Privacy Policy

Effective Date: October 23, 2019


We at Comar Mollé LLP (the “Firm”) respect your privacy. This privacy policy explains the Firm’s online information practices as it applies to our website, www.comarmolle.com. We hope to share how the Firm collects, uses, and discloses personal information as well as explain the choices and rights individuals have regarding their personal information. 


1.    Here is the data we collect from you when you visit our website:


a.    Information collected directly


We may collect personal information about you - such as your name, phone number, email address, and business information - directly from you when you contact us directly (through info@comarmolle.com). 


b.    Information collection automatically


Through the use of cookies, log files, pixel tags, local storage, and other tracking technologies, our server captures information regarding your operating system, the type of computer you are using, the type of browser you are using, your IP address, the URL link you may have come from, the search term you may have used to land on our website, the time and date you came to our website, the content on the website you are looking at, and anything you might download (the “Captured Data”). 


2.     Here is how we use your data:


We use the personal information you provide to respond to your inquiry and in the ordinary court of business. Generally, we use the information that we collection online as follows: 


a.    Website and Business Operations 


To provide and operate our website including display, language, and device preferences and to better understand how users access and use our website. We may also use the information you provide to respond to your inquiries or requests. 


b.    Content Development 


We may use your data to improve and administer more relevant content. For example, we might notice that people are using certain search terms that tend to point them to our website. We might use that information to create content around those areas. We might also notice that a blog post we've written is generating a lot of attention and use that information to make more posts like that.


c.    Legal Obligations 


We may use your personal information to comply with the law, legal proceedings, or other legal obligations. For example, we may disclose information in response to subpoenas, court orders, and/or lawful requests by regulators and/or law enforcement. We may also use your data to protect and defend our legal rights.


d.    Risk Protection and Mitigation


To protect the site and business operations against fraud, unauthorized access, and misuse We might notice that data we are monitoring indicates a DDOS attack, for example. We would conceivably use automatically collected information to enact defenses and to protect the website.


3.    Cookies:


We use cookies to enhance your browsing experience. Cookies are small files that we store on your browser or the hard of your computer when you visit our website. 


Here are the types of cookies we use on our website:


  • Functional cookies -- cookies that help certain widgets and/or apps run on our website. 
  • Analytics and performance cookies -- these are cookies that we use to help keep track of the pages that you visit and the other content you might look at or download. These cookies record only the type of Captured Data we identified earlier, and don't record any type of personally identifiable information such as your name, telephone number, or email address. 


You can block or disable cookies on your device and/or through your web browser. You can also delete cookies. If you do that, our website may look different, or may not work as well. But it's totally up to you.

We might link to other websites (for example, social media platforms or other third-party websites) whose information practices may be different than ours. We don't have any control over the information that is submitted to, or collected by those third-party websites.


4.    How we share your information:


The Firm may share or disclose some personal information we collect with the following categories of providers and for the reasons detailed below: 


  • To our internal and external advisors and auditors.
  • To third-party software platforms or third-party data hosting or analytics programs, in order to run and operate the website and enhance the user experience. The Captured Data may be processed and shared with those platforms or programs as it goes through their systems. 
  • Personally identifiable information you provide over email or through the telephone will be processed through our email system, our email host provider, our internet host provider, our website host provide and/or our phone provider system. 
  • To our vendors who provide services to help run our business (such as banks, accounting firms, and third-party software services). 
  • Information may be shared with law enforcement, regulators, or other legal entities in order to comply with a judicial proceeding, a subpoena, a request from a regulator, or other legal obligation.
  • To third parties engaged in the services we provide to clients such as counsel, arbitrators, and mediators. 
  • To necessary parties if we believe that such disclosure is necessary to otherwise protect and/or defend our rights, property, safety or that of our clients or other users of the website.
  • We do not and will never sell any information we receive from you, whether it's the Captured Data, or any personally identifiable information you disclose to us.


5.    The security and retention of your information is as follows:


We take reasonable and appropriate steps to protect your personal information, including the Captured Data, against unauthorized access, improper use or disclosure, or accidental loss. However, we cannot provide a guarantee that the measures we have taken are sufficient to protect any such information.


We will retain your personal information for the period necessary to fulfill the purposes outlined in this privacy policy. We will retain certain information in accordance with law and regulatory requirements.


6.    Data Subjects Rights 


We respect your rights and control over your personal data. You may exercise any of the following rights by contacting our Global Data Privacy Officer as detailed below. Please note you may ask you to verify your identify before taking further action on your request. 


  • a. Right of Access - the right to be informed of and request access to the personal data we process about you;
  • b. Right of Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
  • c. Right to Erasure - the right to request that we delete your personal data;
  • d. Right to Restrict Processing - the right to request that we temporarily or permanently stop processing all or some of your personal data;
  • e. Right to Object - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
  • f. Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; 
  • g. Right to Lodge a Complaint - You may have the right to complain to a relevant Data Protection Authority if you believe your personal information, including the Collected Data, has been collected or used in breach of privacy rules, or this Privacy Policy. If you are located in the European Union, you should contact the Data Protection Authority in the country in which you are located. If you are located in the United Kingdom, you should contact the Office of the Information Commissioner in the United Kingdom, at www.ico.org.uk. 


7.    Legal Basis of Processing 


It is necessary for us to use your personal information:


  • In order to perform our obligations according to any contract that we may have with you 
  • As a legitimate basis to ensure that we provide the Services in the best way possible. 


8.    California Residents 


California Civil Code Section § 1798.83 permits users of our sites or services 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 contact us using the information provided below.


We do not respond to “Do Not Track” (DNT) signals. 


9.    Changes to this Privacy Policy 


We may update this Privacy Policy to reflect changes to our data practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the changes becoming effective.


10.    Consent


By viewing our website, you agree to this Privacy Policy. In addition, when you visit the website, we ask that you hit "Continue" so that the website runs properly. If you do not hit "Continue," our web platform will not run certain analytics information. However, we ask that if you don't agree to this Privacy Policy, that you simply don't visit the website.


If we materially update this Privacy Policy, we'll put a banner on the front page of our website with the updates, and we will describe what we've changed in plain English. Any information you may have provided will then be subject to the new, updated Privacy Policy.


11.    Contact Our Global Data Privacy Officer and Data Controller

Our Global Data Privacy Officer and Data Controller:


Your privacy is important to us, and so, our Managing Partner, D. Inder Comar, is our Global Data Privacy Officer. If you have any questions or concerns about this Privacy Policy or the data we collect, contact us a info@comarmolle.com. 


For residents of the EEA, the data controller for this website is: Comar Mollé LLP, 1832 Buchanan Street, Suite 201, San Francisco, California, 94115, United States of America.


Thank you for reading through our Privacy Policy.