Information Collected on the NeoPangea Site
Personally Identifiable Information
The majority of the information provided by NeoPangea on the NeoPangea Site is available to you without NeoPangea collecting any information that is identifiable to you as an individual such as your name, email address, street address or telephone number (Personally Identifiable Information). You can review almost the entire NeoPangea Site without disclosing any Personally Identifiable Information. However, NeoPangea does collect Personally Identifiable Information that you may provide voluntarily. Some examples of times when NeoPangea collects Personally Identifiable Information include when you:
- contact us via the contact portal on the NeoPangea Site
- ask us about employment opportunities and send us your resume or other employment experience information
- complete a survey
- sign up to receive our newsletter
- send us an e-mail message
You have a choice as to whether to provide NeoPangea with any Personally Identifiable Information. Although you are not required to disclose any Personally Identifiable Information to us, portions of the NeoPangea Site may not be available to you without your providing this information.
THE NEOPANGEA SITE IS NOT INTENDED FOR USE BY MINORS. ACCORDINGLY, WE DO NOT REQUEST ANY PERSONAL INFORMATION FROM MINORS. MINORS SHOULD NOT POST ANY PERSONAL INFORMATION TO THE NEOPANGEA SITE.
How We Protect Your Personal Information
We implement a variety of security measures to maintain the safety of your personal information. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, while we strive to protect your personal information, we cannot guarantee or warrant the security of any information you transmit to us, or to or from our online products or services. You transmit all such information at your own risk.
Non-Personally Identifiable Information
The second type of information collected on the NeoPangea Site is Non-Personally Identifiable Information, such as the type of Web browser you use, your domain name and links you may have used to locate the NeoPangea Site, but which otherwise does not identify you individually. When you visit an Internet site, you disclose certain information about yourself, such as your Internet [Protocol] (IP) address, browser type, the time of your visit, and the referring location (e.g., the site page that offered a link to our Site page). Other information disclosed includes clickstream data, which includes a record of the clicked selections you make while visiting the NeoPangea Site. This data does not, on its own, permit direct association with a specific individual.
How We Use the Information Collected
NeoPangea uses any Personally Identifiable Information you provide in a limited number of ways. We may use your Personally Identifiable Information to (i) provide you with information about NeoPangea and its services or (ii) enhance or update the NeoPangea Site or (iii) compile demographic statistics about users of the NeoPangea Site. We may also, on occasion, combine information about you that we have with information we obtain from other parties to enhance our ability to provide you with information about NeoPangea and its services that we think may be of interest to you.
Who Might We Share Your Personal Information With?
WHILE WE STRIVE TO SELECT THIRD PARTY PARTNERS WHO HAVE OR SHARE THE SAME STANDARDS IN REGARDS TO PRIVACY POLICIES, THE USER AGREES THAT WITH RESPECT TO THOSE THIRD PARTIES, INCLUDING WITHOUT LIMITATION THE SITES WE LINK TO, WE DO NOT MAKE ANY REPRESENTATION OR WARRANTY REGARDING THE SAME, NOR WILL WE BE RESPONSIBLE TO THE USER OR ANYONE ELSE FOR ANY PRODUCTS, SERVICES OR OTHER MATERIAL THAT MAY BE SOLD, LICENSED, DISTRIBUTED OR PROMOTED BY SUCH THIRD PARTIES OR ON SUCH SITES, OR FOR ANY CONTENT ON SUCH SITES. WE ENCOURAGE VISITORS OF THESE SITES TO REVIEW THE PRIVACY POLICIES POSTED ON THESE SITES.
On an aggregate basis only, we may collect Non-Personally Identifiable Information about users of the NeoPangea Site. NeoPangea will never disclose any Personally Identifiable Information as part of this aggregate information but we may use, transfer, and disclose this Non-Personally Identifiable Information for any purpose. For example, we may record this basic information about visits to the NeoPangea Site in order to track visits to the NeoPangea Site, help diagnose problems with our server, assist us in technical development of the NeoPangea Site, and to improve our services and advertising.
NeoPangea will make every effort to preserve user privacy but we may need disclose your personal information to law enforcement agencies, government/regulatory bodies, and content protection organizations to: (i) protect our legal rights, privacy or safety, and that of our subsidiaries, affiliates, employees, agents, contractors, or other individuals; (ii) protect the safety and security of visitors to our online services or other properties; (iii) protect against fraud or other illegal activity or for risk management purposes; (iv) respond to inquiries or requests from government, regulatory, law enforcement, or public authorities; (v) permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages that we may sustain; or (vi) comply with the law including with subpoenas, search warrants, court orders, and other legal process.
Sale Or Transfer Of All Or Part Of Our Business Or Assets
Cookies And Other Technologies
If for any reason you wish not to take advantage of cookies, you may have your browser not accept them, although this will disable or render unusable some essential features of the NeoPangea Site and services. If you disagree with our usage of cookies, please do not visit the NeoPangea Site.
You should remember that whenever you voluntarily disclose information online, such as on message boards, through e-mail, discussion groups, or in chat areas, your information can be collected and used by others. Although we try to protect your information, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. You are solely responsible of maintaining the secrecy of any passwords you set up and/or any account information.
Other Websites And Links
Accessing and Updating Information
If you wish to change or update any Personally Identifiable Information we have collected about you, request that we delete it, or request that we change how we use it, please send an email to [email protected] with your instructions.
California Privacy Rights/Do Not Track Notice
This paragraph applies only to California residents. As a California resident, you have a legal right to request and receive in writing or by e-mail the names and addresses of all such third-parties who received your Personally Identifiable Information during the previous calendar year and a list of the types of Personally Identifiable information disclosed to such third parties. To request such information, please send an e-mail to [email protected].
We will not honor such a request more than once per calendar year.
The GDPR Policy applies only to residents of the EU.
The term “Personal Data” as used in this Privacy Notice means any information relating to you such as your name, contact details, bank account details etc. Personal Data does not include data from which you can no longer be identified such as anonymized aggregate data.
What Information Do We Collect About You, How Do We Collect It And What Do We Use It For?
The kinds of Personal Data we may collect include contact information, such as your address, email address and telephone number, and employment information, such as your job title. In addition, we collect the Personal Data you choose to provide to us, e.g. if you contact us by letter, telephone, email, via our website, or any other means of electronic or personal communication. Under the GDPR, NeoPangea must possess and identify a lawful basis for collecting or processing your Personal Data which may vary according to the type of Personal Data processed and the individual to whom it relates.We will therefore process your Personal Data only:
- if you have consented to us doing so;
- if we need it to perform a contract we have entered into with you;
- if we need it to comply with a legal obligation; or
- if we (or a third party) have a legitimate interest that is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests will be the providing of services by us, administrative or operational processes within NeoPangea and direct marketing.
We need to collect and use your Personal Data for a number of reasons, the primary purpose being to provide customized products and services to our clients and which may involve the use of your Personal Data. We may also use your Personal Data to inform you about our services and new technological developments. If you provide information to us about someone else (such as one of your associates, directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that information to us and that, without our taking any further steps, we may process that information in accordance with this Policy.
Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
Special Category And Criminal Records Personal Data
If NeoPangea processes your criminal records Personal Data or special category Personal Data relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, health data, biometric data or sexual orientation, we will obtain your explicit consent to those activities unless this is not required by law or the information is required to protect your health in an emergency. Where we are processing Personal Data based on your consent, you have the right to withdraw that consent at any time.
We may use your contact details to send you marketing materials, provided we are permitted to do so by law. You always have the right to unsubscribe from any marketing. You can do so by clicking on the relevant link in the next email we send you.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access Personal Data (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
Accuracy Of Information
It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.
What If You Do Not Provide The Personal Data We Request?
It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, we may not be able to accept an engagement from you, to provide all or some of our legal services, to enter into a contract with you or to send you requested marketing information.
Change Of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data and no longer subject to the GDPR.
With Whom Will We Share Your Information?
When using your Personal Data for the purposes and on the legal basis described above we may share your Personal Data with our affiliate offices as well as other law firms and services providers we work with. Such recipients include but are not limited to: co-counsel, foreign law firms whom we work with on your behalf, NeoPangea’s insurance broker’s and underwriters, NeoPangea’s bank, auditors, and accountants; and NeoPangea’s third-party IT service providers. We may also have to share your Personal Data with regulators, public institutions, courts or other third parties.
When we use third-party organizations to process your Personal Data on our behalf, they must have appropriate security arrangements, must comply with our contractual requirements and instructions, and must certify compliance with the GDPR and any other relevant data protection legislation.
For the purposes described above, we may have to transfer your Personal Data to organizations located in “third countries” (those outside of the EEA). In addition to the security arrangements mentioned above in relation to our engagement of third-party organizations, where such transfers are required we will ensure that your Personal Data is adequately protected, for example, by using a contract for the transfer which contains specific data protection provisions.
If you require further information about this you can request it from [email protected].
How Do We Protect Your Personal Data?
We have security arrangements in place to guard against unauthorized access, improper use, alteration, destruction or accidental loss of your Personal Data. We take appropriate organizational and technical security measures and have rules and procedures in place to ensure that any Personal Data we hold is not accessed by anyone unauthorized to access it. We have in place, and abide by, a specific information security policy about the security standards used to protect your Personal Data.
When we use third-party organizations to process your Personal Data on our behalf, they must also have appropriate security arrangements, must comply with our contractual requirements and instructions and must ensure compliance with the GDPR and any other relevant data protection legislation.
Your rights in relation to your information
Under the GDPR, you have certain rights that you may exercise under certain circumstances in relation to your Personal Data that we possess. For example, you may:
- request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
- request rectification of your Personal Data;
- request the erasure of your Personal Data;
- request the restriction of processing of your Personal Data;
- object to the processing of your Personal Data.
You also have the right to receive your Personal Data in a structured, commonly used and machine-readable format and to have us transmit your Personal Data to another controller, if you have provided the Personal Data to us, if the processing is based on consent pursuant to point (a) of Article 6(1) of GDPR or point (a) of Article 9(2) of GDPR or on a contract pursuant to point (b) of Article 6(1) of GDPR and the processing is carried out by us by automated means, subject, however, to legal restrictions which may apply.
If you want to exercise one of these rights please contact us at [email protected].
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, or, as the case may be, any other competent supervisory authority of an EU member state.
Right To Withdraw Consent
Where you have provided consent, you may withdraw it at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing it. To withdraw your consent, please contact [email protected]. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. In case we processed your Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such marketing purposes. Whenever you withdraw consent, you acknowledge and accept that this may have a negative influence on the quality of the NeoPangea Site and/or Services. You further agree that NeoPangea shall not be held liable with respect to any loss and/or damage to your personal information if you choose to withdraw consent.
How Long Will We Retain Your Information?
We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any contractual, regulatory, legal, accounting or reporting requirements.
Upon conclusion of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.
No Automated Decision Making
We do not apply automated decision making or profiling techniques.
How To Make A Complaint
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk
215 S. 5th Ave.
West Reading, PA 19611