Privacy Policy

Outten & Golden LLP Privacy Policy

Outten & Golden LLP’s (“O&G”) privacy policy (the “Policy”) encompasses any and all Websites that are controlled and managed by our Firm. We care about privacy.

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. This Policy applies to our current data practices and provides you with “notice at collection,” which is notice of the personal information we collect, and the purposes for which we process personal information, among other things as required by the United States privacy laws.

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 be amended 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 revisions is deemed to be acceptance of those changes, so please regularly check the Policy for updates. 

This Policy applies to “Consumers” as defined in applicable privacy laws, including but not limited to:

  • the California Consumer Privacy Act (California Civil Code § 1798.100 et seq.), as amended including, without limitation, by the California Privacy Rights Act;
  • the Colorado Privacy Act (Colorado Revised Statute Title 6 Article 1 Part 13 § 6-1-1301 et seq.);
  • Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring (Public Act No. 22-15);
  • Utah’s Consumer Privacy Act (Utah Code Ann. § 13-61-101 et seq.); and
  • the Virginia Consumer Data Privacy Act (Va. Code Ann. § 59.1-575 et seq.).

(collectively, the “U.S. Privacy Laws”). This Notice is designed to meet our obligations under U.S. Privacy Laws.

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 mail, telephonic and e-mail communications. 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 work and personal e-mail addresses, your telephone number(s), 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 also 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 info@outtengolden.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 Personal Data 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 information regarding your preferences, opinions, and comments where it is relevant to our services.

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 usage and 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’s unique ID, the IP address of your mobile device, your mobile device’s operating system, the type of mobile internet browser you are using, unique device information and other usage and 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, for example, 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, for example, 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 Personal Data such as religious affiliation or ethnicity, you do so on a voluntary basis, unless such information must be obtained by O&G as required by law or is necessary for the purposes for which it was requested.

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.

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 O&G or express an interest in joining O&G.
  • 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 work with service providers to help us deliver our services to you or during the hiring process (“Service Providers”; also referred to in certain privacy laws as “Processors”).  We may share your Personal Data with Service Providers to help us deliver our services to you or in making hiring decisions.
  • For business transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of law firm assets, financing, or acquisition of all or a portion of our business to another entity.
  • 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 services.
  • 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 business 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 provide our service 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, maintain and improve our Website, including to monitor the usage of our Website for security purposes.
  • To manage and administer your 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, mail, 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 and security related 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.

Where We Store and How We Protect Your Personal Data

As our website is hosted in the United States, any personal data collected about you through this website will be transferred to, and stored in, the United States.

We take all necessary protective measures of a technical and physical nature in order to comply with applicable legal requirements and safeguard the data that we collect. In particular, this includes strict physical security policies, web and email content inspection, anti-virus protection against malware and malware-free attacks, intrusion detection and prevention, and continuous and comprehensive endpoint visibility including application control software. Furthermore, we encrypt all firm-managed laptops and support transport layer security (TLS) encryption for secure email communication.

How Long We Store Personal Data

We retain personal data in accordance with applicable laws and regulations and our records retention policy based on these laws and regulations. The exact storage period is determined by a number of criteria, including our legal and regulatory obligations (in particular, our professional storage requirements pursuant to section 50 para. 1 of the Federal Lawyers’ Act), the purposes for which we are using the information, the amount and sensitivity of the information, and the potential risk from any unauthorized use or disclosure of the information.

Disclosure of Your Personal Data

Law Enforcement 

We may disclose your Personal Data if we are required by law or legal process 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 Service 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 doing business with us.

For these Service 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 Service Providers.

In particular, remember that certain Service Providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If your business with us involves the services of a 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 collected in the course of our providing services to you 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 standards 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 persons under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.

Consumer Rights Request

This section details the requirements for a “Verifiable Consumer Request,” which is a request permitted by U.S. Privacy Law that you submit to us that is subject to an identity verification process.

For Consumers that are residents of states that have enacted privacy laws that apply to our relationship with you, we will respond to requests made pursuant to this section and applicable law.  If you are not a resident of a state that has applicable Consumer privacy rights, we will in our sole discretion respond to requests made pursuant

 

CATEGORIES

 

PROCESSING

 

POTENTIAL RECIPIENTS

     

Identifiers and contact information 

For example: name, phone number, address, email address, IP address

 

  • Providing our services
  • Facilitating your relationship with our Service Providers and Business Vendors and Business Vendors
  • Customizing your experience
  • Registering and administering accounts
  • Customer service and communications
  • Research, development, and analytics
  • Market research and customer satisfaction
  • Targeting advertisements
  • Safety, security, and compliance with legal obligations
  • For purposes that are compatible with the purpose of collecting your personal information and that are not prohibited by law
  • For purposes disclosed at the time you provide your personal information

 

Disclosures for business purposes:

  • Software, communications, storage and other business Vendors (“Business Vendors”)
  • Service Providers

Sale/Sharing Recipients:

  • Business Vendors
  • Service Providers

Personal Records 

For example: name, signature, physical address, telephone number, education, employment, employment history

 

  • Providing our services
  • Facilitating your relationship with our Service Providers and Business Vendors and Business Vendors
  • Customizing your experience
  • Registering and administering accounts
  • Customer service and communications
  • Research, development, and analytics
  • Market research and customer satisfaction
  • Safety, security, and compliance with legal obligations
  • For purposes that are compatible with the purpose of collecting your personal information and that are not prohibited by law
  • For purposes disclosed at the time you provide your personal information

 

Disclosures for business purposes:

  • Business Vendors
  • Service Partners
  • Affiliates and related entities

Sale/Sharing Recipients:

  • Business Vendors
  • Service Providers

Personal Characteristics or Traits 

For example: age and gender

 

  • Providing our services
  • Facilitating your relationship with our Service Providers and Business Vendors
  • Customizing your experience, offers, and content
  • Registering and administering accounts
  • Customer service and communications
  • Research, development, and analytics
  • Ad measurement, attribution, and other ad administration
  • Market research and customer satisfaction
  • Targeting advertisements
  • Safety, security, and compliance with legal obligations
  • For purposes that are compatible with the purpose of collecting your personal information and that are not prohibited by law
  • For purposes disclosed at the time you provide your personal information

 

Disclosures for business purposes:

  • Business Vendors
  • Service Providers
  • Affiliates and related entities

Sale/Sharing Recipients:

  • Business Vendors
  • Service Partners

Transaction / Commercial Information 

For example: services purchased or considered; Service Providers’ products or services considered or purchased; and other purchasing or consuming histories or tendencies

 

  • Providing our services
  • Facilitating your relationship with our Service Providers and Business Vendors
  • Customizing your experience, offers, and content
  • Registering and administering accounts
  • Customer service and communications
  • Research, development, and analytics
  • Ad measurement, attribution, and other ad administration
  • Market research and customer satisfaction
  • Targeting advertisements
  • Safety, security, and compliance with legal obligations
  • For purposes that are compatible with the purpose of collecting your personal information and that are not prohibited by law
  • For purposes disclosed at the time you provide your personal information

 

Disclosures for business purposes:

  • Business Vendors
  • Service Providers
  • Affiliates and related entities

Sale/Sharing Recipients:

  • Business Vendors
  • Service Providers

Services Usage Information 

For example: search, browsing history, and other interactions with us

 

  • Providing our services
  • Facilitating your relationship with our Service Providers and Business Vendors
  • Customizing your experience, offers, and content
  • Registering and administering accounts
  • Customer service and communications
  • Research, development, and analytics
  • Ad measurement, attribution, and other ad administration
  • Market research and customer satisfaction
  • Targeting advertisements
  • Safety, security, and compliance with legal obligations
  • For purposes disclosed at the time you provide your personal information
  • For purposes that are compatible with the purpose of collecting your personal information and that are not prohibited by law

 

Disclosures for business purposes:

  • Business Vendors
  • Service Providers
  • Affiliates and related entities

Sale/Sharing Recipients:

  • Business Vendors
  • Service Providers

Location Data 

For example: where you enable location-based features on your device, or we may infer your approximate location

 

  • Providing our services
  • Facilitating your relationship with our Service Providers and Business Vendors
  • Customizing your experience, offers, and content
  • Registering and administering accounts
  • Customer service and communications
  • Research, development, and analytics
  • Ad measurement, attribution, and other ad administration
  • Market research and customer satisfaction
  • Targeting advertisements
  • Safety, security, and compliance with legal obligations
  • For purposes disclosed at the time you provide your personal information
  • For purposes that are compatible with the purpose of collecting your personal information and that are not prohibited by law

 

Disclosures for business purposes:

  • Business Vendors
  • Service Providers
  • Affiliates and related entities

Sale/Sharing Recipients:

  • Business Vendors
  • Service Providers

Professional or Employment Information 

For example: your title, affiliated organization, professional expertise and experience, and education related information

 

  • Providing our services
  • Facilitating your relationship with our Service Providers and Business Vendors
  • Customizing your experience, offers, and content
  • Registering and administering accounts
  • Customer service and communications
  • Research, development, and analytics
  • Ad measurement, attribution, and other ad administration
  • Market research and customer satisfaction
  • Targeting advertisements
  • Safety, security, and compliance with legal obligations
  • For purposes disclosed at the time you provide your personal information
  • For purposes that are compatible with the purpose of collecting your personal information and that are not prohibited by law

 

Disclosures for business purposes:

  • Business Vendors
  • Service Providers
  • Affiliates and related entities

Sale/Sharing Recipients:

  • Business Vendors
  • Service Providers

Inferences from PI Collected 

For example: we may infer your interest in certain content based on the pages of the Website you visit

 

  • Providing our services
  • Facilitating your relationship with our Service Providers and Business Vendors
  • Customizing your experience, offers, and content
  • Registering and administering accounts
  • Customer service and communications
  • Research, development, and analytics
  • Ad measurement, attribution, and other ad administration
  • Market research and customer satisfaction
  • Targeting advertisements
  • Safety, security, and compliance with legal obligations
  • For purposes disclosed at the time you provide your personal information
  • For purposes that are compatible with the purpose of collecting your personal information and that are not prohibited by law

 

Disclosures for business purposes:

  • Business Vendors
  • Service Providers
  • Affiliates and related entities

Sale/Sharing Recipients:

  • Business Vendors
  • Service Providers
 

 

SENSITIVE PERSONAL DATA

 

 

Account information and password 

For example: account log-in in combination with a password

 

  • Providing and services
  • Registering and administering accounts
  • Customer service and communications
  • Safety, security, and compliance with legal obligations
  • For purposes disclosed at the time you provide your personal information
  • For purposes that are compatible with the purpose of collecting your personal information and that are not prohibited by law

 

Disclosures for business purposes:

  • Business Vendors
  • Service Providers
  • Affiliates and related entities

Sale/Sharing Recipients: we do not sell or share this category of PI

Sensitive Personal Characteristics 

For example: race, ethnicity, and religious affiliation that you voluntarily provide

 

  • Providing our services
  • Facilitating your relationship with our Service Providers and Business Vendors
  • Research, development, and analytics
  • Ad measurement, attribution, and other ad administration
  • Targeting advertisements
  • Safety, security, and compliance with legal obligations
  • For purposes disclosed at the time you provide your personal information
  • For purposes that are compatible with the purpose of collecting your personal information and that are not prohibited by law

 

Disclosures for business purposes:

  • Service Providers
  • Affiliates and related entities

Sale/Sharing Recipients:

  • Business Vendors
  • Service Providers

Verification

When we receive your request, we will take steps to verify that you are the person you say you are. If you seek information on behalf of another person, we will take steps to verify that you are authorized to make the request on their behalf.  We will compare the information you provide to us to determine whether we maintain Personal Data about you.

At a minimum, you must provide us with your name and email address. Depending on your request and whether we have your information, we may request additional information from you to verify that you are the Consumer making the request. We will review the information provided with your request and may ask you to provide additional information by e-mail or other method to fulfill our obligation to verify. We will not fulfill your Right to Know – Categories, Right to Know – Specific Pieces, Right to Delete, or Right to Correction related request unless you provide sufficient information for us to reasonably verify that you are the Consumer that is the subject of the request. We reserve the right to apply this or a similar verification process to other types of requests if we suspect fraud.

Depending on the applicable U.S. Privacy Law, the verification process we are required to follow for request varies. We verify your “Categories” request, certain deletion requests, and correction requests to a reasonable degree of certainty for verification purposes, but apply a verification standard of a reasonably high degree of certainty if the request relates to sensitive Personal Data, including matching at least three pieces of Personal Data of our choosing and provided by you with Personal Data maintained by us, which may include obtaining a signed affidavit from you stating that under the penalty of perjury you are the individual whose Personal Data is the subject of the request.

In the event we cannot verify that it is you making the request, we will still take such actions as required by applicable U.S. Privacy Laws.

Using an Agent to Make Your Request

You are permitted to designate an authorized agent to submit a request on your behalf.  The request must be submitted in the manner described above.

U.S. Privacy Laws require that we ensure that a request made by an agent is a Verifiable Consumer Request. This allows us to request additional information to ensure that the Consumer has authorized the agent to make the request on their behalf. We will typically request that an agent provide proof that the Consumer gave the agent written permission to submit the request.  We may further require the Consumer to either (i) verify their own identity or (ii) directly confirm to us that the Consumer provided the agent permission to submit the request.

Making a Request

Requests made pursuant to applicable U.S. Privacy Laws are subject to the identity verification process discussed above. We will attempt to fulfill your request once you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected Personal Data.

To make a request, other than a Do Not Sell, Share or Target request, you can make your request using one of the following methods:

          Email: info@outtengolden.com 

          Phone: +1-866-772-0977

Please be aware that if you make a request for information and we are unable to associate that information with you (e.g., the information about you is anonymized), we cannot include such information in response to your request. If we cannot comply with your request, we will explain the reasons in our response to you.

We will use Personal Data that you provide in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document our responses to your request, unless you also gave that Personal Data to us for another purpose.

Commercially reasonable efforts will be made by us to identify Personal Data that we collect, process, store, disclose, and otherwise use and to respond to a Verifiable Consumer Request. We do not typically charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. If we determine in our sole discretion that you should be charged a fee for your request, or that we are refusing your request, we will explain to you why we made that decision. We will provide you with a cost estimate and the opportunity to accept our fee before we will charge you to respond to your request.

Consumer Privacy Rights

Right to Know – Categories of Personal Information

California residents have the right to request that we provide them with certain information about our collection, use and disclosure of their personal information related to categories of personal information.  The right covers the 12-month period prior to the date of the request. You can request that we confirm whether we are processing your personal information, and disclose to you:

  1. the categories of your personal information about you that we collected;
  2. the categories of sources for the personal information about you that we collected;
  3. our business or commercial purpose for collecting your personal information;
  4. the categories of personal information disclosed for a business purpose in the prior 12 months and for each category, the categories of the recipients of your personal information; and
  5. the categories of personal information shared about you in the prior 12 months and for each, the categories of the recipients of your personal information.

Because we do not sell your personal information, you will not receive a response from us that includes the categories of personal information sold about you in the prior 12 months.

Right to Know – Specific Pieces of Personal Information

Should you request it, and you are legally entitled to it, we will provide you with a transportable copy of the specific pieces of personal information we collected about you. California and Colorado limit this right to the personal information collected about you in the 12-month period prior to the date of your request. Depending on which state you reside, the applicable U.S. Privacy Law may permit a limit to the number of Right to Know requests you can submit.

Right to Delete

You have the right to request that we delete any of your personal information that we have collected directly from you. There are certain exceptions that may apply, and we will explain the exceptions should they apply.

In response to your request to delete, and subject to the applicable U.S. Privacy Law, we may:

  • permanently delete your personal information from our systems but not from archived or back-up systems;
  • deidentify your personal information, or
  • aggregate your personal information with other information.

Our response will inform you of the method used to delete your personal information. Where a legally permissible exception applies to your request for deletion, we will let you know which exceptions apply and your personal information will be limited to purposes permitted under law.

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. 

Right to Correct

If the personal information we maintain about you is inaccurate, you have the right to request that we correct those inaccuracies. Your request and our response are subject to applicable U.S. Privacy Laws.

Right to Appeal

As of the Effective Date, residents of Colorado, Connecticut, and Virginia have the right to appeal our decision regarding your request. You can exercise this right by responding to our response to your request and following the instructions. Within 45 days after receipt of an appeal, we will inform you of any action taken in response to the appeal, if any, along with a written explanation of the reasons for such action or inaction. We may extend the 45-day period by 60 additional days where reasonably necessary.

Right to Limit Sensitive PI Processing

Certain personal information qualifies as sensitive data or sensitive personal information under the U.S. Privacy Laws (“Sensitive Personal Information”). Residents of certain states must give consent for us to process their Sensitive Personal Information.

If you have given us consent to process your Sensitive Personal Information, you can later opt-out of certain processing of Sensitive Personal Information if we use it or disclose it beyond certain business purposes. If applicable, we will treat your opt-out request as a complete revocation of your consent for us to process your Sensitive Personal Information.

Do Not Sell/Share/Target

Some U.S. Privacy Laws give Consumers the right to opt-out of certain data processing activities. For example, California and certain other states provide opt-outs specific to targeted advertising like “cross-context behavioral advertising.” This involves the use of your personal information from different businesses or services to target advertisements to you.

California provides Consumers the right to opt-out of Sharing, which includes providing or making available personal information to third parties for targeted advertising activities.  Other states provide Consumers the right to opt-out from processing personal information for targeted advertising.

The U.S. Privacy Laws treat the sale of personal information differently, but at a minimum, a “sale” requires providing or making available personal information to a third party.

Depending on the applicable U.S. Privacy Law, you can opt out of the Sale of, sharing of, or targeted advertising using your personal information, and it will have the effect of opting you out of the sale of, sharing of, or targeted advertising using your personal information, as follows:

  1. Opt-out for personal information: If you would like to submit a request to opt-out of our processing of your personal information (e.g., your name, address, phone number, email address) for targeted advertising, or opt-out of the sale or sharing of such data, you can make your request using one of the following methods:

          Email: info@outtengolden.com

          Phone: +1-866-772-0977

  1. Opt-out for personal information collected by cookies: You can submit a request to opt-out of our processing of your personal information collected by cookies for targeted advertising, or opt-out of the sale of or sharing of this personal information, you can exercise an opt-out request by using one of the following methods:

          Email: info@outtengolden.com

          Phone: +1-866-772-0977

In order for your election to opt-out to be effective, you must also elect your cookie preferences on each device and/or browser that you use.

Other Cookies Options

Third parties may use cookies and other tracking technologies to recognize your device and/or to collect and record information about your visits to websites, including ours. These cookies and tracking technologies may be used to maintain or enhance website experience or functionality, measure the effectiveness of ads, track page usage, track paths taken while visiting websites, and provide advertisements to you based on our interests. These third parties may provide this data to us.

Persons Under a Certain Age

We do not knowingly sell or share the personal information of Consumers under 16.

Global Privacy Control

Certain U.S. Privacy Laws require businesses to process signals sent by a platform, technology, or mechanism, enabled by you on your devices or browsers, that communicate your choice to opt-out of sale, sharing and/or targeted advertising (“GPC”), whereby the GPC communicates the requests on your behalf.

In order to take advantage of this capability, you must enable GPC. To the best of our knowledge, we have configured our Website to receive and honor GPC signals in accordance with instructions found at https://globalprivacycontrol.org.  Our Website is configure to apply GPC signals as a “Do Not Sell/Share/Target” request as to personal information collected by cookies.  You must enable GPC from every device and/or browser that you use to visit our Website.

We do not:

  1. charge a fee for use of our Website if you have enabled GPC;
  2. change your experience with our Website if you use GPC; or
  3. display a notification, pop-up, text, graphic, animation, sound, video, or any interstitial in response to the GPC.

This capabilities afforded by GPC does not extend to GPC signals for personal information collected by methods other than cookies.  For this, you will need to make a separate request in the manner outlined above.

Automated Decision Making and Profiling

We may engage in processing that constitutes automated decision-making or profiling under the CCPA. In order to detect and prevent fraud and illegal activities, we may carry out activities that constitute profiling in furtherance of decisions that produce legal or similarly significant effects. For us to protect your personal information and prevent fraudulent and illegal transactions, an opt-out of such activities is not available.

Non-Discrimination

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.  However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data.   In addition, we may offer you financial incentives for the collection, sale, retention and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels.  The material aspects of any financial incentive will be explained and described in its program terms.  Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms.  We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.

Limitation of Rights

Notwithstanding anything to the contrary, we may collect, use, and disclose your personal information as required or permitted by applicable law and this may override your CCPA rights. 

We need not honor any request to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

Additional California Notice

California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes.

Separate from CCPA “Do Not Sell” rights, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing use. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

To obtain this information, please send an email message to info@outtengolden.com with “Shine the Light Request” in the subject line.

We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

Additional Nevada Notice

Nevada Consumers have the right to instruct us not to “sell” “covered information” as those terms are defined by Chapter 603A of the Nevada Revised Statutes. Although we do not currently “sell” “covered information” of Nevada “consumers” as those terms are defined under that law, you may contact us at info@outtengolden.com and provide your name, Nevada resident address, and email address to be verified and exercise your opt-out rights in the event we do sell covered information under that law in the future. If you change your email address or other contact information, contact us in the same manner to update your contact information to help facilitate your opt-out. Changing your contact information elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada opt-out information and we will only use the information provided to our opt-out program for managing opt-outs.  It is your responsibility to keep your opt-out information current. If after opting-out you direct us to share you covered information with others, we will do so regardless of your prior opt-out.

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 us at:

          Email: info@outtengolden.com

          Phone: +1-866-772-0977

 

Updated April 26, 2024