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Privacy Policy

Effective date: January 10, 2023

At Frost Brown Todd LLP (“Frost Brown Todd”, “we”, “us”), we respect your privacy and are committed to protecting it. Our privacy policy is available in PDF form here. Individuals with disabilities who are unable to usefully access our privacy policy online or via PDF may contact us at the below-listed contact information to inquire how they can obtain a copy of our policy in another, more easily readable format.

Frost Brown Todd is a full-service law firm that provides legal and other client services (“Services”). We collect your personal information when you use our website or when individuals or businesses engage with us or use our Services. We also may collect personal information about individuals as a result of providing the Services to third parties.

This notice covers information we collect from or about you when you give it to us, visit our website, use one of our apps, visit any of our locations, or interact with our advertisements. It also covers information that we may receive from other persons or companies who have received your information and can share it with us.

If in any case our privacy practices differ from those explained in this notice, we will let you know at the time we ask for or collect your information.

The Information We Collect
We will collect information you provide to us, which may include information such as your name, e-mail address, and other contact information. For example, we collect your contact information if you choose to e-mail us with that information. We also collect your information when you submit job applications.

When you visit our website or use any apps affiliated with our Services, we also may automatically collect information about your computer or device, such as your IP address or the type of browser you are using, the search terms you use on our website, the specific web pages you visit on our website, and the duration of your visits. Information that can be used to directly or indirectly identify you is commonly referred to as personal information.

Our Use and Disclosure of Information About You
We may use the personal information you provide to us to assist us in providing the Services to you. The uses may be as varied as your requests. For example, we may use the personal information you provide solely to respond to your specific inquiry. If you submit a resume by e-mail to Frost Brown Todd in connection with an application for a job or otherwise, we will use it only for the internal application review process. We will not contact you about other matters, unless you specifically request it, nor will we rent, or sell your personal information. We will not disclose your personal information outside Frost Brown Todd except as necessary to perform the Services, which may include sharing your information with third parties that perform data services, such as maintenance and back up. Any such third parties will be under an obligation to maintain the confidentiality of your personal information.

In addition to the examples listed above, we use your personal information in a variety of ways, such as to analyze site traffic (such as aggregated information on the pages visited by our users), which allows us to improve the design and content of our website. Based on this, we may not only use your personal information in order to provide you with information and services that you request, but also information and services which we feel may interest you. We may use your personal information by itself or aggregate it with information we have obtained from others. We may share your personal information with third parties to achieve these objectives and others. In addition, if you are a client of Frost Brown Todd, we may share personal information in accordance with our engagement terms.

We may disclose personal information about you as required by law, or with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our website, or other users; or (d) in an emergency to protect the health and safety of our website’s users or the general public.

We may disclose personal information in the event of a sale or transfer of our business.

We cannot guarantee the protection of the personal information you send to us by means of unencrypted e-mail, or that may be accessible by others while in transit.

Links to Third-Party Sites
Our website may link to or contain links to other third-party websites that we do not control or maintain. We are not responsible for the privacy practices employed by any third-party website.

Cookies and Web Beacons
We use “cookies” and “web beacons” (also called “clear gifs” or “pixel tags”) to obtain certain types of information when your web browser accesses our website. “Cookies” are small files that we transfer to your computer’s hard drive or your Web browser memory so we can remember who you are, and to provide convenience and other features to you, such as recognizing you as a frequent user of our website. “Web beacons” are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, and to provide other information. We use cookies and web beacons to personalize your interaction on our website and to collect anonymous, aggregated information to assist us in understanding how users use our website.

We collect and analyze this information to measure the number of visitors to the different sections of our website, and to evaluate how visitors use our website. We also use the information we collect to understand client needs and trends, to carry out targeted promotional activities, and to generally help us make our website more useful to visitors. We do not use any of this information to identify visitors and we do not share it with third parties. Our websites are not designed to respond to “do not track” signals received from browsers.

We may use your information by itself or aggregate it with similar information we have obtained from others. We may share your information with our affiliates and other third parties to achieve these objectives.

Disabling Cookies
You are not required to accept cookies. However, some parts of our website will not function properly or be available to you if you refuse to accept a cookie or choose to disable the acceptance of cookies.

Our Commitment to Security
We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the information under our control. However, we cannot and do not guarantee or warrant the security of any information you disclose or transmit to us online and we are not responsible for the theft, destruction, or inadvertent disclosure of your personal information.

Changes to Our Privacy Notice
Frost Brown Todd reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the 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.

Contact Information
If you have any questions or comments about this notice, the ways in which Frost Brown Todd collects and uses your information, your choices and rights regarding such use, please do not hesitate to contact us at privacyoffice@fbtlaw.com or 1.800.793.6482.

Your California Privacy Rights

This Privacy Notice for California Residents supplements the information contained in Frost Brown Todd’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumer” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively, the “CCPA”), and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect
Frost Brown Todd may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Example Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
D. Commercial information. Transaction information and information about products and services purchased. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. YES
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO
L. Sensitive personal information Under Cal. Civ. Code § 1798.121(d), we do not infer characteristics about a consumer based on any sensitive personal information collected or processed as defined under Cal. Civ. Code § 1798.140(ae). NO

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Frost Brown Todd obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete, communications you send to us, or documents you provide to us, or when you interact with our website or Services.
  • Third parties. For example, from parties you direct to share your personal information with us.

Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, to perform the Services for you.
  • To provide information to respond to your specific request.
  • To provide you with support, including technical support and address your concerns, and monitor and improve our Services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • When collecting your personal information 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.

Disclosing Personal Information
Frost Brown Todd may disclose your personal information to service providers and contractors for business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both retain that personal information as confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose
We have disclosed the following categories of personal information with our affiliated companies, service providers and public or government (including enforcement) authorities for our business purposes:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category C: Protected classification characteristics under California or federal law.
  • Category D: Commercial information.
  • Category F: Internet or other similar network activity.
  • Category I: Professional or employment related information.
  • Category J: Non-public education information.

In the preceding twelve (12) months, Frost Brown Todd has disclosed the categories of personal information identified above for a business purpose to the following categories of persons:

  • Service providers.
  • Contractors.

Selling or Sharing of Personal Information – Sensitive Personal Information
In the preceding twelve (12) months, Frost Brown Todd has not sold or shared personal information. We do not sell or share personal information as defined under California law, as such, we do not have actual knowledge of our selling or sharing personal information belonging to consumers under 16 years of age.

Under Cal. Civ. Code § 1798.121(d), we do not infer characteristics about a consumer based on any sensitive personal information collected or processed as defined under Cal. Civ. Code § 1798.140(ae).

Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that Frost Brown Todd disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Deletion and Correction Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • 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).
  • If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that Frost Brown Todd 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 Exercising Access, Data Portability, Deletion, and Correction Rights below), we will delete (and direct our service providers/contractors 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 Services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform the Services for you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Correction Requests
If you think some of the personal information we have about you is incorrect, you have the right to request that we correct the personal information in compliance with applicable data protection law. To exercise such right, please see Exercising Access, Data Portability, Deletion, and Correction Rights below.

Exercising Access, Data Portability, Deletion, and Correction Rights
To exercise the access, data portability, deletion, and correction rights described above, please submit a verifiable consumer request to us by:

Only you, or a person registered with the California Secretary of State that you authorize 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 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • 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.

Making a verifiable consumer request does not require you to create a business relationship with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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, we will inform you of the reason and extension period in writing. We will deliver our written response to the email address from which you submit it.

Any disclosures we provide will only cover the 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.

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.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you Services.
  • Charge you different prices or rates for Services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you with 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.

Other California Privacy Rights
California’s “Shine the Light” (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. We do not disclose personal information for marketing purposes so there is no need to make such a request.

Changes to Our Privacy Notice
Frost Brown Todd reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the 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.

Contact Information
If you have any questions or comments about this notice, the ways in which Frost Brown Todd collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: privacyoffice@fbtlaw.com