Effective October 1, 2018.
Bills & Stoll, LLP (“we,” “our,” “us”), which operates https://billsandstoll.com (the “Site”), respects the sensitive nature of any personal information provided to us. We have created this Privacy Policy to demonstrate our commitment to the privacy of those who use the Site. This Privacy Policy describes our information collection, storage and disclosure practices and the choices you have regarding how personal information is collected and used by us and third parties who assist us with the personal, professional and business management services provided by us (“Services”).
Residents of the European Economic Area (“EEA”), which includes the member states of the European Union (“EU”), should consult the sections of this policy relating to the “Rights of EEA Residents” and “International Data Transfers” for provisions that may apply to them.
We reserve the right to change this Privacy Policy at any time. In the event we make changes to this Privacy Policy, such policy will be re-posted in the “Privacy” section of the Site with the date such modifications were made indicated on the top of the page or we may contact you to inform you about the revisions with a link to the revised Privacy Policy. All changes are effective on the date listed at the top of this page and will apply to all information that we have about you. Your continued use of the Site or the Services after any change is posted indicates your acceptance of the changes and your continued consent to our collection and processing of your personal data. If at any point you do not agree to any portion of the Privacy Policy then in effect you should immediately stop using the Services. You may also unsubscribe or opt-out from certain communications by following the procedures set forth in this Privacy Policy, including the section below on “Notifications and Communications from Our Websites/Opt-Out Rights.”
Because this Privacy Policy contains legal obligations we encourage you to review this Privacy Policy carefully. If you have any questions concerning this Privacy Policy or our information collection, storage and disclosure practices, please contact us at info@dev.billsandstoll.com.
Personal Data That We Collect and How We Use It
We may collect certain Personal Data about you when you visit the Site or when you use our Services. “Personal Data” is information that may be used to directly or indirectly identify you, including your name, e-mail address, physical address, phone number, geographical information, non-public financial information or other information about you. The majority of such Personal Data is collected from you or through authorized third parties, including your accountant, attorney, bank(s), securities broker(s) and other investment adviser(s). Some of the Personal Data that we collect is required if you wish to partake in certain Services that we provide.
We use this Personal Data to: (i) add you to our contact lists; (ii) provide information regarding our Services; (iii) provide our Services; and (iv) maintain regular communication with you as may be necessary to inform you about our Services.
Social Networks
If you choose to connect to our Site through a third-party social network such as Facebook, LinkedIn and other networks (each, a “Social Network”), we may collect Personal Data from your profile on such Social Network, such as your name, user name, and e-mail address.
Non-Identifiable Data and Aggregated Personal Data
Regardless of whether you join our mailing list or submit information to us, we and third parties performing services for us may send one or more “cookies” to your computer when you visit the Sites. Cookies are small text files placed on your web browser when you visit our Site that store information on your computer, such as your Site preferences. We use cookies to track your activity on the Site as a unique person. For security purposes, all of this information is stored in encrypted form.
You can set your web browser to inform you when cookies are set, or to prevent cookies from being set altogether. Please note, however, that if you decline to use cookies, you may experience reduced functionality and slower site response times.
We or our service providers may also collect web surfing data related to your use of the Site. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Site. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. We may, for example, use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of marketing and advertising campaigns, search engine optimization strategies, operation and effectiveness of pages on our website, and other marketing activities. We also use it to help optimize the Site based on the needs of our Users.
How and When Your Information Is Shared With Other Parties
We will not disclose, rent or share your Personal Data with other parties, except as disclosed below.
We work with a number of trusted partners who may perform vital functions as part of our operations of the Site. We do not share your Personal Data unless it is necessary to fulfill our responsibilities, including providing information or Services to you.
We will not share your Personal Data if such sharing is prohibited by applicable privacy and data protection law, including, without limitation, the EEA’s General Data Protection Regulation effective May 25, 2018.
With your consent, we may disclose the Personal Data that we collect about you with authorized third parties, including your accountant, attorney, bank(s), security broker(s), and investment advisers in connection with the Services we provide to you.
EEA Residents
This section of the Privacy Policy is applicable to residents of the European Economic Area (“EEA”). The EEA consists of the member states of the European Union, i.e., Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the United Kingdom, and Iceland, Liechtenstein, and Norway. This section also applies to residents of Switzerland and, in the event of its departure from the EU, residents of the United Kingdom. Residents of the EEA and Switzerland are referred to here as “EEA Residents.”
From May 25, 2018, all processing of Personal Data of EEA Residents is performed by us in accordance with the General Data Protection Regulation (2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of Personal Data and on the free movement of such data (“GDPR”).
Under the GDPR, we are both the controller and a co-processor of the Personal Data of EEA Residents. Our purpose for collecting and processing Personal Data from EEA Residents is to provide them with information regarding our Services and to perform our Services for such individuals. The legal basis for collecting Personal Data from EEA Residents is to fulfill our legitimate interests and to perform Services for such Residents. We also rely on your consent to obtain information about our Services through the Site. You may withdraw consent from receiving marketing and promotional communications by clicking the “Unsubscribe” link on the communication or contacting us at info@dev.billsandstoll.com. If EEA Residents do not provide Personal Data to us or withdraw consent for processing such Personal Data, they will not be able to use the Services for the purposes specified above.
EEA Residents may obtain information about the Personal Data that we hold about them by contacting us at info@dev.billsandstoll.com.
International Data Transfers
If you are resident outside the United States, including in the EEA, you may transfer Personal Data to us for processing in the United States. Under the GDPR, we are considered a “controller” and a “co-processor” of the Personal Data of EEA Residents. By providing Personal Data to us for the purpose of using the Services, you consent to the processing of such data in the United States. The transfer of your Personal Data to the United States is necessary for fulfilling our legitimate interests, fulfilling our contractual obligation to provide you with Services and to respond to your requests.
Please note that the United States does not have data protection laws equivalent to those in the EEA and other jurisdictions.
Notifications and Communications from Our Site/Opt-Out Rights
Communications Regarding Our Services
We will send you notifications, communications and information from time to time. Some notifications are general communications relating to us and our Services. You may “opt-out” from receiving general e-mail communications by following the “Unsubscribe” instructions provided in the e-mail.
Legal or Security Communications
We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection. In other cases, these notifications involve changes to various legal agreements, such as the Privacy Policy or Terms of Service. We may also send out communications relating to specific Services that we are providing for you. Generally, you may not opt out of such communications.
Personal Data Retention
We retain the Personal Data we receive as described in this Privacy Policy for as long as you use the Services or as necessary to fulfill the purpose(s) for which it was collected, provide our
Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Deleting Your Information
If you want us to delete your Personal Data from our general mailing lists, please contact us at info@dev.billsandstoll.com with your request. We will take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law. You may not delete information relating to our communications relating to the specific Services that we are providing for you if you wish to continue receiving such Services. Deletion of your Personal Data is subject to our obligations as set forth in the section relating to Personal Data Retention.
Links to Other Sites
If you follow any links that direct you away from the Site, this Privacy Policy will not apply to your activity on the other Sites you visit. We do not control the privacy policies or the privacy practices of any third parties.
Security Policy
We take commercially reasonable steps to protect your Personal Data against unauthorized disclosure or loss. However, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, while we strive to protect user information we cannot ensure or warrant the security of any information you transmit to us or through the Site. You engage in such transmissions at your risk.
If you believe your Personal Data is being improperly used by us or any third party, please immediately notify us via email at info@dev.billsandstoll.com.
Children Under 13
Our Site is restricted to the use of adults over the age of majority in their place of residence. No portion of the Site is directed to children under the age of 13. Consequently, we do not knowingly collect personal identifying information from any person we know is a child under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 we will delete that information as quickly as possible. If you are a parent or guardian of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at info@dev.billsandstoll.com.
Do Not Track
Although some browsers currently offer a “do not track (‘DNT’) option,” no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers’ DNT signals.
Your California Privacy Rights
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California customer, a business may be required to provide information regarding how that business has shared personal information of customers with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that do not disclose personal information to third parties for direct marketing purposes.
Your Rights and Obligations
We ask that you keep the Personal Data that you provide to us current and that you correct any information you have provided us by contacting us at info@dev.billsandstoll.com. You represent and warrant that all Personal Data you provide us is true and correct and relates to you and not to any other person.
If you are a resident of the EEA and wish to access or correct the Personal Data that we have about you or have any questions relating to the processing of your Personal Data, please contact us at info@dev.billsandstoll.com with the subject line “GDPR Data.”
