ZwillGen Privacy Policy

Last Updated: March 27, 2024

ZwillGen PLLC and ZwillGen Law LLP (collectively the “Firm,” “we,” or “us”) are providing this Privacy Policy to explain our policies and procedures regarding the collection, use, disclosure, and security of information we collect, use, and disclose via www.zwillgen.com and blog.zwillgen.com (the “Sites”) and through other means. 

This Policy does not apply to information about employees, former employees, or job applicants. Please visit our Applicant Privacy Policy for more information about our privacy practices for job applicants.

Information We Collect and How We Use It

The information we collect about you depends on how you interact with us. We collect information 1) when you provide it directly to us, 2) automatically through technology when you visit the Sites, and 3) from other sources.

Information You Provide Us Directly

We collect information that you voluntarily submit to us, such as your name, email address, and other contact information, when you sign up to receive our newsletter, submit a comment in response to a blog posting, email us to ask questions, fill out a form, or contact us to explore a potential attorney-client relationship. We also receive information from or on behalf of our clients. Because of the nature of our services, this could include any type of personal data.

We use this information to respond to your requests, determine whether to enter into a relationship with you, provide you with legal services if you are or become a client of the Firm, monitor and analyze our business operations and Site usage, and for the firm’s educational, networking, marketing, social, recruiting, and other business purposes.

Automatically Collected Information

We, or our third-party service providers, also collect device information, IP Addresses, http referrer fields, and other information about your computer or device and your usage of our Sites. We use that information for a variety of purposes, including educational, analytics, networking, marketing, social, recruiting, and other business purposes.

We also use third-party web analytics services on the Sites and in our emails, such as those provided by DealFront, Google Analytics and others. These service providers use electronic tools to help us analyze how visitors interact with the Sites and our email campaigns and may collect information from your device (including your IP Address) that can be used to track your device over time and across third party websites. To learn about opting out of Google Analytics, please click here.

Information We Collect from Other Sources

We may supplement the information we collect with information we obtain from other sources, such as clients and referral sources, as well publicly available sources such as social networking sites.

De-identified and Aggregate Information

We may de-identify or aggregate any of the information we collect and use or disclose it for any purpose permitted by law and applicable ethics rules.

How We Disclose Information

We disclose information about you:

  • to our service providers who assist us in providing our services, transmitting our marketing materials, and maintaining our Sites, 
  • with your consent or as directed by you in the course of providing legal advice or representing you in legal proceedings or in front of government agencies, 
  • otherwise in connection with the provision of services, 
  • to protect our rights, including collecting unpaid invoices, or 
  • as otherwise required or permitted by law or our ethical obligations. 

Cookies

We use cookies, web beacons, and other electronic tools to manage and track your interaction with the Sites and our email newsletters. A cookie is a piece of data that a website you visit can set on your browser or elsewhere on your device. These technologies collect information that helps us better serve you and enhance this Site, such as by tracking return visits, collecting Site usage information, and performing research, analysis, and Site analytics. Third parties whose products or services are accessible via links from the Sites may also use cookies or similar tools, and we advise you to check their privacy policies for information about their cookies and other privacy practices. If you prefer not to accept cookies through our Sites, you can set your browser to warn you before accepting cookies or disable them altogether.

Information for International Residents

Laws that govern privacy and data protection (“Data Protection Laws”) in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose information relating to identified or identifiable natural persons (“personal data”). To the extent those laws apply, our legal grounds are as follows:

  • Legitimate interests: In most cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
    • Providing our services pursuant to our contract with our client
    • Marketing
    • Protecting our clients, personnel, and property
    • Analyzing and improving our business
    • Processing job or other applications
    • Addressing legal and ethical issues
  • Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.
  • To honor our contractual commitments to an individual: Some of our processing of personal data is to meet our contractual obligations to the individual to whom the personal data pertains.
  • Consent: Where required by law, and in some other cases, we handle personal data on the basis of implied or express consent.

ZwillGen PLLC is considered the “data controller” of the personal data that we handle under this Privacy Policy, including data about visitors to the Sites and contact information for clients and potential clients. Where we act as a “data processor” of personal data on behalf of a client, we process the personal data pursuant to our contract with the client and our legal and ethical obligations.

How Long We Keep Personal Data

We generally retain personal data for so long as it may be relevant to the purposes above, consistent with any applicable agreement with a client, which often requires holding all communications for a period of at least three years. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

Security

We maintain administrative, technical, and physical safeguards to protect information that we collect. However, no system is completely secure or error-free. We do not, and cannot, guarantee the complete security of your information.

Privacy Choices

We provide individuals with the ability to opt-out of receiving marketing and other communications from us, and to update, supplement or delete the information we have about them by contacting us using the methods provided below.

To the extent Data Protection Laws apply and we hold your personal data in our capacity as a controller, you may request that we:

  • Provide access to and/or a copy of certain personal data (including, in some cases, in portable form);
  • Prevent the processing of your personal data for direct-marketing purposes (including any direct marketing processing based on profiling);
  • Update personal data that is out of date or incorrect;
  • Delete certain personal data which we are holding about you;
  • Object to our processing of personal data;
  • Restrict the way that we process and disclose certain of your information;
  • Transfer your personal data to a third party; or
  • Honor a revocation of your consent for the processing of your personal data (without retroactive effect).

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with additional information to confirm your identity before responding to your request. You have the right to lodge a complaint with the authorities applicable to your situation, though we invite you to contact us with any concern, as we would be happy to try to resolve it directly.

Children’s Privacy

The Sites are intended for users over the age of 18. If we become aware that a child under 13 (or a higher age threshold where applicable) has provided us with personal data, we will take steps to comply with any applicable legal requirement to remove such information.

Links to Third-Party Websites

Please note that the Sites may contain links to third-party websites, including social networking websites. Since we do not control third-party sites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.

Changes

We reserve the right to change this Policy at any time. Please check this page periodically for updates. If we make any material changes to this Privacy Policy, we will post the changes here and notify you either via email or by notice on this Site.

Information for California Residents

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with certain information about how we collect, use and disclose “personal information” (as that term is defined in the CCPA). The information and rights discussed below do not apply to information that ZwillGen collects as a service provider on behalf of its clients, or information about employees, former employees, or job applicants.

Categories of Personal Information We Collect, Use and Disclose

The following are the categories of personal information under the CCPA that we collect from California consumers and that we may, as discussed throughout this Policy, use and disclose for our business purposes:  

Identifiers (such as name, address, email address); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history or app usage); general geolocation data from IP addresses; any inquiries or feedback that you provide; professional or employment related data. 

We may also disclose this information to third parties for legal purposes and to protect our rights, as described further in “How We Disclose Your Information” above.

We and our service providers may use the categories of personal information we collect from and about you for the following business purposes (as those terms are defined in applicable law).  

  • Our or our service providers’ operational purposes;
  • Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
  • Bug detection and error reporting;
  • Customizing content that we or our service providers display on the Sites;
  • Providing services to you (e.g., responding to inquiries and administering the Sites);
  • Improving our Sites and services and developing new services; and
  • Other uses about which we notify you. 

Sale/Sharing of Personal Information

The CCPA requires us to disclose whether we “sell or “share” personal information, as those terms are defined in that law. We do not “sell” or “share” personal information within the meaning of the CCPA, and have not done so within the past 12 months. We also do not disclose information to third parties for their own direct marketing purposes. 

California Privacy Rights

California residents can make certain requests about their personal information under the CCPA.  Specifically, if you are a California resident, you may request that we:

  • provide you with information about: the categories of personal information we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties to whom we disclose personal information.  Such information is also set forth in this Privacy Policy; 
  • provide access to and/or a copy of certain information we hold about you;
  • correct inaccurate personal information we hold about you; and/or
  • delete certain information we have about you; 

California residents can also designate an authorized agent to make access and/or deletion requests on their behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.  

We will take reasonable steps to verify your identity before responding to a request for access and/or deletion from you or your designated agent.  If we are unable to verify you, we may be unable to respond to your requests. 

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.  

Please note that certain information may be exempt from such requests under California law.  For example, we need certain business contact information in order to provide legal services requested by our clients.

If you are a California resident and would like to exercise any of your legal rights under the CCPA, please contact us using the contact information in the “Contact Us” section below.

Contact Us

Should you have any questions or concerns about our Privacy Policy, please send us an email at info@zwillgen.com or fill out the form on our Contact page; write to us at ZwillGen PLLC, 1900 M Street NW, Suite 250, Washington, DC 20036; or call us at (202) 296-3585.

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