Privacy Policy
Last Updated: August 30, 2024
This policy is governed by Florida law except where other laws provide otherwise.
Marlowe Law does not intentionally provide any services to California residents; however, to the extent a California resident may use our website or complete a form, this policy also explains the rights of California residents regarding the collection, use, sale, and sharing of their personal information under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We may update and make changes to this policy, so we encourage you to review it periodically.
- Key Terms. It would be helpful to start by explaining some key terms used in this policy:
We, us, our | Ronald J. Marlowe, P.A. dba Marlowe Law
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Ronald J. Marlowe | Managing Attorney 2202 N West Shore Blvd Suite 200 Tampa, FL 33607 [email protected] |
Personal information | Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household.
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Sensitive personal information | Personal information revealing a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, and citizenship or immigration status.
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Biometric Information | An individual’s physiological, biological, or behavioral characteristics, including information about an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. |
- Personal Information We Collect About You. In the preceding 12 months, we have collected the following categories and specific types of consumer personal information:
Categories of Personal Information | Specific Types of Personal Information Collected |
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, bank account information, or other similar identifiers) | Depending on your legal matter, we may collect extensive personal identification information about you including, but not limited to, your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, and other similar identifiers
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Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
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Depending on your legal matter, we may collect any or all of this information as well as additional information, as necessary, related to your matter |
Characteristics of protected classifications under state or federal law | Protected documents shall be protected in accordance with state and federal law. We do not keep or store any credit card or bank account numbers. To the extent you provide these to us or our processor for payment, these are held in an encrypted form by a third-party payment processor in encrypted form in accordance with federal (and state) law. We encourage you to directly input them into our payment system rather than provide them by phone to us for security reasons.
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Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
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Depending on your legal matter, we may collect such commercial information as may be relevant to your legal matter |
Biometric information | We do not collect any biometric information at this time
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Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement) | We do not collect any Internet or other electronic network activity information except as may be necessary to validate an Internet session and validate payment through third-party payment processors
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Geolocation data | We collect geolocation data for the purpose of validating the ability to provide legal services to prospective clients
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Audio, electronic, visual, thermal, olfactory, or similar information | We do not collect any audio, electronic, visual, thermal, olfactory, or similar information except with the consent of the consumer and then only to the extent necessary to establish an audio and/or video conference call
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Professional or employment-related information | Depending on your legal matter, we may collect such professional or employment-related information as may be relevant to your legal matter but only with your consent
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Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)
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We do not collect education information except with your consent |
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | We may draw inferences from the information obtained or shared by you as to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We do not share this information without your consent
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Sensitive Personal Information | Depending on your legal matter, we may collect other sensitive personal information needed to adequately represent you. We do not share this sensitive personal information without your consent |
- How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information from the following categories of sources:
- Publicly accessible sources (e.g., property records);
- Third party (e.g., sanctions screening providers, credit reporting agencies, customer due diligence providers, advertising networks, internet service providers, social networks, data analytics providers, government entities, and data brokers);
- Third party with your consent (e.g., your bank);
- Cookies on our website;
- Automated information collection;
- Our IT systems, including:
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems; and
- Our Client Portal.
- Why We Use Your Personal Information. We collect consumer personal information for the following business purposes:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;
- Debugging to identify and repair errors that impair existing intended functionality;
- Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, providing legal services, verifying customer information, processing payments, providing storage, or providing similar services on behalf of the law firm;
- Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer;
- Undertaking internal research for technological development and demonstration;
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business;
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party (to the extent permitted by law and ethical guidelines); or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for | Our reasons |
To provide services to you | For the performance of our contract with you or to take steps at your request before entering into a contract
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To prevent and detect fraud against you or Marlowe Law | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
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Conducting checks to identify our clients and verify their identity
Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator
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To comply with our legal and regulatory obligations |
Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies | To comply with our legal and regulatory obligations
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Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
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Operational reasons, such as improving efficiency, training, and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
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Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
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Statistical analysis to help us manage our business, e.g., in relation to our performance and efficiency | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
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Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
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Updating and enhancing client records | For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
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Statutory returns | To comply with our legal and regulatory obligations
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Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
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Marketing our services to:
—existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.
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For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers |
External audits and quality checks | To comply with our legal and regulatory obligations |
- Who We Share Your Personal Information With. In the preceding 12 months, we have shared consumers’ personal information with:
- Service providers we use to help deliver our services to you, such as payment service providers and delivery companies;
- Other third parties we use to help us run our business, such as marketing agencies or website hosts;
- Third parties approved by you;
- Our bank;
- Our payment processors;
- External auditors and bookkeepers.
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
- Categories of Personal Information We Shared. In the preceding 12 months, we have shared the following categories of personal information:
- Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
- Characteristics of protected classifications under state or federal law;
- Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement);
- Geolocation data;
- Audio, electronic, and visual information;
- Professional or employment-related information;
- Education information, defined as information that is not publicly available personally identifiable information as defined in the FERPA; and
- Sensitive personal information
- Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
- Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
- Characteristics of protected classifications under state or federal law;
- Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement);
- Geolocation data;
- Audio, electronic, visual, thermal, olfactory, or similar information;
- Professional or employment-related information;
- Education information, defined as information that is not publicly available personally identifiable information as defined in the FERPA; and
- Sensitive personal information
- How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. Our typical records retention policy is to maintain key records for two (2) years and all other records for seven (7) years; however, we reserve the right to delete any records sixty (60) days following the conclusion of our representation if permitted by law.
- Your Rights Under the CCPA/CPRA. We do not intentionally represent any citizens/residents of California. If this Privacy Policy should apply to any California resident, you have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You | You have the right to know, and request disclosure of:
• The categories of personal information we have collected about you, including sensitive personal information; • The categories of sources from which the personal information is collected; • Our business or commercial purpose for collecting, selling, or sharing personal information; • The categories of third parties to whom we disclose personal information, if any; and • The specific pieces of personal information we have collected about you. Please note that we are not required to: • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or • Provide the personal information to you more than twice in a 12-month period. |
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose | In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:
• The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose. You have the right to opt-out of the sale of your personal information or sharing of your personal information for targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION FOR TARGETED BAHAVIORIAL ADVERTISING. THEREFORE, THERE IS NO OPT-OUT PROVISION AVAILABLE AS YOU ARE AUTOMATICALLY OPTED-OUT. |
Right to Limit Use of Sensitive Personal Information | You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, if the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and · As authorized by further regulations. You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. NO CALIFORNIA RESIDENT’S INFORMATION WILL BE USED FOR ANY OTHER PURPOSE AND, ACCORDINGLY NO OPT-OUT PROVISION IS PROVIDED.
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Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
• Delete your personal information from our records; and • Direct any service providers or contractors to delete your personal information from their records. • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.
Please note that we may not delete your personal information if it is reasonably necessary to:
• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes; • Debug to identify and repair errors that impair existing intended functionality; • Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law; • Comply with the California Electronic Communications Privacy Act; • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; • Comply with an existing legal obligation; or • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. |
Right of Correction | If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. |
Protection Against Retaliation | You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:
• Deny goods or services to you; • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; • Provide a different level or quality of goods or services to you; or • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information. |
- How to Exercise Your Rights if a California Resident. If you are a California resident, your rights under this Privacy Policy are automatic once we are advise of your state of residence. You may advise of us your residence here: ____________________. You may also call us at 813-575-7702 or email us at [email protected].
Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly by website/email/phone/in writing, you will need to provide us with:
- Enough information to identify you (e.g., your full name, address);
- Proof of your identity and address (e.g., a copy of your driving license and a recent utility or credit card bill); and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
- Correction of Personal Information. You have the right to access, correct and delete certain personal information. We do not knowing maintain incorrect information except for archival purposes or as may be required by law. We will correct or delete information except as may be required by law. You may request deletion or correction of material and we will fulfill that request in the same manner as provided in Section 9 for California residence under “Right for Deletion” and “Right to Correction.”
- How to Exercise Your Rights if not a California Resident. If you are not a California resident, you may exercise your rights under Section 11 for deletion or correction here: ____________________. You may also call us at 888-MARLOWE (627-5683) or email us at [email protected]. If you are a client, you also may use the Client Portal.
If you choose to contact us directly by website/email/phone/in writing, you will need to provide us with:
- Enough information to identify you (e.g., your full name, address);
- Proof of your identity and address (e.g., a copy of your driving license); and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
We partner with Thomson Reuters, who might also collect data as part of our marketing efforts. To learn more about the Thomson Reuters privacy policy and the data that might be collected, please visit: Thomson Reuters Privacy Statement.