Frazier & Deeter’s Privacy Policy
Last Updated: August 17, 2023

 

Frazier & Deeter, LLC, and its affiliates (collectively, “FD,” “we,” “us,” or “our”) developed this Privacy Notice to explain how we collect, use, share, and protect Personal Information (defined below), and to make you aware of your choices about the collection and use of Personal Information.

 

1. Scope

This Notice applies when you use or access the website, www.frazierdeeter.com, www.fdopportunities.com, fdraadev.wpenginepowered.com,  and their subdomains or portals (collectively, the “Site”); or otherwise provide Personal Information or interact with us online or in-person. We refer to all of the above as “Services.” Our Services are used by our Clients (“Clients”), individuals who visit our Site (“Site Visitors”) and individuals applying for employment with FD (“Employment Applicants”). By using the Services, you agree to our Terms of Service.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that Personal Information is necessary to provide you with the Services or if we are legally required to collect it.

If you have any questions about this Privacy Notice, please contact us using the information in the How to Contact Us section below.

1.  WHAT IS PERSONAL INFORMATION?

“Personal Information” is information that, either alone or in combination with other information, identifies you. Examples of Personal Information include, among others, name, email address, phone number, and mailing address. When we combine Personal Information with other information (i.e., information that does not, on its own, identify you), we treat the combined information as Personal Information.

2.   PERSONAL INFORMATION WE COLLECT AND USE

A.   Information We Receive from Clients

Our Clients may provide us with Personal Information from time to time in the course of our engagement with them. Personal Information obtained from or relating to Clients or former Clients may be subject to additional limitations and protections under our Code of Ethics, applicable codes of professional conduct, laws, regulations, and the terms of our engagement letter or other agreements in place with our Clients that outline the services being provided and use restrictions in place regarding Personal Information.

B.   Information We Receive from Site Visitors

In various places on the Site, we request information, including Personal Information, from you via forms. The exact information we need to collect will depend on the purpose of the form. We will indicate on the form whether a particular field of information is mandatory or optional. If you choose not to provide certain information, we may not be able to provide the requested services. We collect Personal Information as follows:

• Contact information such as name, email address and phone number when you sign up for our newsletter; register to receive some of our proprietary content such as webcasts, articles, and videos; complete a survey; or sign up to participate in one of our events.
• Contact information; professional employment history and education; and information about your gender, race, disability status and veteran status when you apply to work at FD.

C.   Information We Receive from Employment Applicants

We may collect the following Personal Information from Employment Applicants:

• Contact information such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers;
• Your current or past employment or educational information;
• Relevant licenses and certifications; and/or
• Other information that could reasonably be used to identify you personally.

D.   Information We Receive from Your Use of the Site

We collect the following types of information automatically from Clients, Site Visitors and Employment Applicants through your use of the Site:

Cookies, Device Identifiers, and Similar Technologies

When you use or access the Site, we use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect information about how you use the Site. We process the information collected through such technologies, which may include Personal Information, to help operate certain features of the Site (e.g., to prevent online poll participants from voting more than once), to enhance your experience through personalization, and to help us better understand the features of the Site that you and other users are most interested in.

Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of device identifiers. If you choose to reject cookies or block device identifiers, some features of the Site may not be available or some functionality may be limited or unavailable. Please review your help pages of your browser or mobile device for assistance with changing your settings.

To help you make an informed choice concerning your acceptance of cookies on the Site, we have prepared the following table:

 

Types of Cookies	Description
Essential Strictly Necessary Cookies	Essential cookies enable you to navigate our Site and use certain features, such as accessing secure areas of our Site and using other features of our service that require us to keep track of certain information as you navigate from page to page. Although some of these cookies are “required” to enable certain functionality, you can disable them in the browser, but doing so will limit your ability to use the features supported by such cookies (e.g., automatic log-in).
Functionality Cookies	Functionality cookies are cookies that support features of the Site, such as remembering your preferences. Examples of functionality cookies include: ·Remembering your email address in order to view select videos and recorded webinars/podcasts which are hosted in wistia.com.
Performance Cookies	These cookies collect information about how you use our Site, including which pages you go to most often and if they receive error messages from certain pages. These cookies are only used to improve how our Site functions and performs. Examples of performance cookies include:·         _ga, _gid, _gat: Allows tracking various statistics relating to Website and Service usage through Google Analytics.
Tracking or Targeting Cookies	From time-to-time, we may engage third parties that track individuals who visit our Site. These third parties may track your use of the Site for purposes of providing us with certain marketing automation features (to help us improve our outreach to current and prospective Clients) and providing you with targeted advertisements. Examples of tracking and targeting cookies include:·         visitorid: Used by Pardot, a SalesForce marketing automation tool, to track use of our Site. Please see this article for more information on these cookies. Also used by NextRoll, Inc., an advertising platform, to track use of our Site. You can opt out of seeing personalized ads from NextRoll (and other companies) using the NAI opt out tool here. Please note you will still see ads even if you opt out, but they will not be personalized by NextRoll.

Some of our service providers may use cookies or other methods to gather information regarding your use of the Site and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy policy of that third party. Because we do not engage in such tracking, we do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com.

Log File Information

When you use our Site, our servers automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Site), number of clicks, and how you interact with links on the Site, domain names associated with your internet service provider, pages viewed, and other such information (collectively, “Log File Information”). We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients. We use Log File Information collected from our implementation of the Site to further our legitimate interests in securing the Site by identifying potential threats and vulnerabilities, and in analyzing the effectiveness of our Site to improve the Site’s function and content.

Location Data

To help personalize our Site and to better understand the demographics of users of our Site, we may use information derived from your IP address to estimate your location (roughly at the precision of your zip code). If we require access to more precise location data to provide you a certain feature (e.g., to help you identify nearby opportunities), we will only access your device’s location in accordance with the consent that you provide through your browser or device, which you may revoke at any time by following the instructions provided by your browser or device manufacturer.

Third Party Advertising

We share information about your use of our Site, and your interaction with our ads on other websites with advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit educational pages from the Network Advertising Initiative (https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work) or the Digital Advertising Alliance (https://youradchoices.com/).

You can opt out of targeted advertising by visiting the following:

• Facebook/Meta – https://www.facebook.com/settings/?tab=ads
• Google – https://adssettings.google.com
• Bing – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
• LinkedIn – https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

 

E.    Information Made Available through Client Portals

We offer an investor portal for Client investors through a third-party vendor. For your convenience and to help ensure the security of transmission, we provide you with access to financial records, which contain Personal Information, through these portals. For more information regarding how we collect, use, disclose, and protection Personal Information collected through these portals, please refer to the privacy notice published on the portal.

3.   HOW WE USE PERSONAL INFORMATION

We use Personal Information from you for various purposes depending on the context in which we collected it. For example, on our Site, we collect contact information from you if you wish to sign up for our newsletter so that we can send you information on regulatory requirements, emerging trends, and upcoming events. As another example, we or one of our service providers collect survey information from you to help us improve our events and services.

In other words, we process Personal Information with your consent, as necessary to provide the Site, or for our legitimate interests, such as:

• Enabling secure use of the Site (e.g., log-in for secure areas);
• Providing, analyzing, administering, and improving the Site and our services;
• Contacting you in connection with our Site and certain services, notifications, events, programs, offerings, or surveys that you may have registered for or participated in;
• Sending you newsletters and other information that you have registered for or requested;
• Responding to inquiries regarding the Site;
• Processing job applications and other human resources administration purposes;
• Protecting our rights or our property;
• Meeting legal obligations;
• Providing services within the scope of our engagement with a Client;
• For other purposes related to the reasons for which you provide Personal Information.

4.   DISCLOSURE OF PERSONAL INFORMATION

We will not disclose your Personal Information except as set forth in this Privacy Notice or with your consent. In particular, we do not sell, lease, or exchange your Personal Information.

This section describes to whom we disclose Personal Information, and for what purposes:

• Our Service Providers. We employ service providers to perform tasks on our behalf and to assist us in providing the Site. For example, among other services, we use third parties to provide services such as website analytics, document repository software, job application processing, customer satisfaction surveys, marketing, customer relationship management, and video- and podcast-hosting. We take reasonable steps to help ensure our service providers provide at least the same level of protection for Personal Information as we do.
• Companies Involved in Mergers and Acquisitions Transactions. If we sell or otherwise transfer part or the whole of FD or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), any information collected through the Site, including Personal Information, may be among the items sold or transferred.
• Law Enforcement, Government Agencies, and Courts. We may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or another legal process to establish, protect, or exercise our rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of any other person. We may also disclose Personal Information to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity.

5.   PERSONAL INFORMATION TRANSFERRED FROM OUTSIDE THE U.S.

If you are using the Site from outside the United States, please be aware that Personal Information may be transferred to, stored, and processed in the United States. Although we take steps to provide adequate safeguards, the data protection laws of the United States might not be as comprehensive as those in your country. By using the Site, you consent to your information being transferred to the United States for the purposes described in this Privacy Notice.

6.   HOW WE PROTECT THE CONFIDENTIALITY OF PERSONAL INFORMATION

FD strives to protect the confidentiality and security of information we obtain in the course of business. Our Code of Ethics, which applies to all employees, restricts the use of personal non-public information (that includes Personal Information as defined in this Privacy Notice) and requires that it be held in strict confidence. We also use reasonable safeguards, such as industry-standard encryption technology, to help keep the information collected through the Site secure.

Despite these efforts to store Personal Information in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as so-called hackers from illegally obtaining access to Personal Information. We do not represent or warrant that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.

7.  CHILDREN’S PRIVACY

FD does not knowingly collect or solicit any Personal Information from children other than information that may be required for the preparation of individual tax returns. In the event that we learn that we have collected Personal Information from a child without parental consent, we will promptly take steps to delete such information. If you believe that we have received Personal Information from a child under the age of 16, you may contact us at privacy@frazierdeeter.com to request deletion of that information.

8.  YOUR PRIVACY CHOICES

We hope to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information under applicable law. We take every reasonable step to ensure that the Personal Information that we process are limited to the Personal Information that are reasonably required in connection with the purposes set out in this Privacy Notice.

If you would like to access, amend, erase, export, or object to or restrict the processing of Personal Information about you, you may submit a request to privacy@frazierdeeter.com. We will promptly review all such requests in accordance with applicable laws. When we process Personal Information about you on behalf of a Client, we must act on our Client’s instructions—including with regard to how to respond to your request.

9.   RETENTION OF PERSONAL INFORMATION

FD will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

We have implemented measures intended to ensure that we will delete your personal data when it is no longer needed to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Note, however, that if we have a legitimate interest in retaining the data, or if we are required to do so by applicable law, we will retain the data in accordance with our data retention policies.

In some circumstances we may choose to anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION

This Section of our Privacy Notice applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). This Policy is intended to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this Section.

Under applicable law, we may be considered a “data controller” or “data processor” of the personal information we handle under this Notice. In other words, FD may be responsible under applicable law for deciding how to collect, use, or disclose this information, or may instead be contracted to “process” personal information in conjunction with services we provide to a data controller, such as an employer. If you have questions about the circumstances in which we may act in these different capacities or how we may process Personal Information, you may contact us at privacy@frazierdeeter.com.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

• The right to access, update or delete the information we have collected from you. You can access, update, or request deletion of your Personal Information by using the contact information below.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Information.
• The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
• The right to data portability. You have the right to be provided with a copy of the information we have about you in a structured, machine-readable, and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where FD relied on your consent to process your Personal Information.

A.   Legal Basis for Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

• We may process Personal Information that you provide to us when you interact with our Services, such as commenting in our community blog, watching our videos, or registering for our newsletter, seminars, or podcasts; or when such processing is necessary to respond to or implement your request prior to entering into a contract with us.
• When you apply for employment through our Site, we will process your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) as necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Site.
• We use account-related data to set up accounts for users in our platform and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Services, contact you regarding your use of the Services or to notify you of important changes to the Services. Such use is necessary for the performance of the contract between you and us.
• We will send you information by email regarding our new services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.
• Our use of data relating to your use of the Site and/or the Services, described above, is necessary for our legitimate interests in understanding how the Site and the Services are being usedand to improve your experience on the Site and with our Services offerings. We have also a legitimate interest in aggregating and/or anonymizing the information that we collect through our Site and/or the Services and using this information for our business purposes, as described above. When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below.

B.  How to Exercise Your Rights Under GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for whom you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows:

Frazier & Deeter
20 St Dunstan’s Hill
London
EC3R 8HL
United Kingdom

main: +44 (0) 203 795 2569

11. YOUR RIGHTS UNDER THE UK GDPR

If you are based in the United Kingdom, the following provisions also apply:

UK GDPR means the Retained Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

If we share your personal data within FD or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.

You have the same data subject rights as those for the EU listed above, except that references to the “GDPR” should be read as references to the “UK GDPR” and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.

12.  ADDITIONAL NOTICE FOR CALIFORNIA CONSUMERS

This section of our Privacy Notice applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).

If you are a California resident, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.

A.   Right to Access and Information Regarding Personal Information

You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting or selling personal information;
• The categories of third parties with whom we share personal information;
• The specific pieces of information we have collected about you;
• The categories of personal information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of personal information for each third party to which we disclosed the personal information; and
• The categories of personal information about you that we disclosed for a business purpose.
• The categories of sensitive personal information to be collected and the purposes for which the categories of sensitive personal information are collected or used and whether such information is sold or shared, except for such information that is collected or processed without the purpose of inferring characteristics about you.

We will deliver personal information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the personal information to you electronically or by mail at your option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit the information from one entity to another without hinderance.

B. Right to Deletion of Personal Information

You have the right to request that we delete Personal Information about you that we have collected directly from you. If we have received your Personal Information from a Client, we may not be able to delete that Personal Information, as there are business requirements and contracts in place with our Clients that require us to retain some portion of your Personal Information for our financial records and for audit purposes. You may contact us as outlined below to let us know if you want your Personal Information deleted.

C. Right to Opt Out

You have the right to opt out of the disclosure of Personal Information about you for monetary or other valuable consideration. We don’t disclose your Personal Information for monetary or valuable consideration but if this changes, we will update this Privacy Notice and accept your requests regarding your preferences.

D. Right to No Discrimination

We may not discriminate against you because of your exercise of any of the foregoing rights under the CCPA, including by:

• Denying you services;
• Charging different prices or rates for services, including through the use of discounts or other benefits or imposing penalties;
• Providing you a different level or quality of services; or
• Suggesting that you will receive a different price or rate for services or at a different level or quality of services.

We may, however, charge different prices or rates, or provide a different level or quality of services, if that difference is reasonably related to the value provided to us by your personal information.

E. Personal Information We Collect about California Consumers

We describe the personal information we have collected in the twelve (12) months preceding the effective date of this Privacy Notice in the part of our Privacy Notice titled “Types of Information We Collect and Use” above. The information we collect includes the following:

Category of Personal Information Collected	Collected	Sources of Personal Information Collected	Business or Commercial Purpose for Collection	Sold	Shared
Identifiers such as name, address, email address, phone number as described in the “Types of Personal Information We Collect and Use” section above.	Yes	You Automatically Third Parties	To provide our products and Services To provide information you request To improve our products and Services To identify potential customers To market our products and Services For verifying identity For fraud prevention purposes To process payments To comply with law To offer employment, to provide insurance and benefits, and for background checks	No	No
The following categories of personal information described in California Civil Code §1798.80€: (1) the personal information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Types of Information We Collect and Use” above.	Yes	You Automatically Third Parties	To provide our products and Services To provide information you requested To improve our products and Services To identify potential clients To market our products and Services For verifying identity For fraud prevention purposes To process payments To comply with law To manage payroll and provide and administer employee benefits	No	No
Characteristics of protected classifications under California or federal law that we collect may for employees or prospective employees include Race, Gender, Age, Marital Status, voluntary disability status and Military or Veteran status.	No	N/A	To provide our products and Services to clients To improve our products and Services To offer employment, to provide insurance and benefits, and for background checks To comply with law	No	No
Commercial information, including information about services; registration information, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time.	Yes	You Automatically Third Parties	To provide our products and Services To market our products and Services To improve our products and Services To provide information you requested To comply with law	No	No
Biometric Information.	No	N/A	N/A	No	No
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, mobile apps, advertisements that we display on third party sites and apps, or pages or accounts on any third-party social media platforms.	Yes	Automatically	To provide our products and services To market our products and services To improve our products and services (e.g., usage pattern data) To track employee actions for internal reports and information security purposes	No	Yes (for marketing and analytics)
Geolocation data.	No	Automatically	To market our products and services For detecting security incidents and protecting our Site	No	No
Audio information from calls placed with us.	Yes	Automatically	To provide our products and services	No	No
Professional or employment-related information Inferences drawn from (1) the information we collect when you visit our websites, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet) and (3) information about consumers preference and behavior that we collect on our websites in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics.	Yes	You Automatically Third Parties	To provide our products and Services   To offer employment, to provide insurance and benefits, for background checks	No	No
Education information.	No	N/A	N/A	N/A	N/A
Inferences drawn from (1) the information we collect when you visit our websites, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumer preferences and behavior that we collect on our websites and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	Yes	Third Parties	To provide our products and services To market our products and services To improve our products and services For detecting security incidents and protecting our Site	No	Yes
Sensitive Personal Information such as racial / ethnic origin, political opinions, religious / philosophical beliefs, genetic data, biometric data, sex life / sexual orientation, criminal convictions, mail, email and text message content, precise geolocation data, social security, driver’s license, state identification card, or passport number, account login, financial account, debit card, or credit card number.	Yes	You	To provide our products and services To improve our products and services For detecting security incidents and protecting our Site	No	No

 

We receive some of this Personal Information from our Clients and do not collect it directly from California consumers. For more information, please see “Personal Information We Collect and Use” above.

F. Disclosures of Personal Information for Monetary or Other Valuable Consideration

We do not disclose the Personal Information we collect to other businesses or third parties for monetary or other valuable consideration.

We have disclosed Personal Information in all or substantially all of the categories identified in this Additional Notice for California Consumers for various business purposes. For more information about the categories of Personal Information we have disclosed, the categories of entities to which we have disclosed this information, and the purposes for which we have disclosed the information, please see “Disclosure of Personal Information” above.

For information regarding the purposes for which we collect and use the personal information we collect, please see “Personal Information We Collect and Use” and “Disclosure of Personal Information” sections above.

G.   Requests to Exercise Your Rights

You or your authorized agent may request to exercise the aforementioned rights by:

• Submitting a request to privacy@frazierdeeter.com
• Calling us toll-free at 866.886.2104

Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. We may limit our response to your exercise of the above rights as permitted by law.

If you use an authorized agent to submit your CCPA request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency in order to obtain the information, and you are entitled to make this request only twice in a 12-month period. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the response time period.

H.   Data Sharing for Direct Marketing Purposes

If you are a California or Nevada resident, you may ask us for a notice describing what categories of Personal Information we share with third parties or affiliates for those third parties or affiliates’ direct marketing purposes and identify the name and address of the third parties that received such Personal Information. We do not share your Personal Information with others for their direct marketing purposes. We will update this Privacy Notice if that ever changes. You can always contact us per the contact information below to let us know your preferences.

YOUR PRIVACY RIGHTS UNDER OTHER US STATE LAWS

If you are a resident of Colorado, Connecticut or Virginia, you have the right, upon a verified request, to:

• Confirm whether a controller is processing your personal data and to access such personal data;
• Correct inaccuracies in your personal data;
• Delete your personal data;
• Obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;
• Opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To exercise these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by using or contacting us using the information in the How to Contact Us section below.

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency in order to obtain the information. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident of Colorado, Connecticut, or Virginia. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the response time period.

A.   Right to Opt Out Under Applicable State Laws

Residents of Colorado, Connecticut, and Virginia have the right to opt out of the sale of their Personal Information and targeted advertising. To exercise your right, please click on .

California residents may have additional rights, as shown in the “Additional Notice for California Consumers” section above.

B.   Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions. When we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

C.   Appeals of Our Decisions

In some states, you may appeal to us if we refuse to take action on your exercise of certain choices described above. To appeal such a refusal, please contact us using the information in the How to Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. If your appeal is denied, residents of certain states can contact their attorney general as follows:

• Virginia Attorney General
• Colorado Attorney General
• Connecticut Attorney General

13.  OPTING OUT OF RECEIVING E-MAIL COMMUNICATIONS

With your permission, we may send notifications, newsletters, promotions, or other information via email (“Communications”). You may follow the unsubscribe instructions in any email you receive. You may also send a global unsubscribe request to privacy@frazierdeeter.com.

14. OTHER WEBSITES AND SERVICES, INCLUDING SOCIAL MEDIA

We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. A link to a third party’s website should not be construed as an endorsement by FD. We encourage you to investigate and ask questions before disclosing your Personal Information to third parties, including social media sites on which you choose to share your FD content.

15. CHANGES TO OUR PRIVACY NOTICE

We may modify or update this Privacy Notice from time to time, so please review it periodically. We may provide you with notice of material changes to the Privacy Notice as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY NOTICE WILL APPLY IMMEDIATELY UPON POSTING TO THE SITE.

16. HOW TO CONTACT US

If you have any questions about this Privacy Notice or the Site, please email us at privacy@frazierdeeter.com or call 866.226.2104 or write to:

Data Privacy Officer
Frazier & Deeter
1230 Peachtree Street NE Suite 1500
Atlanta GA 30309