures is Brad Linberg, Chief Technology Officer, 929-564-5875, requests@sirillp.com. You may lodge a complaint with us by contacting the person above. Residents of Quebec may lodge a complaint with the Office of the Privacy Commissioner of Quebec, and residents of Canada may lodge a complaint with the Office of the Privacy Commissioner of Canada.

Location of Data Processing

All data processing activities undertaken by us take place in the United States.

Third-Party Websites

This Website may contain hyperlinks to websites operated by parties other than us. We provide such hyperlinks for your reference only. We do not control such websites and are not responsible for their contents or the privacy or other practices of such websites. It is up to you to read and fully understand their Privacy Policies. Our inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators.

Do Not Track

Do Not Track is a preference you can set on your browser to inform websites that you do not want to be tracked. We do not support Do Not Track (“DNT”). You can either enable or disable Do Not Track by visiting the Preferences or Settings page of your browser.

Transferring Data

We plan to transfer data to the United States. This means that your information may be processed in a country outside of Canada and it may be accessible to law enforcement authorities and national security authorities of that country and jurisdiction.

Changes

We reserve the right to make changes to this Privacy Policy at any time. We will not provide you with any notice when we make changes to this Privacy Policy. Therefore, we suggest that you regularly review all of our legal notices, including our Cookie Policy, Disclaimer, EULA, Privacy Policy, and Terms of Service, and by continuing to use the Website you will have accepted the then-current versions of those documents.

Questions

If you have any questions about this Privacy Policy, please contact us at privacy@sirillp.com.