ABOUT THE FIRM AND THIS PRIVACY STATEMENT



Atkins, Hollmann, Jones, Peacock, Lewis & Lyon Inc. ("AHJPLL," the "Firm," "we," or "us") is committed to safeguarding our clients’ privacy and personal data. With a few exceptions, such as when we provide data room or e-discovery services (in the context of which our role is limited to that of a data processor), AHJPLL is generally the controller of personal data provided to us.

This Privacy Policy is intended to inform clients, prospective clients, and, more generally, all visitors to this Website about how we collect, use, share, protect, or otherwise process personal and other data.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

  • Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights, please contact us. To appeal a decision regarding consumer rights, please request reconsideration of the decision by contacting us.

Nevada provides its residents with a limited right to opt out of certain personal information sales. Residents who wish to exercise opt-out rights may submit a request to us. However, please note that AHJPLL does not currently sell data triggering that statute’s opt-out requirements.

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.

When, How and What Data We Collect

In general, you are not required to provide any personal information to consult our Website. However, you may elect to contact us by completing the form provided on the "Contact Us" page of this Website; in this case, we ask you to provide your name and email address and submit specific questions to us. You may also elect to contact us by telephone or e-mail. All personal data processed by us is necessary to fulfill the purposes for which it was collected.

During the course of an engagement, or when consideration is being given to such an engagement, we may collect and process personal, financial, or related data about our clients, prospective clients, their affiliates, or the relevant members of their personnel. In addition, AHJPLL may assemble and maintain information relating to the legal services provided. The information that AHJPLL may assemble and maintain may be obtained from the client, generated as a result of the services provided, or received from third parties.

For compliance with the Corporate Transparency Act, your personal identification picture is submitted through our secure ShareFile link, which limited AHJPLL employees can access. Photo identification and other personal information submitted for Corporate Transparency Act compliance is only retained long enough to complete the Beneficial Owner Information to be submitted to FinCEN. Following submission of your FinCEN information, other than a FinCEN receipt kept for our records, all other non-billing related information shall be deleted.

How Data Is Used

We will use your personal data to process your request, contact you, and provide you with the information you requested. Or, if submitted for Corporate Transparency Act purposes, to submit the necessary required Beneficial Ownership Information.

We may also use personal data and other data received from clients or prospective clients:

  • to conduct pre-engagement assessments and formalities such as anti-money laundering checks, conflict of interest checks, etc.;
  • to perform the tasks entrusted to us by our clients;
  • for client relationship management purposes;
  • for internal administrative or operational processes;
  • to analyze the services you may be interested in; and
  • to satisfy any legal, professional, regulatory, accounting, or reporting requirements.

We will process personal and other data if and to the extent applicable law provides a lawful basis for us to do so and in particular:

  • if the data subjects have consented to us doing so;
  • if we need it to perform the contract we have entered into with a data subject;
  • 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 the data subjects’ interests or fundamental rights and freedoms. Such legitimate interests will be providing legal services, and administrative or operational processes within AHJPLL.

This Website is not directed at children under the age of 13 and does not knowingly collect personal information from children under the age of 13. If AHJPLL obtains actual knowledge that it has obtained personal information about a child under the age of 13, that information will be immediately and permanently deleted from our records.

With Whom Data May Be Shared

Please note that in order to process a query or fulfill any of the purposes set out in the section above, we may be required to share personal and other data with other law firms, FinCEN, and service providers with whom we work. We will not share personal or other data with any third party except as required by law. If you are or become a client of AHJPLL, you should know that all information that AHJPLL receives from a client is held in confidence and is not released to people outside the Firm, except as agreed to by the client or as allowed or required under applicable law and the rules of professional conduct governing the provision of legal services.

How Long Data Is Retained

We will retain your personal and other data for as long as necessary to fulfill the purposes for which it was collected and processed in compliance with this Privacy Policy. To determine the retention period for personal and other data, we will take into consideration the purposes for which they were collected, the amount, the nature, the sensitivity, and the applicable legal requirements. Generally, AHJPLL retains information in its files until the completion of the matter to which that information relates. After that, those files may be purged, placed in storage, or returned to the client. AHJPLL may retain copies of files returned to clients. Files retained by AHJPLL after the completion of a matter are not retained or marked for destruction in accordance with a fixed schedule. Instead, inactive files are maintained until AHJPLL determines that those files are no longer useful in rendering services to the client or are not otherwise required in connection with our role as counsel or former counsel.

For Corporate Transparency Act purposes, non-billing data retained other than receipt of our submission to FinCEN regarding your Beneficial Ownership Information is deleted from our secure server upon confirmation from FinCEN that your information has been submitted successfully and approved.

While retaining personal and other data, we take physical, technical and administrative security measures against accidental or intentional manipulation, partial or complete loss, destruction, or unauthorized access by third parties. To guard clients’ nonpublic data or the nonpublic data of business entities, AHJPLL maintains physical, electronic, and procedural safeguards that comply with professional standards and generally exceed the requirements imposed under federal law. Our security measures are continuously improved in line with technological developments.

What Rights You Have

We rely on you to provide accurate, complete, and current personal data to us.

You may also contact us to request more information in connection with our data processing activities.

Where we have relied on your consent as the legal grounds for processing your data, you may withdraw your consent at any time. Withdrawal does not invalidate the consent-based processing that occurred prior to withdrawal. If you object to the processing of your personal data, please do not provide such data.

You have the right to contact us at any time if you wish to complain about our processing of your personal data.

When contacting us in connection with the processing of your personal data (described above), you will need to provide sufficient identifying information, such as name, address, and birth date, before your request can be processed. We may limit or deny access to personal data where providing such access would be unreasonably burdensome or expensive in the circumstances or as otherwise permitted by law. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal data.



CHANGES TO THE PRIVACY POLICY



Any changes we make to this Privacy Statement in the future will be posted on this page. Please check back periodically for any updates or changes to our Privacy Statement.

How to Contact Us

If you have any questions in relation to this Privacy Statement or the processing of your personal data, please contact us.