- What information does Vorys collect about you on our Website?
- How do we collect your information?
- How do we use the information we collect about you?
- How does Vorys share information with Service Providers and Third Parties and for what purposes?
- What are my privacy choices?
- How does Vorys address children’s privacy?
- How does Vorys secure personal information on our Website?
- How does our Website interact with third-party websites and content?
- Where is personal information stored and processed?
- What other terms govern my use of the Website?
- How may I contact Vorys?
- Applicable to California Residents
We collect different types of information about our Website visitors. In the past 12 months, we may have collected:
- Device Information: When you visit our Website, interact with our Social Media Pages or online ads, or open our emails, we learn about your browser, device type, IP address, internet service provider, and other technical information about your device.
- Location Information: We use various technologies to learn your geographic location, including by collecting your IP address or other device information, which may depend on your device's settings for location services.
- Contact Information: We may collect contact information, which includes personal information like name, email address, phone number, and home address.
- Call and Email Records: If you call or email us, we may keep records of those conversations.
- Website Interactions: We collect information about your interactions with our Website including pages visited, links clicked, buttons clicked, mouse movement, and scroll behavior. This data may then be used to replay your interaction, which may be used to troubleshoot Website issues, either individually or in the aggregate, to improve Website functionality and to analyze user interaction. This information could include personal information, depending on what information you provide.
- Submitted Content: We collect any content you submit to our Website, Social Media Pages, or to us in person including photos or videos.
- Demographic Information: We have access to demographic details about our customers like birthdate, gender, ZIP code, and other similar details.
- Social Media Usage: We receive aggregated information about people who visit and interact with our Social Media Pages. “Aggregated” means information that doesn't include personal information associated with identified people.
We may collect the information described above directly from you, from third parties we partner with, or through cookies or other automated means. These sources may include:
- You: We collect information directly from you, whenever you: visit our Website, contact us with questions or comments; upload content to our Website or Social Media Pages; or fill out any forms on our Website or Social Media Pages.
- Your device or browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Website, interact with our Social Media Pages or online advertising, or open our emails.
- Third parties: We work with third parties who provide services to us such as analytics or advertising companies. Your information may be collected and processed independently in accordance with the third party’s own privacy notices. These third parties share information they have collected with us.
- Social media platforms: Social media platforms share information, which is typically aggregated and doesn’t include personal data, with us. You can learn more about how social media platforms collect and use your information by reviewing their privacy policies and settings.
- Fulfillment: We may use the information you provide to respond to your inquiries or to complete your registration.
- Advertising: Presenting advertising online and via email, or other communication channels, including through partnerships with social media platforms and internet search engines.
- Understanding Our Website Users: Analyzing your activity with us (including your interactions with our Website, Social Media Pages, emails, or other forms of communications). We keep track of the pages you visit and the manner in which you use the Website to determine whether to make changes to the Website. We may, from time to time, review your information and information of other Website users to help us analyze trends, preferences, and demographics.
- Communications: Communicating with you, including responding to your requests, asking for feedback through surveys or other messages, or sending you information that we think may be of interest to you.
- Website Experience: Serving content on our Website and Social Media Pages and developing our services.
- Security: Protecting Vorys and our Website users from fraud, security threats, and other illegal or harmful activity. We and our third party service providers may disclose specific individual information if we or they reasonably believe it is necessary to: (i) investigate any suspected misuse of a Website; (ii) protect or defend the rights, property and interests of Vorys, our Website users, or the interests of our third party service providers; or (iii) under exigent circumstances, to protect the personal safety of users of a Website or the public.
- Legal Obligations: Complying with legal and regulatory requirements and responding to requests from courts or other government bodies.
Vorys may share personal information with third parties for certain purposes. For example, we may share personal information with:
- Service Providers: We partner with third parties to assist with many aspects of our business, including advertising and analyzing your interests and activity on our Website and Social Media Pages, and helping us communicate with you. These third parties may provide services related to any of the purposes described in How do we use the information we collect about you?, and we may share with them any types of information described in What information does Vorys collect about you on our Website? We may also receive information collected by these third parties and combine it with the information we have collected. Some of these third parties may be located outside the United States. Your information may also be collected and processed by third parties who will process your information independently in accordance with their own privacy notices.
- Marketing Providers: We partner with third parties to assist with the advertising and marketing of our business. We may share with them the types of information described in What information does Vorys collect about you on our Website? We may also receive information collected by these third parties and combine it with the information we have collected.
- Other Third Parties: We will disclose information about you, including to government bodies or law enforcement agencies, when we believe it to be necessary for compliance with the law or to protect our Website users, our Website, or the public.
If you are a California resident, you can learn more about your privacy rights below.
You can control the information we collect and use in the following ways:
- Location Information: You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Website from accessing your location information. Note that some services may not be available if you disable location-based services.
- Emails: You may opt-out of our marketing emails by following the instructions listed in any email communications that you receive.
- Postal Marketing: To opt-out of other forms of marketing (such as postal marketing), please contact us using the contact details provided under the How may I contact Vorys? section below.
- Online Advertising: For information about opting out of third party advertising, visit: NAI Opt-Out or DAA. You will leave this Website for a separately managed online site where you can specify your preferences. You can also click on the icon that may appear on some of our advertising served through this technology. We may use more than one third party company for placing this advertising, which would require you to opt out of each company.
Our Website and Social Media Pages are not intended for children under 13. No one under 13 should share any personal information with us. We do not knowingly collect any personal information from children under 13. To request deletion of personal data relating to a child under 13, please complete the form on our Contact Us page.
We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. While we use these security measures on our Website, you should be aware that 100% security is not always possible.
For your convenience, we may enable you to navigate to third-party sites through links on our Website. We do not endorse these third-party sites, do not have any affiliation with these third-party sites, and we do not control and are not responsible for their Internet and web practices. Whether the third-party content appears within our Website environment (like a map frame), or you leave our Website for another website to view it, the terms, conditions, and privacy policies of those other websites govern your online experience. Please review their separate terms of service and privacy policies if you have any questions about their practices.
As a resident of California, you have rights under the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations and as may be amended from time to time, “CCPA”) relevant to your Personal Information (as defined under the CCPA), as well as other laws. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.
California Consumer Rights Under the CCPA: If your Personal Information is subject to the CCPA, you may have certain privacy rights with regard to that information. You may have the right to:
- Request that we provide you access to the following no more than twice in a 12-month period:
- the categories and specific pieces of Personal Information that we have collected about you;
- the categories of sources from which the Personal Information is collected;
- the business or commercial purpose for collecting or sharing your Personal Information;
- the categories of third parties with whom we share your Personal Information; and
- the categories of Personal Information that are sold (as defined under the CCPA) and the categories of third parties to whom the Personal Information was sold.
- Request that we delete your Personal Information, subject to exceptions under the CCPA or other applicable law; and
- Request that we not “sell” your Personal Information by opting out of the sale of your Personal Information.
California residents also have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by the CCPA, as described in this section. Vorys will not discriminate against you because you have exercised any of your rights under the CCPA.
How to Submit a Request
If you wish to exercise your right to request access to your Personal Information or to request deletion of your Personal Information, please submit your request through this form or toll-free at 1-833-525-2097.
We are required to provide you with access to your Personal Information or delete your Personal Information only in response to verifiable consumer requests. We will compare the information you provide to us in your request to any information we may have in our possession in order to verify your request. You may be asked to provide us with information such as your home address, email address, and telephone number. We may also contact you to request additional information in relation to your request. Please promptly respond to any follow-up inquiries so that we may verify your identity. If you request that we provide you with specific pieces of information about you, or that we delete sensitive Personal Information, we may apply heightened verification standards than what we would apply to other types of requests. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Information is not disclosed to any person who does not have the right to receive it. The information collected through this process will be used for verification purposes only.
Please note that you may authorize an agent to exercise any of these rights on your behalf by contacting us toll-free at 1-833-525-2097 or by submitting the request via this form. If you use an agent, we will take measures to verify your agent’s authorization similar to the verification described above for fulfilling any access or deletion requests. We may require more information to ensure proper verification of you and your agent’s identity and authorization.
Categories of Personal Information Disclosed for a Business Purpose
We share personal information about you with service providers and third parties for business purposes, such as operational purposes and other purposes related to providing you with the services you seek from us. For more information about the business purposes for which we disclose Personal Information, see How do we use the information we collect about you? and see What information does Vorys collect about you on our Website? for what types of information may be shared.
“Do Not Sell” Rights
We may disclose your Personal Information for the following purposes, which are not a sale: (i) for reasons mentioned above; (ii) if you direct us to share Personal Information; (iii) to comply with your requests under the CCPA; (iv) as part of a merger or asset sale; and (v) as otherwise required or permitted by applicable law.
You may request that we delete your Personal Information that we have collected directly from you. Under the CCPA, we may decline to delete your Personal Information under certain circumstances, for example, if we need the Personal Information to complete transactions or provide services you have requested or that are reasonably anticipated, for security purposes, for internal business purposes (including maintaining business records), to comply with law, or to exercise or defend legal claims. Note also that we are not required to delete your Personal Information that we did not collect directly from you. We require a reasonable or high degree of certainty that the requester is the consumer for which a deletion request is applicable, depending on the sensitivity of the Personal Information.
Additional California Privacy Rights
We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine the Light law”) with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us through this form or sending a letter to Vorys, Sater, Seymour and Pease LLP at 52 E Gay St, Columbus, OH 43215, (Attention: Privacy Inquiry). Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per individual each year, and we are not required to respond to requests made by means other than through this form or mail address.
Effective Date (last updated on): January 11, 2021