I. INTRODUCTION
Associated Fire Protection (“AFP”, “we” or the “Firm”) has updated our Privacy Policy (the “Policy”), effective October 1st, 2019. AFP is committed to protecting and respecting individuals’ privacy rights. Because of this commitment, we have developed and implemented the Policy outlined below.
This Policy explains:
- personal information we collected about you
- how we obtain your personal information
- how we use your personal information
- they ways we use your personal information
- who we share your personal information with
- how we protect your personal information
- how and why we may transfer your personal information outside of the EU
We may collect your personal information in your capacity as a client, potential client, job applicant and/or as a visitor or subscriber to our website(s), including www.associatedfire.com (“our website” or “AFP website”).
II. DATA CONTROLLER AND RESPONSIBLE OFFICER
Associated Fire Protection, located at 100 Jackson St Paterson, NJ 07501, is the Data Controller responsible for the implementation of this Policy.
Should you have any questions about this Policy or how AFP handles your personal information, please contact info@associatedfire.com.
III. TYPES OF PERSONAL INFORMATION AFP COLLECTS ABOUT INDIVIDUALS
We may collect your personal information when conducting our business, including when you contact us, seek information from us, use one of our websites or engage, utilize our Contact Us form or engage us to provide our legal or other services. We may also collect your personal information for recruiting purposes.
The personal information that we process includes:
- personal identifying information, such as your name (including prefix or title);
- employment information, including your employer’s name, your title and job description;
- in connection with our recruitment efforts, background check information to enable us to assess a prospective employee’s suitability for employment;
- contact details, including your postal address, email address and telephone numbers;
- personal information required to satisfy legal requirements, such as your anti-money laundering requirements (for example, passport details);
- financial information (for example, your bank account details);
- technical information (for example, the number of visits you make to our websites, or your receipt and use of materials and communications we send to you electronically);
- personal information you provide to us in advance of and during meetings and events, including your physical access and dietary requirements;
- personal information we receive by or on behalf of our clients, or created by us when providing services to our clients, which may include special categories of data; and
- any other information relating to you that you may provide to us.
IV. HOW WE RECEIVE YOUR PERSONAL INFORMATION
We come into possession of your personal information in many ways, including:
- during the monitoring of our technology, including the associatedfire.com website and any other affiliated sites (e.g., our blogs) and email communications sent to and from AFP;
- as part of our employment/business onboarding processes;
- during the course of our providing legal services;
- when you provide information to us, or during your interactions with us directly, including face‑to‑face interactions with our staff and online interactions using the AFP website or email; and
- third-party sources (including, for example, LinkedIn and other social media).
V. HOW WE USE YOUR PERSONAL INFORMATION
We “collect and process” your personal information in a variety of ways, including when you use the AFP website and when we provide our services to you. When we collect and process personal information, we use it to:
- manage and administer our relationship with clients, vendors and other third parties in the conduct of Associated Fire Protection business;
- provide legal services, which may include handling personal information;
- make available information requested by you;
- meet any of our legal, regulatory and risk management obligations;
- market our services;
- engage in hiring or attorneys and staff members; and
- administer and monitor use of our website.
In connection with providing our clients with Fire protection services, we may, to the extent reasonably necessary in connection with our services, need to share personal information with third parties. Please also see sections 7 and 8 below.
When distributing marketing content or other marketing communications, Associated Fire Protection may use your personal information to try to understand:
- whether you open our emails or other materials, either by downloading images in the emails or clicking links;
- whether you click on the web links, unsubscribe links or event RSVP links included in our emails and marketing materials;
- whether and how you visit our websites after you click on links we have shared with you, both immediately and on future visits. We do this by using software that places a cookie on your device that tracks this activity and records it against your email address. Please see our Cookie Policy, below;
- our client relationships, through the use of a client relationship management (“CRM”) tool, in order to help manage our information more efficiently and effectively, and to avoid overburdening our clients and friends with more information than is necessary.
When attending AFP meetings and events, we may collect and process personal information about you in relation to your attendance, including your contact information, name and employer. We also may collect special categories of personal information, including dietary requirements, allergies or access requirements, so that we can appropriately cater to your needs and meet any other legal or regulatory obligations we may have. We may share your information with our business partners and contractors who are involved in organizing or hosting the relevant events.
To our friends in the European Union. If you are or consider yourself to be a Data Subject under the EU’s General Data Protection Regulation (GDPR), kindly advise us at any time whether you wish to discontinue receiving Associated Fire Protection marketing communications by emailing us at info@associatedfire.com or by completing our Contact Us form.
A note about the Associated Fire Protection website, when you use the www.associatedfire.com website, you may be asked to provide us with personal information; for example, when you sign up to our newsletter, you will be asked to provide your name and contact information. When you provide us with personal information in this way, we only use it for the purposes stated to you at the time we collect that information.
What About Cookies? We also use cookies on the AFP website. Please see our Cookie Policy, below, which is posted on our website, for more information on how to manage and remove cookies.
VI. WHEN AND HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information in connection with the following:
- the performance of any necessary contractual obligations, including the provision of legal and other professional services;
- legitimate business purpose;
- your explicit consent;
- in order to comply with legal and regulatory obligations; and
- the establishment, exercise or defense of legal claims and proceedings.
VII. WE SHARE YOUR INFORMATION WITH
We are headquartered in New Jersey, New York, Utah. Information that you provide to us may be shared with and processed by any of the AFP offices.
If AFP’s business structure changes in the future, we may transfer your information to new AFP offices or to third parties for the purpose of carrying out AFP’s business.
We may share your personal information with third parties in accordance with the contractual arrangements we have put in place with them, including with:
- our professional advisers and auditors;
- third‑party suppliers we engage to conduct certain services on our behalf, including translators and document reviewers, meeting planners, event organizers and IT service providers; and
- other third parties we engage when providing services to our clients, including experts, data room providers, transcript and case management service providers.
We also may share personal information with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies where such disclosure is necessary, including to comply with legal or regulatory requirements. Unless we are restricted from doing so by law, we will use reasonable endeavors to notify you before we make any such disclosure.
We do not allow personal information to be made commercially available to any third party unless we have first obtained your prior permission.
VIII. TRANSFERRING YOUR PERSONAL INFORMATION TO THIRD COUNTRIES
When providing our services, we may need to transfer your personal information outside of the country in which you are located for the purposes set out in this Policy. This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA.
The level of information protection in countries outside the EEA may be less than that which is offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. Where our third‑party service providers process personal information outside the EEA in the course of providing services to us, appropriate measures, usually standard contractual clauses, will be included in our written agreement for the service provision.
IX. HOW WE PROTECT YOUR PERSONAL INFORMATION
Consistent with applicable data protection laws, we utilize technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, alteration or destruction.
X. RIGHTS OF EUROPEAN UNION RESIDENTS REGARDING YOUR PERSONAL INFORMATION
Pursuant to the European Union’s General Data Protection Regulation and other applicable data protection laws, data subjects within the European Union have certain rights that we are obliged to protect.
You are entitled to request details of the information we hold about you and how we process it.
In certain circumstances, you also may have the right to have the information that we hold about you rectified or deleted, restrict our processing of that information, request that we stop unauthorized transfers of your personal information to a third party, and request that we do not transfer information relating to you to another organization. You also may have the right to lodge a complaint in relation to AFP’s processing of your personal information with a local supervisory authority.
Where you object to our processing of your personal information, or where you withdraw consent previously given, it is important to understand that we may be able to continue to process your personal information to the extent required or otherwise permitted by law, particularly in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
Please inform us of any changes to your information by emailing us at info@associatedfire.com or info@associatedfire.com, or via our Contact Us form, so we can keep your information up to date.
XI. MAKING A COMPLAINT
We strive to meet the highest standards when handling your personal information and deal seriously with any complaints we receive.
If you think that AFP’s collection or use of information is unfair, misleading or inappropriate, please bring it to our attention by contacting us via our Contact Us form.
If you are not satisfied with our use of your personal data or our response to any exercise of these rights, you have the right to complain to the relevant Supervisory Authority (data protection regulator).
XII. CHANGES TO OUR PRIVACY POLICY
Associated Fire Protection reserves the right to change this Policy from time to time as needed.
COOKIE POLICY
INFORMATION ABOUT OUR USE OF COOKIES
Cookies are small text files that are stored in your computer’s memory and hard drive when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website. A cookie cannot read data from your hard disk or read cookie files created by other sites.
Our website, www.associatedfire.com, uses cookies to distinguish you from other site users. This helps us to provide you with a good experience when you browse our sites and also allows us to improve our sites. The use of cookies is relatively standard. Most Internet browsers are initially set up to accept cookies, but you can use your browser to either notify you when you receive a cookie or to disable cookies. For more information on cookies, visit www.allaboutcookies.org
By continuing to browse the sites, you are agreeing to our use of cookies.
Associated Fire Protection reserves the right to change this and any other policies.
[Updated as of October 1, 2019.]
