IN-HOUSE FOCUS, LLC PRIVACY POLICY

Effective as of January 1, 2019

In-House Focus, LLC (“IHF” or “we”) produces, aggregates and distributes legal content and continuing legal education in the form of live and recorded educational programs and webcasts hosted on our website at www.inhousefocus.com and/or available on our mobile app(s) (the “Service”). We are committed to protecting the privacy of individuals who come to our website and/or access our Service. We may collect information about you in connection with the Service. This Privacy Statement describes IHF’s privacy practices in relation to the collection of your information and use of our website and Service. By providing Personal Information (defined below) to us, you agree to the terms and conditions of this Privacy Policy. If you, or an entity you are affiliated with (for example as an employee or a partner), has entered into a separate Subscription Agreement with IHF, such Subscription Agreement may contain additional terms and conditions regarding collection and use of your information. In the event of a conflict between the provisions of this Privacy Policy and the applicable Subscription Agreement, the terms of the Subscription Agreement shall govern.


PERSONAL INFORMATION

What is Personal Information?

“Personal Information” is information that identifies you as an individual, which may include your name, mailing address, telephone number, fax number, credit card information, professional/bar license number and email address.   If you provide any Personal Information relating to other people to us or to our service providers in connection with the Service, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

How Personal Information May Be Collected

We and our service providers may collect Personal Information in a variety of ways, including:

  • Through the Service: When you use the Service we may collect Personal Information, for example, when you create an account, register for a program, complete an evaluation of a program, request a completion certificate, make a purchase or otherwise interact with the Service.
  • Offline: We may collect Personal Information from you offline, such as when you attend one of our live programs, place an order over the phone or contact customer service.
  • From Other Sources: We may receive your Personal Information from other sources, such as public databases; joint marketing partners; social media platforms; from a company or law firm with which you are affiliated pursuant to their subscription to the Service; from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties.

How Personal Information May be Used

We and our service providers may use Personal Information: To complete and fulfill your purchases, for example, to process your payments, grant you access to the Service, communicate with you regarding your subscription and use of the Service and provide you with related customer service.

  • To respond to your inquiries and fulfill your customer support requests.
  • To send you newsletters, brochures, catalogs and e-mails.
  • To send administrative or billing information to you.
  • To send you changes to our terms and policies.
  • To send you highly targeted marketing communications based on your interests and practice areas.
  • To personalize your experience by presenting products and offers tailored to you.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Service, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed:

  • To our third-party service providers who provide services to support the Service such as video streaming, account and platform management, CLE accreditation, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and other similar services.
  • By you, on message boards, Q&A forums, chat rooms, profile pages and blogs.
  • To a third party in the event of any reorganization, merger, sale, joint venture, partnership, assignment, license, transfer or other disposition of all or any portion of our business, content, assets or ownership interests (including in connection with any bankruptcy or similar proceedings).
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • If you access the Service through a subscription provided by another party, such as a company or law firm with which you are affiliated or employed, we may share your information, including Personal Information, with that party.

We do not sell, or otherwise provide, your Personal Information to third parties for their use in marketing their products and services to you.


OTHER INFORMATION

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

  • Browser and device information
  • Information collected through cookies, pixel tags and other technologies
  • Demographic information
  • Program preferences, evaluations, feedback and other information provided by you
  • Aggregated information

provided that in all of the foregoing examples, the information does not reveal your specific identity.

 

We and our third-party service providers may collect Other Information in a variety of ways, including:

  • Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Service functions properly.
  • Through the use of our apps: When you download and use one of our apps, we and our service providers may track and collect app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device number.
  • Using cookies: Cookies are data stored directly on the computer that you are using. Cookies allow us to collect data such as browser type, time spent on our website and Service, pages visited, language preferences, searches run, anonymous traffic data, among other non-personal information. We, and our service providers, use the information for security purposes, to aid navigation, display information more quickly, and to personalize your experience while using our Service. We can recognize your computer to assist your use of our website and Service. We also gather statistical information about the usage of our website and Service to continually improve the design and functionality, understand how visitors and customers use our website and Service, and to assist us with resolving questions regarding our website and Service. Cookies further allow us to select which of our offers are most likely to appeal to you and display them while you are on our website and Service. We may also use cookies in online advertising to track responses to our advertisements. If you do not want information collected through cookies, you may be able to decline cookies through settings in your internet browser; however, your use of our website and Service may not function properly. For example, we may not be able to recognize your computer, and you may need to log in every time you access the Service.
  • Analytics: Third-party services, such as Google Analytics, may be used in connection with the Service. Such third-party services, including Google Analytics, may use cookies and similar technologies to collect and analyze information about the Service use and to report on activities and trends. Such services may also collect information regarding the use of other websites, apps and online resources. For more information regarding Google Analytics, please go to www.google.com/policies/privacy/partners/; you can download the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.
  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
  • IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels of the Service, helping diagnose server problems, and administering the Service.
  • From you: Information such as your location, your preferred means of communication, company, professional role/title, program preferences, evaluations and feedback, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Service.
  • By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Service, (for example, we may aggregate Personal Information to calculate the percentage of our users who are licensed in a particular state).

How We May Use and Disclose Other Information

We primarily use and disclose Other Information in order to better understand user preferences and trends, what users watch, what they like and dislike and why. This information informs our content strategy and pipeline in terms of presenters, topics and format, all in an effort to continually improve our programs, enhance the user experience and maximize the value of the overall offering to our audience. We may also use and disclose Other Information to third parties in connection with content development, marketing initiatives, surveys and publications, and other strategic initiatives.

 

If we are required to treat Other Information as Personal Information under applicable law, then we will use it as described in the “Personal Information” section above.   In some instances, we may combine Other Information with Personal Information (such as combining your name with your zip code). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.


THIRD-PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which our website or the Service contains a link. The inclusion of a link on our website or the Service does not imply endorsement of the linked site or service by us or by our affiliates.   Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Service. Currently we use a third- party CLE platform provider, CE21 LLC, to deliver our content, track program attendance and manage user accounts (which may include the storage of Your Personal Information). Please note that we are not responsible for CE21 LLC’s usage and disclosure of Your Personal Information. For information regarding their policies and practices please visit https://www.ce21.com/privacy-policy/.


THIRD-PARTY ADVERTISERS

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access or use our website or the Service. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit https://tools.google.com/dlpage/gaoptout and http://optout.networkadvertising.org/?c=1#!/.


SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100 percent secure. Please also be aware that we use third-party service providers (e.g., CE21 LLC) that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us in accordance with the “Contact Us” section below.


CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

  • Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by sending an email to cle@inhousefocus.com or follow the unsubscribe instructions included in the footer of our marketing-related emails.
  • Receiving telephone calls, fax messages or postal mail from us: If you no longer want to receive marketing-related telephone calls or postal mail from us on a going-forward basis, you may opt-out of receiving these marketing communications by sending an email to cle@inhousefocus.com and specifying the contact information used and form of marketing from which you are opting out.

We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt-out from receiving such administrative messages.

How you can access or change or delete your Personal Information

If you would like to request to review correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by writing to us at cle@inhousefocus.com or to Personal Information Request, In-House Focus, One Market Street, Spear Tower, 36th Floor, San Francisco, CA 94105.   In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.   Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).


RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.


USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Information through the Services.


UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised. Your use of the Services following these changes means that you accept the revised Privacy Policy.


CONTACTING US

If you have any questions about this Privacy Policy, please contact us by email at cle@inhousefocus.com, or please write to the following address:   In-House Focus Attn: Director of Marketing One Market Street, Spear Tower, 36th Floor, San Francisco, CA 94105   Please note that email communications are not always secure; so please do not include credit card information or sensitive information in your emails to us.

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