Privacy PolicyEdward Clough, Esq. (“Clough Legal” or “we”) is committed to protecting your privacy. This Privacy Policy describes the ways Clough Legal manages Personal Information (as defined below) that it receives: (i) in the course of its operations involving current, prospective and former clients (collectively, “Clients”); (ii) from visitors and guests; including in each such case on our website, www.cloughlegal.biz, blogs, social media pages and mobile site (collectively, the “Site”). All individuals who process Personal Information on behalf of Clough Legal are expected to protect Personal Information by adherence to this Privacy Policy. Personal Information Generally “Personal Information” or “personal data” is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Process” or “processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, acquisition, holding, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Collection and Use of Personal Information The types of Personal Information we may collect (directly from you or from third parties) depend on the nature of the relationship you have with Clough Legal and the requirements of applicable law. Below are the legal bases and some of the ways we may collect and use Personal Information. Clients: The data Clough Legal collects from or on behalf of its Clients include information such as title, name, address, phone number, email address, business or company affiliation, username and answer to a security question and password (if you have access to any of our secure online resources), government identification (e.g., driver’s license and/or passport), credit card and other financial information related to payments for services or goods, agreements executed with Clough Legal and other details Clients may provide. In certain Client engagements, we may collect employee and other information of our Clients, as well as employee or other Personal Information of others who have a relationship or otherwise interact with our Clients (e.g., in the context of Client investments, mergers, acquisitions or disputes). We process Personal Information about or on behalf of Clients for a variety of business purposes including but not limited to: provide legal services; generally manage Client information; respond to questions and requests; provide access to certain areas and features of the Site; verify Client identity; communicate about Client accounts and activities on the Site and systems, and, in Clough Legal’s discretion, changes to any Clough Legal policy; tailor content, publications, advertisements and offers we believe may be of interest to Clients; process transactions and payment for services purchased by Clients; improve the Site and systems;develop new services; and further purposes disclosed at the time that Clients provide Personal Information, or otherwise with consent. Other Personal Data Collection on the Site and through Electronic Communications: In general, you can visit the Site without providing us with Personal Information about yourself. However, in order to access certain information, services or features on the Site, you may be asked to provide Personal Information. Where you have consented to Clough Legal’s processing of your Personal Information, subject to applicable legal and ethical obligations that may apply to us and to our lawful ability to enforce our rights or your obligations to us, you may withdraw that consent at any time and opt out. Publications and Email Alerts: On the Site, you may choose to receive publications and email alerts from Clough Legal. If you elect to sign up, we may ask you for information such as your name, address, company, telephone number, email address and publications of interest. We use the information you provide to send the requested communications and to communicate with you about other topics that we believe may be of interest to you. We offer you the option to decline these communications at no cost. Blogs: You may subscribe on the Site to receive an RSS feed or email from Clough Legal blogs. We use this information to send you the requested communications and to communicate with you in connection with our blogs. You may also be able to submit comments to Clough Legal blogs that include Personal Information, such as your name and email address, with your comment. We may use your name to identify you if you comment on our blogs. Contact Us: You may communicate with us through the “Contact Us” link on our Site. If you choose to contact us via the Site, we may ask you for information such as your name, address, company, telephone number and email address so we can respond to your questions and comments. We also may use the information you provide to communicate with you about topics that we believe may be of interest to you. Email Communications: When you engage in email communications with any Clough Legal employees, we may retain records of your email address, along with other information that we collect, such as your name, title, address, phone number, email address, or company affiliation, as well as information about your engagement with emails, attachments, and/or links that we send to you. We may use this information for a variety of business purposes, including for business development. Aggregate Information: From time to time, we may collect and monitor other nonpersonal information about the use of the Site, such as the number and frequency of visitors to our Site. This information may include the websites that you access immediately before and after your visit to the Site, the browser and operating system you are using, your Internet protocol (IP) address, host name, device type, geographic data, and screen resolution. We collect this information in order to determine which areas of the Site are most popular and to help us develop and improve our Site. We may group this information into aggregate visitor data in order to describe the use of and preferences on the Site. However, this aggregate data does not personally identify you or any other visitors to the Site. Cookies and Other Tracking Technologies: When you visit our Site, we may collect certain information by automated means to help us improve our Site and provide customized services and information. Like many companies, we may collect this information through the use of “cookies” and other tracking technologies. These cookies are set by Google to distinguish and track Site visitors for analytics and marketing purposes. This persistent cookie is used to distinguish and collect statistics about Site visitors’ usage, such as when a visitor last visited the Site. This information is then used to improve the user experience on the Site. This cookie contains a randomly generated ID used to recognize the browser when a visitor reads a page. If you wish to restrict, block, or delete the cookies that are set by our Site, you can do so using your browser settings. Most browsers allow you to control cookies, including whether to accept them and how to disable existing cookies. You may also set most browsers to notify you if you receive a new cookie. Please note that some features of the Site may not function properly or may be slower without cookies. To make full use of the Site, your computer or mobile device will need to accept cookies. Other tracking technologies may record information such as your IP address, browser software and operating system, host name, referring site, clickstream data, device type, geographic data, and dates and times that our Site is accessed. An IP address is a number that your Internet service provider automatically assigns to the computer you are using. An IP address is identified and logged automatically whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites. Our Site does not respond to "do not track" signals. It is not our practice to link the information we record using cookies or other tracking technologies to any Personal Information you submit through the Site. However, we reserve the right to use cookies and other tracking technologies to identify a visitor. We may do so, for example, when we believe it is necessary to protect the Site, our visitors, clients or other third parties, or to protect our rights or defend against a claim relating to us, or when we believe that the law requires it. Clough Legal does not sell, rent, trade or otherwise disclose Personal Information, except as described in this Privacy Policy or as you explicitly consent. We may share your information among Clough Legal entities and affiliates. We also may share the information with third-party service providers we have retained to perform services on our behalf to help with our business activities. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements. We may disclose information about you (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation or arbitration; (iv) to enforce Clough Legal policies, contracts or other rights; (v) to collect amounts owed to Clough Legal; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if in good faith we believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Site. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities. We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of Clough Legal or of any of our assets (including should Clough Legal cease to trade, become insolvent, enter into receivership or any similar event occur). Should such an event take place, we will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Policy. Protection of InformationClough Legal takes reasonable and appropriate steps to protect the Personal Information you share with us from unauthorized access or disclosure. While we strive to protect your Personal Information and privacy, Clough Legal cannot guarantee or warrant the security of any information disclosed or transmitted to us and cannot be responsible for the theft, destruction or inadvertent disclosure of your Personal Information. Cross-Border Transfer Your Personal Information may be stored and processed in any country where we have offices or servers or in which we engage service providers. Your Personal Information may be transferred to countries outside your country of residence, including the United States, which may have different data protection and data processing laws than those in your country. Our Privacy Policy requires all of our offices to at all times ensure a level of protection at least as protective as those mandated by the European Economic Area. Any such transfer shall take place only in accordance with and as permitted by the law of your jurisdiction, but please be aware that the laws and practices relating to the protection of Personal Information are likely to be different and in some cases may be weaker than those within your home jurisdiction. Regardless, in all events, we shall apply the provisions of this Privacy Policy to your Personal Information wherever it is located. Children’s Privacy on the Site The Site is not intended for use by children under the age of 13. We do not knowingly collect Personal Information from anyone under 13 years of age through the Site. If you are under 13, please do not submit any Personal Information on the Site. Retention Clough Legal will retain the Personal Information we receive as described in this Privacy Policy for as long as necessary to fulfill the purpose(s) for which it was collected, provide our services and products, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with all applicable laws and in accordance with our routine information storage policies. Your Rights To the extent required by law, we provide users with reasonable access to the Personal Information provided to Clough Legal, a portable copy of the information, and the ability to review, correct, delete, restrict or object to the processing of such information. Although Clough Legal makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which Clough Legal is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where the information is commercially proprietary. If Clough Legal determines that access should be restricted in any particular instance, we will endeavor to provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Clough Legal will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information. If you would like to review or update your Personal Information or preferences, or have your information removed from our mailing lists, please let us know by emailing us at privacy@cloughlegal.biz We may update or change this Privacy Policy from time to time and without prior notice to you. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site.