PRIVACY POLICY

This privacy policy (this “Privacy Policy”) describes the information that Forward Counsel LLP ("Forward Counsel" or the “Firm”) collects through its website (the "Website"), and how Forward Counsel uses that information. This Privacy Policy does not apply to Forward Counsel's collection of information by any other means, including without limitation from its clients in the course of representing them. Should you ("You," or "Your") ultimately formally enter into a client-lawyerrelationship with Forward Counsel, the Firm’s obligations with respect to information that itreceives from You during the course of that relationship will be governed by applicable Rulesof Professional Conduct and other applicable law.Please review the Policy carefully. By accessing the Website, You are indicating youragreement to the Privacy Policy. The Firm reserves the right to modify the Privacy Policy at any time, withoutnotice. Such changes will be incorporated into this document and posted on the Websiteand will become effective as soon as they are posted on the Website. The current version ofthe Privacy Policy supersedes any prior versions.

Each time You use the Website, the then-current version of this Privacy Policy will apply. Accordingly, each time You visit the Website, You should check the date appearing at the end of this Privacy Policy. If that date is later than the date of Your last visit, You should review any changes to this Privacy Policy. IF AT ANY TIME YOU FIND THIS PRIVACY POLICY UNACCEPTABLE, YOU MUST IMMEDIATELY LEAVE THE WEBSITE. Unless Forward Counsel obtains Your express consent, any revised Privacy Policy will apply only to information collected by Forward Counsel after such time as the revised Privacy Policy takes effect.

  1. Information Collection

a. Personal Information.

You need not provide Forward Counsel with personally identifying information (e.g., name, telephone number, email address, city and/or state of residence) as a condition of using the Website. However, Your failure to provide certain personally identifying information when asked will prevent certain features of the Website from functioning, or will prevent Forward Counsel from effectively responding to certain of Your requests. The Website will collect only that personally identifying information that You affirmatively provide in response to a direct request.

b. Non-Personal Information.

Forward Counsel uses cookies to collect non-personally identifying information in connection with the Website. A cookie ("Cookie") is a string of information that a website stores on a user's computer, and that the user's browser provides to the website each time the user submits a query to the website. The purpose of any Cookie placed on Your computer will be to identify You as a unique user of the Website. Forward Counsel does not use Cookies to personally identify users of the Website. In addition, Forward Counsel uses common tools to automatically gather information of the sort that Web browsers automatically make available, such as the user's: (i) IP addresses; (ii) domain servers; and (iii) computer and Web browser type (collectively "Traffic Data").

c. Children.

The Website is not directed to children under thirteen years of age. It is the policy of Forward Counsel not to knowingly collect personally identifiable information children under the age of thirteen.

  1. Information Use and Disclosure

a. Personal Information.

The Website and Forward Counsel will use the personally identifying information You provide to perform the function or functions in connection with which You provide it. Forward Counsel may disclose Your personally identifying information to third parties who assist Forward Counsel in performing those functions, provided those third parties have agreed to abide by this Privacy Policy. Forward Counsel will not without your prior consent disclose Your personally identifying information to unaffiliated third parties for direct marketing. Forward Counsel reserves the right to disclose Your personally identifying information under the following circumstances: (1) when required to do so by law; (2) in response to a subpoena, court order, or other valid process; or (3) when Forward Counsel believes in its sole discretion that disclosure is necessary to protect the property or rights of Forward Counsel, third parties or the public at large.

b. Cookie Policy – Tracking Over Time and Across Different Websites

“Cookies” are text files that are placed on your computer by websites that you visit or certain emails that you open. A Cookie acts as a string of information stored on a user’s computer or mobile device, and that the user’s browser provides to the website each time the user submits a query to the website.  The purpose of a Cookie is to identify the user as a unique user of the Service.

Forward Counsel uses two types of Cookies – “first-party cookies” and “third-party cookies.”

First-Party Cookies

Forward Counsel uses first-party cookies on the Service, including but not limited to the Google Analytics Cookie, for the following purposes:

    • to gather visitor and access information relevant to customizing the Service to your interests; and

    • to store your password so you do not have to re-enter it each time you use the Service.

 IF YOU DO NOT WISH TO HAVE FIRST-PARTY COOKIES PLACED ON YOUR COMPUTER OR MOBILE DEVICE, YOU SHOULD SET YOUR BROWSERS TO REFUSE COOKIES BEFORE ACCESSING THE SERVICE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE SERVICE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF COOKIES. IF YOU REFUSE COOKIES, YOU ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Third-Party Cookies

In addition to these purposes, third party providers, including without limitation Google, Inc. (“Google”), uses third-party cookies on our site to serve online interest-based advertisements to you on other sites. As an important example, Google uses a Cookie known as “DoubleClick” to enable both Google and Google’s third-party marketing partners to serve advertisements to You based on information gathered during Your use of the Service or Your visit to other websites and services.

Forward Counsel may advertise on other third-party websites to You after You access the Website. We and third-party marketing partners, including without limitation Google, Facebook, Inc., and Twitter, Inc., may use first-party cookies (such as the Google Analytics cookie) and third-party Cookies (such as the DoubleClick cookie) to inform, optimize, and serve advertisements to You based on your use of the Website.

Google allows users to customize Cookie preferences in Google Ads Settings page. You can also learn more about how to delete or control Cookies at www.aboutcookies.org.

  1. Business Transfers; Bankruptcy

Forward Counsel reserves the right to transfer Your personally identifying information to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of Forward Counsel's assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred personally identifying information will be subject to this Privacy Policy, or to a new privacy policy if You are given notice of that new privacy policy and an opportunity to affirmatively opt out of it. Personally-identifying information submitted or collected after a transfer may be subject to a new privacy policy adopted by Forward Counsel's successor organization. 


  1. Third-Party Websites


The Website may contain links to third-party websites, possibly including those of certain Forward Counsel clients. This Privacy Policy does not apply to any information collected by those third-party websites. Before visiting or providing personally identifying information to any third-party website, You should review its privacy policy and practices, and should take those steps necessary to, in Your discretion, protect Your privacy.

  1. Ability to Access, Update, and Correct Personal Information

To confirm the completeness and accuracy of, or make changes to, Your personally identifying information on file with Forward Counsel, or if You no longer wish to receive Forward Counsel's newsletter or other materials requested from Forward Counsel, please contact Forward Counsel at info@ForwardCounsel.com.

  1. Communications Made to Third Parties by Means of the Website; Share this Page Feature

You acknowledge that any communications sent by You to third parties by means of the Website (e.g., through a "tell-a-friend" form), whether by email or otherwise, are not private, and such communications may be read by third parties with or without Your knowledge. Further, You agree that the content of any communications that You send to third parties by means of the Website shall be non-confidential and non-proprietary. Forward Counsel reserves the right to use such communication for any purpose.

The "Share this Page" feature of the Website allows You to share information about Forward Counsel by sending emails containing links to certain Website pages. If You choose the "Send this Page" feature, or similar feature, Forward Counsel will automatically send an email on Your behalf to the indicated recipient. Your name and email address will appear in the "From" line of such email, while the "Subject" line and body of the email message will explain the email's contents. Forward Counsel does not retain, share, or store any recipient email address provided in connection with the "Send this Page" feature, or similar feature.

  1. Security of Personal Information

Forward Counsel has implemented and maintains reasonable security procedures and practices to protect against the unauthorized access, use, modification, destruction, or disclosure of Your personally identifying information. 


  1. California Do Not Track Disclosures; Your California Privacy Rights

Without changing or revoking any of Your privacy protections contained in this Privacy Policy, Forward Counsel does not alter its behavior or change its services upon receiving “do not track” signals, as the term appears in Cal. Bus. & Prof. Code §§ 22575(b)(5). “Do not track” is a privacy preference that You can set in your Internet search browser thatsends a signal to a website that You do not want the website operator to track certainbrowsing information about you. However, because the Website is not configured to detect“do not track” signals from a user’s computer, we are unable to respond to Do Not Trackrequests.The California Civil Code grants residents of California the right to request certain information regarding the disclosure of personally identifiable information to third parties, if the information is used for the third-party’s direct marketing purposes. To make such a request, please contact us at info@ForwardCounsel.comwith the subject “Privacy Policy Inquiry.”

9.    Accessing the Website Outside the United States

 

If You reside outside the United States, any information that You may provide to the Firm through the Website will be transferred out of Your country and into the United States. If You do not wish for your personal information to leave Your country, please do not provide such information. By providing personal information via the Website, You expressly consent to the transfer of your information to the United States.

 

Date: January 17, 2020.

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