Privacy policy.

Privacy

Applicability of this policy

This policy applies to visitors to the www.SAM NOLE LLP.com website (the “Site”). 

SAM NOLE LLP is committed to maintaining the privacy and security of your personally identifiable information.  As part of our commitment to information privacy, we have adopted this Privacy Policy to inform you of our information gathering practices and the ways in which we may use the information we receive. This Privacy Policy applies to all personal information submitted to SAM NOLE LLP for use with or in connection with its website located at www.NOLELLP.com.  By providing your personal information to us on our Site, you consent to the collection and use of that information in accordance with this Policy.

Information We Collect and How We Use It

“Personal Information” means any information by which you can be identified, including name, postal address, e-mail address, location IP address and telephone number.

SAM NOLE LLP gathers Personal Information about you in order to respond to your requests and provide you with appropriate information about SAM NOLE LLP’s products, services, and events.  The information is collected and used in the following ways:

Requests for Information: When you enter information into the “Contact Us” online inquiry form on our Site to request general information about SAM NOLE LLP’s products, services, and events, or to register for an event, you may be required to provide some or all of the following Personal Information: name, email address, company name and location, title, telephone contact information. 

Submission of Requests for Information about Jobs at SAM NOLE LLP: When you send an email to the email address listed on our Site for our Human Resources department.

SAM NOLE LLP may use this information to respond to your requests, including retaining information in order to better respond to further requests or inquiries we receive from you.  SAM NOLE LLP may also send you information from time to time regarding products, services and events that we think may be of interest to you.  Please see the “User Choice” section below for instructions on how to change your mailing preferences if you do not wish to receive such information.

Contacting Us By E-mail: When you send SAM NOLE LLP an e-mail from our Site, you may be required to provide some or all of the following Personal Information: name, email address, company name and address, title, telephone contact information.  SAM NOLE LLP may use this information to respond to your requests, including retaining the information you provide, the content of your e-mail, our response, and any follow-up questions and further requests and inquiries you may have.  SAM NOLE LLP may also use information sent by e-mail for market research and to improve our products and services.

Employment: If you choose to apply for employment with SAM NOLE LLP online, you will be required to provide your name, address, contact information and work authorization status, and upload a resume or curriculum vitae (CV).  SAM NOLE LLP will only use this information to match you with available employment opportunities.

Cookies: SAM NOLE LLP uses technology such as “cookies” on our Site that helps us analyze the use of our website.  “Cookies” are small files placed on your hard drive that assist us in providing our services.  Certain features on our Site may only be available through the use of “cookies.”

Other Web Technologies: SAM NOLE LLP uses technology, including through the use of third party analytics providers, that lets us know what type of browser you are using, the website from which you enter our Site, the type of device you are using, the pages you view as you visit the Site, and other information related to your technology or use of the Site.  This technology does not identify you personally – it simply helps us compile aggregate statistics about our guests and their use of our Site.  We use these statistics and analytics services to improve our Site design and content, to evaluate how the Site is used, analyze traffic patterns, and to prepare and deliver our marketing programs and materials.

To Whom We Disclose Information

SAM NOLE LLP will not share your Personal Information with third parties, except as follows:

  • SAM NOLE LLP will share your Personal Information with some of its affiliates, and business partners and service providers who perform services for us.

  • SAM NOLE LLP will share your Personal Information with others when you have given us permission to do so in writing or through user preferences selected on the Site.

  • SAM NOLE LLP will disclose Personal Information without your permission when we believe in good faith that such disclosure is required by law or is necessary to investigate and protect against harmful activity to SAM NOLE LLP, its customers, its employees and others, or its property, including this Site.

  • If SAM NOLE LLP or a substantial part of its assets are transferred to another entity (by merger, consolidation, sale or bankruptcy process), Personal Information may be one of the assets transferred.

  • SAM NOLE LLP may share aggregate data developed from Personal Information with third parties for research, education or marketing purposes.  Such aggregate data will not include any information that can be used to identify any particular individual. User Choice Regarding Collection, Use and Distribution of Personal Information

  • The extent and type of Personal Information SAM NOLE LLP collects depends on the information you provide to us through our e-mail and/or through the registration processes on the Site. You may choose not to provide us with any Personal Information

Third Party Links

This Site may contain links to other websites maintained by third parties over whom SAM NOLE LLP has no control.  When you click on one of those links, you are accessing a website that is not owned, operated, or controlled by SAM NOLE LLP, and your visits to those websites are not covered by this Privacy Policy.  The operator of such website may have its own privacy policy (which we encourage you to read carefully), and that policy will govern the collection and use of your data on that website.  SAM NOLE LLP does not share your Personal Information with these parties and is not responsible for their privacy policies.

Our Commitment to Children’s Privacy

SAM NOLE LLP understands the importance of protecting children’s privacy.  For that reason, we do not collect and maintain information from those we actually know are under 13 years of age, and no part of the Site is structured to attract anyone under 13 years of age.

Data Security

SAM NOLE LLP will take reasonable precautions to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction.  However, these measures, standing alone, are not sufficient to ensure the security of your Personal Information.  It is also important for you to guard against unauthorized access to your passwords and the unauthorized use of your computer.

Your California Privacy Rights

Individual customers who reside in California and have provided their Personal Information to SAM NOLE LLP may request information about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes.  SAM NOLE LLP tracks your movement through our website through use of “cookies.” Cookies help assist us provide services to visitors to our website.  You should be aware that certain features on our Site may only be available through the use of “cookies.” 

Effective Date and Changes to Privacy Policy

This Privacy Policy was effective on June 22, 2018.

We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy simply by posting such change, update, or modification on this Site.  Any such change, update, or modification will be effective immediately upon posting on the Site.  The date in this section will be updated whenever this Privacy Policy is changed.  You agree that we may notify you about material changes in the way we treat Personal Information by placing a notice on the Site.

If you have any additional questions after reading this Policy or would like to give us feedback, please e-mail us at clients@Nolellp.com 

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1. The data we collect about you on or through the Site
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

    • Identity Data includes first and last name and company name.

    • Contact Data includes email address.

    • Technical Data may include internet protocol (IP) address, geolocation data, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site.

    • Usage Data may include information about how you use our website and services.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).  Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms on the Site, or by corresponding with us by email using one of the email addresses posted to our Site. This includes personal data you provide when you:

  • Submit a question or comment through the “contact us” feature on our Site; or

  • When you send an email to any email address posted to our Site.

Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about you, your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.  We may also receive Technical Data about you if you visit other websites employing our cookies, if any.  A list of cookies we use on our Site is available upon request.

We use the following analytics providers to help us understand traffic and manage our Site:

Analytics Product

Provider Name (company name)

Type of Data Collected

Google Analytics

Google LLC

1600 Amphitheatre Parkway, Mountain View, CA 94043

Technical Data

Bing Webmaster Tools

Microsoft Corporation

1 Microsoft Way, Redmond, VA 98052

Technical Data

Google Console

Google LLC

1600 Amphitheatre Parkway, Mountain View, CA 94043

Technical Data

  

By using our Site, you consent to our use of such service providers and services, and the collection of your personal data. 

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • When you submit a request for information on our Site, so that we can respond to your request; 

  • When you submit a comment or provide feedback to us on our Site, so that we can act on the feedback and respond to your comment; 

  • To send you marketing emails using the information you provided to us on the Site;

  • When you submit an inquiry or apply for work through the use of contact details provided on our Site, so that we can process that information and your application, if any;

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or

  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or using the ‘unsubscribe’ link in our e-mails to you.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register your interest in our services

(a) Identity

(b) Contact

(c) Technical

Performance of a contract with you

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy

(a) Identity

(b) Contact

(c) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Usage

(d) Marketing and Communications

(e) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Thought Pieces and Legal Updates

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and information may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by following the ‘unsubscribe’ link on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service we provide to you or to a third party and which may involve your personal data.

Cookies

Please see the section above in our general Privacy Policy regarding our use of cookies on our Site.

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 and that reason is compatible with the original purpose.  We may also use your personal data to send you marketing emails. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the rules set forth in this Privacy Policy, where this is required or permitted by law.

4. Disclosures of your personal data 

We may share your personal data with certain third parties, as required for the operation of our business, which includes processors and sub-processors.

  • Internal Third Parties as set out in the Glossary.

  • External Third Parties as set out in the Glossary.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We contract with our third-party service providers to require that they do not use your personal data for their own purposes and to authorize them to process your personal data for specified purposes and in accordance with our instructions.

6. Data security
Please see the section above in our general Privacy Policy regarding data security measures used in an attempt to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, or disclosed to unauthorized third parties.
7. Data retention
We are developing a data retention policy which will dictate how long we retain your personal data collected through or on our Site, with the intent that we will retain your personal data only for so long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data

  • Request correction of your personal data

  • Request erasure of your personal data

  • Object to processing of your personal data

  • Request restriction of processing your personal data

  • Request transfer of your personal data

  • Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.Information We Collect and How We Use It

“Personal Information” means any Personal Information or Personal Information relating to a living individual (including Sensitive Personal Information) by which they may be identified, including (but not limited to) their name, postal address, telephone number, e-mail address, location IP address or other on-line identifier, or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.

We gather Personal Information about you directly in order to respond to your requests and provide you with appropriate information about our products, services, and events.  The information is collected and used in the following ways:

  • Requests for Information: When you enter information into the “Contact Us” online inquiry form on our Site to request general information about our products, services, and events, or to register for an event, you may be required to provide some or all of the following Personal Information: name, email address, company name and location, title, telephone contact information;

  • Sensitive Personal Information: We may collect certain information about you which is considered more sensitive under applicable data protection laws (e.g. about your race, ethnic origin, religious views and philosophical beliefs, membership of professional or trade associations, gender identity or sexual orientation, mental or physical health conditions, biometric, genetic, or health data).

  • Response to Requests: We may use your Personal Information to respond to your requests, including retaining information in order to better respond to further requests or inquiries we may receive from you regarding our service offerings.  We may also send you information from time to time regarding products, services and events that we think may be of interest to you.  Please see the “User Choice Regarding Collection, Use and Distribution of Personal Information” section below for instructions on how to change your mailing preferences if you do not wish to consent to receive such information.

  • Gathering certain Personal Information from other sources: We may also receive information from other sources e.g. personal details of various types when we conduct anti-money laundering, countering financing of terrorism or other compliance screening services utilized in the course of conducting our business activities.

  • Contacting Us By E-mail: When you send us an e-mail from our Site, you may be required to provide some or all of the following Personal Information: name, email address, company name and address, title, telephone contact information.  We may use this information to respond to your requests, including retaining the information you provide, the content of your e-mail, our response, and any follow-up questions and further requests and inquiries you may have.  We may also use information sent by e-mail for market research and to improve our products and services.

  • Submission of Requests for Information about Jobs with us: When you send an email to the email address listed on the Site for the attention of our Human Resources department.

  • Employment: If you choose to apply for employment with us online, you will be required to provide your name, address, contact information and work authorization status, and upload a resume or curriculum vitae (CV).  We will only use this information to match you with available employment opportunities.

Legal Basis for Processing Personal Information

We will only process your Personal Information when we have a legal basis for doing so (including but not limited the following legal conditions:

  • Consent: In specific situations we may collect and process Personal Information with your consent

  • Contractual obligations: In certain circumstances we will need to process certain Personal Information to comply with contractual obligations for which we have been engaged.

  • Legal compliance: If the law requires we may need to process your Personal Information.

  • Legitimate interest: In specific situations we requires your Personal Information to pursue our legitimate interests in a way which might reasonably be expected as part of running its businesses and which does not materially impact your rights, freedom or interests (e.g. disclosure in compliance with regulatory obligations).

How quickly shall we response to a written access request from you seeking access to your Personal Information being held or controlled by us?

Unless we advise to the contrary, we shall respond to written requests for access to Personal Information not later than 30 days after receipt of any such written request. We shall advise if for any reason we are unable to meet your requests within this timeframe (e.g. where a large amount of Personal Information is requested or required to be searched through and meeting the timelines would unreasonably interfere with SAM NOLE LLP’s day-to-day business operations); (b) where more time may be required to consult with any relevant third party prior to SAM NOLE LLP being able to decide whether or not to provide access to the requested Personal Information; or (c) you provide consent to an extension of the 30 day timeframe.  We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.  

We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying confirmation shall be used only for that purpose.

What we need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

It is also important that the Personal Information we hold about you is accurate and current. Please keep us informed if any of your Personal Information provided to us changes during your relationship with us.

Are there costs to you for requesting access to your Personal Information?

We will in many instances be able to provide you with your requested Personal Information free of charge except where any request made is determined to be manifestly unfounded or excessive because the request is (a) repetitive; (b) fraudulent in nature; or would divert our resources unreasonably. In the event of (a) (b) or (c) arising, may in certain instances decide to charge such fee as covers the cost of providing the requested Personal Information or may refuse to act on the request and provide you with our reason(s) for so doing.

Direct Marketing

You may contact us directly at any time to make a request to us to stop using your Personal Information for direct marketing purposes.

International Transfer of Personal Information

Your Personal Information may be transferred to and stored by persons outside the Cayman Islands and may be transferred to and stored by affiliates or service providers of SAM NOLE LLP or third parties retained by SAM NOLE LLP outside the Cayman Islands. In such cases, SAM NOLE LLP shall ensure that any such transfer is subject to appropriate safeguards or is otherwise permitted under applicable laws.

Changes to this Addendum

We may occasionally update or amend this Addendum to reflect changes to our practices and service offerings or to alternatively reflect changes required due to legislative changes.  We recommend you check this page from time to time to inform yourself of any changes to this Addendum going forward.

Effective Date and Changes to Addendum

This Addendum was effective on October 8, 2019.

We reserve the right, at any time and without notice, to add to, change, update, or modify this Addendum simply by posting such change, update, or modification on this Site.  Any such change, update, or modification will be effective immediately upon posting on the Site.  The date in this section will be updated whenever this Addendum is changed.  You agree that we may notify you about material changes in the way we treat Personal Information by placing a notice on the Site.

If you have any additional questions after reading this Policy or would like to give us feedback, please e-mail us at clients@Nolellp.com