PRIVACY POLICY

Owner and information Controller

Marulli, Mannarino, Erichsen & Tomaszewski, LLP
175 W Broadway
New York, NY 10013

Owner contact email: jarnone@marullilaw.com

Our website address is: https://marullilaw.com

What personal information we collect and why it is collected

Comments or Inquiry
After leaving a comment or inquiry on the website forms we collect that information shown in the feedback form,
and also a visitor’s IP address and browser user agent string to help spam detection.

Types of information collected
A variety of Personal information that marullilaw.com collects, on its own or by third parties, these pertain to: Cookies,
Various types of information, email addresses, gender, first and last name, company name, a phone number, geographic location, birth date and email.

A complete explanation of each area of Personal information that is collected is explained in the privacy policy section or
by specific explanatory information provided.
Visitors may share Personal information freely, or, in case of Usage information, stored automatically when using marullilaw.com.
All requested information by marullilaw.com is necessary and refusing to share this information makes it difficult for marullilaw.com to provide its services.
In cases where marullilaw.com states that some information is not required, Users are allowed not to share this information with no penalty to the usage
or the functioning of the Service.
Any visitor uncertain about what Personal information is mandatory is welcome to contact the Owner.
Any use of Cookies or additional tracking tools – by marullilaw.com or by the owners of third-party services used by marullilaw.com provides
our Service required by the User, in addition to various functions described in the Cookie Policy.

Visitors are responsible for any Personal information gathered or shared through marullilaw.com and confirm consent to make available that information to the website Owner.

Methods of managing
Marulli, Mannarino, Erichsen & Tomaszewski, LLP assumes proper security measures to prevent unauthorized access, disclosure, modification,
or unauthorized destruction of the information.
The information gathering is processed using computers and/or IT enabled tools, managed with organized procedures related to the expressed purpose.
In addition to the Owner, as deemed necessary, the information may be available to particular persons involved with the operation of marullilaw.com
(administrative, legal, system records) or external parties (such as technical services, mail carriers, hosting parties, IT company, email services) approved,
as required, as information Processors by the Owner. The updated list of information gathered may be requested from the Owner.

Legal basis of processing
Marulli, Mannarino, Erichsen & Tomaszewski, LLP may process information relating to visitors if one of the following applies:

Users have given their permission for one or a few purposes.
Note: Under some legislations Marulli, Mannarino, Erichsen & Tomaszewski, LLP may be permitted to process Personal information until the visitor objects (“opt-out”), without needing to depend upon consent or any other of the following legal bases. This, does not pertain when the processing of Personal information is subject to European information protection law; use of information is required for the processing of an agreement with the visitor and/or for any pre-contractual obligations thereof; processing is required for compliance with a legal obligation to which the visitor is subject; processing is in connection to a duty that is processed in the public interest or in the process of official authority vested in the Owner; processing is needed for the goal of the legitimate interests pursued by the Owner or by a third party.
Marulli, Mannarino, Erichsen & Tomaszewski, LLP will assist to clarify the legal grounds that applies to the processing and whether the provision of Personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place
Information is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Dependent upon a visitors location, information transfers may pertain to transferring the User’s information to a country other than their own.
To be informed about the place of processing of such transferred information, visitors may inquire within the section containing details about the processing of Personal information.

Visitors are permitted to inquire about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their information.

If any such transfer occurs, visitors may inquire additional information by checking the relevant areas of this notice or inquire with the Owner using the resources provided in the contact section.

Retention time
Personal information is processed and stored for as long as required by the purpose they have been collected for.

Therefore: Personal information gathered related to the processing of a contract between the Owner and the visitor will be retained until such contract has been fully performed.
Personal information gathered for the use of the Owner’s legal interests will be held as long as needed to fulfill such purposes.
Visitors may gather specific information regarding the legal interests processed by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to maintain information for a longer time as the visitor has provided consent to such processing, as long as such consent is not withdrawn.
In addition, the Owner may be obligated to maintain Personal information for an extended time when required for the performance of a legal obligation or upon order of an authority.

As soon as the retention time ends, Personal information will be deleted.
Therefore, the authority to access, the authority of erasure, the authority to rectify and the authority of information portability cannot be enforced after expiration of the retention time.

The purpose of processing
The details regarding the visitor is gathered to permit the Owner provision of its Services, in addition to the following purposes:
Analytics, Processing payments, Contacting the User, information transfer outside the EU, Displaying content from external platforms, communications with information collection tools and other third parties, Geolocation-based interactions, Maintaining contacts and sending messages, providing support and contact inquiries, SPAM protection, Website optimization and visitor information management.

Visitors may gather detailed information about such use of processing and about the detailed Personal information processed in the respective areas of this notice.

Contact forms
By submitting information on our mailing list or for the newsletter, the visitors email address shall be included the contact list of visitors that may receive email messages pertaining to information of commercial or promotional nature concerning marullilaw.com. Your email address may be included on this list as a result of submitting to a marullilaw.com contact form or after providing such information.

Personal information collected: email address, first name, last name and phone number.

Phone contact (marullilaw.com)
Visitors providing a phone number may be contacted for commercial or promotional purposes related to marullilaw.com, in addition to fulfilling support requests.

Personal information collected: phone number.

Handling Payments
Payment processing services permits marullilaw.com to process payments by credit card, bank transfer or other means. To ensure greater security, marullilaw.com provides only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

Managing Support
This allows marullilaw.com to provide support and communications received via email, phone or by other means, such as the contact form. The Personal information gathered is dependent on the information provided by the visitor within the messages and the tools used for communication (e.g. email address).

Personal information collected: email address, name, phone number, address, gender.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Analytics
Google Analytics and Google Analytics with anonymized IP. Google Analytics is a service provided by Google Inc. (“Google”). Google gathers information to track and examine the use of marullilaw.com, to provide reports on its activities and share them with other Google services.

Personal information: Cookies and Usage information
Place of processing: United States – Privacy Policy – Opt Out.

Displaying content from external platforms:
Fonts.com Web Fonts and Google Fonts
Fonts.com Web Fonts (Monotype Imaging Holdings Inc.)
Fonts.com Web Fonts is a typeface provided by Monotype Imaging Holdings Inc. and permits marullilaw.com to provide content of this kind on its pages.

Google Fonts (Google Inc.): Google Fonts is a typeface provided by Google Inc. that permits marullilaw.com to provide content of this kind on its pages.

Social tools and YouTube video tools
Personal information: Usage information

Google Site Search, Google Maps widget, Vimeo video and YouTube video widget
Personal information: Cookies and Usage information

SPAM protection
Akismet: Personal information: various types of information as specified in the privacy policy of the service

Google reCAPTCHA: Personal information: Cookies and Usage information

Information transfer outside the EU
Marulli, Mannarino, Erichsen & Tomaszewski, LLP is permitted to transfer information gathered within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such information transfer is acted upon the legal bases described below.
Visitors may request from the Owner an understanding of which legal basis applies to which specific service.

Information transfer abroad based on standard contractual clauses (marullilaw.com)
If such is the legal basis, the transfer of information from the EU to third countries is processed by the Owner in accordance to “standard contractual clauses”
provided by the European Commission. Therefore, any information visitors have permitted to process will be in as much compliance with the information protection standards set forth by EU information protection legislation.
For additional information, Visitors are asked to inquire from the Owner through the contact details provided in the present document.

Personal information collected: various types of information.

information transfer abroad based on consent (marullilaw.com) As such is the legal basis, Personal information of visitors will be transferred from the EU to third countries only if the visitor has expressly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards. In such cases, the Owner will inform visitors and gather their explicit consent via marullilaw.com.

Personal information collected: various types of information.

How long we maintain your information
If you provide a reply, the reply and its meta information is held indefinitely. This is maintained to recognize and permit any follow-up communications.

Your rights of your information
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal information we hold about you, including any information you have provided to us. You can also request that we erase any personal information we hold about you. This does not include any information we are obliged to keep for administrative, legal, or security purposes.

Where we send your information
Visitor communications may be processed through an automated spam detection service.

Security
We provide organizational, technical and administrative means to protect information within our firm. Regretfully, no communications or storage provided can guaranteed to be completely secure, any processing of information via the internet is not fully secure. If you are concerned that your communication with us is no longer secure or is compromised), please immediately notify us of the problem by contacting us.

Our Policy on Children
Our website is not provided for children under 16. If a parent or guardian is made aware that his or her child has shared with us information without their consent, he or she must contact us. We will delete this information from our records as soon as reasonably practicable.

The rights of visitors: Visitors have the right to the following:

Retract permissions at any time: Visitors may withdraw consent where they have previously given their consent to the maintenance of their Personal information.

Object to processing of their information: Visitors may refuse the maintenance of their information if the maintenance is carried out on a legal basis other than consent.

Access any personal information: Visitors may learn what information is being processed by the Owner, may gather information pertaining to certain processing and obtain a copy of the information’

Verify and request confirmation: Visitors may seek to verify the accuracy of shared information and request for it to be updated or corrected.

Limit any processing of their information: Visitors are permitted, under certain circumstances, to limit the processing of their information. In such circumstances, the Owner will not process their information for any purpose other than storing it.

Personal information deleted or otherwise removed: Visitors are permitted, under certain circumstances, to request the erasure of their information from the Owner.

Gather their information and transfer it to another controller: Visitors are permitted to obtain their information in a structured format and, if possible, have it transferred to another controller. This action is offered and assumed that the information is processed by automated services and that the process is by the visitors agreement, on a contract which the visitor is part of or on pre-contractual obligations thereof.

Lodge a complaint: Visitors may process a claim before their competent information protection authority.

Information about the right to object to processing: Where Personal information is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Processing these rights: A desire to exercise visitor rights can be sent to the Owner through the contact information provided within this document. Any requests can be processed free of charge and will be replied by the Owner as early as possible and always within one month.

Cookie Policy
marullilaw.com uses Cookies. For a detailed cookie usage the visitor can consult the Cookie Policy.

Legal action
A visitors Personal information can be processed for legal purposes by the Owner in Court or in the actions leading toward legal action from from improper use of marullilaw.com or the its Services. The visitor confirms to be aware that the Owner may be obliged to share personal information upon request of public authorities.

More about Personal information
As well as information provided in this privacy policy, marullilaw.com may share with a visitor additional and contextual information relating to particular Services or a gathering and processing of Personal information upon request.

System files and maintenance
For proper usage and maintenance purposes, marullilaw.com and any third-party services may gather files that record interaction with marullilaw.com (System records) and use other Personal information (such as an IP Address) for this purpose.

Information not provided in this policy
Additional information pertaining to the collection or processing of Personal information may be sought from the Owner at any time. See review contact information at the top of this notice.

How “Do Not Track” requests are handled
marullilaw.com cannot process “Do Not Track” requests. To gauge whether a third-party service honors the “Do Not Track” request, please read their privacy policies.

Changes pertaining to our privacy policy
The Owner reserves the right to make changes any time and will provide notice to its visitor by email and possibly within marullilaw.com. It is highly encouraged to review this notice often, referring to the date of the last modification provided at the bottom.

3/14/20




299 Broadway, Suite 605 New York, NY 10007
212-553-3200
Ferichsen@marullilaw.com

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