Privacy Policy

Frblaw.com (our “Website”) is provided by Falcon Rappaport and Berkman LLP (“FRB,” the “Firm”, “We” or “Us”). FRB respects your privacy. As professionals engaged in the practice of law, the Firm is committed to protecting the privacy of confidential and Personal Information (as defined below) through our compliance with this website privacy policy (this “Privacy Policy”). It has always been and remains the policy of the Firm to comply with the rules of professional conduct applicable in all jurisdictions where our attorneys practice law, which impose a duty to preserve and protect confidential information upon lawyers and their associated personnel.

This Privacy Policy describes the types of information that We may collect from you or that you may provide when you interact with Us, including but not limited to when you call our offices, visit our Website, or visit our official social media pages, such as Facebook, X (formerly Twitter), LinkedIn and other social media platforms (collectively, our “Platforms”). This Privacy Policy also describes our practices for collecting, using, maintaining, transmitting, protecting, and disclosing such information. We implement this Policy in light of our obligations to comply with applicable law, preserve client confidentiality, and to represent our clients as effectively as possible within the bounds of the law.

This Privacy Policy applies to information We collect:

In email, text, and other electronic messages between you and the Firm or through links to our Website;
In phone calls with the Firm;
When you attend online or in person events sponsored by the Firm;
When you interact with our advertising and features on (i) our Website, or (ii) third-party websites, applications, and services if those websites, applications, or services include links to this Privacy Policy or our Website.

This Privacy Policy shall not apply to information collected by:

Us offline or through any other means, including, without limitation, on any other website operated by any third party; or
Any third party, including information collected by any third party through any application or content that may link or be accessible from or on our Website.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOU DO NOT HAVE OUR PERMISSION TO USE OUR WEBSITE. BY ACCESSING OR USING OUR WEBSITE, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY. WE MAY UPDATE, REVISE OR MODIFY ALL OR A PORTION OF THIS PRIVACY POLICY FROM TIME TO TIME (SEE CHANGES TO OUR PRIVACY POLICY — SECTION IV OF THIS PRIVACY POLICY). YOUR CONTINUED USE OF OUR WEBSITE AFTER WE MAKE SUCH UPDATES, REVISIONS OR MODIFICATIONS IS DEEMED TO BE ACCEPTANCE OF SUCH UPDATES, REVISIONS OR MODIFICATIONS; SO, IT IS IMPERATIVE THAT YOU CONSULT THIS PRIVACY POLICY PERIODICALLY FOR UPDATES.

1. Websites Covered by this Privacy Policy.

(a) This Privacy Policy covers both our Website and our Platforms.

(b) Our Website may from time-to-time link to third party websites for your convenience and to provide easy access to additional useful information. Should you select such a link, you will leave our Website. We do not control those sites nor their privacy practices, which may differ from our practices and policies, including but not limited to this Privacy Policy. Any personal data you choose to provide or that is collected by such third parties is not in any way covered by this Privacy Policy. We recommend that you read over such a website’s privacy policy before providing any personal information. A link to another website from Us does not constitute an endorsement or representation about the value, quality, or usefulness of anything found on that third-party website.

(c) PLEASE BE AWARE THAT IF YOU ELECT TO HAVE US SHARE YOUR INFORMATION WITH THIRD PARTIES, THOSE ELECTIONS TO HAVE YOUR INFORMATION SHARED WILL SUPERSIDE ANYTHING TO THE CONTRARY IN THIS PRIVACY POLICY.

2. Changes to this Privacy Policy.

(a) We reserve the right to amend this Privacy Policy at our discretion and at any time. It is our policy to post any changes we make to this Privacy Policy on this page with a notice that this Privacy Policy has been updated on the Website home page. If We make material changes to how We treat our users’ Personal Information (as defined below), We will notify you by email to the primary email address specified in your account and/or through a notice on our Website home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring We have an active, up-to-date, and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

(b) PLEASE NOTE THAT FOR CALIFORNIA RESIDENTS THE CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”) AS REVISED BY THE CALIFORNIA PRIVACY RIGHTS ACT (“CPRA”) WILL GOVERN OUR USE AND YOUR RIGHTS WITH REGARD TO YOUR PERSONAL INFORMATION.

3. Contact Information. You have the right to request information with respect to the types of Personal Information We share with third parties and the identities of the third parties with whom We have shared such information during the immediately preceding calendar year. To obtain this information, please submit a request via email to info@frblaw.com. Please allow in excess of thirty (30) days for a response.

4. Collection and Use of Personal Information.

(a) The Firm collects several types of information (1) when you interact with us or review materials we publish; (2) to gather information about our legal services or to consider engaging us to provide you legal services; (3) when we provide services to the Firm’s clients and (4) from and about users of our Website when you access our Website, depending on the context of your interactions with Us and our Website, including information:

(i) By which you may be personally identified, such as: name, e-mail address, telephone number, gender, mailing address, ZIP code/postal code, or other additional information supplied to you, by which you may be contacted online or offline.

(ii) Necessary to process your payment if you pay for legal services, including payment details such as your payment instrument number (i.e., a credit card number), and the security code associated with your payment instrument, collected in connection with payment for legal services. All payment data is stored after tokenizing your account or collected in connection with your historical use of the Firm for legal services.

(iii) If you call, email, text, or chat with Us, We may keep records of those conversations.

(b) We collect this information:

(i) Directly from you when you provide it to Us; and

(ii) Automatically as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies.

(i) Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website and/or services requested; and

(ii) Records and copies of your correspondence (including email addresses and related contact information) if you contact Us.

(d) Your information may be aggregated with other clients’ information on a purely non-identifiable basis to understand how our services are used, to improve our services. Credit card information is used solely for payment processing and fraud prevention efforts. Credit card information, and other sensitive personal information, is not used for any other purposes by use or our financial services providers.

(e) Information We Collect Through Automatic Data Collection Technologies.

(i) As you navigate through and interact with our Website, We may use automatic data collection technologies, including artificial intelligence (“AI”) technologies, to collect certain information about your equipment, browsing actions, and patterns, including:

(A) Details of your visits to our Website, including traffic data, location data, logs, and other communication data, and the resources that you access and use on our Website; and

(B) Information about your device and internet connection, including your IP address, operating system, and browser type.

(ii) The information We collect automatically is only statistical data and does not include Personal Information that We collect in other ways or receive from third parties. It helps Us to improve our Website and to deliver a better and more personalized service, including by enabling Us to:

(A) Estimate our audience size and usage patterns; and

(B) To protect our services. We may use your information as part of our efforts to keep our Website safe and secure (e.g., for fraud monitoring and prevention).

(iii) The technologies We use for this automatic data collection may include:

(A) Cookies (or Browser Cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. These technologies are able to store a unique identifier for a device to allow a certain internet sites to recognize the device whenever the device is used to visit a site. These technologies may be used for many purposes by Us and our third-party service providers, such as automatically collecting data about how individuals interact with a website, application, service, or device (“Usage Information”), enabling features, remembering your preferences, and providing you with targeted advertising elsewhere online. If you do not want to accept cookies, you can block them by adjusting the settings on your internet browser. You can find more information about cookies and how they work at www.allaboutcookie.org.

(B) Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

(C) Web Beacons. Pages of our website may contain small electronic files known as web beacons (also referred to as clear gifts, pixel tags, and single-pixel gifts) that permit the Firm, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

(D) Web Browsers. Certain browsers, or browser add-ons, may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Website may make use of this local storage.

(E) Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with our Website, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected and is deactivated or deleted thereafter.

(f) We do not collect Personal Information automatically, but We may tie this information to Personal Information about you that We collect from other sources, or you provide to Us.

(g) Third Party Use of Cookies and Other Tracking Technologies.

(i) Some content or applications on our Website are served by third parties, including, without limitation, advertisers, advertising networks and servers, content providers, and application providers (each, a “Third-Party Data Collector”). The Third-Party Data Collector may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information a Third-Party Data Collector collects may be associated with your personal information, or your online activities over time, across external websites and other online services. A Third-Party Data Collector may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

(ii) We do not control the tracking technologies of any Third-Party Data Collector nor how information collected by any Third-Party Data Collector may be used. If you have any questions about an advertisement or other targeted content, you should contact the relevant Third-Party Data Collector directly.

(h) Do We Collect Information From Minors? Our Platforms are general audience points of contact and are not directed at children under the age of thirteen (13) years of age. Further, We do not knowingly solicit data from our market to children under eighteen (18) years of age. By using our Website, you represent that you are at least eighteen (18) years of age or that you are the parent or guardian of such a minor and have consented to such a child’s direct use of our Website.

5. How We Use Your Personal Information.

(a) We may use your Personal Information We collect about you or that you provide to Us where it is in our legitimate interest to do so for the following purposes:

(i) To contact you and respond to your requests and inquiries.

(ii) To present our Website and its contents to you and to carry out, monitor, and analyze our business or our Website operations;

(iii) To provide you with information or legal services that you request from Us, if you are or become a client of the Firm, and otherwise deal with you, and administer the matters you instruct Us on;

(iv) To contact you (unless you tell Us that you prefer Us not to) regarding legal or law firm developments that may be of interest to you;

(v) To enter into or carry out contracts of various kinds;

(vi) To carry out our obligations and enforce our rights arising from any contracts entered into between you and Us, including for billing and collection;

(vii) To comply with applicable laws, regulations, guidance or professional obligations that We may be subject to, including but not limited to anti-money laundering requirements. Where Personal Information is necessary for the Firm to carry out its anti-money laundering checks, failure to provide such information may result in the Firm not being able to provide the representation;

(viii) To notify you about changes to our Website or any services We offer or provide through it;

(ix) To detect, prevent, and remediate fraud or other potentially prohibited or illegal activities; and/or

(x) For any other purposes with your consent.

(b) Credit Cards/Electronic Payments. Credit card and electronic payment information is used solely for payment processing and fraud prevention efforts. Credit card information, and other sensitive personal information required to process a credit card decision, is not used for any other purposes by Us or our financial service providers and will not be retained any longer than necessary to provide our services to you.

6. Confidentiality and Security of Personal Information. It has always been the policy of the Firm to exercise the utmost discretion regarding the information our clients entrust to Us.

(a) We maintain reasonable and appropriate (but not infallible) physical, electronic and procedural safeguards intended to maintain the confidentiality of and protect and secure from accidental loss and/or unauthorized access, use, alteration and disclosure of your Personal Information, including those provided by a visitor or user of our Website and provided while using our other Platforms. We require consultants, suppliers and vendors to maintain data protection consistent with reasonable and appropriate obligations of data processors, including, where applicable, the European Union’s data protection laws and regulations.

(b) However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be one hundred percent (100%) secure. Although We do our best to protect your Personal Information, We cannot guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information transmitted to our Website. Although We will do our best to protect your Personal Information, any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website. You should only access our Website within a secure environment.

7. Disclosure and Transfer of Personal Information.

(a) We do not disclose any Personal Information to any parties outside the Firm except in limited circumstances. Such limited circumstances include:

(i) Disclosures to our agents or data processors or other contractors acting on our behalf and at our discretion, subject to appropriate confidentiality, privacy and information security commitments provided by the receiving party;

(ii) Where we believe it necessary to provide a service which you have requested;

(iii) As permitted or required by law; or

(iv) As otherwise authorized or directed by you.

(b) We may provide Personal Information to regulatory authorities and law enforcement officials in accordance with applicable law or when We otherwise believe, in good faith, that the provision of such information is required or permitted by law (i.e., in connection with the investigation or assertion of our legal defenses or for our compliance matters).

(c) As a nationwide law firm, We operate systems that may make data related to your matters accessible from our various offices around the United States and often transfer client data, which may include Personal Information, between our offices.

8. Cookies.

(a) To facilitate and customize your experience with our Website, We may store cookies on your computer. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes which contains information about that user. Cookies can be categorized as session cookies or persistent cookies. Session cookies, unlike persistent cookies, are temporary and expire and are normally deleted when you close your browser. Persistent cookies remain stored on your computer after you close your browser until either (i) you delete them manually or (ii) they expire. We use both session and persistent cookies. We use session management cookies that maintain user sessions during navigation and security-related cookies to protect against cross-site request forgery (CSRF) and other threats. We use persistent cookies to remind Us who you are. Use of this information helps Us to detect and remember your region and language preferences, and track your activities on our Platforms. These tracking scripts are not used to gather information on your use of the internet unrelated to the Firm, and they do not identify you unless you choose to provide Personal Information to the Firm.

(b) Although the Firm uses the services of third parties in connection with these cookies, We do not allow the third-party service provider to use Personal Information about the users of our Platforms. Any information collected by Us or by third parties through the use of cookies or similar technologies may be linked with other information We collect about you. We have no access to or control over these cookies.

(c) None of these cookies are strictly necessary to access our Platforms. You may reset your browser to refuse all cookies or to allow your browser to alert you when a cookie is set; however, certain parts of our Platforms may function differently and not as well. Unless you have adjusted your browser setting so that it will refuse cookies, our Platforms will issue cookies when you interact with our Platforms. This Privacy Policy covers the use of cookies by our Website only and does not cover the use of cookies by any advertiser or other third party. To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/.

9. Analytics. Visitors to our Website who have JavaScript enabled are tracked using Google Analytics. Google Analytics may collect some or all of the following types of information from you: type of user agent (web browser) used, software manufacture and version number; type of operating system; color processing ability of your screen; JavaScript support; Flash version; screen resolution; network location; IP address; country, city, state, region, county, or any other geographic data; hostname; bandwidth (internet connection speed); time of visit; pages visited; time spent on each page of our Website; referring site statistics; the website URL you came through in order to arrive at our Website; or search engine query used to find our Website. This data is primarily used to optimize our Website for our visitors and for internal marketing purposes.

10. Other Tracking Devices. We may use other industry standard technologies like pixel tags and web beacons to track your use of our Website. Pixel tags and web beacons are tiny graphic images placed on certain pages on our Website, or in our emails that allow Us to determine whether you have performed a specific action. When you access these pages or open or click an email, pixel tags and web beacons generate a notice of that action. Pixel tags allow Us to measure and improve our understanding of visitor traffic and behavior on our Website, as well as give Us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our affiliates and/or partners for the same purposes.

11. Controls for Do-Not-Track Features. Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, We do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that We must follow in the future, We will inform you about that practice in a revised version of this Privacy Policy. Our Website operates no differently if these DNT signals are enabled or disabled. Our Platforms do not allow any third parties to collect Personal Information about your online activities over time or across websites for their own purposes.

12. Interaction with our Platforms.

(a) Social Networking Features. Functionality on our Website and our Platforms may permit interactions between our Website or our Platforms and a third-party service such as Facebook or Instagram (“Social Networking Features”). Examples of Social Networking Features include enabling you to “Like” or “Share” content from our Website or our Platforms or to “Like” or “Share” our Website or our Platforms on a third-party service; to automatically or selectively show your social media posts on our Platforms; and to otherwise connect our Platforms to a third-party service. If you choose to share content or to otherwise post information on our Platforms, that information may be publicly displayed. Similarly, if you post information on a third-party service that references Us (for example, by using a hashtag associated with Us in your post), your post may be published on our Platforms or otherwise in accordance with the terms of that third party. Also, both We and the third party may have access to certain information about you and your use of our Platforms and the third-party service. These third-party social networking companies may collect information about your visit to our Platforms through the Social Networking Features We have integrated into each given Platform and, if you are signed into your account with such a third-party social networking company, it may collect additional information in accordance with the terms of your agreement with such third party. In addition, We may receive information about you if other users of a third-party service give Us access to their profiles and you are one of their “Connections” or information about you is otherwise accessible through your profile or similar page on a social networking or other third-party service. The information We collect in connection with Social Networking Features is subject to this Privacy Policy. The information collected and stored by any third party remains subject to such third party’s privacy practices, including whether such third party continues to share information with Us, the types of information shared, and your choices with regard to what is visible to others on that third-party service.

(b) All personal information that you provide to Us must be true, complete, and accurate, and you must notify Us of any changes to such personal information.

(c) Employment Applications. If you apply for a job through our Website or our Platforms, We or our service provider(s) may ask you to provide self-identifying information (such as veteran status, gender, and ethnicity) in conjunction with laws and regulations enforced by, as applicable, the Equal Employment Opportunity Commission and other federal, state, provincial/territorial, and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, We and/or our service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints.

13. Your Privacy Choices.

(a) You can control the information We collect and use in the following ways:

(i) Location Information. You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Website from accessing your location information.

(ii) Emails. You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that We send or by contacting Us using the details provided below. You will then be removed from the marketing email list, however, We may still communicate with you, for example, to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out you may contact Us using the contact information provided.

(iii) Online Advertising. For information about opting out of third-party advertising, visit: NAI Opt-Out (http://www.aboutads.info/choices/) and DAA Opt-Out (http://optout.networkadvertising.org/?c=1) (you will leave our Website for a separately managed online site where you can specify your preference under those programs). You can also click on the icon that may appear on some of our advertising provided through these technologies. We may use more than one third party company for placing this advertising, which would require you to opt out of each company.).

(b) Based on the applicable laws of your country, you may have the right to request access to the Personal Information We collect from you, change that information, or delete it in some circumstances. To request review, update, or delete your Personal Information, please email Us at info@frblaw.com/.

(c) If you are a resident of the State of California, you can learn more about your privacy rights below in our California Privacy Rights Notice annexed hereto as Exhibit A.

EXHIBIT A

CALIFORNIA PRIVACY RIGHTS NOTICE

Additional Notice for California Residents

This Privacy Notice for California Residents (this “Notice”) supplements the information contained in the privacy policy (the “Privacy Policy”) of Falcon Rappaport and Berkman, LLP (the “Company”, “We” or “Us”), and applies solely to all visitors, users, and others who reside in the State of California (“Consumers” or “You”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2023 (“CPRA”) and any capitalized terms not defined herein shall have the meanings ascribed to same in the CCPA and CPRA.

This Notice does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B Personal Information”) from some its requirements.

The CCPA permits our users who are California residents to request and obtain from Us, once a year and free of charge, information about categories of personal information (if any) We disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which We shared personal information in the immediately preceding calendar year. If You are a California resident and would like to make such a request, please submit your request in writing to Us using the contact information provided below.

If You are under eighteen (18) years of age, reside in California, and have a registered account with the Company’s website, frblaw.com (our “Website”), You have the right to request removal of unwanted data that You publicly post on our Website. To request removal of such data, please contact Us using the contact information provided below, and include the email address associated with your account and a statement that You reside in California. We will make sure the data is not publicly displayed on our Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

Definition of “Resident”.
1. The California Code of Regulations defines a “Resident” as:
  1. Every individual who is in the State of California for other than a temporary or transitory purpose; and
  2. Every individual who is domiciled in the State of California but who is outside the State of California for a temporary or transitory purpose.
2. All other individuals are defined as “Non-Residents”
3. If this definition of “Resident” applies to You, We must adhere to certain rights and obligations regarding your personal information.
Sharing Personal Information.
1. We may disclose your personal information to a third party for a business purpose. When We disclose personal information for a business purpose, We require the recipient to both keep that personal information confidential and not use it for any purpose except for use in connection with performing the services on our behalf. The CCPA prohibits third parties who obtain the personal information We hold from reselling it unless You have received explicit notice and an opportunity to opt-out of further sales. We may disclose your personal information with our service providers pursuant to a written contract between Us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
2. We may use your personal information for our own business purposes. This is not considered to be “Selling” of your personal data.
3. We may use or disclose the personal information We collect for one or more of our business purposes in our Privacy Policy or as otherwise set forth in the CCPA. We will not collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes without providing you notice.
4. The Firm discloses the following categories of personal information for a business purpose:
  1. Identifiers.
  2. California Customer Records.

Personal Information Categories.

Commercial information.
Internet or other Electronic Network Activity Information (i.e., browsing history and information regarding a consumer’s interaction with our Website).
Geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties:
1. Our affiliates; and
2. Third parties to whom You authorize Us to disclose your personal information in connection with the products or services We provide to You.
CCPA Rights. The CCPA provides consumers who are California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights:
1. Access to Specific Information and Data Portability Rights. You have the right to request that We disclose certain information to You about our collection and use of your personal information over the past twelve (12) months. Once We receive and confirm your verifiable consumer request (see Section 4 of this Notice), We will disclose to you:
  1. The categories of personal information We collected about You;
  2. The categories of sources for the personal information We collected about You;

Our business or commercial purpose for collecting or selling that personal information;

The categories of third parties with whom We share that personal information;
The specific pieces of personal information We collected about You (also called a data portability request); and
If We sold or disclosed your personal information for a business purpose, with two separate lists disclosing:
1. Identifying the personal information categories that each category of recipient purchased; and
2. Disclosures for a business purpose. Identifying the personal information categories that each category of recipient obtained. We do not provide access and data portability rights for B2B Personal Information.
Deletion Request Rights. You have the right to request that We delete any of your personal information that We collected from You and retained, subject to certain exceptions. Once We receive and confirm your verifiable consumer request (see Section 4 of this Notice), We will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for Us or our service provider(s) to:
1. Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with You;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

Debug products to identify and repair errors that impair existing intended functionality;

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if You previously provided informed consent;

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Us;
Comply with a legal obligation; and

Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

Exercising Access, Data Portability, and Deletion Rights.
1. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Us by emailing Us at info@FRBLaw.com.
2. Only You, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period.
3. The verifiable consumer request must:
  1. Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative thereof.
  2. Describe your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide You with personal information if We cannot verify your identity or authority to make the request and confirm the personal information relates to You. You do not need to create an account with Us to submit a request to know or delete. However, We do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it. If, however, We cannot verify your identity from the information already maintained by Us, We may request that You provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as We finish verifying You. For instructions on exercising your sale opt-out or opt-in rights, see Section 4(e) of this Notice.
4. Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time (up to ninety (90) days), We will inform You of the reason and extension period in writing. If You have an account with Us, We will deliver our written response to that account. If You do not have an account with Us, We will deliver our written response by mail or electronically, at your option. Any disclosures We provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell You why We made that decision and provide You with a cost estimate before completing your request.
5. Personal Information Sales Opt-Out and Opt-In Rights. If You are sixteen (16) years of age or older, You have the right to direct Us not to sell your personal information at any time (the “Right to Opt-Out”). We do not sell the personal information of consumers We actually know are less than sixteen (16) years of age, unless We receive affirmative authorization (the “Right to Opt-In”) from either the consumer who is at least thirteen (13) but not yet sixteen (16) years of age, or the parent or guardian of a consumer less than thirteen (13) years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the Right to Opt-Out, You (or your authorized representative) may submit a request to Us by emailing us at info@frblaw.com. Once You make an opt-out request, We will wait at least twelve (12) months before asking You to reauthorize personal information sales. However, You may change your mind and opt back into personal information sales at any time by amending your preferences in an email to Us at info@frblaw.com. You do not need to create an account with Us to exercise your Right to Opt-Out or Right to Opt-In. We will only use personal information provided in an opt-out request to review and comply with the request.
6. In accordance with applicable law, We are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights.
1. We will not discriminate against You for exercising any of your CCPA rights. Unless permitted by the CCPA, We will not:
  1. Deny You services;
  2. Charge You different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;

Provide You a different level or quality of services;

Suggest that You may receive a different price or rate for services or a different level or quality of services.

However, We may offer You certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive We offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which You may revoke at any time.

CCPA Rights Request Metrics. Metrics regarding the consumer rights requests We received from California residents from January 1, 2024 to December 31, 2024 appear in the following chart:

Request Type: [Right to Know]

[Right to Delete]

[Right to Opt-Out]

Received: 0

Granted (in whole or in part): 0

Denied: 0

Median Days to Respond: 0

Requests to Know: 0

Unverifiable: 0

Not by a California Resident: 0

Called for Information Exempt From Disclosure: 0

Denied on Other Grounds: 0

Requests to Delete: 0

Requests to Opt-Out of Personal Information Sales: 0

Other California Privacy Rights. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@frblaw.com.
Changes to this Notice. We reserve the right to amend this Notice at our discretion and at any time. When We make changes to this Notice, We will post the updated notice on our Website and update the Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

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