Who we are
Your privacy is important to R. Michael Brown LLC. This Privacy Notice explains how we handle and treat your personal data when you use the products or services that R. Michael Brown LLC provides.
What personal data we collect and why we collect it
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Contact forms
What We Collect:
- Name and job title
- Contact information including the identity and contact information of the company you work for and your email address, where provided
- Payment information
- Information that you provide to us as part of us providing services to you, which depends on the nature of your instructions to R. Michael Brown LLC
- Relevant information as required by Anti-Money Laundering and Anti-Bribery Regulations in the context of the Know Your Client personal data processing carried out as part of our client intake procedures. This may possibly include, documents obtained from you, evidence of sources of funds, and possibly information obtained from third party sources online or offline
- Information you provide to us for the purposes of attending meetings and events, including dietary requirements, and
- Other information relevant to provision of services.
We are committed to keeping your personal data secure and we have implemented appropriate information security policies, rules and technical measures to protect it from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
All of our partners, employees, consultants and data processors, who have access to, and are associated with the processing of personal data, are obliged to respect its confidentiality.
Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Analytics
WordPress and Google collect general analytic data. We do not have direct contact information in that analytic data.
Who we share your data with
If you request a password reset, your IP address will be included in the reset email.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where we send your data
Visitor comments may be checked through an automated spam detection service.
Your contact information
Your contact information is confidential. We will only use your contact information in the course of doing business directly with you. We will not sell or rent it.
We are committed to keeping your personal data secure and we have implemented appropriate information security policies, rules and technical measures to protect it from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
All of our partners, employees, consultants and data processors, who have access to, and are associated with the processing of personal data, are obliged to respect its confidentiality.
Additional information
We use your personal data for the purposes listed below. Whenever we process your personal data, we do so on the basis of a lawful “justification” (or lawful basis) for processing, which we have identified in the table below.
| Purpose for processing | Lawful basis | |
| 1 | To carry out administrative operations relating to agreements, orders, receipt of deliveries, invoices, payments, accounting in relation to customer accounts management, etc. | To carry out administrative operations relating to agreements, orders, receipt of deliveries, invoices, payments, accounting in relation to customer accounts management, etc. |
| 2 | To carry out administrative operations relating to agreements, orders, receipt of deliveries, invoices, payments, accounting in relation to customer accounts management, etc. | We consider that we have a legitimate interest in conducting analysis regarding our activities to help us take business decisions. |
| 3 | To provide a selection of customers for the needs of R. Michael Brown LLC. | We consider that we have a legitimate interest in maintaining a list of our customers to conduct our business operations. |
| 4 | To maintain a documentation on customers. | We consider that we have a legitimate interest in maintaining such a documentation to conduct our business operations. |
| 5 | To send you marketing communications regarding our services and products. | We consider that we have a legitimate interest in ensuring that our customers are kept up to date with information about our products and services, as this helps us to preserve our business operations or grow our business. However, where we are required by law to obtain your consent before sending you such information, we will rely upon such consent as our basis for processing. |
| 6 | To comply with our legal obligations in terms of client verifications (including any Know Your Client, Anti-Money Laundering or Anti-Bribery regulations), conflicts or similar obligations including, but without limitation, maintaining regulatory insurance. | This processing is necessary to comply with our legal obligations. However, where such legal obligations result from laws other than EU or Member State law, then we consider that we have a legitimate interest in complying with such legal obligations when non-compliance may result in sanctions or other adverse consequences for our organization or the R. Michael Brown LLC in general. |
| 7 | To comply with any applicable law, court order, other judicial process, or the requirements of a regulator. | This processing is necessary to comply with our legal obligations. |
| 8 | This processing is necessary to comply with our legal obligations. | We consider that we have a legitimate interest in ensuring that our contracts are performed correctly and in defending our rights where necessary. |
| 9 | To enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you. | We consider that we have a legitimate interest in protecting our organization from breaches of legal obligations owed to it and to defend itself from litigation. |
| 10 | To protect the rights of third parties. | This processing is necessary for the compliance with legal obligations to which R. Michael Brown LLC is subject. This processing is also necessary for the purpose of the legitimate interests pursued by R. Michael Brown LLC. We consider that we have a legitimate interest in ensuring our activities do not violate any third parties’ rights. |
| 11 | In contemplation of and/or in connection with a business transaction such as a merger, or a restructuring, or sale. | We consider that we have a legitimate interest as we need to be able to make decisions relating to the future of our business in order to preserve our business operations or grow our business. |
| 12 | Organization of marketing activities including meals or other events where information on food restrictions may be collected. | We rely on your consent to collect information for the organization of marketing activities where you may be involved, to better serve you. |
If you are an employee of one of R. Michael Brown LLC’s corporate customers, we only use your contact information for the management of the relationship with your employer. We consider that we have a legitimate interest in ensuring we can communicate with you and preserve our business operations with your employer.
Who do we disclose your personal data to?
We may share your personal data with a variety of the following categories of third parties as necessary:
- Other entities working directly with R. Michael Brown LLC (example freelance or contract workers like graphic designers, video production specialists, writers) that are working on your project.
- Third party service providers (maintenance, storage, payment, logistics, marketing services, reputation audits, etc.),
- Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter,
- Our professional advisers such as lawyers and accountants, auditors,
- Government or regulatory authorities,
- Professional indemnity or other relevant insurers,
- Regulators/tax authorities/corporate registries,
- Partners, and
- Banks
Please note this list is non-exhaustive and there may be other examples where we need to share with other parties where justified by our legitimate interest, permitted by applicable law, or necessary for compliance with a legal obligation to which we are subject.
