The General Counsel Law Firm Privacy Policy

ATTORNEY-CLIENT RELATIONSHIP DISCLAIMER

Submission of information through this website, whether via general contact forms, email links, or dedicated intake forms, does not create an attorney-client relationship between you and The General Counsel Law Firm. Furthermore, The General Counsel Law Firm does not intend to treat any unsolicited information provided through this website as confidential. You should not disclose any confidential or sensitive personal information. Please be aware that any information you provide could be used in the future against you, and we must screen all potential clients for conflicts of interest before engagement. By submitting information you acknowledge and accept these terms.

1. Introduction and Scope of This Policy

This Privacy Policy describes how The General Counsel Law Firm (“we,” “us,” or “our”) collects, uses, and discloses personal information about individuals who visit our website, www.thegeneral-counsel.com (the “Site”), and interacts with us through our online platforms. Your privacy is of the utmost importance to us, and we are committed to protecting it through our compliance with this policy and applicable law.

This Privacy Policy applies only to information collected through the Site and our public-facing online platforms. It does not cover information that you exchange with us in the course of an attorney-client relationship or as part of legal representation; such information is governed by a separate client notice and/or engagement agreement and may be subject to different confidentiality obligations (including rules of professional conduct and attorney-client privilege).

For the purposes of this policy, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Please note that contacting us through the Site does not create an attorney-client relationship. Do not submit any confidential or sensitive information through web forms; please contact us to discuss your matter separately.

Important Limitation: This Privacy Policy does not apply to Protected Health Information (PHI) as defined by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Our handling of PHI is governed exclusively by the terms of our client agreements and the Business Associate Agreements (BAAs) executed with our healthcare clients, in accordance with HIPAA’s Privacy and Security Rules.

2. The Personal Information We Collect and Its Sources

We collect Personal Information from and about you in several ways, depending on how you interact with our Site and services. This transparency is a cornerstone of our commitment to privacy and is aligned with the disclosure requirements of modern privacy laws.

• Information You Provide Directly to Us: We collect Personal Information that you voluntarily provide when you fill out forms on our Site, request information about our services, subscribe to our newsletters or other communications, or otherwise contact us directly.
• Information Collected Automatically: As you navigate through and interact with our Site, we may use automatic data collection technologies, such as cookies, web beacons, and pixels, to collect certain information about your equipment, browsing actions, and patterns. This practice is common across websites and helps us improve our Site and deliver a better, more personalized service.
• Information from Third-Party Sources: We may receive Personal Information about you from other sources, such as our business partners, data analytics providers, or publicly available sources.

The following table provides a detailed breakdown of the categories of Personal Information we may collect:

Table 1: Categories of Personal Information We Collect

Category of Personal Information	Examples of Data Collected
Individual Identifiers & Contact Information	Name, email address, phone number, mailing address, job title, company name, Internet Protocol (IP) address, and other online identifiers.
Commercial Information	Records of services you have considered or inquired about; communications with us regarding our services.
Internet or Other Electronic Network Activity	Browsing history, search history, and information regarding your interaction with our Site, advertisements, or emails (e.g., pages viewed, links clicked, access times). Device information such as operating system, browser type, and general location derived from IP address.
Inferences Drawn from Other Personal Information	Profiles reflecting a person’s preferences, characteristics, or predispositions as they relate to our business services (e.g., interest in specific service offerings).
Sensitive Personal Information	We do not intentionally collect sensitive personal information (as defined by the Florida Digital Bill of Rights, such as racial or ethnic origin, religious beliefs, or mental or physical health diagnosis) through our public Site. If you voluntarily provide such information in a free-text field or communication, we will handle it in accordance with this policy and applicable law.

3. How and Why We Use Your Personal Information

We use the Personal Information we collect for specific business and commercial purposes, in accordance with the principles of purpose limitation and data minimization. These purposes include:

• To Provide and Improve Our Services: To respond to your inquiries, provide you with information or services that you request from us, fulfill the purposes for which you provided the information, and manage our client relationships. We also use this information to maintain and improve the quality, safety, and security of our Site and service offerings.
• For Communication and Marketing: To send you informational content, newsletters, and promotional materials about our services that may be of interest to you. All such communications will comply with applicable laws, such as the CAN-SPAM Act, and will include a clear and easy way for you to opt-out of future marketing messages.
• For Analytics and Personalization: To understand how users interact with our Site, to personalize your experience, and to measure the effectiveness of our advertising and content.
• For Security and Fraud Prevention: To protect the integrity and security of our Site, systems, and business operations, including detecting security incidents, protecting against malicious or fraudulent activity, and debugging to identify and repair errors.
• To Comply with Legal Obligations: To comply with applicable laws, regulations, court orders, or other legal processes, such as responding to lawful requests from public authorities.

4. How We Disclose Your Personal Information

Except as specifically disclosed in this policy or required by law, we do not sell or share your personal information with third parties for their own direct marketing purposes.

• Service Providers and Vendors: We may share your Personal Information with third-party vendors, service providers, contractors, or agents who perform services on our behalf. These may include IT and hosting providers, customer relationship management (CRM) platforms, email marketing services, and data analytics providers. We enter into contracts with these service providers that require them to keep your Personal Information confidential and to use it only for the purposes of performing the services they provide to us, consistent with the requirements for data processors under applicable law.
• Advertising Partners: We may “share” or “sell” (as these terms are defined by applicable privacy laws) your Internet or Other Electronic Network Activity information and Individual Identifiers with third-party advertising partners to facilitate cross-context behavioral or targeted advertising on other websites and platforms; however, we do not provide Personal Information to third parties for their own direct marketing purposes except as specifically disclosed in this policy or as required by law. You have the right to opt-out of this activity, as detailed in Section 7 of this policy.
• In Connection with Business Transactions: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, or sale of all or a portion of our assets, your Personal Information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
• For Legal Reasons: We may disclose your Personal Information if we believe in good faith that such disclosure is necessary to (a) comply with a legal obligation, (b) protect and defend our rights or property, (c) prevent or investigate possible wrongdoing in connection with our services, (d) protect the personal safety of users of the Site or the public, or (e) protect against legal liability.

5. Cookies, Analytics, and Your Choices

Our Site uses “cookies” and similar tracking technologies (such as web beacons and pixels) to help us operate and improve the Site, analyze its use, and personalize your experience. A cookie is a small text file placed on your device.

Analytics and third-party tracking tools (for example, Google Analytics and similar providers) may collect and process information about your use of the Site; analytics data may be transferred outside the United States and will be processed according to the privacy practices of the analytics provider.

• Types of Cookies We Use:
  • Essential Cookies: These are necessary for the Site to function and cannot be switched off in our systems.
  • Performance and Analytics Cookies: These allow us to count visits and traffic sources so we can measure and improve the performance of our Site.
  • Advertising Cookies: These may be set through our site by our advertising partners to build a profile of your interests and show you relevant advertisements on other sites.
• Your Choices: You can control and manage cookies in several ways. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser. Please consult your browser’s help documentation for instructions. Additionally, you can opt out of interest-based advertising from many ad networks by visiting industry opt-out pages such as the Network Advertising Initiative (NAI) and the Digital Advertising Alliance (DAA). The mechanism to opt out of the “sale” or “sharing” of your data for targeted advertising is provided in Section 7.

6. Our Commitment to Data Security and Retention

We have implemented and maintain reasonable administrative, technical, and physical security safeguards designed to protect the Personal Information we collect from unauthorized access, use, disclosure, alteration, or destruction. This comprehensive approach to security is intended to satisfy the “reasonable measures” requirement of the Florida Information Protection Act (FIPA) and is aligned with the principles of the HIPAA Security Rule, reflecting a high standard of data protection. While we take commercially reasonable measures to protect your data, no security system is impenetrable, and we cannot guarantee the absolute security of your information.

We retain Personal Information for no longer than is reasonably necessary to fulfill the purposes for which it was collected, to perform our contractual and legal obligations, and for any applicable statute of limitation periods. This practice reflects the data minimization principles of modern privacy law.

7. Your Privacy Rights and Choices

In line with our commitment to proactive compliance with modern privacy standards, we provide you with certain rights regarding your Personal Information. These rights are consistent with those provided under the Florida Digital Bill of Rights (FDBR).

• The Right to Know and Access: You have the right to request confirmation as to whether we are processing your Personal Information and to access that information, including details about the categories of Personal Information collected and the purposes for which it is used.
• The Right to Correct: You have the right to request that we correct inaccuracies in the Personal Information we maintain about you.
• The Right to Delete: You have the right to request the deletion of your Personal Information, subject to certain legal exceptions (for example, where the information is necessary to complete a transaction, detect security incidents, or comply with a legal obligation).
• The Right to Data Portability: You have the right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• The Right to Opt-Out: You have the right to direct us not to do the following:
  • “Sell” or “Share” your Personal Information for targeted advertising.
  • Process your Personal Information for targeted advertising.
  • Collect your Personal Information through the operation of a voice recognition or facial recognition feature (if applicable).
• How to Exercise Your Rights: To exercise any of the rights described above, please submit a verifiable request to us by either:
  • Emailing us at info@thegeneral-counsel.com

We must be able to verify your identity before processing your request. To verify your identity we may ask you to provide information that reasonably matches the information we already maintain about you (for example, name, email address, postal address, date of birth, or the last four digits of your Social Security number). We will only request the minimum information necessary to verify your identity and will protect any information you provide in the verification process in accordance with this Policy. We will respond to your request within 45 days of receipt, though this period may be extended once by an additional 15 days where reasonably necessary. We will not discriminate against you for exercising any of your privacy rights.

Please note that contacting us through the Site does not create an attorney-client relationship. Do not submit any confidential or sensitive information through web forms; please contact us to discuss your matter separately.

8. Supplemental Notice for Florida Residents

This section provides additional information for residents of Florida, in accordance with the Florida Information Protection Act (FIPA) and the Florida Digital Bill of Rights (FDBR).

• Your Florida Privacy Rights: As a Florida resident, you have the rights detailed in Section 7 of this policy, including the rights to know/access, correct, delete, obtain a copy of, and opt-out of the sale or sharing of your Personal Information. We do not sell or share your personal information with third parties for their own direct marketing purposes, except as specifically disclosed in this policy.
• Data Security and Breach Notification: We adhere to FIPA’s requirement to implement reasonable security measures to protect your Personal Information. In the event of a data breach affecting your Personal Information, we will provide notification in accordance with FIPA’s stringent timelines and requirements.
• Sale of Data Notice:
  • If we engage in the “sale” of sensitive personal data as defined by the FDBR, this policy and our homepage will be updated to include the following notice: “NOTICE: This website may sell your sensitive personal data.”.
  • If we engage in the “sale” of biometric personal data as defined by the FDBR, this policy and our homepage will be updated to include the following notice: “NOTICE: This website may sell your biometric personal data.”.

9. HIPAA and Client Data (Protected Health Information)

This section serves as a critical and explicit clarification of the scope of this Privacy Policy.

This Privacy Policy applies only to the information collected through our public website, www.thegeneral-counsel.com, and our other public-facing online platforms. It does not govern our processing of Protected Health Information (PHI) or information exchanged with the firm in the course of legal representation; such information is governed by separate engagement agreements, client notices, and (where applicable) Business Associate Agreements (BAAs).

All PHI we receive in the course of providing services to our healthcare clients is handled in strict accordance with the HIPAA Privacy Rule, the HIPAA Security Rule, and the terms of the applicable Business Associate Agreement (BAA) in place with that client.

10. Children’s Privacy

Our Site and services are intended for a professional audience and are not directed to individuals under the age of 18. We do not knowingly collect Personal Information online from children. This policy is in accordance with the Children’s Online Privacy Protection Act (COPPA). If we become aware that we have inadvertently collected Personal Information from a child under the age of 18 without parental consent, we will take steps to delete such information from our systems promptly.

11. External Links and Third-Party Websites

Our Site may contain links to other websites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

12. International Users and Data Transfer

Our Site is hosted and operated in the United States. If you are visiting the Site from outside the United States, your information will be transferred to, stored, and processed in the United States in accordance with U.S. law, which may not be as comprehensive as the laws in your country. By using our Site, you consent to this transfer.

13. Updates and Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post any changes on this page and update the “Last Updated” date at the top of this policy. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

14. How to Contact Us

If you have any questions, comments, or concerns about this Privacy Policy, our data practices, or if you wish to exercise your privacy rights, please do not hesitate to contact us at:

Email: info@thegeneral-counsel.com

If you need this policy in another format due to disability, please contact us for assistance.

Analytics data may be transferred outside the United States and processed according to the privacy practices of the analytics provider.