Volpe Koenig Privacy and Data Protection Policy

Volpe Koenig is sensitive to your concerns about data privacy. We developed this Privacy Policy to explain how we handle your information and to describe the rights of those whose information is subject to the U.S. and international laws and regulations, including the General Data Protection Regulation (GDPR). Readers to whom this Policy applies include clients and prospective clients, job applicants, and visitors to our website.

Below, we clarify which of your information we keep, how we obtain your information, our reasons for collecting your information, the measures we take to safeguard your information, and your available rights.

We collect the following types of information about you.

I. Client Information. We process information you choose to provide to us as a client or prospective client. We may also keep certain information made known to us in the course of providing services to you. Customarily, these categories include following:

• Contact information (including name, position, company/organization, telephone number, email address).
• Payment information.
• Data obtained from public databases and court records.
•  Information disclosed by other advisors who serve our clients.
• Any other information relevant to our provision of services, which depends on the nature of your engagement with Volpe and Koenig, P.C.

As unsolicited communications are not protected by attorney-client privilege, please refrain from sending us confidential information until we have confirmed in writing that we represent you or your organization.

II. Personal Information. We record personal information you submit through forms on our website, through emails and responses to our emails, and certain information made public through professional networks, social media, and publications. Information collected in this manner includes

• Contact information.
• Job title and employer information.
• Business information identifying you in relation to matters on which you instruct us or in which you are involved.

III. Applicant Information. We also keep information related to employment inquiries that you submit, for instance, through the careers section of our website. Applicant information includes contact information and any information contained within materials provided, and is only available to parties involved in the hiring process.

IV. Web Analytics Information. Our website automatically collects non-identifying information about visitors, which includes the following:

• Browser type.
• Operating system.
• Domain name
• Pages viewed.
• Length of visit.
• Interaction information.
• Other similar statistics.

The tools we use to analyze activity on our website may save this information by placing “cookies” on your computer. While we use cookies to record use of our website, it is solely for analytics purposes. You may disable cookies by changing your browser settings. We use Google Analytics to assist with analyzing traffic to our website.  If you wish to know how Google Analytics collects and processes data, please visit Google at this link.

We use your data to deliver services and fulfill our obligations.

Every purpose for which we use your data has an underlying legal basis, whether serving your legitimate interests or those of a third party, establishing or enforcing our own rights, or enabling an official authority to act in the public interest. While you may always provide explicit consent to our usage in some circumstances, below are several reasons why we process your information:

1. Service. We process client information as necessary to verify your identity, provide legal advice, carry out your requests, and perform contracts to which you are a party.
2. Compliance. We use your information to comply with applicable laws and regulations, court orders, and requests from law enforcement officials. We also use your data to identify conflicts-of-interest and remain in good standing under the applicable rules of professional conduct.
3. Marketing and Business Development. We use your information to contact you about our services and keep you up-to-date on changes in the law through emails and newsletters. We manage your data to shape our relationship with you, identify business opportunities, and develop our promotional campaigns.
4. Administration. We maintain your information as part of our record-keeping procedures, and for hiring, billing and accounting purposes. We also analyze the activity of visitors on our website to monitor for security threats and ensure our technology is being used appropriately.

We share your information only as necessary.

Your data is accessible to all Volpe Koenig attorneys, to their management, and other employees pursuant to a recognized business purpose. In addition to members of the firm, we share your information with certain categories of third parties as is necessary and appropriate to deliver services and comply with the law. These categories include the following:

• Government and regulatory authorities.
• Other professionals who represent you in the same legal matters.
• Opposing counsel, advisors, and experts.
• Other service providers as necessary to fulfil contractual and legal obligations (such as tax advisors, accountants, IT service provides, translators, and confidential waste disposal service providers).

Notwithstanding our Privacy Policy, we also reserve the right to disclose personal information in three rare circumstances:

1) Where the firm believes or has reason to believe that disclosure of such personal information is necessary to identify, contact, or institute legal action against an individual(s) who may be interfering with or causing injury to, either intentionally or unintentionally, the rights of Volpe Koenig.
2) Where the firm, in good faith, believes the law requires it.
3) In a situation involving threats to the physical safety of any person.

We take the following steps to protect your data.

We keep your information only as long as is required by law, or as long as is necessary to provide our services. Our retention period depends, however, on several factors such as whether you or your company or organization are an existing client or have interacted with recent promotional materials or attended events recently.

We maintain the data and information provided by you confidential in accordance with the laws governing the legal profession and pursuant to our contractual arrangements with you or with the entity/entities you represent. We do not trade your information, and we do not make it commercially available to any other third party.

In the event we share your information with a third party service provider, we conduct an appropriate level of due diligence and prepare contractual documentation to ensure that they process personal information appropriately and according to our legal and regulatory obligations.

We implement organizational, administrative, technical and physical measures to protect your data from being disclosed to third parties. We cannot, however, guarantee the security of your personal information. Please note that no transmission over the Internet is completely secure or error-free, and that the information security policies, rules, and technical measures taken may be compromised.

We respect your rights to raise concerns.

As Chapter 8 of the GDPR establishes, you have the following rights in relation to your personal information:

1. Access. You may ask us whether we use your data and request a copy of any of your personal information we possess.
2. Correction. You may request that we resolve incorrect or incomplete information.
3. Erasure. You may request deletion of any or all of your information, with limited exceptions as set forth by law.
4. Restriction. You may ask us to cease usage of your information.
5. Transfer. You may ask us to transfer your information to a third party, or to provide an easily-read copy for reuse at your discretion elsewhere.
6. Objection. You may dispute our usage of your information when we use it for legitimate purposes, for direct marketing, or for research and statistics.
7. Automated Decisions. We do not currently utilize automated decision-making or intend to use automated decision-making. However, if we begin utilizing you may opt-out of automated decision-making that produces a legal effect.
8. Consent. If you previously consented to our use of your information, you may withdraw your consent at any time.
9. Complaint. If you are concerned with the way we handle your information, you may lodge a complaint with a supervisory authority in your place of work, place of residence, or the place of the alleged infringement.

To exercise any of these rights, or to inquire further about our Privacy Policy, please contact our Data Privacy Officer, John J. O'Malley, in writing at privacy@vklaw.com.

This Policy is effective July 12, 2023. We reserve the right to revise this Policy from time to time.