PRIVACY POLICY

INTRODUCTION

Stairs Dillenbeck Finley Mayer PLLC, its partners, associates, employees, trainees, and other staff members (together, the "Firm" or "We") respect your privacy and are committed to protecting it through our compliance with this privacy policy (this "Policy").

This Policy describes the types of information we may collect from you or that you may provide when you visit the website www.stairsdillenbeck.com (our "Website") or engage with us to use the products and services that the Firm provides (our "Services") and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Policy also sets out your rights in respect of our processing of your personal information.

If you have any questions about this Policy or want to exercise your rights set out in this Policy, please contact us by:

• sending us an email to mayer@stairsdillenbeck.com; or
• calling us at +1-212-697-2700 extension 2

This Policy applies to information we collect:

• on this Website;
• in email, text, and any other form of communication between you and the Firm.

INFORMATION WE COLLECT ABOUT YOU

We may collect information from you by which you may be personally identified, such as your name, postal address, email address, telephone number, social security number or any other identifier ("personal information"). We may collect personal information from you in the course of our business, including through your use of our Website, when you contact or request information from us, when you engage our Services or as a result of your relationship with one or more of our attorneys or staff.

We may process the following personal information:

• If you are a visitor to the Website:
• name and job title;
• contact information;
• demographic information such as your address, preferences and interests; and
• other information relevant to the rendering of our Services.
• If you are an individual client in receipt of our Services or a prospective individual client:
• name and job title;
• contact information;
• payment information;
• information that you provide to us as part of our providing the Services to you;
• relevant information as required by Know Your Client or Anti-Money Laundering or Anti-Bribery laws and regulations and as part of our client intake procedures;
• information you provide to us for the purposes of attending meetings and events, including dietary requirements; and
• other information relevant to the provision of our Services.

For clients and prospective clients, we also collect information to enable us to market our Services. For this purpose we collect:

• name and contact details;
• other business information such as job title and the company you work for; and
• areas or topics that interest you.

If you are a potential recruit to join the Firm:

• name and job title;
• contact information including email address;
• curriculum vitae, including your age and/or gender if you provide it to us, your education, employment history and similar information that you may provide to us; and
• other information relevant to your potential recruitment by the Firm.

This is a non-exhaustive list which reflects the varied nature of the personal information processed by the Firm.

HOW DO WE USE YOUR PERSONAL INFORMATION?

• Fulfilment of Services
  We collect and maintain personal information that you voluntarily submit to us during your use of our Website and our Services to enable us to develop, deliver, render and improve our Services;
• Client services
  Our Website uses various user interfaces to allow you to request information about our Services. Contact information may be requested in each case, together with other personal information that is relevant to your enquiry. This information is used in order to enable us to respond to your requests or inquiries.
• Business administration and legal compliance
  We use your personal information for the following business administration and legal compliance purposes:
• to verify your identity;
• to carry out requests made by you on our Website or in relation to our Services;
• to comply with our legal obligations (including any Know Your Client or Anti-Money Laundering or Anti-Bribery laws and regulations and any other applicable laws and regulations, conflicts of interest, or similar obligations, including maintaining regulatory insurance), court order, other judicial process, or the requirements of a regulator;
• to enforce our legal rights and our agreements with you; and
• to protect the rights of third parties.
• Recruitment
  We use your personal information for the following recruitment purposes:
• to assess your suitability for any position for which you may apply at the Firm whether such application has been received by us online, via email or hard copy, or an in-person application; and
• to ensure that the Firm does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other protected classification covered by and in accordance with applicable legislation.

• Marketing communications
  We may carry out marketing activities (g., sending newsletters or event notifications) using your personal information if you have consented to receive such marketing communications or we have a lawful right to do so.

• Client insight and analysis
  Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the mobile device or computer hardware and software you use to access the Website. This includes the following:
• an IP address to monitor traffic on our Website;
• a session ID to track usage statistics on our Website; and
• information regarding your personal or professional interests, demographics, experiences with our Services and contact preferences.

WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share personal information with the following categories of third parties as reasonably necessary to perform our Services on your behalf, including but not limited to:

• lawyers, accountants and other professional advisers;
• government or regulatory authorities;
• professional indemnity or other insurers;
• regulators, tax authorities, and corporate registries;
• third parties to whom we outsource certain services such as, document processing and translation services, document review platforms, confidential waste disposal, IT systems or software providers, IT support service providers, and document and information storage providers;
• third party service providers to assist us with client insight analytics, such as Google Analytics; and
• third party postal or courier providers who assist us in delivering documents.

Please note this list is non-exhaustive and there may be other examples where we need to share your personal information with third parties in order to provide our Services.

TRANSFERING YOUR PERSONAL INFORMATION

To provide the Services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it.

If you are based within the European Economic Area (EEA), please note that where reasonably necessary to deliver the Services we will transfer personal information to countries outside the EEA.

We do not sell your personal information.

YOUR RIGHT TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS

You have the following rights in relation to the personal information we hold about you:

• Your right to access
  If you ask us, we will confirm whether we are processing your personal information and, if necessary, provide you with a copy of that personal information.
  
  
• Your right to rectification
  If the personal information we hold about you is inaccurate, incomplete or out of date, you are entitled to request to have it corrected.
  
  
• Your right to erasure
  You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable).
  
  
• Your right to restrict processing
  You can ask us to 'block' or suppress the processing of your personal information in certain circumstances, such as where you object to the processing or contest the accuracy of that personal information.
  
  
• Your right to data portability
  You have the right to a “portable” copy of your personal information that you have provided to us.  Generally, this means your right to request that we move, copy or transmit your personal information to you or to another data controller in a commonly used, machine readable format.
  
  
• Your right to object (opt-out)
  You can ask us to stop processing your personal information, except if we can demonstrate compelling legal grounds for the processing. You also have a right to object where we are processing your personal information for direct marketing purposes.
  
  
• Your right to withdraw consent
  If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

If you would like to exercise any of these rights, please send an email to mayer@stairsdillenbeck.com.

Please note that some of these rights may be limited where we have an overriding interest (e.g., to enforce or apply our terms of use and other agreements, including for billing and collection purposes) or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.

INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website; and
• information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information. It helps us to improve our Website and to deliver better and more personalized services, including by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Website according to your individual interests;
• speed up your searches; and
• recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Firm, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

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 Website and its contents to you;
• to provide you with information or Services that you request from us;
• 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 Website or any Services we offer or provide through it;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent.

DISCLOSURE OF YOUR INFORMATION

We may disclose personal information that we collect or you provide as described in this Policy:

• to contractors, service providers, and other third parties we use to support our business;
• to fulfill the purpose for which you provide it; and
• with your consent.

We may also disclose your personal information:

• to comply with our legal and ethical obligations, any court order, 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; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Firm, our clients, or others.

ACCESSING AND CORRECTING YOUR INFORMATION

You may send us an email at mayer@stairsdillenbeck.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for the Firm to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled.

DATA SECURITY

We have implemented measures to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. Please do not share your password with anyone.

As the transmission of information over the internet is inherently insecure, we cannot guarantee the security of any information, including your personal information, transmitted to us via e-mail or through our Website. Any transmission of such information, including personal information, is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Website.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to this Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in our records and/or through a notice on our Website. The date this Policy was last revised is identified at the bottom of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

CONTACT INFORMATION

To ask questions or comment about this Policy and our privacy practices, contact us by email at

mayer@sdfm.nyc

or via telephone at

+1-212-697-2700 extension 2.

LAST UPDATE

This Policy was last updated in January 2023.