Michael Best Privacy Policy
Last Updated: July 19, 2024
Michael Best & Friedrich LLP and Michael Best Strategies LLC (together “Michael Best”) respects your privacy rights. We have developed this Privacy Policy (“Policy”) to describe how we collect, use, share, and protect Personal Information.
This Policy applies to data we collect in multiple ways, including when we provide legal and other professional services (“Services”), when you visit our offices, when you participate in our events, when you apply for a job, when you visit our websites: www.michaelbest.com, bestworkplacesolutions.com, michaelbeststrategies.com, and venturebest.com (collectively, our “Sites”), or when you otherwise communicate with us.
This Policy outlines our general data protection practices, including how we process Personal Information during our legal representation of clients. We balance our general data protection practices with our overarching responsibilities to our clients as described in our client agreements and communications, to protect the confidentiality of our clients and to meet our professional responsibilities under applicable laws. Providing Personal Information to us, as set forth below, does not create an attorney-client relationship. If you have questions or concerns about this Policy, please contact us.
IF YOU ARE A RESIDENT OF CALIFORNIA OR TEXAS, PLEASE SEE THE “YOUR STATE PRIVACY RIGHTS” SECTION BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU .
IF YOU ARE LOCATED IN THE EUROPEAN ECONOMIC AREA (“EEA”), SWITZERLAND, OR THE UNITED KINGDOM (“UK”), PLEASE SEE THE “YOUR EEA, SWISS, AND UK PRIVACY RIGHTS” SECTION BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.
IF YOU ARE A RESIDENT OF CANADA, PLEASE SEE THE “YOUR CANADIAN PRIVACY RIGHTS” SECTION BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.
IF YOU ARE A RESIDENT OF MEXICO, PLEASE SEE THE “YOUR MEXICAN PRIVACY RIGHTS” SECTION BELOW FOR ADDITIONAL TERMS THAT APPLY TO YOU.
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For purposes of this Policy, the terms “Personal Information” or “Personal Data” mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Personal Information excludes publicly available information or aggregated information that does not include personal data elements.
We may collect the following categories of Personal Information from or about you in connection with the operation of our organization:
Category
Examples
Retention Period
Identifiers
Your name, alias, telephone number, email address, postal address, IP address, driver’s license or state identification number, social security number and passport number.
We retain this information for so long as needed for business, legal and compliance purposes, or as provided in our engagement letter with you.
Client Records
Client records such as your name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy numbers, education, employment history, bank account numbers, credit card numbers, debit card numbers, financial information, medical information, or health insurance information.
We retain this information in accordance with our engagement letter with you. If no engagement letter exists, we retain the information for so long as needed for business, legal and compliance purposes.
Commercial Activity
Records related to Services we provide and your communications with us.
We retain this information for so long as needed for business, legal and compliance purposes or in accordance with our engagement letter with you.
Internet
Geolocation
General geographic location.
We retain this information as long as needed for the purpose for which we collected this information.
Audio, Electronic, and Video Information
Recordings for events we hold, security footage and phone or video calls for business reasons as permitted by law.
We retain this information as long as needed for the purpose for which we collect it.
Protected Classifications
Characteristics such as gender, ethnicity, veteran or military status, and citizenship.
As required by law.
Employment Information
Professional or employment-related information, including information you provide when applying for a position with us.
Educational Information
Education-related information, including information you provide when you apply for a position with us.
We collect Personal Information in the following ways:
DIRECTLY FROM YOU: We collect Personal Information directly from you as described below:
INFORMATION WE COLLECT USING TECHNOLOGY.
We collect Personal Information using technology. For instance, we use Cookies and other online tracking mechanisms on our Sites to automatically collect certain information from you when you visit our Sites. Please review the Cookie section of our Policy below for more information.
THIRD-PARTY SOURCES.
We may collect Personal Information from third-party sources as described below:
Purpose
To Communicate with You
To respond to your questions, requests, comments, or concerns
To share client alerts
To provide Services
To notify you of changes to this Policy, other terms on our Sites or similar communications
To communicate regarding our Services
To provide promotional e-mails
To keep your information current
As you request or consent
Internet Activity
Audio, Electronic, and Video
To Provide Professional Services
To communicate with you regarding your client matters
To communicate with you about Services we are providing to you or your organization
To maintain your account information
For billing and collection purposes
Business Purposes, Marketing, and Promotional Activities
To operate our business
To facilitate transactions
To inform our business strategies
To recruit employees
To administer employment and benefits
To operate our information technology systems
For marketing and advertising purposes
To notify you about upcoming events and other information about our organization
To customize content and to improve our ability to contact you
To enhance our marketing capabilities, and to inform marketing, communication plans, and strategies
For Targeted Advertising
To serve targeted advertising to you about events and information which may be of interest to you
Geolocation Information
To Perform Analytics
To improve the content of our Sites
To enhance users’ experience when visiting our Sites
To generate statistical information about Site usage and traffic patterns
To prevent fraud
Site Management
To operate the Sites and troubleshoot problems with the Sites
To improve the content and functionality of the Sites and your user experience
To improve the security of the Sites
To conduct statistical and other analyses of the Sites
For Employment Purposes
To consider you for employment
To process employee benefits
Education Information
Legal Purposes and Protection of Rights
To protect the legal rights or interests of our clients, our employees, our organization and those of third parties
To bring a legal action against you or anyone who may be causing harm to us, employees, Clients, our Sites, or to other users of the Sites
To seek business, financial, or legal advice
To respond to subpoenas, court orders, and other legal processes
In connection with business transactions
In the chart below, we explain the types of Personal Information we share or disclose, the categories of parties with whom we share or disclose such Personal Information, and the purposes for which we share or disclose Personal Information.
Entity
Category of Information
Affiliated Companies
We may share your Personal Information with our affiliates to assist in offering and providing Services.
Commercial Information
Service Providers
We disclose your Personal Information to our service providers in accordance with contracts we have with them requiring that they protect your Personal Information
To help us collect and analyze Personal Information for a Business Purpose
To help us host, operate, support and secure our Sites
To improve the content and functionality of the Sites
To provide public relations and marketing services
To provide IT services
To provide data processing services
Third Party Advertising Networks and Analytics Providers
To enable them to provide services to us
To provide us targeted advertising or analytics services
To perform data analysis and statistical analysis of our website usage and operations
To provide learning management systems
Social Media Companies
To allow you to interface with our Sites and your social media sites
Professional Advisors
To receive advice from our professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to us
Government Officials and Law Enforcement
To comply with court orders or other valid legal process
To comply with applicable laws
To enforce the policies on our Sites
To protect our clients, employees, Sites, third parties and our organization
To identify, contact, or bring a legal action against someone who may cause or be causing harm to our clients, employees, our organization or to another person, including persons who are interfering with our information technology systems and equipment, or an individual’s privacy or property
Parties to Business Transactions
If we are involved in a potential business transaction, including a due diligence process, merger, asset sale, financing, corporate divestiture, reorganization, or acquisition of all or some portion of our business to another company or if we undergo liquidation or bankruptcy proceedings, we may share your Personal Information in connection with such transaction or proceeding before and or after the transaction closes or the proceedings are completed, and we may transfer that Personal Information to be owned and used by the new owner or successor at the end of the process.
Use and Disclosure of De-Identified or Aggregated Information
We may de-identify or aggregate your Personal Information so it can no longer be used to identify you. Once we do this, the information is no longer considered Personal Information and we can use it for any lawful purpose. We will not attempt to reverse this process or attempt to re-identify you based on the de-identified or anonymized information.
CHILDREN
The Sites are not directed at, nor do we knowingly collect information from, individuals under the age of majority. If a parent or legal guardian learns that their child provided us with Personal Information without consent, please contact us and we will delete such Personal Information. For clarity, we do not knowingly sell or share the Personal Information of anyone under the age of majority without affirmative authorization. SOCIAL MEDIA We are active on social media, including Facebook, YouTube, X, and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Sites and our Social Media pages any comments or content that you post on our Social Media pages. Your use of Social Media is governed by the privacy policies and terms of the third parties that own and operate those websites and not this Policy. We encourage you to review those policies and terms. YouTube. We use the YouTube application programming interface (API) Services to allow you to access YouTube content from our Sites. Your use of YouTube is governed by YouTube’s Terms of Service and Privacy Policy, and not by our Terms of Use or Privacy Policy. We encourage you to read the YouTube Terms of Service and Privacy Policy, which are available on its website at https://www.youtube.com/t/terms.
We use commercially reasonable physical, technical, and organizational measures to help secure Personal Information against the unauthorized access to, acquisition of, loss, misuse, alteration or deletion of that information.
The Sites may link to, or be linked to, websites not maintained or controlled by Michael Best, including YouTube. Michael Best is not responsible for the privacy policies or practices of any third parties or any third-party websites. This Policy does not apply to any third-party websites, or to any personal or other information that you may provide to third parties. We encourage you to read the privacy policy for each website that you visit.
We use Cookies, web beacons, and other tracking technologies (collectively “Cookies”) when you use our Sites. A Cookie is a small text file that our Sites save onto your computer or device when you use the Sites. The Cookies allow the Sites to remember your actions and preferences and recognize you or your browser. Web beacons are small graphics on a webpage that monitor your activity when viewing a webpage. Most browsers automatically accept Cookies. You can disable this function by changing your browser settings, but disabling Cookies may impact your use and enjoyment of the Sites. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Sites. You can manually delete persistent Cookies, or Cookies that track your activity across websites, through your browser settings. We describe below some of the tools we use on our Sites to collect information, including Personal Information, for targeted advertising and analytics and how you can opt-out, customize ad preferences, or limit collection of use of Personal Information for those purposes. TARGETED ADVERTISING AND ANALYTICS We use Cookies to serve targeted advertising and perform analytics regarding use of the Site including:
For more information on how Google uses this data, visit Google’s Privacy Policy and Google’s page on How Google uses data when you use our partners’ Sites or apps. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics opt-out browser add-on will not prevent the Company from using other analytics tools and will not prevent Personal Information from being sent to the Sites or to Google.
10. YOUR CONSUMER PRIVACY OPTIONS
You have several options to limit the use of your Personal Information. OPT-OUT OF TARGETED MARKETING
Change your preferences. You may reduce the number of advertisements you receive by changing your preferences online. To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, visit the National Advertising Initiative Consumer opt-out page Opt Out - NAI: Network Advertising Initiative (thenai.org) or the Digital Advertising Alliance Self-Regulatory Program. YourAdChoices.com | Consumer Assistance | WebChoices, AppChoices and YourAdChoices. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opt-out of marketing emails. If you Opt-In to receive marketing communications from us, we will collect your name, email, mailing address, and phone number. We use this information to send you promotional and other electronic and hardcopy communications. We may use third-party providers to deliver communications to you. You may Opt-Out of such emails by using the unsubscribe link in the email or contacting us at Privacy@michaelbest.com with “Unsubscribe” in the subject line. To Opt-Out of other communications (e.g. postal marketing), please contact us by phone, e-mail or mail using the contact information below. Opting Out of marketing communications does not opt you out of non-marketing communications.
We may update this Policy at any time. All changes will be effective immediately upon posting to the Sites. We will notify you of such updates by posting a notice at the top of the Policy or the Sites or communicating to you in another manner.
12. YOUR STATE PRIVACY RIGHTS
This Section 12 provides additional terms that apply only to residents of California and Texas. In the event of a conflict between this Section 12 and the remainder of this Policy, this Section 12 shall take precedence for California and Texas residents. Capitalized terms in this section that are not defined elsewhere in this Policy have the definitions set forth in the California Consumer Privacy Act (“CCPA”) or Texas Data Privacy and Security Act (“TDPSA”), as applicable.
ADDITIONAL INFORMATION ABOUT OUR PROCESSING We do not sell Personal Information for monetary compensation. In the last 12 months, we have shared the following categories of Personal Information with certain third parties for targeted advertising and analytics. See the section above titled “Categories of Personal Information We Collect” for more detail on the type of Personal Information in each category.
In the last 12 months, we have disclosed the following categories of Personal Information to our service providers for business purposes. See the section above titled “Categories of Personal Information We Collect” for more detail on the type of Personal Information in each category.
YOUR CONSUMER PRIVACY RIGHTS.
Subject to certain exceptions, residents of California and Texas have the following additional privacy rights: Right to Know If you are a California resident, once we have verified your information, we will provide the following at your request (subject to some limitations):
If you are a Texas resident, once we have verified your request, we will confirm whether we are processing your Personal Information and allow you to access that Personal Information.
Right to Delete You have a right to request that we delete the Personal Information we collect from or about you. Right to Correct Your Information You have a right to request that we correct your inaccurate Personal Information. If you request that we correct inaccurate Personal Information about you, we will use commercially reasonable efforts to correct it. If necessary, we may ask that you provide documentation showing that the information we retained is inaccurate.
Please note, we may choose to delete the Personal Information you have requested to correct as an alternative to correcting it, if doing so would not negatively impact you or with your consent. Right to Data Portability You may request a copy of the Personal Information you previously provided to us in a portable form and, to the extent technically feasible, readily usable format. Right to Non-Discrimination You have a right to not receive discriminatory treatment for exercising any of your rights.
HOW TO EXERCISE YOUR CALIFORNIA OR TEXAS PRIVACY RIGHTS If you are a resident of California or Texas, you may exercise your privacy rights by submitting your request to us:
Who May Exercise Your Rights. You or a person that you authorize to act on your behalf, may exercise your data privacy rights. See the section titled "Authorized Agents" below for more information. Verifiable Consumer Request. You must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.
We will use the information we already have about you to verify your identity. However, depending on the sensitivity and value of the data, the risk of harm, the likelihood of fraud, and similar considerations, we may ask you to provide additional information to confirm your identity, including Personal Information. We will only use Personal Information we collect from you during the verification process for the purpose of verifying your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request and let you know why. Authorized Agents. You may submit a request to exercise your rights through an authorized agent – another person you authorize to act on your behalf.
California requires that, if you submit a rights request through an agent, you must (a) provide signed, written permission that authorizes the agent to submit requests on your behalf and (b) verify your identity directly with us or (c) directly confirm with us that you granted permission to the authorized agent to submit the request on your behalf. For clarity, if you are a California resident, you are required to verify your identity and the identity of your authorized agent.
We may deny a request from an authorized agent if we do not have proof that you authorized them to act on your behalf. When We Will Respond. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide to California residents will only cover the 12-month period preceding our receipt of your request.
RIGHT TO OPT-OUT OF TARGETED ADVERTISING
You have the right to opt-out of targeted advertising. This means you can request that we do not share your Personal Information with third parties for targeted advertising purposes. In addition to opt-out methods listed in Section 10, “Your Consumer Privacy Options,” you may opt-out:
Additionally, you may opt-out of the sale or sharing of your Personal Information by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
RIGHT TO APPEAL FOR TEXAS RESIDENTS
If you are a Texas resident and we deny your rights request, you have the right to appeal. You must submit your appeal within 60 days of your receipt of our denial:
We will acknowledge your appeal when we receive it. Within 60 days of receiving your appeal, we provide a written explanation of our decision and the reasons for our decision.
If you disagree, you may submit an appeal to the Texas Attorney General’s office online or by calling the Consumer Protection Hotline at 1-800-621-0508. SHINE THE LIGHT Pursuant to California Civil Code Section 1798.83, if you are a California resident you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by contacting us per the “Contact Us” section above.
We are based in the United States. We may transfer your Personal Information to the United States in connection with the operation of our business. To assist us in meeting our operational and legal obligations, we may also transfer or make your Personal Information accessible to one of our service providers located either in the United States or throughout the world.
The terms in this section are only applicable to those located in the EEA, Switzerland, and the UK.
The purpose of this Section is to provide information and additional provisions that apply to Michael Best’s processing of Personal Data in accordance with the EU General Data Protection Regulation 2016/679, the UK General Data Protection Regulation and the Swiss Federal Data Protection Act (collectively the “GDPR”). In the event of a conflict between this section and the remainder of the Policy, this section shall control for those persons located in the EEA, Switzerland, or the UK.
Legal Basis for Processing
When Michael Best processes your Personal Data, it has one of the following legal bases for doing so as required under GDPR: (a) it has received your express opt-in consent for such processing (“Consent”), (b) the processing is necessary for performance of a contract (“Contract”), (c) the processing is necessary for a legal obligation to which Michael Best is subject (“Legal Obligation”), (d) the processing is necessary to protect the vital interests of the data subject (“Vital Interest”), (e) the processing is necessary for a task carried out in the public interest (“Public Interest”), or (f) if Michael Best or a third party has a legitimate interest that is not overridden by the interests or fundamental rights and freedoms of the data subject (“Legitimate Interest”). We have set out the purpose and legal bases for which we process Personal Data below:
Right To Withdraw Consent
In the event you provide your consent for us to process your Personal Data, you may withdraw your consent.
Additional Privacy Rights
You also have the following privacy rights under GDPR:
To exercise the above rights, please submit a request by contacting us at:
Email: Privacy@michaelbest.com Webform: https://privacyportal-uk.onetrust.com/webform/d62d448c-a576-4b12-91c8-0a4f7e10689d/db3dd28d-14a9-4a81-855d-f8bc032df4ae Phone: (262) 956-6560
Mailing Address: Michael Best Attention: Privacy Two Riverwood Place N19 W24133 Riverwood Drive, Suite 200 Waukesha, WI 53188
The terms in this section are only applicable to Canadian residents.
Your Canadian Privacy Rights. Under Canadian privacy laws, you have rights related to your Personal Information, subject to identity verification requirements and certain exceptions.
Right to Access. You have the right to confirm that we hold Personal Information about you, receive an explanation about how we use your Personal Information, and obtain access to your Personal Information.
Right to Rectification. You have a right to examine and challenge the accuracy and completeness of your Personal Information, and have your Personal Information amended where appropriate.
Right to Withdraw Your Consent. You have the right to withdraw your consent to processing your Personal Information at any time, subject to legal or contractual restrictions and reasonable notice. If your withdrawal of consent implicates the quality of our services to you, we will notify you.
Right to Complain to a Data Protection Authority. You also have the right to lodge a complaint regarding the processing of your Personal Information with the applicable data protection authority. Please contact your local data protection authority for more information.
How to Exercise Your Rights. To exercise your rights described in this section, you may submit your request to us:
ADDITIONAL TERMS APPLICABLE TO QUEBEC RESIDENTS ONLY
If you are resident of Quebec, Quebec law provides you with additional rights regarding the use of your Personal Information, subject to identity verification requirements and certain exceptions.
Right to Restriction of Processing. You have a right to direct us to cease disseminating your Personal Information or to de-index any hyperlink attached to your name that provides access to the information by a technological means, if the dissemination of the information contravenes the law or a court order.
Right to Request Deletion. You have a right to request that we delete Personal Information we collected from you. We will comply with such requests, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.
Right to Portability. You may request copies of the Personal Information you have provided to us. Where possible, we will deliver the copy of your Personal Information to you using a structured, commonly used, and machine-readable format. Alternatively, you may request that we send your Personal Information to another business.
Translations. This Policy may be provided in several languages. In the event of conflict or inconsistency, the English language version of this Policy controls, unless otherwise required by applicable law. En cas de conflit ou d'incohérence, la version anglaise de cette politique de confidentialité contrôle, sauf si la loi applicable l'exige.
The terms in this section are only applicable to residents of Mexico. If you are a resident of Mexico, you have the following additional rights under the Federal Law on Protection of Personal Data Held by Individuals (“LFPD”), subject to identity verification requirements and certain exceptions.
Right to Access. You have the right to obtain access to your Personal Data and receive an explanation about how we use your Personal Data.
Right to Rectification. You have a right to request, at any time, that we correct your Personal Data if it is inaccurate or incomplete.
Right to Cancel. You have the right to cancel your Personal Data when you deem it is not required for the purposes established in this Policy or that it is being used for unauthorized purposes and to oppose the processing of your Personal Data for certain specific purposes.
You may exercise these rights:
We will respond to your petition within a reasonable amount of time and inform you of its outcome through the phone number and/or email address you provide.
Right to Complain to a Data Protection Authority. You also have the right to file a complaint with the Federal Public Information Access Institute at www.ifai.org.mx.
If you have any questions, you may contact us as set forth below:
Any information you convey to Michael Best & Friedrich LLP via the internet may not be secure, and any information conveyed prior to establishing an attorney-client relationship may not be privileged or confidential. The establishment of an attorney-client relationship requires prior satisfaction of multiple factors, including resolution of conflicts and mutual agreement on the terms of the engagement. Before speaking with a Michael Best attorney, please do not convey any more information than is reasonably necessary to describe generally the matter, and to identify the adverse parties. Please do not convey any information you deem as confidential. Please click the “Accept” button below to confirm that you understand and accept the foregoing statement and wish to proceed in sending a message. Michael Best & Friedrich LLP - Email Disclaimer