Effective 6/8/22

Postlethwaite & Netterville (A Professional Accounting Corporation) and its affiliated or subsidiary entities (collectively, “P&N,” “we,” “our,” or “us”) provides this Privacy Policy (the “Policy”) to describe the information we collect, how we use it, and when and with whom we share it. Except as explicitly provided herein, this Policy applies only to information that we collect and use about you when you access or use our websites or other online services that links to or otherwise presents this Policy to you (collectively, the “Services”).

By accessing or using the Services, you agree to this Policy. If you do not agree to this Policy, please do not access or use the Services.

This Policy does not apply to information we process as a data processor or service provider on behalf of our clients. For example, we may provide settlement fund services, which may include the collection of personal information through settlement fund websites for receipt of claims requests. In connection with our settlement fund services, for example, we may collect your name, telephone number, email address, mailing address, government-issued identifiers, health information, date of birth, and any account information relevant to the particular settlement. To view the privacy practices specific to these settlement fund services, please review the privacy policy on the respective settlement fund website.

The Information We Collect

We obtain information about you through the means discussed below when we provide the Services. Please note that we need certain types of information to provide the Services to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain Services. The information collected depends in part on which of our Services you use.

Information you provide directly to us

We may collect information that you provide directly to us:

When you use our Services, e.g. when you register for an account;
When you fill out forms;
When you request information;
When you transmit user content to us;
When you request support or technical assistance; and
When you otherwise communicate with us through the Services.

The information you provide directly to us may concern you or others and may include, but is not limited to:

Identifiers and Contact Information. We may collect identifiers and other contact information from you, such as your name, personal email address, telephone number, and social security number.
Demographics. You may also provide us with demographic information when using the Services, such as age and gender.
Education and Employment Information. You may provide us with information about your education or employment history, including professional titles held and schools attended.
Industry and or commercial information. You may provide us with revenue or information regarding your business.

You are not required to provide us with such information, but certain features of the Services may not be accessible or available, absent the provision of the requested information.

Information from affiliates and non-affiliated third parties

We may collect information about you or others through our affiliates or through non-affiliated third parties. We may combine information that we collect from you through the Services with information that we obtain from such third parties and information derived from other products or services we provide.

Information we collect automatically

Device/Usage Information. We and our third-party service providers, which include ad networks and analytics companies such as Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Services. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); and (i) the type of device that you use. We may also track when and how frequently you access or use the Services, including how you engage with or navigate our website or mobile application. We use this information (including the information collected by our third-party service providers) for analytics (including to determine which portions of the Services are used most frequently and what our users like/do not like), to assist in determining relevant advertising (both on and off the Services), to evaluate the success of our advertising campaigns, and as otherwise described in this Policy.

Cookies and Other Electronic Technologies. We and our third-party service providers may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the Services. These technologies, for example, may allow us to tailor the Services to your needs, save your password in password-protected areas, track the pages you visit, help us manage content, and compile statistics about usage of our Services. We or our third-party service providers also may use certain of these technologies in emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Services, because the Services may not function properly. As we adopt additional technologies, we may also gather additional information through other methods.

Location Information. When you use the Services, we may collect general location information (such as general location inferred from an IP address).

How We Use Your Information

We use your information for business and commercial purposes, such as:

To provide you with the Services, including to register you for an account;
To respond to your questions or inquiries, including to provide customer support and troubleshooting assistance;
To communicate with you, including to send you emails about products and services that may interest you;
To manage and remember your preferences and personalize the Services;
To analyze and improve the Services or any other products and services we provide;
To administer surveys;
To verify your identity;
To comply with our legal obligations or as permitted by law;
To protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services;
To prevent fraud and enforce our legal terms; and
To administer and troubleshoot the Services.

We may aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also share such data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

When We Share Your Information

We may share or disclose information in the following ways:

Affiliates. We may share your information with any of our affiliates.

Consent/At Your Direction. We may disclose your information to nonaffiliated third parties based on your consent to do so. Such consent includes the disclosure of your information (a) when we have your permission; or (b) as described in this Policy, the Terms of Service, or any other legal terms governing your use of the Services.

Vendors That Provide Services to Us. We provide access to or share your information with select third parties who perform services on our behalf. They provide a variety of services to us, including data storage, analytics, billing, marketing, product content and features, customer service, data storage, security, fraud prevention, and legal services.

Protection of P&N and Others. We may share or disclose certain information if we believe in good faith that doing so is necessary or appropriate to (i) protect or defend the rights, safety, or property of P&N or third parties, including to defend or enforce our Policy, our Terms of Service, or any other contractual arrangement or (ii) respond to your requests for customer service; and/or (iii) protect the rights, property or personal safety of P&N, its agents and affiliates, its employees, users and/or the public.

Legal Requirements: We may share or disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.

Business Transfer: We may share or disclose certain information, in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Aggregate/Anonymous Information: From time to time, we may share aggregate/anonymous information about use of the Services, such as by creating reports on usage trends. The sharing of such data is unrestricted.

Online Analytics and Tailored Advertising

Analytics

We may use third-party web analytics services on the Services, such as those of Google Analytics. These service providers use the sort of technology described in the “Information we collect automatically” section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.

Tailored Advertising

Third parties whose products or services are accessible or marketed via the Services may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our websites and other sites and (b) report how our marketing content impressions, other uses of marketing services, and interactions with these marketing impressions and marketing services are related to visits to our websites. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technologies, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider in hashed, non-human-readable form.

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Link and/or the Digital Advertising Alliance’s (“DAA”) Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites, accessible by the above links.

Children’s Information

Our Services are not designed for minors under 18. Only persons 18 years of age or older may use the Services. If we discover that an individual under 18 has provided us with personal information, we will close the account and delete the personal information to the extent required by the Children’s Online Privacy Protection Act. We may, where permitted by law, retain certain information internally for purposes described in this Policy.

Security of Your Information

We implement technical, administrative, and physical safeguards to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. We cannot promise that your personal information will not be collected, disclosed and/or used by others. We are not responsible for the unauthorized use of your information nor for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

Third-Party Sites and Services

The Services may contain links to third-party websites or services. For example, the Services may include sharing buttons or “like” buttons provided by third parties like Facebook. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third parties.

Your Choices

You have certain rights and choices with respect to your information such as:

Marketing Emails: You can unsubscribe from marketing emails by following the directions in those emails.

Cookies & Analytics: You can opt out of certain cookie-related and analytics processing by following the instructions in this Policy.

Nevada Residents: Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. We do not engage in such activity.

California Residents: Please review the Supplemental Privacy Notice for California Residents to view additional information on rights and choices for California residents.

Consent to Transfer of Information

Computer systems maintain your information may be based in various countries, including in the United States. Your personal information may thus be processed in locations where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using the Services, you agree to this Policy and you consent to the transfer of all such information to our servers in the United States and elsewhere, which may not offer a level of protection equivalent to that required in the European Union or certain other countries, and to the processing of that information as described in this Policy.

Updates to Our Privacy Policy

We may change this Policy to reflect changes in the law, our information practices or the features of the Services. At the top of our Policy, we will indicate the date of the most recent update. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Policy.

Contact Us

If you have questions about this Policy, please contact us at PNWebRequest@pncpa.com.

Supplemental Privacy Notice for California Residents

This Supplemental Privacy Notice for California Residents (the “Supplemental Notice”) supplements the information in our Policy above, and except as provided herein, applies solely to California residents. Except as provided below, it applies to personal information we collect on or through the Services and through other means (such as information collected offline, in person, and over the telephone).

This Supplemental Notice does not apply to the following: (1) personal information we process in our capacity as a service provider, such as personal information processed through settlement fund services we provide to our clients; (2) personal information we collect from our employees and job applicants in their capacity as employees and job applicants; and (3) personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.

Information Collected

California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.

As described further in our Policy above, in the preceding twelve months, we or our service providers may have collected the below categories of personal information for business or commercial purposes:

Identifiers: We may collect identifiers such as name, email address, phone number, government identifiers, and other account information.
Commercial Information: We may collect commercial information, such as transaction data regarding the transactions you’ve made with or through us.
Demographic Information: We may collect demographic information.
Financial or Payment Information: We or our service providers may collect payment or other financial information, such as to process payments.
Business and Employment Information: We may collect employment and business contact information, such as job positions and titles, and business contact information.
Education Information: We may collect information regarding educational background, including schools attended.
Internet or Other Network or Device Activity: We may collect network or device information, such as an IP address, unique device identifiers, advertising and app identifiers, browsing history, or other usage data.
Location Information: We may collect general location information (such as those inferred from an IP address).
Sensory Information: We may collect audio recordings if, for example, we record customer support calls.
Personal Information Related to Protected Classifications: Our users may provide us with information that reveals information related to protected classifications, such as gender, sexual orientation, marital status, political opinions, or ethnicity.
Other Information that Identifies or Can Be Reasonably Associated With You: We may also collect other information that identifies or can be reasonably associated with you, such as when you send us communications.

We collect the categories of personal information identified above from the following sources: (1) directly from you, such as through our Services or through conferences and events; (2) through your use of the Services; (3) affiliates; and (4) third-party sites such as social media sites.

We collect the categories of personal information identified above for the following business and commercial purposes:

Provide the Services (e.g., customer service, advertising and marketing, analytics, and communication about the Services);
Operational purposes (e.g. to enable and troubleshoot our Services);
Auditing consumer interactions on our site (e.g., measuring ad impressions);
Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
Bug detection, error reporting, and activities to maintain the quality or safety of our Services;
Short-term, transient use, such as customizing content that we or our service providers display on the Services;
Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
Other uses that advance our commercial or economic interests, such as business development and third-party advertising and communicating with you about relevant offers from third-party partners;
Complying with our legal obligations; and
Other uses about which we notify you.

We describe our information sharing practices in the Policy above. For example, in the previous twelve months, we may have shared information with vendors that provide services to us or as required by applicable law.

Your California Rights

If you are a California resident, you may have certain rights. California law may permit you to request that we:

Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
Provide access to and/or a copy of certain information we hold about you.
Delete certain information we have about you.

You have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.

If you would like to exercise any of these rights, please contact us at PNWebRequest@pncpa.com. You will be required to verify your identity before we fulfill your request.

You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

California residents may opt out of the “sale” of their personal information. The CCPA broadly defines “sale” in a way that may include allowing third parties to receive certain information such as cookie identifiers, IP addresses and/or browsing behavior to add to a profile about your device, browser or you. Such profiles may enable delivery of interest-based advertising by such third parties within their platform or on other sites. Pursuant to the definition of sell under the CCPA and current guidance, we do not engage in such activity, including for minors under 16 years of age without affirmative authorization. Please note, we do share certain personal information with our service providers and certain other entities as set forth in "When We Share Your Information."

California Do-Not Track Disclosure

P&N is committed to providing you with meaningful choices about the information collected on our Services for third party purposes. That is why we have provided links (above) to the NAI “Consumer Opt-Out” link, the DAA opt-out link, and a Google opt-out link. However, P&N does not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations and solutions.