Polsinelli Privacy Policy

This is the privacy policy (“Privacy Policy”) that governs how Polsinelli PC, Polsinelli LLP in California ("Polsinelli", "we", "our" or "us"), use Personal Data (defined below) that we collect, receive and store about individuals in connection with providing our services, including through our website (www.polsinelli.com, www.distressindex.com, polsinellifirmstore.com, polsinelliri.com, healthcaredealmakers.com, missouririverflooding.com, PolsinelliBlogs.com, PolsinelliAtWork.com, PolsinelliFCA.com, PolsinelliOnPrivacy.com, polsinellidrones-robots.com, polsinellionpostgrant.com, and PolsinelliHealthCareSolutions.com), client portals, any other websites that link to this Privacy Policy (collectively, the "Service"). 
Our Service may contain links to third-party websites and services that are not owned or controlled by Polsinelli. We are not responsible for the privacy practices or the content of third party websites, services and advertisements, and you visit them at your own risk.

1. Introduction.
We are committed to respecting privacy and recognize the need for appropriate protection and management of any Personal Data that is shared with us as part of using our Service. As used in this Privacy Policy, "Personal Data" means any information that may be used, either alone or in combination with other information, to personally identify an individual.

2. Information Collected.

We may receive and/or collect Personal Data in the following ways:

2.1. Personal Data Received from Clients. Our clients may provide us with Personal Data from time to time in the course of our representation of them. Information obtained from or relating to clients or former clients is further subject to the terms of any privacy notice to the client, any engagement letter or other similar letters or agreements with the client, the Rules of Professional Conduct, and applicable laws and professional standards.
2.2. Personal Data You Provide To Us On Our Service. If you send us a "Contact Us" request, register for an event, or sign up to receive updates, you may be required to provide us with certain information that may constitute Personal Data, such as your name, email address, company name, and phone number.

2.3. Information Collected Automatically. Certain information on our Service is collected automatically by means of various software tools. We have a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of our Service. Alone or in combination with other information, such automatically collected information may constitute Personal Data. Some of our service providers (described in Section 4, below) may use cookies or other methods to gather information regarding your use of our Service. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your use of our Service with any of your Personal Data that they may have. The use of such information by a third party depends on the privacy policy of that third party. 

a) Log Files On Our Service. The information inside the log files includes internet protocol (“IP”) addresses, type of browser, Internet Service Provider (“ISP”), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us.

b) Other Tracking Technologies. When you visit our Service, we may collect your IP address. For example, we may use IP addresses to monitor the regions from which you navigate our Services. We may also use web beacons alone or in conjunction with cookies to compile information about your usage of our Service and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our Service. We may use web beacons to operate and improve our Service and email communications.

c) Cookies. We use cookies to make interactions with our Service easy and meaningful. When you visit our Service, our servers may send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser. We may use cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your web browser’s ability to accept cookies, you will be able to navigate our Service, but you may not be able to successfully use all of the features of our Service. We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our websites and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Service will not then work. These cookies do not store any Personal Data.

Analytical/performance cookies. They allow us to recognize and count the number of website visitors and to see how visitors move around our websites when they are using them. This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site, and will not be able to monitor its performance.

Functionality cookies. These are used to recognize you when you return to our websites. This enables us to personalize our content for you, greet you by name and remember your preferences (e.g., your choice of language or region).

Targeting cookies. These cookies record your visit to our websites, the pages you have visited and the links you have followed. We will use this information to make our websites and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

d) We also allow third parties to place cookies on your device through the Services to:

• Help us understand and improve how visitors use our websites, including which of our pages and products are viewed most frequently;

• More effectively market our products and services and advertise other products and services that may be of interest to you;

• Obtain your feedback on our products and the Services;

• Allow you to engage in our social media offerings.

e) The use of third-party cookies is not covered by our Privacy Policy. We do not have access or control over these cookies. You may visit the third-party links below to opt out of their tracking and learn about their privacy practices. However, we are not in control of the location of the instructions and information provided by the third parties below and, therefore, you may have to locate the particular instructions and information for the respective third party if these links are no longer current.

• Google Analytics

o To view Google’s privacy policy, please click here.

o To opt out, please download and install the "Google Analytics Opt-out Browser Add-on by clicking here.

• Oracle AddThis

o To view AddThis’s privacy policy, please click here.

o To opt out, please click here.

3. The Purposes For Which We Use Personal Data.

If you submit or we collect Personal Data through our Service, then such Personal Data may be used in the following ways: (i) to represent our clients in accordance with our legal and ethical obligations; (ii) to provide, analyze, administer, and improve our Service and services; (iii) to contact you in connection with our Service and certain services, notifications, events, programs or offerings that you may have registered for; (iv) to send you updates and promotional materials that you have registered for; (v) to identify and authenticate your access to the parts of our Service (e.g., client portals and extranet) and services that you are authorized to access; (vi) for recruiting and human resources administration purposes; and (vii) to protect our rights and/or our property and to ensure the technical functionality and security of our Service.

4. How We Disclose Personal Data.

We do not sell, lease, rent or otherwise disclose the Personal Data collected from our Service to third parties unless otherwise stated below or with your consent.

4.1. Our Third Party Providers. We transfer or provide access to Personal Data to our third party service providers to perform tasks on our behalf and to assist us in providing our Service. For example, we employ service providers who help us provide secure client portals and eRooms (Legal Anywhere; EMC Corporation); analyze website traffic and demographics (Google Analytics); enabling sharing of content on our website (Oracle AddThis); and conduct marketing services on our blogs (MailChimp). Such information may be transferred to other countries around the world. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Data. Notwithstanding the foregoing, we will comply with applicable laws regarding Personal Data transfers as well as any transfer restriction that is specified in an agreement between Polsinelli and a client. 

4.2. Our Clients. We may disclose Personal Data to our clients as necessary in the course of our representation.

4.3. In the Event of Merger, Sale, or Change of Control. We may transfer or assign this Privacy Policy and any Personal Data to a third party entity that acquires or is merged with as part of a merger, acquisition, consolidation, restructuring, the sale of substantially all of our shares and/or assets, in connection with bankruptcy proceedings, reorganization, or other change of control.

4.4. Other Disclosures. We may disclose Personal Data about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our terms of use, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Polsinelli, our users, or the public.

5. Retention of Personal Data.

We reserve the right to retain any Personal Data as long as the Personal Data are needed to: (i) fulfill the purposes that are described in Section 3 (The Purposes For Which We Use Personal Data), and (ii) comply with applicable law. We will take all reasonable steps to destroy, or erase from our systems, all Personal Data which is no longer required for the purposes for which the Personal Data was collected.

6. Your Rights.

6.1. Personal Data. If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via our Service, you may submit a request to privacy@polsinelli.com or write to us at:

Rebecca Frigy Romine

Privacy Officer

Polsinelli PC

100 S. Fourth Street, Suite 1000

St. Louis, Missouri 63102

We will promptly review all such requests in accordance with applicable laws.
Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Data about you. We encourage you to first reach out to us at privacy@polsinelli.com, so we have an opportunity to address your concerns directly before you do so.

6.2. Opting-Out of Promotional Emails. You may choose not to receive future promotional or advertising emails from us by selecting an unsubscribe link at the bottom of each email that you receive from us. Additionally, you may send a request specifying your communications preferences to privacy@polsinelli.com. You cannot opt out of receiving transactional emails related to the performance of our services. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any "Contact Us" request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).

7. Personal Data Transferred from the EU or Switzerland To The United States.

Due to the global reach of Polsinelli’s legal services, Polsinelli sometimes collects, analyzes and reviews data that originates from the EU, EEA, or Switzerland on behalf of its clients, adverse parties, or other parties to legal matters as necessary. In turn, Polsinelli may transfer this data to its clients, adverse parties, tribunals, courts, government agencies, vendors, and other third parties to provide legal services, assist in providing legal services, or subject to a client request.

Polsinelli has chosen to voluntarily participate in the Privacy Shield, and to certify its adherence to the EU-U.S. and Swiss-U.S. Privacy Shield Framework (“Privacy Shield”) and its Principles, including the Supplemental Principles (collectively, the “Principles”), as set forth by the Department of Commerce. If there is any conflict between the terms of this policy and the Principles, the Principles shall govern. Polsinelli is eligible to participate in the Privacy Shield because it falls under the jurisdiction of the Federal Trade Commission (“FTC”). To learn more about the Privacy Shield program, please visit www.privacyshield.gov

In compliance with the Privacy Shield Principles, Polsinelli commits to resolve complaints about your privacy and our collection or use of Personal Data about you. Persons from the EEA and Switzerland who have inquiries or complaints regarding this Statement should first contact us via email at: privacy@polsinelli.com. Polsinelli will respond to an individual complaint within 45 days. Polsinelli has committed to refer unresolved privacy complaints under the EU-US Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework to American Arbitration Association (“AAA”), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://go.adr.org/privacyshield.html for more information and to file a complaint. In the event that we or the AAA determine that we did not comply with this Privacy Policy, we will take appropriate steps to address any adverse effects and to promote future compliance.
These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law. Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration. In cases of onward transfer to third parties of Personal Data of EU and Swiss individuals received pursuant to the EU-US Privacy Shield and the Swiss -U.S. Privacy Shield, Polsinelli is potentially liable.

8. Data Security.

The security of Personal Data is important to us. We take appropriate technical and organizational data security measures against unlawful or unauthorized processing of Personal Data, and against the accidental loss of, or damage to, Personal data. We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Further, while we attempt to ensure the integrity and security of Personal Data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to Personal Data. Therefore, while we strive to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security.

9. Changes to this Privacy Policy.

We reserve the right, at our discretion, to change the terms of this Privacy Policy at any time. You can see when this Privacy Policy was last updated by reviewing the “Last Updated” legend on the top of this page. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING. 

10. Children's Privacy.

We do not intend to collect Personal Data from anyone we know to be a child, except as permitted by law in the course of providing our client services.

11. Contacting Us and our Privacy Officer.

Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to the Polsinelli Privacy Officer at privacy@polsinelli.com. We seek to promptly resolve any concerns you may have.


This policy is immediately effective as of June 5, 2018.