Planet Waves has created this privacy policy (the Policy) because of our steadfast commitment to protecting your privacy. This Policy encompasses any and all Websites that are controlled and managed by our Firm.
The Planet Waves Website(s) (collectively Planet Waves or Website), as well as the ancillary services that we manage is provided to support Planet Waves’s companies, not-for-profits and public sector entities in a wide spectrum of practice areas. Use of our Website for any purposes other than that for which it is intended is unauthorized and prohibited.
This Policy describes the types of information we may collect from you or that you may provide to us when you visit and/or use our Website. It also describes our practice for collecting, using, maintaining, protecting and disclosing that information.
Please read this Policy carefully to understand our policies and practices regarding your information and how we use and treat it. By accessing, interacting with and/or using the Website, you agree to all of the terms in this Policy. This Policy may change from time to time. Any modifications will be effective immediately. You can determine when the Policy was last revised by referring to the “Last Modified” legend at the top of this page. Your continued use of the Website after we make such changes is deemed to be acceptance of those changes, so please regularly check the Policy for updates.
The Information We Collect
Personal Data
We collect and may transmit personally identifiable information that you voluntarily provide to us through the Website and other means, for instance by telephonic or e-mail communication. Personally identifiable information that we collect and transmit may include, but will not be limited to your first and last name, your company name, your job title, your e-mail address, your telephone number, your mailing address, educational history, professional qualifications, information contained in any e-mail or other communication you send to us, information you give to us in any other way and any other identifier that permits us to identify or contact you (Personal Data).
This information may be collected through various portions of the Website. Some of the ways in which we may collect Personal Data from you include, but are not limited to, our:
Careers webpage
“Contact Us” form
Subscribing to our mailing platform
Events page
Contacting webadmin@bsk.com or privacy@bsk.com
Attorney Profiles correspondence
In addition to some or all of the information listed above, there may be personally identifiable data that we collect for our legal services through our Website. This information may include identification information from you or from your organization or other third parties for compliance with our legal and professional duties, payment data and other related billing information and other personal data regarding your preferences, opinions and comments where it is relevant to our services.
Special Category Data
In limited circumstances related to our services, we may collect Personal Data that is identified under the European Union’s General Data Protection Regulation (GDPR) as special category data. For more information, please see the European General Data Protection section below. Special category data includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, personal or political opinions, trade union membership, information about your health and genetic and biometric data. In some situations, pre-employment background checks that collect information about an individual’s criminal history may be performed. We will only process special category data where we have a lawful basis for doing so.
Usage Data
Data may be collected from you automatically when you access or interact with the Website.
We may collect information about how you access and use the Website (Usage Data). Usage Data may include information such as your device’s Internet Protocol address (e.g. IP address), the type of browser or application you are using to access the Website, browser version, the operating system, the time and date of your visit, the pages of the Website that you visit, the time spent on those pages, unique device identifiers and other diagnostic data. We may also collect information regarding the device(s) you use to access or use the Website.
When you visit the Website with a mobile device, we may collect certain information automatically, including, but not limited to: the type of mobile device you are using, your mobile device unique ID, the IP address of your mobile device, your mobile device operating system, the type of mobile internet browser you are using, unique device information and other diagnostic data.
Employment Data
We may receive Personal Data about you that may include information you provide to us, information we generate as part of the recruiting and applications process, and information we receive about you from third parties. We use your Personal Data to recruit and evaluate potential candidates, to process and evaluate applications and make hiring decisions, to conduct background checks, to communicate with you and your references and to comply with legal obligations. Your application and Personal Data may be collected and processed through our Website. If we hire you, we may transfer Personal Data we collect in connection with the application and hiring process into our human resources systems, use it to manage the new-hire process, to incorporate it into your employee file and to create your own administrative profile, if applicable, for hiring purposes.
We process Personal Data from you during the application process for the following purposes:
To identify potential candidates, process and evaluate applications and make hiring decisions: We may collect and use your information, including Personal Data, to process your application, assess your capabilities and qualifications for a role and make hiring decisions. This information may include e.g., your education information, qualifications, previous work experience, citizenship and work authorization status, skills, cover letter information, salary information, professional and other work-related licenses, memberships, permits and certifications held, demographic information as required or permitted under applicable law, social media profile information and any other information that you elect to provide to us (e.g., career objectives, employment preferences, willingness to relocate or travel, awards).
To conduct background checks: We may collect and use information, including Personal Data, while conducting reference checks and, if we offer you a position, while conducting background checks. This information may include e.g., professional and other work-related licenses, memberships, permits and certifications held, graduation date, degree and institution, name and contact information for your references, government issued IDs and criminal records and/or credit reports as allowed by applicable law.
Compliance with applicable laws: We may collect and use your information, including Personal Data, to comply with our legal obligations under applicable law, respond to legal requirements (statutes, regulations or court orders), administrative or judicial processes or contracts, including a subpoena or search warrant. For example, we may collect immigration status and work authorization information. We may also collect and use your information to cooperate with governmental agencies or law enforcement, to the extent allowed or required by and in accordance with applicable law. For example, if you are applying for a role located in the United States, you may provide us information about your gender, race, ethnicity, veteran status, disabilities and visa status.
If you provide us with Special Category Data such as religious affiliation or ethnicity, you do so on a voluntary basis, unless such information must be processed by Planet Waves as required by law or is necessary for the purposes for which it was requested. If you are an EU resident and you would like further information relating to our processing of the Personal Data of EU residents, see the European General Data Protection Regulation section below.
Tracking and Cookies Data
We may use cookies or other tracking technologies to collect Usage Data and track how you use the Website. We may use cookies for statistical reporting for the Website and for other purposes relating to making our Website available to you. Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses. We use cookies and similar tracking technologies to track activity on our Website and store certain information. Tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyze our Website.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, some features of the Website may be unavailable to you.
We use the following cookies for the purposes set out below:
Session Cookies: in order to operate our Website.
Preference Cookies: to remember your preferences and various settings
Security Cookies: for security purposes
For more information, please review our Cookie Policy found here.
How We Collect Your Personal Data
We may collect Personal Data in a number of circumstances and ways when you visit and/or use our Website, including:
When you make an inquiry about our services or otherwise interact on our Website
When you attend a seminar or event with us or a third party we are working with or sign up to receive publications from us
When you apply to join our Planet Waves or express an interest in joining Planet Waves
When you interact with us by telephone, email and other electronic communication
From social media sites
By making inquiries from your organization, other organizations with whom you have dealings such as former employers and educational institutions, or from third-party sources
Automatically by using cookies and other tracking software
We (and our service providers) may share your Personal Data when you visit and/or use our Website in the following situations:
With website providers: We may share your Personal Data with Website Providers to monitor and analyze the use of our Website.
Service providers: We may share your Personal Data with Service Providers to help us deliver our services to you.
For business transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
With affiliates: We may share your Personal Data with our affiliates, in which case we will require those affiliates to honor this Policy.
With business partners: We may share your Personal Data with our business partners to offer you certain products, services, websites or promotions.
With third party vendors: We may share your Personal Data with third party vendors to provide behavioral remarketing or advertising services.
Promotional Communications
We may use your Personal Data to connect you with newsletters, marketing or promotional materials and other information that may be of interest to you. We have a legitimate interest in using your data for promotional purposes (see “Why We Collect Your Personal Data” below). You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any e-mail we send.
Why We Collect Your Personal Data
As outlined above, when you visit and/or use our Website, most of the Personal Data we collect is provided to us directly by you so that we can bring our service and products to you. Your Personal Data is collected for our legitimate business interests or those of our service providers as outlined below:
To provide legal advice or other services, including online or legal technology services as instructed or requested by you or your organization
To provide and maintain our Website, including to monitor the usage of our Website
To manage and administer you or your organization’s relationship with us, including billing and collection, marketing and support services and taking other steps linked to the performance of our business relationship
To contact you by phone, e-mail, text message or other equivalent means of electronic communication regarding updates to our products and services
To provide you with news and general information about us and our services, unless you have opted not to receive such information. For example, with your permission, we may send you emails regarding our services
To detect, prevent and address technical issues
To provide you with news, special offers and general information about our services, Website and events which we offer that are similar to those you have previously attended or inquired about unless you have opted not to receive such information.
For insurance purposes
To personalize and foster the quality of our communications and interaction with you
To prevent and detect criminal and/or fraudulent activity that would be damaging to you and us
For employment purposes
To promote our business to new and existing clients
To gather analysis or valuable information so that we can improve our services
Disclosure of Your Personal Data
Law Enforcement
We may disclose your Personal Data if we are required by law to do so or in response to legitimate requests of public authorities (e.g. a court or government agency).
Disclosure Through Business Transfers
We may buy, merge, or partner with another company or business and in doing so acquire or transfer Personal Data. Personal Data collected through the Website may be among the transferred business assets. In the event of an acquisition or merger, your Personal Data may be transferred so that we may continue to provide products and/or services to you. In the course of such a transaction, your Personal Data would likely be considered a business asset, and, notwithstanding limitations imposed by applicable data privacy legislation, you hereby agree to such a transfer.
Other Reasons for Disclosure
We may disclose your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend our rights
Prevent or investigate possible wrongdoing in connection with the Website
Protect the personal safety of users of the Website or the public
Protect against legal liability
Third-Party Services
In general, the third-party providers used by us will only collect, use and disclose your Personal Data to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers have their own privacy policies with respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your Personal Data will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, your Personal Data may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your Personal Data used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
Once you leave our Website or are redirected to a third-party website or application, you are no longer governed by our policies, including this Policy.
Google Analytics
Google Analytics is a web analytics website offered by Google that tracks and reports (non-personally identifiable) website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google Websites. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visit activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page.
Social Media, Widgets and Open Forums
Our Website may allow you to engage with social media services, such as Facebook, Twitter, Instagram, LinkedIn and YouTube (Social Networks), and widgets such as the “Share this” button, or interactive mini-programs that run on our Website or which link from Social Networks to our Website (Social Functions). These Social Functions may access, collect and integrate with your Social Network accounts and information. For example, these Social Functions may collect your IP address, identify which page you are visiting on our Website, or set a cookie. If you choose to use these Social Functions, you may be sharing certain Social Network profile elements with us. This sharing is subject to each Social Network’s own privacy policy and terms of use. We do not control those Social Networks or your profiles on those services. We do not modify your privacy settings on those services or establish rules about how your personal information on those services will be used. Social Functions are either hosted by a third party or hosted directly on our Website. Your interactions with them are governed by the privacy policy of the company providing them. Please refer to the privacy settings in your Social Network account to manage the data that is shared with us through your account.
Further, information you include and transmit online in a publicly accessible blog, chat room or Social Network, or that you share in an open forum such as an in-person panel or survey, may be viewed and used by others without any restrictions. As noted above, we do not control such uses of your personal information. By using such services, you assume the risk and acknowledge that the personal information provided by you may be viewed and used by us and/or third parties for any number of purposes, and that the usage restrictions set forth in this Privacy Policy do not apply to such services.
Links
When you click on links within our Website, they may direct you away from our Website to the websites of third parties. We are not responsible for the privacy practices of third parties and encourage you to read the privacy statements of any third-party website you are directed to. Complaints, claims, concerns, or questions regarding third-party practices should be directed to the third-party.
Security
The security of your Personal Data is important to us, but remember that no method of transmission over the Internet is 100% secure. To protect your Personal Data, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. Even so, technical mistakes are possible. No company, including us, can fully eliminate security risks associated with the transmission of Personal Data over the Internet.
We restrict access to your Personal Data obtained when you visit and/or use our Website to our employees, service providers and third parties who need to know the information in order to process it on our behalf. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes, or fail to follow policies. Therefore, while we use commercially reasonable efforts to protect your Personal Data, we cannot guarantee its absolute security. If an applicable law imposes any non-disclaimable duty to protect your Personal Data, you agree that intentional misconduct will be the standard used to measure our compliance with this duty.
While we use commercially reasonable security measures to prevent unauthorized persons from accessing our files or tampering with the Website, we cannot guarantee that these efforts will always be successful. We do not represent, warrant, or guarantee that our safeguards will protect the total privacy of your Personal Data disclosed on the Website. Your Personal Data may be accessed and viewed by other Internet users without your knowledge or permission while in transit to or from us. We cannot and do not ensure, represent, warrant, or guarantee the security of any information you transmit through the Website.
Transfer of Your Personal Data
If you are located in the European Economic Area (EEA), we may need to collect, use, process, disclose and transfer your Personal Data outside of the EEA. You hereby consent to such collection, use, processing, disclosure and transfer. For further certainty, any consent relating to a right to transfer information referred to in this paragraph shall be deemed to include your consent to the transfer of the applicable information to a jurisdiction which may provide a different level of privacy protection than that available in your own country.
Age of Consent
Our Website is not intended for use by those under the age of 18, nor is it targeted to those under the age of 18. If you use our Website, you hereby represent and warrant that you are at least 18 years of age. No one under the age of 18 may provide any information to or on our Website. We do not knowingly collect Personal Data from those under the age of 18, nor do we knowingly sell or otherwise disclose the Personal Data of those under the age of 18. If you are under the age of 18, do not (i) use or provide any information on our Website or through any of its features, (ii) use any of the interactive or fillable features of the Website, or (iii) provide any information about yourself to us, including your name, address, telephone number, e-mail address or any other information that could be used to identify you. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
California Privacy Rights
If you are a California resident, you have certain data protection rights. Under the California Consumer Privacy Act of 2018 (CCPA) and California Civil Code § 1798.83, you have the right to exercise the following rights:
Disclosures of Personal Information We Collect
You have the right to know:
The categories of Personal Data we have collected about you
The categories of sources from which we have collected Personal Data
Our business or commercial purpose for collecting or selling Personal Data
The categories of third parties with whom we share Personal Data
The specific pieces of Personal Data we have collected about you
Personal Data We Sell or Use for a Business Purpose
In connection with any Personal Data we may sell or disclose to a third party for business purposes, you have the right to know:
The categories of Personal Data that we sold
The categories of third parties to whom Personal Data was sold
The categories of Personal Data that we disclosed for a business purpose
Planet Waves does not sell (as is defined in the CCPA) the Personal Data we collect, and will not sell it without providing a right to opt out.
Right to Deletion
Subject to certain exceptions set out below, upon receipt of a verifiable request from you, we will:
Delete your Personal Data from our records; and
Direct any service providers to delete your Personal Data from their records.
Please note that we may not delete your Personal Data if it is necessary to:
Complete the transaction for which your Personal Data was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you
Detect and protect against security incidents, fraudulent or illegal activity, or for prosecuting those responsible for such activity
Debug, identify, or repair errors that impair existing functionality
Exercise free speech
Comply with the California Electronic Communications Privacy Act
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all applicable ethics and privacy laws
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
Comply with an existing legal obligation
Otherwise use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information
Protection Against Discrimination
You have the right not to be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot:
Deny goods or services to you
Provide a different level or quality of services to you
Please note that we may charge a different price or rate to you if that difference is reasonably related to the value provided to us by your Personal Data.
California’s Shine the Light Law
In addition to CCPA, California Civil Code § 1798.83 permits users that are residents of California to request the following information regarding our disclosure of your Personal Data to third parties for those third parties’ direct marketing purposes: (i) a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year; and (iii) where the nature of the third parties’ business is not reasonably determinable, examples of the products or services marketed (if we have that information) . If you are a California resident and would like to make such a request, please email us at privacy@bsk.com.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Website does not respond to or support Do Not Track (DNT) signals.
Do Not Track is a preference you can set in your web browser to inform websites you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
European General Data Privacy Regulation (GDPR)
If you are a resident of the European Union (EU), you have certain data protection rights under the European General Data Protection Regulation (GDPR).
Legal Basis for Processing Your Personal Data Under GDPR
To process your Personal Data, we must have a legal basis for doing so. We may process your Personal Data under the following conditions:
Performance of a Contract: when your Personal Data is necessary for the performance of an agreement that we make with you and/or for any contractual obligations thereof
Legal Obligation: when your Personal Data is necessary for compliance with a legal obligation to which Planet Waves is subject
Legitimate Interests: when processing your Personal Data is necessary for the purpose of the legitimate interests pursued by Planet Waves
Consent: you have given your consent for processing Personal Data for one or more specific purposes
Vital Interests: when your Personal Data is processed in order to protect your vital interests or those of another natural person
Public Interests: when your Personal Data is processed relating to a task that is carried out in the public interest or in the exercise of official authority vested in Planet Waves
Your Data Protection Rights Under GDPR
In certain circumstances, you have the following data protection rights with respect to your Personal Data that we collect and process:
The Right to Request Access. You have the right to access, update, or delete the information we have about you.
The Right of Rectification. You have the right to have any incomplete or inaccurate information we hold about you corrected.
The Right to Object. You have the right to object to our processing of your Personal Data.
The Right to Restrict Processing. You have the right to request that we restrict the processing of your Personal Data.
The Right of Erasure. In certain circumstances, you have the right to ask us to remove or delete your Personal Data.
The Right to be Forgotten. You have the right to request that we delete your personal information, in certain situations.
The Right to Transfer. Upon request we will provide you (or a third-party you have chosen) the Personal Data we have collected about you. Your Personal Data will be provided in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the Personal Data to perform a contract with you.
Withdraw Your Consent. You have the right to withdraw your consent at any time where Planet Waves relied on your consent to process your Personal Data.
Exercising Your Rights Under GDPR
You may exercise any of the rights enumerated above by contacting us at privacy@planetwaves.net. Please note that we may ask you to verify your identity before responding to such requests.
You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area.
If a Data Processing Addendum (DPA) is required, that can be requested using the information below.
Contact Us
If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, please contact our Privacy Compliance Officer at the at:
Email: privacy@planetwaves.net