Privacy Policy

Effective Date: December 1, 2022

Last modified: December 1, 2022

The Law Office of Josh Brown LLC (“we,” “us,” “our” "Brown" ) is committed to protecting the privacy of your information. The following Privacy Policy sets forth our practices regarding the collection, use, and disclosure of the information we receive through your use and navigation of www.smallbusinesscounselors.com (“website”). This Privacy Policy may occasionally change, so please refer to this page periodically to check for updates.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using this website, you agree to this Policy. This Privacy Policy may occasionally change, so please refer to this page periodically to check for updates. Your continued use of the website after we make changes is deemed to be acceptable of those changes.

Scope

This Privacy Policy applies to our website and any subdomains of our website, unless explicitly stated otherwise, regardless of the medium in which it is accessed (e.g., via a web browser or mobile browser).

This Privacy Policy does NOT apply to information you provide to or that is collected by any third party, including through any application or content that may link to or be accessible from the website (such as the Payment Portal).

The Information We Collect About You

We may collect different types of information from you when you use or navigate our website:

Personal Information: When you use and navigate the website, we may collect personally identifiable information, such as your name, mailing address, email address, telephone number, work or educational history, gender, and other information that may be used to identify you or contact you (collectively, “Personal Information”) from you only when you provide such Personal Information to us voluntarily.

Website Usage Information: When you use and navigate our website, we may collect additional information from you that may not by itself reasonably identify you as the source (collectively, “Usage Information”). Usage Information may include, but is not limited to, information regarding your computer, your IP address, the type of Internet browser you are using, the location from which you are visiting the website, the type of computer operating system you are using to access the website, the domain name of the website from which you linked to the website, or the areas of the website you visited and the actions you performed on the website.

How We Collect Information

We may collect information about you from a variety of sources:

Directly From You. We collect Personal Information from you when you voluntarily provide such information to us by, for example, completing one of our various website forms to contact us, subscribing to receive email news alerts or information regarding our firm’s activities, registering to attend one of the firm’s events, and submitting a job application.

Through Your Use of the Website. Our systems may record your Usage Information as you use and navigate our website. For example, our servers automatically record Usage Information that your browser transmits when you visit our website. We also may automatically collect Usage Information about how you access and interact with the website through the use of automated tracking technology. We may use cookies, which are small data files that are transferred to a web browser, which enables our website to remember and customize your subsequent visit. Most Internet browsers automatically accept cookies. You can instruct your browser to block the acceptance of cookies or to provide you with a warning prompt before you accept a cookie from the website. Please refer to your Internet browser’s instructions to learn more about these functions. If you reject cookies, the functionality of the website may be limited, and you may not be able to participate in several of our website’s features. Additionally, we may use web beacons, which are single-pixel, electronic images embedded in the website that allow us to gather information about your browsing activities on the website. We may also use certain third-party applications, which may use cookies, to gather and analyze information about your browsing activities on the website.

From third parties, such as our trusted business partners. Some content on the website and in our communications to you are served by third parties, including content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you interact with our website and other communications, such as email news alerts. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different online services.

How We Use Information

We may use information about you in the following ways:

Personal Information: We may use your Personal Information, which you voluntarily provide to us, for a variety of purposes, including to:

Directly contact you to respond to messages or inquiries that you submitted using our website forms;
Send you periodic updates about the firm’s insights and activities via email, in accordance with your subscription preferences and from which you may opt-out of receiving;
Process your job applications;
Analyze the effectiveness of our marketing activities; and
Manage our everyday business needs.

Usage Information: We may also use your Usage Information for a variety of purposes, including to:

Analyze website users’ browsing and usage activities and patterns to better understand users’ interests and preferences with respect to our services; and
Research the effectiveness of the website, which will help us to improve the website.

How We Disclose Information

We do not sell your information to third parties. We may, however, disclose your information to third parties in the following ways:

Third-Party Services Providers: We may share your Personal Information with third parties who assist us with our marketing efforts. We may also share your Usage Information, including cookies, with third-party applications and web analysis providers. For example, we share your Usage Information with Google Analytics, a web analysis services provided by Google. Google Analytics plants a cookie on your web browser to identify you as a unique user each time you visit the Site, but the cookie cannot be used by anyone but Google. We use Google Analytics to analyze Usage Information and assist us in researching the effectiveness of our website and understanding website users’ preferences. Google’s ability to use and share information collected by Google Analytics about your visits to our website is restricted by the Google Analytics Terms of Use, located at https://www.google.com/analytics/terms/us.html, and Google’s Privacy Policy, located at http://www.google.com/policies/privacy. You may prevent Google Analytics from recognizing your future visits to the website by disabling cookies on your browser or installing Google Analytics’ opt-out browser add-on, which can be accessed at https://tools.google.com/dlpage/gaoptout.

Law Enforcement, Safety, and Legal Processes. We may share your Personal Information and/or Usage Information with law enforcement or other government officials if it relates to a criminal investigation or alleged criminal activity. We may also disclose your Personal Information and/or Usage Information if required or permitted to do so by law; for fraud protection and credit risk reduction purposes, or in the good-faith belief that such action is necessary to protect and defend the rights or property of Brown or the users of the website; and to act under urgent circumstances to protect the safety of Brown, its employees, or a member of the public. We may also disclose your information to comply with a judicial proceeding, court order, subpoena, or legal process.

Sale or Acquisition of Assets. If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, we may disclose and/or transfer your Personal Information as part of the transaction.

Security of Personal Information

We understand the importance of keeping personal information safe and secure. We take reasonable measures to protect the information we collect from you. However, the transmission of information via the Internet is not, and cannot be made, completely secure. We cannot and do not guarantee, ensure, or warrant that Personal Information will be completely secure from misappropriation by attack actors or from other nefarious or criminal activities, or from the failure of computer hardware, software, or a telecommunications network. We will notify you, as required by law, if we discover a security breach involving your personal information (as defined by the applicable state and federal laws) processed by us.

Brown cannot be responsible for disclosures of your Personal Information due to errors in transmission or unauthorized acts of third parties, and encourages you to exercise prudence in selecting the information you send via the Internet, including via email. Please do not send confidential or sensitive information to us through our website or via email until you speak with one of our attorneys and receive authorization to do so.

Individuals in the European Economic Area

Under the European Union’s (EU) General Data Protection Regulation (GDPR), individuals in the European Economic Area have additional privacy rights:

Right to be Informed. Individuals have the right to transparency regarding our collection of personal data.
Right of Access. Individuals have the right to know exactly what information is held about them and how it is processed.
Right of Rectification. Individuals will be entitled to have personal data rectified if it is inaccurate or incomplete.
Right to Erasure. Also known as 'the right to be forgotten', this refers to an individual's right to having their personal data deleted or removed without the need for a specific reason as to why they wish to discontinue.
Right to Restrict Processing. An individual's right to block or suppress processing of their personal data.
Right to Data Portability. This allows individuals to retain and reuse their personal data for their own purpose.
Right to Object. In certain circumstances, individuals are entitled to object to their personal data being used.
Rights of Automated Decision Making and Profiling. The GDPR has put in place safeguards to protect individuals against the risk that a potentially damaging decision is made without human intervention.

To exercise the above rights, please contact us at the information provided below. We will consider and process your request within a reasonable period of time. Please be aware under certain circumstances, the GDPR may limit your exercise of these rights.

California Residents Privacy Rights

This section is our Privacy Notice for California Residents (“Notice”) and applies to visitors, users, and others who reside in the State of California (“consumers,” or “you/your”) and use our Services. This notice is provided to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.

Scope

This California Notice applies to the personal information we collect, both online and offline, about California consumers, including personal information that we collect:

from users of our website, including the services available via our website;
about clients and individuals who use or inquire about our legal and related services that we make available (“Services”);
about individuals who attend events hosted or sponsored by us, reply to our emails or communications, visit our offices, or otherwise communicate or engage with us; or
about individuals from clients and others related to the Services we provide.

This California Notice does not address or apply to:

our handling of personal information that is exempt under Section 1798.145 of the CCPA,
personal information we collect about employees, contractors or job applicants or other individuals who are not California residents, or
personal information we collect about individuals acting in their capacity as representatives (“B2B contacts”) of our clients, prospective clients, vendors and other businesses that we conduct business with, to the extent we use their personal information only in the context of conducting our business relationship with the respective business.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or devices ("Personal Information").

Personal Information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We collect different types of information from users, and we use and/or disclose this information for different business purposes. The chart below identifies the Personal Information we may collect and lists the parties with whom we may share this information and for what business purpose:

Category of Personal Information

Specific Personal Information that may be collected

Purpose of collecting the Personal Information

Categories of sources from which the personal information is collected

Is this category of Personal Information shared with third parties?

Categories of third parties with which the Personal Information may be shared

Purpose of disclosing or sharing Personal Information

Identifiers

Name, mailing address, email address, gender, and telephone number; financial payment information; IP address; account information

To uniquely identify an individual in support of business activities

From you

Yes

Services Providers

Business processes

Commercial information

Bank account details, contact information, client services history

To support business transactions

From your engagement and transactions with us

Yes

Services Providers (payment processor)

Business processes

Internet or other similar network activity

IP address; browser type and version; browsing history, search history, information on a consumer's interaction with a website, application, or advertisement

To allow access to and optimize our website and business operations

From you and third party technologies

No (but we may share aggregated statistical or demographic data with our services providers)

Services Providers

Improve Website functionality, servicess

Inferences drawn from other Personal Information

Your product or services preferences based on responses to our own or our third party’s marketing or promotions

Personalization

From you and external data sources

In limited circumstances

Marketing partners

Marketing

How We Collect Personal Information

We obtain the above categories of Personal Information directly from you, automatically as you navigate through the website, and from third parties, such as our trusted business partners, as described above (see “Information We Collect About You and How We Collect Information”).

Use of Personal Information

We do not sell your Personal Information. We may use or disclose the Personal Information we collect for one or more of the purposes listed in the chart above.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose and have disclosed in the past 12 months Personal Information to third parties for business purposes as set forth in the chart above and in this Privacy Policy. In the preceding twelve (12) months, we have not sold Personal Information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

1. Access to Specific Information and Data Portability Rights.

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Your Rights” section), we will disclose to you:

§ The categories of Personal Information we collected about you;

§ The categories of sources for the Personal Information we collected about you;

§ Our business or commercial purpose for collecting or selling that Personal Information;

§ The categories of third parties with whom we share that Personal Information;

§ The specific pieces of Personal Information we collected about you (also called a data portability request;

§ If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

· Sales, identifying the Personal Information categories that each category of recipient purchased; and

· Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

2. Deletion Request Rights.

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Your Rights” section), we will delete (and direct our services providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our services provider(s) to:

§ Complete the transaction for which we collected the Personal Information, provide a good or services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

§ Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

§ Debug products to identify and repair errors that impair existing intended functionality.

§ Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

§ Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

§ 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

§ Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

§ Comply with a legal obligation.

§ Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

3. Exercising Your Rights.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

§ Calling us at (614) 284-4394

§ Emailing us at info@smallbusinesscounselors.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

§ Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

§ Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Please be aware that under certain circumstances, the CCPA may limit your exercise of these rights.

4. Response Timing and Format.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

§ Deny you goods or services.

§ Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

§ Provide you a different level or quality of goods or services.

§ Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other Provisions

Accessing and Updating Personal Information and Opting-Out. If you would like to access, update, or modify your Personal Information or request us to delete your Personal Information, you may do so by contacting us at the contact information listed below. Further, if you would like to opt-out of receiving emails or other communications directly from us, you may do so by following any instructions included in the email or other communication or by contacting us at the contact information listed below. Opting-out from our communications or modifying, updating, or deleting your Personal Information will not result in the modification, updating, or deletion of any Personal Information that may reside in back-up or disaster-recovery storage.

Do Not Track Signals. Certain web browsers and other devices you may use to access the website may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, the website does not respond to "Do Not Track" signals.

Children Under 13. We do not market to and do not knowingly collect any Personal Information from or about a child under the age of 13 without the consent of the child’s parent or legal guardian. If we discover that we have inadvertently collected information from a child under 13 years of age, we will promptly take all reasonable measures to delete such information from our systems.

Links. Our website may contain links to third-party websites, including links that enable you to share the contents of our website through various social media platforms. If you click on one of those links, you will be taken to websites we do not control and to which this Privacy Policy does not apply. We are not responsible for such third-party websites, and encourage you to carefully read the privacy policies and statements of those websites.

Contact Information

Please contact us at the contact information listed below:

The Law Office of Josh Brown LLC

3979 Main Street

Hilliard, OH 43026

(614) 284-4394

info@smallbusinesscounselors.com

Effective Date: December 1, 2022

Last modified: December 1, 2022

The Law Office of Josh Brown LLC (“we,” “us,” “our”) is committed to protecting the privacy of your information. The following Privacy Policy sets forth our practices regarding the collection, use, and disclosure of the information we receive through your use and navigation of www.smallbusinesscounselors.com (“website”). This Privacy Policy may occasionally change, so please refer to this page periodically to check for updates.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using this website, you agree to this Policy. This Privacy Policy may occasionally change, so please refer to this page periodically to check for updates. Your continued use of the website after we make changes is deemed to be acceptable of those changes.

Scope

The Information We Collect About You

We may collect different types of information from you when you use or navigate our website:

How We Collect Information

We may collect information about you from a variety of sources:

How We Use Information

We may use information about you in the following ways:

Personal Information: We may use your Personal Information, which you voluntarily provide to us, for a variety of purposes, including to:

Directly contact you to respond to messages or inquiries that you submitted using our website forms;
Send you periodic updates about the firm’s insights and activities via email, in accordance with your subscription preferences and from which you may opt-out of receiving;
Process your job applications;
Analyze the effectiveness of our marketing activities; and
Manage our everyday business needs.

Usage Information: We may also use your Usage Information for a variety of purposes, including to:

Analyze website users’ browsing and usage activities and patterns to better understand users’ interests and preferences with respect to our services; and
Research the effectiveness of the website, which will help us to improve the website.

How We Disclose Information

We do not sell your information to third parties. We may, however, disclose your information to third parties in the following ways:

Security of Personal Information

Individuals in the European Economic Area

Under the European Union’s (EU) General Data Protection Regulation (GDPR), individuals in the European Economic Area have additional privacy rights:

Right to be Informed. Individuals have the right to transparency regarding our collection of personal data.
Right of Access. Individuals have the right to know exactly what information is held about them and how it is processed.
Right of Rectification. Individuals will be entitled to have personal data rectified if it is inaccurate or incomplete.
Right to Erasure. Also known as 'the right to be forgotten', this refers to an individual's right to having their personal data deleted or removed without the need for a specific reason as to why they wish to discontinue.
Right to Restrict Processing. An individual's right to block or suppress processing of their personal data.
Right to Data Portability. This allows individuals to retain and reuse their personal data for their own purpose.
Right to Object. In certain circumstances, individuals are entitled to object to their personal data being used.
Rights of Automated Decision Making and Profiling. The GDPR has put in place safeguards to protect individuals against the risk that a potentially damaging decision is made without human intervention.

California Residents Privacy Rights

from users of our website, including the services available via our website;
about clients and individuals who use or inquire about our legal and related services that we make available (“Services”);
about individuals who attend events hosted or sponsored by us, reply to our emails or communications, visit our offices, or otherwise communicate or engage with us; or
about individuals from clients and others related to the Services we provide.

This California Notice does not address or apply to:

our handling of personal information that is exempt under Section 1798.145 of the CCPA,
personal information we collect about employees, contractors or job applicants or other individuals who are not California residents, or
personal information we collect about individuals acting in their capacity as representatives (“B2B contacts”) of our clients, prospective clients, vendors and other businesses that we conduct business with, to the extent we use their personal information only in the context of conducting our business relationship with the respective business.

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.