Data Privacy at Tower Legal Solutions
Please note, however, that additional or different terms may apply in connection with a particular Service. We will inform you of any such additional or different terms either: (i) before we collect Personal Information that will be subject to those terms; or (ii) before we use or disclose previously collected Personal Information in accordance with those terms. We also may ask for your consent to particular uses and/or disclosures of your Personal Information. To the extent that there is any conflict between this Policy and any such separate consent or other terms, your consent and/or the other terms (as applicable) will apply.
By providing us with your Personal Information (including by providing any authorization for us to obtain your Personal Information from a third party) and/or by using this Site or our Services, you agree that we may use and disclose your Personal Information in accordance with this Policy. If you do not consent to these terms, you should not use this Site or our Services or otherwise provide us with any Personal Information.
“Personal Information” means information that we are required by law to protect and that: (a) personally identifies you; or (b) may not personally identify you, but reasonably might be used to identify you or your computing device. Personal Information does not include information that does not identify you and cannot reasonably be used to identify you or your computing device on an individual basis, such as “de-identified,” anonymized, or aggregated data.
“Sensitive Personal Information” means Personal Information that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sex life, or trade-union memberships.
“Site” means http://www.towerls.com/, all web pages hosted at that domain, and any other web page that directly links to this policy when you click on “Privacy Statement” in the website footer.
EU and Swiss Safe Harbor Compliance
(collectively, the “Safe Harbors“). Tower Legal Solutions has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement with respect to such Personal Information.
Among other things, this means that if your Personal Information is subject to the Safe Harbors, we will give you the opportunity to opt out of any use of your Personal Information or any Disclosure of your Personal Information to a third party for a purpose that is incompatible with the purpose(s) for which it was originally collected or which you have subsequently authorized. To the extent that we provide your Personal Information to a third party that is acting as our agent, we will require the third party to subscribe to the Safe Harbor Privacy Principles or verify that it is subject to legal or contractual requirements to provide at least an equivalent level of privacy protection. We also will take commercially reasonable steps to ensure that your Personal Information is reliable for its intended use, accurate, complete, and current.
We have further committed to refer unresolved privacy complaints under the U.S.-EU and U.S.-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, which is operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if we do not satisfactorily address your complaint, please visit the BBB EU Safe Harbor website at http://www.bbb.org/council/eusafeharbor/bbb-eu-safe-harbor-dispute-resolution-program/ for more information and to file a complaint.
To learn more about the Safe Harbor program, and to view Tower Legal Solution’s certification, please visit http://www.export.gov/safeharbor/.
Personal Information We May Collect
Below are examples of the types of Personal Information that we may collect or receive from you or others in order to provide our Services or otherwise in connection with your use of our Site. We make commercially reasonable efforts only to collect such Personal Information as is relevant to its intended purpose(s). Please refrain from providing us with more or different Personal Information than we request (for example, do not include Sensitive Personal Information or other private information like a government identification number in a résumé; wait until we ask for such information).
- Contact information for you (e.g., from referral sources or clients; from you or your résumé, business cards, and communications to us; or from forms you complete such as to obtain a newsletter or to be included in our staffing databases). Typical examples include name, title, postal and email addresses, telephone numbers, and fax numbers.
- Professional information: This may include information about your employment, compensation, work history, education, preferences, résumé, language abilities, skills, and so on. We use this information only in connection with the legal staffing services that we perform for our clients and do not sell or rent your information to any third parties.
- Background checks, verification, applications, references and interview information, etc.: If you are providing information to us in connection with a search for employment or a temporary staffing position, we and/or our client may obtain Personal Information about you from third parties, such as background checks and verifications of your references, work history, and other professional information. To the extent that we are required to do so, we may ask you to separately consent to such communications (e.g., by providing us with your written authorization to obtain a credit report or background check from a consumer reporting agency).
- Sensitive Personal Information: Depending upon the Service, and subject to applicable law, we may ask you to provide us with Sensitive Personal Information. We will only use and disclose such Sensitive Personal Information for the purpose(s) for which you provide it to us or for such purposes as you subsequently may affirmatively authorize.
- Publicly Available Personal Information: We might obtain Personal Information about you from public records and/or other publicly available sources, such as newspapers, press releases, industry or trade organization directories, the Internet, lawfully accessible social media, and so on.
- Security Data: We might also collect or receive Personal Information about you for security purposes to the extent that you interact with us physically. For example, if you go to one of our offices for an in-person interview, your image might be captured on a security camera, or we might ask you to provide Personal Information in order to verify your identity and/or to provide you with an access badge or identification card.
- Site Usage Data: As discussed in more detail below under “Cookies and Other Technologies,” we may obtain Personal Information about you in connection with your use of our Site by using cookies and other tracking technologies.
Cookies and Other Technologies
If you use the Site, it may collect certain information about you and/or your computer or other access device through the use of “cookies” and other tracking software or tracking mechanisms (collectively, “Technologies“). This information may be included in databases owned and maintained by Tower Legal Solutions or its service providers. Tower Legal Solutions retains all rights to these databases and the information contained in them.
A cookie is a small text file that our Site delivers to the hard drive of your computer, phone, tablet, or other device when you access our Site. The next time that you visit the Site, our web server will detect whether you have one of our cookies on your computer in order for us and/or our service providers or business partners to collect data about your use of the Site and/or other web pages that you have visited. We may use a technology known as a “web beacon“—sometimes called a single-pixel GIF—to collect “web log” information. A web beacon is a graphic on a web page or in an email message designed to track pages viewed or messages opened. Our server gathers web log information when you visit one of our websites, including information such as the date and time you visited our site, the pages you visited, the website you came from, the type of browser you are using (e.g., Mozilla Firefox), the type of operating system you are using (e.g., Windows 7), and the domain name and address of your Internet service provider (e.g., Outlook.com). We also may include web beacons in promotional email messages in order to determine whether and when messages have been opened. Please note, however, that the Technologies that we may use may differ depending upon the device that you use to access the Site and may change as Technologies and access channels develop or change.
Cookies and other Technologies help us to add functionality to the Site and to analyze site usage more accurately. The types of information that we may collect through cookies and other Technologies include, but may not be limited to, your IP address and information about your browser, including whether you are accessing the site through a mobile device. We generally may use or otherwise disclose this information in order to provide Services to you or to our clients and for purposes of Site functionality (e.g., to remember your log-in information), but we generally reserve the right to use and disclose such information for any lawful purpose.
California Disclosure. CA Bus. & Prof. Code § 22575 requires us to disclose how our Site responds to web browser “do not track” signals and/or other mechanisms that seek to provide consumers with the ability to control the collection of information through online tracking Technologies for certain purposes, such as targeted or behavioral advertising.
How We May Use and Disclose Personal Information
We may use and disclose Personal Information to provide Services to you and/or to our clients, to administer the Site, and to otherwise perform obligations, exercise rights, and further the activities for which the Personal Information was provided to us. For example, we may provide Personal Information that you have provided to us in connection with a temporary staffing engagement (e.g., information about your professional experience) to our employer clients.
Subject to applicable law, other reasons that we may use or disclose your Personal Information include, but are not limited to:
- To fulfill your requests, such as including your résumé in our database(s) or registering you as a newsletter subscriber, or otherwise in accordance with this Policy and/or your express consent;
- To provide Services to our clients, which may ask us to provide them with Personal Information that you have provided to us or that we otherwise have lawfully obtained;
- To enable potential employers to evaluate your candidacy;
- To create de-identified, anonymized, aggregated, or similar non-personally-identifiable data, which we may use for any lawful business purpose (e.g., we may use aggregate compensation information from similarly situated candidates to help clients set compensation levels);
- To engage in routine business uses and disclosures that an ordinary and reasonable person should expect in the context of the Services that we provide, the reasons for which we collect Personal Information, and/or the ways that similar businesses ordinarily operate, including, for example, uses and disclosures:
- To meet our obligations and enforce our rights, to make disclosures to our agents, contractors, or partners, in connection with the Services that these individuals or entities perform for, or with, Tower Legal Solutions (e.g., service providers, information technology providers, mailing and other business process providers, outsourcing providers, data processing services, and so on). These third parties are restricted from using this data in any way other than to perform services for or in collaboration with Tower Legal Solutions;
- To better understand your needs and to operate and improve our Site, Services, and business;
- For security, antifraud, authentication, and verification purposes;
- To respond to questions or requests or to contact you for lawful purposes, including for surveys;
- To vendors and their service providers who reasonably need the Personal Information to do their jobs;
- To verify your identity, authority, professional history, or other information;
- To respond to or participate in commercial disputes (e.g., lawsuits or investigations);
- To persons appearing to have a lawful interest in the Personal Information (e.g., to an insurance company processing an insurance claim involving you); or
- To comply with applicable law;
- In connection with a merger or other business combination or separation (including, but not limited to, a voluntary or involuntary change in our business or structure, reorganization, sale of all or part of our stock or assets, spinoff, bankruptcy, or dissolution);
- To respond to legal process or regulatory authorities (such as subpoenas; warrants; investigative demands from law enforcement, regulators, or others; national or international security letters or demands; etc.);
- To protect against fraud, claims, or other liability or harm to you, us, or others;
- To exercise or perform a legal, ethical, contractual, or other right or obligation, including enforcing an agreement you or a client made; and
- For such lawful purposes as may be disclosed or evident at the time that you provide Personal Information to us, such as to contact you and/or provide you with information about our Services (e.g., when you provide Personal Information in response to a survey, to sign up for an event, or to register for a newsletter).
It is not possible for us to list every lawful use that we might make of Personal Information, so the uses and disclosures described above are nonexclusive illustrations. We reserve the right to engage in any lawful use or disclosure of Personal Information that is consistent with this Policy. Note, however, that we will not engage in any of the uses described above to the extent that they are prohibited by applicable law. We may obtain separate consents from you (or make separate disclosures to you) regarding particular uses or disclosures of Personal Information, to the extent that we are required to do so.
We use what we believe to be commercially reasonable measures to protect your Personal Information from loss, misuse, or unauthorized access, disclosure, alteration, or destruction. Nevertheless, please be advised that no security measure, system, or control is infallible. WE ACCORDINGLY DO NOT GUARANTEE THE SECURITY OR CONFIDENTIALITY OF PERSONAL INFORMATION AND DISCLAIM ANY EXPRESS OR IMPLIED WARRANTIES, DUTIES, OR CONDITIONS IN THAT REGARD. If any applicable law imposes on us a duty with respect to these matters that cannot be disclaimed, you acknowledge and agree that our commercially reasonable precautions shall be considered to satisfy that duty unless (and only unless) we have engaged in willful misconduct.
Please also note the following:
- When Personal Information is provided to us in the expectation that we will provide it to one or more of our clients (e.g., in connection with a staffing matter), we do not control, and assume no responsibility for, that Personal Information once it is in the client’s hands. While we typically ask our clients to keep such Personal Information confidential, we cannot guarantee that they will do so.
- You also have a role in the security of your Personal Information. For example, you should not provide us with Personal Information that we do not request, you are responsible for controlling access to any personal computing device through which your Personal Information may be stored or accessed, and you are responsible for safeguarding any passwords or other log-in credentials that may be used to access to your Personal Information.
Data Access and Integrity
If you want to access, change, or delete Personal Information that we may maintain about you, you may submit a request to us by writing to us at the following address:
Tower Legal Solutions
Attn: Privacy Officer
65 Broadway, 13th Floor
New York, NY 10006
We will honor requests submitted through other means if required by law or if we determine in our sole discretion to do so.
We reserve the right to deny your request, subject to applicable law. For example, we may deny a request to access Personal Information where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where such access would compromise the rights of other persons.
We may respond to a request to access Personal Information by supplying a copy of or access to the relevant Personal Information within a reasonable time. As a general matter, this means that we will respond in no less time than is needed by us or our service providers to retrieve that information from our systems or records in the ordinary course of business.
We also may keep a record of changes or deletions and use or disclose that record for lawful purposes. If you ask us to delete Personal Information, the information may be immediately deleted. However, if technical constraints prevent us from easily doing so, we instead may take reasonable measures to prevent internal or external access to such information until it is deleted from our systems or records (such as by being overwritten).
Subject to any legal right that you may have to require us to delete your Personal Information, we may keep Personal Information for as long as is necessary for our business and legal needs, and we reserve the right to retain it to the fullest extent required or permitted by law. Note, however, that you should retain your own records, because we also may delete Personal Information in our discretion at any time, unless the deletion would be detrimental to your legitimate interests or would violate retention periods set by law, statute, or contract.
We do not charge for responding to requests to access, change, or delete Personal Information. If we have a duty to require third parties to delete or cease using Personal Information, we may satisfy that duty by sending them notice to do so without further action on our part (except as expressly required by law).
We may provide notifications to you that are required by law or that are for marketing or other business-related purposes. Subject to applicable law, we may provide such notifications to you via email, in hard copy, or through conspicuous posting on our Site. We reserve the right to determine the form and means of providing notifications to you.
You may manage your receipt of marketing and other non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or by writing to Tower Legal Solutions at the following address:
Tower Legal Solutions
Attn: Privacy Officer
65 Broadway, 13th Floor
New York, NY 10006
Please note that you may continue to receive materials while we update our contact lists. Also note that you may not be able to opt out of receiving transactional emails related to your relationship with Tower Legal Solutions.
You should be aware that this site is not intended for, or designed to attract, individuals under the age of 18. We do not collect Personal Inforamation from any person we actually know is an individual under the age of 18. If a minor has provided us with Personal Information without parental or guardian consent, the parent or guardian should contact us at email@example.com, and we will use commercially reasonable efforts to delete that Personal Information, subject to applicable law and this Policy.
Other Privacy Policies
The Site might link to or have functionalities that lead to other sites or services maintained by third parties. If you access such third-party sites or services, any information that you provide to such parties will be subject to their privacy policies and procedures and not to this Policy. You agree, however, that if such third parties provide your Personal Information to us, this Policy will apply to what we receive.
We may update, revise, supplement, or replace this Policy from time to time. When the Policy changes, we will post the substitute version and change the effective date listed at the beginning of the Policy. To the extent not prohibited by law, any amendment or update to this Policy will apply to Personal Information that we have already collected and to any Personal Information that we may subsequently obtain.
When required by applicable law, however, we may provide you with advance notice of any changes to this Policy and with an opportunity to object to such changes. If you exercise your right to object, the changes will not become effective with respect to your Personal Information, but your ability to use our Services may be terminated or impaired. We will explicitly notify you of the consequences of objection or non-objection to the extent and in the manner required by law.
At least once a year we will investigate our compliance with this Policy through a reassessment. We have procedures for taking appropriate action against those who violate this Policy when they are required to follow it.
EFFECTIVE DATE: APRIL 23, 2014