Privacy Notice for California Residents
Last Updated: June 30, 2023
This Notice does not apply to personal information collected from California-based job applicants, which is subject to the California Job Applicant Privacy Notice.
This Notice explains our online and offline practices in connection with the collection, processing, and disclosure of personal information relating to California consumers. Specifically, this Notice applies to our processing activity when we are acting as a “business” under the CCPA—meaning that we control the purposes and means of processing your personal information.
As a law firm, we may also process personal information during our legal representation of a client, such processing is performed on behalf of and at the direction of our client, subject to our client agreements and professional responsibilities, and is not covered by this Notice.
Some of the personal information we collect may be subject to other data protection laws and may be exempt from some or all of the requirements under the CCPA. Accordingly, please read this Notice carefully before sharing information with us so you understand our practices regarding your information.
Information We Collect and Disclose
As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, or household. Personal information does not include deidentified or aggregated consumer information, certain regulated information, or information made available to the general public.
In the past twelve (12) months, Fredrikson has collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for the business or commercial purposes described below.
|Categories of PI Collected
|Categories of Third Parties to Whom Disclosed
|A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
|A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, or employment information.
Some personal information included in this category may overlap with other categories.
|Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|Internet or other similar network activity.
|Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
|Voicemail or similar audio recordings.
Please note that we may also use, disclose, or transfer your information in connection with the sale, merger, dissolution, restructuring, divestiture, or acquisition of our company or its assets. We may also disclose your personal information in response to a court order, subpoena, search warrant, law, or regulation.
Collection of Personal Information
Fredrikson collects these categories of personal information from the following categories of sources:
- Direct collection: We collect information directly from you when you choose to provide it to us by filling out forms on our website, signing up to receive emails or other information from us, communicating with us, visiting our offices, attending an event, webinar or presentation, engaging us to provide legal services, paying for services from us, or otherwise directly providing the information to us (such as by submitting a query on our website).
- Collection via social media: We may collect personal data about social media users. The type and scope of personal data obtained from social media platforms depends on the type of APIs and permissions set out by the respective platforms and the administrative permissions granted by customers, where applicable.
- Third-party collection: From time-to-time, we may receive marketing, lead, or invitee lists from third parties, including in connection with events that we are co-hosting with other law firms or companies.
Sensitive Personal Information
Fredrikson does not collect “sensitive personal information” (as defined by the CCPA) for the purposes of inferring characteristics about California consumers. Accordingly, Fredrikson treats such information as “personal information” consistent with applicable provisions of the CCPA.
Use of Personal Information
- Providing and administering legal and other services to our clients;
- Optimizing your experience on our website and ensure that our content is presented to you in the most effective manner;
- Communicating with you and responding to your inquiries about our services and legal issues that may be relevant to you, including providing you with information that you request from us about our activities or events, notifying you about changes to our website or any services we offer, and investigating any concerns you have about our services;
- Researching, developing, and improving our services, including by improving our knowledge and insights regarding clients and potential clients;
- Managing our business relationships with our clients, vendors and suppliers, including carrying out our obligations and enforcing our rights arising from any agreements, processing invoices and collecting payments;
- Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the website or use of our services;
- Protecting and maintaining the safety, security and integrity of our firm, our rights or property (including our website, databases, and other technology assets), to protect someone’s health, safety, or welfare, and to comply with a law or regulation, court order, our ethical obligations, or other legal process; and
- Performing other functions as otherwise described to you at the time of collection.
Applicable Retention Periods
For each category of personal information identified above, we will retain your personal information only for as long as necessary to fulfill your requests or the purposes for which it was obtained, as set forth in this Notice. The criteria used to determine our retention periods include (a) to fulfill the purpose for which the information was collected, (b) for as long as we have an ongoing relationship with you, and (c) as required by a legal obligation to which we are subject.
Disclosure of Personal Information
As indicated above, we may share some of the personal information with third-party service providers and vendors as necessary for our business purposes. For example, such vendors could include our marketing service providers that assist us with managing our promotional communications. From time to time, Fredrikson may also be required to disclose your information to governmental authorities for the purpose of complying with applicable laws and regulations or in response to legal process.
Sale or Sharing of Personal Information
In the past twelve (12) months, Fredrikson has not “sold” any categories of personal information, or “shared” any such information for the purposes of cross-context behavioral advertising Likewise, Fredrikson does not have actual knowledge of any sales or sharing of personal information regarding minors under 16 years of age.
Your Rights Under the CPPA
Subject to exceptions, the CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.
1. Right to Request Access Information. You have the right to request that we disclose certain information about our collection and use of your personal information during the past 12 months. Specifically, you may request that we disclose:
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- The business and commercial purposes for collecting your personal information;
- The categories of third parties with whom we disclosed your personal information;
- The specific pieces of personal information we collected about you; and
- If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party.
2. Right to Data Portability. You have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible. Consistent with the CCPA and our interest in the security of your personal information, we will not provide copies of certain personal information we may receive from you (e.g., social security number, driver’s license number, other government-issued identification number, financial account number, health or medical identification number, account password, or security questions or answers) in response to a CCPA request, to the extent any of those items are in our possession.
3. Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.
4. Right to Correct Inaccurate Information. If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
5. Right to Opt-Out. Consumers in California have the right to opt-out of (a) the sale of personal information, or (b) the sharing of their personal information for the purposes of cross-context behavioral advertising (as defined in the CCPA). Because Fredrikson does not “sell” or “share” personal information, these rights are not available.
Exercising Your Rights
To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by sending an e-mail to: CAPrivacy@fredlaw.com with the subject line: “CCPA Request” or calling us at 1-800-865-4804. Your request must include your name, e-mail address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. In order to protect the privacy and data security of consumers, the verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such consumer; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We may also request that you provide additional information if needed to verify your identity or authority to make the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or the consumer on whose behalf you are making the request.
Response Timing and Format
The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response via e-mail. Except as otherwise required by the CCPA, any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request, provided that you may request disclosure beyond the 12-month period as permitted by the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another. We will not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request.
Our Commitment Not to Discriminate
Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by:
- Denying you goods or services.
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Providing you a different level or quality of goods or services.
- Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Data Disclosures for Direct Marketing Purposes
California Civil Code § 1798.83 (California’s Shine the Light Act) further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from providing your personal information to certain third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.
Changes to Our Privacy Notice
We reserve the right to amend this Notice at our discretion and at any time. If there are changes to this Notice, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes. Please check this page periodically for updates.
If you have any questions or comments about this Notice, please contact us at:
Fredrikson & Byron, P.A.
Attn: CCPA Inquiries
60 South Sixth Street
Minneapolis, MN 55402-4400