Privacy Policy

1. Introduction.

‍This privacy policy (the “Policy”) is designed to inform our customers, subscribers, and users of our website (schiffonwong.com) (the “Platform”), and other individuals from whom we collect personal information, about how Schiffon Wong LLC (“Company,” “we,” or “us”) collects, uses, and/or shares personal information in connection with the services that we provide. We take individual privacy seriously and endeavor to inform you of the uses that we have for information that we obtain from you (collectively, “Personal Information”). We will take reasonable commercial steps to protect your privacy consistent with the guidelines set forth in this Policy and with applicable federal and state laws. In this Policy, "user," “your,” or "you" refers to any individual from whom we obtain Personal Information, whether by browsing our Platform, submitting any request through our Platform, creating any account with our Platform, or participating in any other activities or accessing services through us. As the manners in which we obtain Personal Information and our uses for Personal Information may change, we encourage you to return to and reread this Policy from time to time. By accessing or using our Platform, you acknowledge that you have read, understand, and agree to be bound by this Policy. If you do not agree to the terms of this Policy, do not use our Platform.

‍‍

2. What Information Do We Collect?

We may collect two types of Personal Information from you: (i) Individualized Information, and (ii) Device Information:

‍

2.1. Individualized Information. We may collect certain Individualized Information from you when you use our Platform; submit any request for information or content, press or media inquiry, or job application to us (including through our Platform); purchase any product or service from us or request that we provide any product or service; or otherwise interact or engage with Company. Depending on the circumstances, this “Individualized Information” may include: your first and last name; the name of your organization; your email address; and information about your inquiry, such as the type of engagement you are interested in, a description of the matter or challenge you are navigating, and your desired timing. We collect this information when you choose to provide it, for example by submitting our contact form or emailing us directly. If we obtain your Individualized Information from other sources we may add it to the Individualized Information that we have already collected from you in order to improve our products, services, and/or our Platform.

‍

2.2. Device Information. We may collect certain web tracking information about the device that you use to connect to and browse our Platform. Depending on the circumstances, this “Device Information” may include, but is not limited to: information about your web browser (e.g., browser type, domain names, access times, and operating system); Internet protocol address (“IP address“); individual web pages that you have viewed; web pages or search terms that referred you to our Platform; how you interact with our Platform; the time zone in which you are located; or information about the cookies installed on your device. As described in this Policy, we may also occasionally use cookies and navigational data like Uniform Resource Locators (“URLs”) to help us collect the date and time of your visit, the information for which you searched and you viewed, and other Device Information.

‍

3. Cookies

3.1. What are Cookies? A cookie is a small file containing a string of characters that is sent to your browser when you visit a website. When you visit the website again, the cookie allows the website to recognize your browser. Cookies also may store user preferences and other information. Cookies offer a form of convenience in that they save the user time by allowing the website to identify preferences that the user has displayed or selected in the past.

‍

3.2. Why Does Company Use Cookies? Company may use cookies from time to time for several reasons. Some cookies are required for technical reasons for our Platform to operate. Other cookies enable us to track and target the interests of users to enhance their experience on our Platform. For example, depending on the circumstances, Company may use cookies to collect data regarding the specific pages or sections of our Platform that you visit. This data is used to determine which pages are most helpful to you or popular to our users in general, and to deliver customized content on our Platform to customers whose behavior indicates that they are interested in a particular subject area.

‍

3.3. How Can You Control Cookies? You can decide whether to accept, block, or reject cookies. You can generally select to accept, block, or reject cookies through your own browser controls, and you should visit your browser’s help menu for instructions on how to do so and additional information. Company is not responsible for making this selection for you. If you choose to reject cookies, you may still use our Platform, but your access to some functionality and areas of our Platform may be restricted. For more information on how cookies work and how to control them, you may visit www.allaboutcookies.org.

‍

4. How Do We Use Your Information?

4.1. Use of Personal Information. We may use Personal Information for a variety of purposes including, but not limited to: providing or communicating with you regarding our products and services (including tailoring information for you or responding to any inquiry or purchase order you have initiated); establishing and maintaining customer accounts; responding to questions you send us and otherwise providing customer service and updates regarding our products and services; processing orders and transactions (including payments); verifying customer information; detecting security incidents that may compromise the confidentiality of Personal Information in our possession; maintaining or improving the quality or safety of our Platform, products, or services; monitoring usage patterns and analyzing trends through analytical tools; processing job applications; or enforcing our legal rights or as required by applicable law or requested by any judicial process or government agency.

‍

4.2. Use of Device Information. We may also specifically use Device Information for a variety of purposes including, but not limited to: helping us screen for and prevent potential risk and fraud (in particular, through any IP address we collect from you); diagnosing and mitigating Platform errors; administering and optimizing our Platform; making our Platform, products, and services more useful to you; generating analytics about how our customers browse and interact with our Platform; assessing the success of any marketing or advertising campaigns; or storing user preferences. Using Device Information for these purposes allows us to determine which Platform features users like best and generally helps us improve and secure our Platform and personalize each user’s experience.

‍

4.3. Minimum Amount Necessary. We (including our individual staff members) will not use your Personal Information beyond the minimum amount and scope necessary to achieve the above purposes without first obtaining your consent.

‍

4.4. Aggregated Data. To the extent permitted under applicable law, we may also create statistical, de-identified, anonymized, or aggregated data (collectively, “Aggregated Data”) relating to our users and our Platform to use for analytical, research, or any other legal purposes. Aggregated Data includes data derived from Personal Information and data collected by Company from other sources that has been anonymized so that it does not relate to and could not reasonably be used to identify any individual.

‍

4.5. Email Communications. If you provide us with your email address, we may in the future begin to send you administrative or promotional emails, including newsletters or updates regarding our products and services. If you wish to opt out of any such emails, you may do so by following the "unsubscribe" instructions in the email.

‍

5. What Information Do We Share or Disclose?

5.1. Disclosure of Personal Information. We do not sell your Personal Information. We also generally will not share or disclose Personal Information with any third-parties, except in accordance with applicable law under the following circumstances:

‍

5.1.1. When you have consented to us sharing or disclosing your Personal Information.

5.1.2. When the Personal Information is shared with or disclosed to a parent company, subsidiary, joint venture, or other entity under common control with us in order to achieve any of the purposes described in Section 4.

5.1.3. Subject to the terms of a confidentiality agreement, in connection with, and for the purposes of, a business deal (or negotiation of a business deal) involving the sale or transfer of all or a part of our business or assets. These deals may include any merger, financing, acquisition, or bankruptcy proceeding.

5.1.4. With a third-party contractor engaged to provide management, administrative, data collection, marketing, or other support services on our behalf (a "Contractor"), which require the Contractor to have access to Personal Information (including as described in Section 2.2). In this instance, we generally enter an agreement with the Contractor limiting their use of the Personal Information to the minimum amount necessary to perform the services for which we have engaged them; requiring the Contractor to report any suspected or actual breach of security or other incident related to the Personal Information to us; and requiring the Contractor to adhere to the same level of privacy requirements that are required of us by all applicable law. By accessing or using our Platform, you consent to our sharing your Personal Information with any Contractors and to the Contractors’ use of your Personal Information in accordance with all applicable law, this Policy, and the other terms and conditions applicable to our Platform.

5.1.5. To detect, prevent, or otherwise address security, fraud, or technical issues.

5.1.6. To ensure the personal safety of any individual, including our staff members or job applicants, Platform users, or members of the general public.

5.1.7. To the extent required to comply with legal obligations, processes, or requests; enforce our policies, contracts, and agreements (including this Policy); or protect or defend our legal rights.

‍

5.2. Aggregated Data. To the extent permitted by applicable law, we may in our sole discretion disclose any Aggregated Data that does not contain Personal Information to any third-parties for any legal purpose.

‍

5.3. Network Operators. Use of our Platform may involve the use of third-party search engine operators or telecommunications carriers. These operators are not our Contractors, and any information that these operators collect in connection with your use of our Platform is not a part of our collected Personal Information and is not subject to this Policy. We are not responsible for the acts or omissions of these operators.

‍

‍

6. Your Rights Regarding Your Information.

6.1. Privacy Settings / Right to Remove. If you would like your Personal Information to be permanently removed from our database, please contact us by email at schiffon@schiffonwong.com or call us at 617-221-6206. We may ask you to verify your identity to assist us in processing your request. Users who have requested that their Personal Information be permanently removed may still be contacted by Company for administrative purposes. The removal of your Personal Information may take some time to complete and may be subject to certain restrictions, consistent with applicable law. Please also note that the removal of any Personal Information will not necessarily result in the removal of records of past transactions or the deletion of information stored in our data archives. Aggregated Data is not subject to requests for removal. 

‍

6.2. Access / Updates. Company will, to the best of our ability and in accordance with applicable law, allow you to access, review, correct, or add to your Personal Information held in our database. To make any such request, please contact us by email at schiffon@schiffonwong.com or call us at 617-221-6206. We will make our best efforts to process your request promptly once we receive it. Please note that we may ask you certain follow-up questions prior to processing your request in order to confirm your identity and the specific Personal Information that is the subject of your request, in accordance with applicable law.

‍

7. Additional Policies.

7.1. Security. To the extent required by applicable law, Company will utilize appropriate, commercially reasonable physical, electronic, and managerial procedures and security precautions to protect Personal Information against unauthorized access, deletion, loss, alteration, or misuse. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. We are not responsible for the actions of hackers and other unauthorized third-parties that breach our reasonable security procedures. Additionally, to the extent that your use of our Platform requires you to create an account and password, you are solely responsible for maintaining the secrecy of this login information. This Policy is not intended to confer, nor does it confer, any rights or remedies to users.

‍

7.2. Third-Party Activity. Our Platform may contain links to other websites, cookies, or other materials from, or which may be operated by, third-party entities. The information practices and privacy policies of these third-party entities may be different than those of Company. We are not responsible for any actions or omissions by any such third-party entities. This Policy applies only to Personal Information collected by Company.

‍

7.3. Data Retention. Unless you ask us to delete your Personal Information sooner, we will maintain it until such time that we determine, in our sole discretion, that (1) it is no longer necessary for any purpose for which Company may use it in accordance with this Policy; and (2) it may be destroyed or deleted in accordance with applicable law.

‍

7.4. Do Not Track. We do not respond to Do Not Track (DNT) signals or requests. DNT is a web browser setting that informs a website that you do not want to be tracked.

‍

7.5. Accessibility. Any person with a disability that prevents or restricts them from accessing this Policy through Company’s website may request a copy in an alternative format by contacting us by email at schiffon@schiffonwong.com or call us at 617-221-6206.

‍

7.6. Children. Company does not knowingly collect or maintain Personal Information from persons under 18 years of age, and no part of our Platform is directed at persons under 18. Please do not use our Platform if you are under 18. If Company learns that Personal Information of persons under 18 has been collected without verifiable parental consent, Company will delete the Personal Information.

‍

7.7. Platform Users from Outside the United States. Company and its servers are located and operate in the United States, subject to the applicable state and federal laws of the United States. Those who choose to access our Platform do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules, and regulations. We may limit our Platform’s availability, in whole or in part, to any person, geographic area, or jurisdiction we choose, at any time and in our sole discretion. We do not represent or warrant that our Platform, or any part thereof, is appropriate or available for use in any other jurisdiction. If you choose to access or use our Platform, you consent to the use and disclosure of information in accordance with this Policy and subject to all applicable laws.

‍

7.8. Amendments. Company will review this Policy from time to time and may modify or amend it as necessary to comply with applicable law. We may also update the Policy to reflect changes to our practices or for other operational reasons. If we make any material changes to how Personal Information is collected, used, disclosed, or transferred, we will notify you of these changes by modifying the version of this Policy that is available for your review on our Platform. Accordingly, we encourage you to review this Policy from time to time. Notwithstanding any modifications we may make, all Personal Information will be treated in accordance with the version of the Policy that is/was in effect at the time the Personal Information was collected, unless we obtain your consent otherwise.

‍

8. Notice for Residents of European Economic Area, United Kingdom, or Switzerland.

8.1. No Marketing to Such Residents. We do not market our services to residents of Europe, the United Kingdom (UK), or Switzerland, and are not subject to Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of Personal Information and free movement of Personal Information, known as the General Data Protection Regulation (“GDPR”), or the corresponding laws of the UK and Switzerland. If you reside in the European Economic Area (“EEA”), UK, or Switzerland, please be aware that if you voluntarily provide us with any Personal Information, that information will be transferred from your location to data centers located in the United States for processing, and this transfer will be deemed to have been made with your consent.

‍

8.2. Rights Honored. Although we are not subject to the GDPR or the corresponding laws of the UK or Switzerland, we will generally make commercially reasonable efforts to honor your data privacy rights upon request, subject to certain limitations. If you reside in the EEA, UK, or Switzerland, you have the rights, as applicable under the GDPR, to:

‍

8.2.1. Request an accounting of Personal Information that we possess that pertains to you in an electronically portable format.

8.2.2. Request that we correct or update Personal Information that pertains to you.

8.2.3. Request that we delete Personal Information that pertains to you.

8.2.4. Fully or partially withdraw your consent to the collection, processing, and/or transfer of your Personal Information.

‍

8.3. Requests and Complaints. Please contact us by email at schiffon@schiffonwong.com or call us at 617-221-6206 to request an accounting of your Personal Information, a correction or update to your Personal Information, deletion of your Personal Information, or to withdraw your consent to the collection, processing, and/or transfer of your Personal Information. We will make our best efforts to process your request promptly once we receive it unless there are legitimate grounds for further processing the Personal Information that override your interests, rights, and freedoms, or unless we further process the Personal Information only for the establishment, exercise, or defense of legal claims. If you believe we are unlawfully possessing, using, or disclosing your Personal Information, you have the right to complain to your local data protection supervisory authority. You can find contact details here: https://edpb.europa.eu/about-edpb/board/members_en.

‍

9. Contact

Please contact us by email at schiffon@schiffonwong.com or call us at 617-221-6206 in the event you have any questions for us, wish to submit a complaint about how we have processed any Personal Information, or would like to contact us for any other reasons. We will deal with any complaints or requests as soon as possible, and without prejudice to you. In the event that you submit a complaint to us, you may of course also file any complaint with a relevant government agency in the state or jurisdiction in which you live or work.