PRIVACY POLICY

Privacy Policy

Effective Date: March 16, 2021

Sweeney Conrad, P.S. (“Sweeney Conrad,” “the Company,” “we,” “us,” or “our”) is committed to privacy and data protection. This Privacy Policy applies to personal data Sweeney Conrad collects from you, through our interactions with you, through www.sweeneyconrad.com and other websites or services under the control of Sweeney Conrad that link to this Privacy Policy. (collectively “Services”), as well as how we use and protect your personal data. You can download a printable copy of this Privacy Policy here.

YOUR PRIVACY IS IMPORTANT TO US. PLEASE READ THIS PRIVACY POLICY TO LEARN ABOUT THE INFORMATION THAT SWEENEY CONRAD COLLECTS FROM YOU AND HOW SWEENEY CONRAD USES THAT INFORMATION.

BY USING THE SERVICES YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SERVICES.

Scope

This Privacy Policy does not apply to any third party applications or software that integrate with our Services, or any other third party services or businesses (collectively, “Third Party Services”). Third Party Services are governed by their own privacy policies. We recommend you review the privacy policy governing any Third Party Services before using them.

This Privacy Policy does not apply to any Service that does not display, reference, or link to this Privacy Policy.

California Residents: If you are a resident of California you may have additional rights regarding your personal information. Please review our California Consumer Privacy Act (“CCPA”) Section below regarding your rights under the CCPA.

Personal data we collect

Sweeney Conrad collects data to provide the Services you request, ease your navigation on our website, communicate with you, and improve your experience using our Services. Some of this information is provided by you directly, such as when you access our ShareFile site. Some of the information is collected through your interactions with our Services. We collect such data using technologies like cookies and other tracking technologies, error reports and usage data collected when you interact with the Sweeney Conrad website.

We also obtain data from third parties or use third parties to assist us with data collection. We also use services from other companies to help us determine a location based on your IP address, notably to customize certain Services to your location. In addition, we utilize third party services to collect usage data.

The data we collect depends on the Services and features thereof that you use, and includes the following:

Name and contact data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. We process passwords and related security information used for authentication and ShareFile account access and information security purposes.

Financial data. Information about your finances, such as your tax records, financial information, and other information we need to provide our services, such as your assets, liabilities, income and expenses.

Payment data. We collect data necessary to process your payment if you make payments online, such as such as a credit card or debit card number.

Job application and internship data. We collect information regarding your employment history, resume, references, education (including GPA), and other information to help us evaluate you for an internship or employment with Sweeney Conrad.

Usage data. We collect personalized information about your use of our Services, to better understand uses thereof and identify potential improvements, as well as to send you promotional communications or offers tailored to your use of our Services and interest thereto.

Examples include:

  • Information on the web pages you visit on and off our website.
  • Information regarding the performance of our Services and any problems you may experience while using them. This information enables us to diagnose problems and offer support in resolution.
  • Data about your device and the network you use to connect to our website, including IP address, device identifiers and regional and language settings.

Web requests. We collect information regarding every web request sent to the relevant servers. This information is used to provide support, as well as to assess usage and performance of our Services. The data collected for each request can include such things as timestamps, any exception messages, user agent, IP address and request time and duration.

Location data. We collect your IP address and infer location such as city or postcode therefrom, when necessary in order to provide you with the Services or to send you promotional communications or for client relationship management purposes.

Content. We may collect the content of messages you send to us, such as feedback or questions you ask our technical support representatives, when necessary to provide you with the Services you use. We will collect and utilize any data files you send to us for troubleshooting and improving our Services. When you contact us, phone conversations or chat sessions with our representatives may be monitored and recorded in order to improve our Services and facilitate the processing and resolution of your request or complaint.

How we use personal data

We will only use your personal data when the law allows us to and 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.

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

Sweeney Conrad uses information that we collect from clients and visitors for the purposes of:

  • Providing our services;
  • Processing payments;
  • Providing ongoing support;
  • Evaluating you for a job or internship;
  • Communicating with you;
  • Providing information about other Services;
  • Helping us run our company, for example to improve our Services or our security, train staff or perform marketing activities;
  • Complying with our legal obligations; and
  • Accounting and other administrative purposes.

Examples of the uses of information include:

Providing Services. We use data to provide services to you. Often, this includes financial data, contact data, and other personal information. We may collect additional information when you register to use the Services, including contact information and credentials. We may use this data to diagnose and address problems and provide other support services.

Sweeny Conrad may use ShareFile to exchange personal, financial, and other information with you. You may be asked to create an account with and log into the ShareFile service. We do not control and are not responsible for the ShareFile service. For more information about ShareFile’s privacy practices please visit: https://www.sharefile.com/.

Evaluating You for a Job or Internship. By emailing your cover letter and resume to resume@sweeneyconrad.com, we will use your data to evaluate you for any potential job openings

Improving Services. We use data to continually improve our Services, including adding new features or capabilities. Data is collected throughout your interactions with our Services that enable us to understand client usage and tailor future capabilities.

We track general, non-personalized information (e.g., operating system, browser version and type of device being used) to know how many people visit specific pages of our Services or utilize specific areas of our Services so that we may improve those Services. We may use your IP address to customize Services to your location, such as the language displayed on our Services.

Please note that we use IP addresses on a highly restrictive basis to analyze trends, to administer the site, and to collect general information for aggregate use.

Service Communications. We use data we collect to deliver and personalize our communications with you. For example, we may contact you by email or other means to notify you of changes in information and updates to our Services or to our Privacy Policy.

Marketing and event communication: We use personal data to deliver marketing and event communications to you across various platforms, such as email, direct mail, social media and online via our Services. For information about managing email subscriptions and promotional communications, please visit the “Your Rights Regarding Personal Data” Section of this Privacy Policy.

Processing Payments: If you make a payment to Sweeney Conrad, we will ask for Payment Information and other information requested for processing your payment. We use third party payment processors to assist in securely processing your Payment Information. If you pay with a credit card, the Payment Information that you provide through the Services is encrypted and transmitted directly to the payment processor. We do not store your Payment Information and do not control and are not responsible for the payment processors or their collection or use of your information.

All payments received via credit card are processed securely by Sweeney Conrad’s payment processing vendors using measures that comply with the Payment Card Industry Data Security Standard (“PCI DSS”).

How we share personal data

It is the policy of Sweeney Conrad to protect users' information both online and off-line. Access to our users' information is restricted to only those employees or agents, contractors or subcontractors of Sweeney Conrad who have valid reasons to access this information to perform any Service you have requested or authorized, or for any other purpose described in this Privacy Policy. The information you provide will not be sold or rented to third parties.

We may provide your personal data to:

  • Sweeney Conrad-controlled affiliates and subsidiaries, located in and outside your country or region;
  • outsourced service providers who perform functions on our behalf, located inside or outside of your country or region. For example, when you provide payment data to pay online, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction;
  • anyone expressly authorized by you to receive your personal data;
  • anyone to whom we are required by law to disclose personal data, upon valid and enforceable request thereof.

Sweeney Conrad may share personal data if Sweeney Conrad or one of its affiliates is involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control (in whole or in part). In such an event, Sweeney Conrad requires that the Personal Data shared be subject to a confidentiality agreement in favor of Sweeney Conrad.

We will access, disclose and preserve personal data when we have a good faith belief that doing so is necessary to:

  • comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies, upon valid and enforceable request thereof; or
  • operate and maintain the security of our Services, including to prevent or stop an attack on our computer systems or networks.

Please note that some of our Services may direct you to services of third parties whose privacy practices differ from Sweeney Conrad’s privacy practices. If you provide personal data to any of those services, your data is governed by their privacy statements or policies. Sweeney Conrad is not responsible for the privacy practices of these other websites. Please review the privacy policies for those websites to understand how they process your information.

Handling of personal data

Security of Personal Data

Sweeney Conrad is committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal data. We review our strategies and update as necessary to meet our business needs, changes in technology and regulatory requirements.

These measures include, but are not limited to, technical and organizational security policies and procedures, security controls and employee training.

You are responsible for maintaining the security of your account credentials for the Services. Sweeney Conrad will treat access to the Services through your account credentials as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

If we become aware of a breach that affects the security of your personal data, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, Sweeney Conrad will provide any such notice that Sweeney Conrad must provide to you at your account’s email address. By using the Services, you agree to accept notice electronically.

Storage and Transfer of Personal Data

Personal data collected by Sweeney Conrad may be stored and processed in your region, in the United States or in any other country where Sweeney Conrad maintain facilities. We take steps to ensure that the data we collect under this Privacy Policy is processed pursuant to the terms thereof and the requirements of applicable law wherever the data is located.

Sweeney Conrad also collaborates with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business and clients. In some cases, we may need to disclose or transfer your personal data within Sweeney Conrad or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal data is processed, secured and transferred according to applicable law.

If you would like to know more about our data transfer practices, please contact us at information@sweeneyconrad.com.

Retention of Personal Data

Sweeney Conrad retains personal data for as long as necessary to provide the Services and fulfill the business relationship, or for other business purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g., statute of limitations). If your personal data is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.

Your rights regarding your personal data

Sweeney Conrad respects your right to access and control your personal data. You have choices about the data we collect. When you are asked to provide personal data that is not necessary for the purposes of providing you with our Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features or Services.

We aim to keep all personal data that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact us at information@sweeneyconrad.com.

Access to personal data: In some jurisdictions, you have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).

If you are a corporate user of our Services (which means your employer is a Sweeney Conrad client of such Services): please first request access to your personal data with your employer. Your employer will then be in touch with us with respect to your request.

Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data is required to provide you with the services you requested, e.g. to send an invoice to your email address, or that it is required by the applicable law.

Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via e-mail, postal mail or telephone about Sweeney Conrad services and events that may be of interest to you, including our newsletter.

E-mail communications you receive from Sweeney Conrad will generally provide an unsubscribe link allowing you to opt-out of receiving future e-mail or to change your contact preferences. Please remember that even if you opt-out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.

You can also request changes to your account and marketing preferences by emailing Sweeney Conrad at information@sweeneyconrad.com.

California Shine the Light Law: California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to information@sweeneyconrad.com or write us at: Sweeny Conrad, P.S. 2606 10210 NE Points Dr., Suite 300, Kirkland, WA 98033.

Cookies & similar technologies

Sweeney Conrad uses cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (“Cookies”) to provide our website and help collect data. This Cookies Policy describes how we use Cookies to collect information about the way you use our website, and how you can control them.

How We Use Cookies

We use Cookies to track how you use the website by providing usage statistics. Cookies are also used to deliver Sweeney Conrad information (including updates) based upon your browsing history and previous visits to the website. Information supplied to us using Cookies helps us to provide a better online experience to our visitors and users and send marketing communications to them.

We may combine the information we collect via Cookies with personal data that we have collected from you to learn more about how you use our website to improve them.

Types of Cookies

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our website can be grouped into the following categories:

  • Strictly Necessary: These Cookies are necessary for the website to work properly. They include any essential authentication and authorization cookies for our website.
  • Functionality: These Cookies enable technical performance and allow us to “remember” the choices you make while browsing our website, including any preferences you set. They also include sign-in and authentication cookies and IDs that enable you to return without additional sign-in.
  • Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the website running on your device. They help us understand which areas you use and what we can do to improve them.
  • Targeting: These Cookies are used to deliver relevant information related to our website to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit our website. Some of these types of Cookies on our website are operated by third parties with our permission and are used to identify advertising sources that are effectively driving clients to our website.

Cookies Set by Third Party Services

To enhance our content and to deliver a better online experience for our users, we sometimes embed images and videos from other websites on the Sweeney Conrad website. We currently use, and may in the future use, content from websites such as Facebook, LinkedIn and Twitter. You may be presented with Cookies from these third party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the third parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using cookies or other means. You should consult and review the relevant third party privacy statement or policy for information on how these cookies are used and how you can control them.

We also use Google, a third party analytics provider, to collect information about website usage and the users of the website, including demographic and interest-level information. Google uses cookies in order to collect demographic and interest-level information and usage information from users that visit the website, including information about the pages where users enter and exit the website and what pages users view on the website, time spent, browser, operating system and IP address. Cookies allow Google to recognize a user when a user visits the website and when the user visits other website. Google uses the information it collects from the website and other website to share with us and other website operators’ information about users including age range, gender, geographic regions, general interests and details about devices used to visit website. We do not link information we receive from Google with any of your personally identifiable information. For more information regarding Google’s use of cookies and collection and use of information, see the Google Privacy Policy (available at https://policies.google.com/privacy?hl=en). If you would like to opt-out of Google Analytics tracking, please visit the Google Analytics Opt-out Browser Add-on (available at https://tools.google.com/dlpage/gaoptout).

Other Similar Technologies

Sweeney Conrad web pages may use other technologies such as web beacons to help deliver cookies on our website and count users who have visited the website. We also may include web beacons in our promotional email messages or newsletters to determine whether you open and act on them as well as for statistical purposes.

In addition to standard cookies and web beacons, our Services can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally.

How to Control and Delete Cookies

Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the “Help” section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access the website, you will need to manage your Cookie preferences across these environments.

If you are using a mobile device to access our website, you will need to refer to your instruction manual or other help/settings resource to find out how you can control Cookies on your device.

Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the website may not operate properly, and you may not have access to our webpages available through the website. Except as required by applicable law or this Privacy Policy, Sweeney Conrad shall not be liable for any impossibility to use the website or degraded functioning thereof, including where such are caused by your settings and choices regarding Cookies.

To learn more about cookies and web beacons, visit www.allaboutcookies.org.

Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Sweeney Conrad, do not respond to DNT signals.

Children's privacy

SERVICES ARE NOT INTENDED FOR CHILDREN

You must be at least the age of majority in your place of residence to use the Services. The Services are not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to inform the child (or his or her parent or legal guardian) that he or she cannot use the Services.

California Minors: While the Services are not intended for anyone under the age of 18, if you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: information@sweeneyconrad.com. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or information. Removal of your content or information from the Services does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.

California residents

Information We Collect

Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, the Services collect or may have collected the following categories of personal information in the last twelve (12) months. We obtain the categories of personal information as described below and in the “Personal Data We Collect” section above.

We may collect the following categories of personal information:

  • Identifiers. Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Such as name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
  • Commercial information. Information about your transactions with us, such as your account balances, investments and tax information and information we need to prepare a financial plan, such as your assets, liabilities, income and expenses.
  • Internet or other similar network activity. Such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  • Geolocation data. Such as physical location or movements.
  • Professional or employment-related information. Such as current or past job history or performance evaluations.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the business purposes indicated in the “How We Use Personal Data” section above.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the categories of third parties listed in the “How We Share Personal Data” section above.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • Identifiers
  • California Customer Records personal information categories
  • Commercial information
  • Internet or other similar network activity
  • Geolocation data
  • Professional or employment-related information

We do not sell personal information. In the event that we do sell any personal information, we will update this Privacy Policy to list the categories of consumers’ personal information sold.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Access Specific Information and Data Portability Right

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed your personal information for a business purpose, the business purpose for which personal information was disclosed, and the personal information categories that each category of recipient obtained.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Exercising Your Rights

To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at: (800) 729-7811
  • Mailing us at: Sweeney Conrad, P.S.
    Attn: Privacy Policy Issues
    10210 NE Points Dr.,
    Suite 300
    Kirkland, WA 98033

For submissions via email, please complete and send us a completed copy of this Verifiable Consumer Request Form.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make such a request for access or data portability twice within a 12-month period. 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, and describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

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. Making a verifiable consumer request does not require you to create an account with us. 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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your 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 your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Changes to this privacy policy

We may update this Privacy Policy based upon evolving laws, regulations and industry standards, or as we may make changes to our business including our Services. We will post changes to our Privacy Policy on this page and encourage you to review our Privacy Policy when you use our Services to stay informed. If we make changes that materially alter your privacy rights, Sweeney Conrad will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should discontinue your use of the Services. You may also request access and control of your personal data as outlined in the “Your Rights Regarding Personal Data” Section of this Privacy Policy.

Questions or complaints handling

We understand that you may have questions or concerns about this Privacy Policy or our privacy practices or may wish to file a complaint. In such case, please contact us in one of the following ways:

Email: information@sweeneyconrad.com
Phone: (800) 729-7811
Mail: Sweeney Conrad, P.S.
Attn: Privacy Policy Issues
10210 NE Points Dr., Suite 300, Kirkland, WA 98033