Privacy Policy

Last updated May 15, 2024

Welcome to DLx Law. Thank you for visiting https://www.dlxlaw.com/ (the “Website,” as defined further in the Terms and Conditions to which you have agreed, available at https://www.dlxlaw.com/terms-and-conditions), where you can find information about legal and regulatory advisory services and other content related to ‍CohenWilson LLP (d.b.a. “DLx Law”), a U.S. law firm with offices in Delaware, the District of Columbia, and New York.

DLx Law maintains this Privacy Policy (this “Policy”) to demonstrate its commitment to privacy, security, and your rights, if any, under applicable law. This Privacy Policy is available at https://www.dlxlaw.com/privacy-policy.

DLx Law gathers certain types of information from Website users and believes it is important that you fully understand what information DLx Law gathers and how it obtains, uses, shares, and manages that information, so please read this Policy carefully. Accordingly, DLx Law is providing this Privacy Policy to you to disclose what information is gathered through the Website and how that information is obtained, used, shared, and managed. This Policy is only applicable to information gathered by DLx Law through the Website and not to information that DLx Law may obtain through any of its other business activities or from other sources.

If you have any questions about this Policy, you may contact DLx Law by email at contact@dlxlaw.com.

IMPORTANT NOTICE: DLx Law reserves the right to change the provisions of this Policy at any time and without providing notice to you. The date of the most recent version of this Policy will appear at the top of this page. Accordingly, you should visit this Policy periodically to review its provisions and note any changes that may affect you.

ADDITIONAL IMPORTANT NOTICES:

• Attention California Residents: See DLx Law’s California Privacy Supplement (available at https://www.dlxlaw.com/california-privacy-supplement), which is incorporated as part of this Policy, for additional disclosures about your rights and DLx Law’s collection and use of your personal information under the California Consumer Privacy Act (“CCPA”), and for information on submitting CCPA requests.

• Attention Colorado, Connecticut, Utah, and Virginia Residents: See DLx Law’s U.S. State Privacy Supplement, which is incorporated as part of this Policy (and available at https://www.dlxlaw.com/us-state-privacy-supplement) for additional disclosures about your rights and DLx Law’s collection and use of your personal information under relevant state legislation.

• Attention Residents of Europe: If you are a resident of the United Kingdom (U.K.) or European Economic Area (EEA), then please see DLx Law’s Europe Privacy Supplement (available at https://www.dlxlaw.com/europe-privacy-supplement) for additional disclosures about your rights and DLx Law’s collection and use of your personal information under the General Data Protection Regulation (“GDPR”) and U.K. law, and for information on filing complaints under GDPR.

1. Your Personally Identifiable Information

• Personal Information Collected. DLx Law collects information that you voluntarily provide via the Website using one or more devices to receive products, services, or related information that you may request from DLx Law or its partners or suppliers. The information you submit may include your name, company information, street address, email address, phone number, and, in some cases, social security number or other tax ID number. DLx Law considers this information to be your personally identifiable information (your “PII”). Unless DLx Law has your complete street address, DLx Law does not consider your city, state, ZIP code, or general geographic location to be your PII. DLx Law also collects information about the devices you use to access the Website. DLx Law does not consider this information to be your PII, but certain device information of California residents may be considered “Personal Information,” under the California Consumer Privacy Act (“CCPA”), or “Personal Data,” under the privacy laws of Colorado, Connecticut, Utah, or Virginia.

• ‍Use of Your Personal Information. Your PII may be shared between DLx Law and its partners or suppliers and may also be disclosed to other entities based on any separate requests you may make to DLx Law. When you provide PII like your phone number or email address, such as when submitting a “Get In Touch” form through the Website (available at https://www.dlxlaw.com/get-in-touch), DLx Law may use it to reach you to fulfill your request, answer your questions, and obtain or associate additional information about you or your organization. DLx Law may use whatever information it may have or know about you, including your PII, to customize or enhance your experience on the Website, provide you with information on or access to DLx Law’s or its partners and suppliers’ products or services, or to communicate with you about those products or services. DLx Law may use this information to optimize the manner in which Website-based products, services, features, and interface operate. DLx Law may also aggregate and use this information to produce reports and analytics for its own purposes. DLx Law does not sell your PII to third parties, and DLx Law does not otherwise make commercial use out of your PII other than for business purposes directly related to supporting the provision of the Website to you or as otherwise specified above.

• ‍Disclosure of Your Personal Information. DLx Law may disclose whatever information it may have or know about you, including your PII, without first providing you additional notice or obtaining your consent, to (i) third-party service providers that provide advice, products, or services to DLx Law, or that help DLx Law improve its services, features, or content and their value to Website visitors or DLx Law’s partners or suppliers; (ii) a potential acquirer in connection with any merger, acquisition, or sale of at least substantially all DLx Law’s business assets; (iii) third parties to whom disclosure of your information is deemed to be required by law, regulation, or legal process, or that is or may be reasonably necessary to enforce or take appropriate action under the Terms and Conditions (available at https://www.dlxlaw.com/terms-and-conditions); or (iv) other third parties when reasonably necessary to protect the rights, property, or safety of DLx Law, its partners and suppliers, the Website, or other Website visitors. DLx Law may also disclose your PII to social media companies in an encoded (or “hashed”) format that can only be recognized if you have an account on those companies’ platforms. DLx Law only discloses your PII to those of its partners, suppliers, or other service providers with appropriate controls for handling and protecting your PII. DLx Law also imposes contractual obligations on service providers to ensure they only use your PII in accordance with applicable law as necessary to provide services to DLx Law or you.

• ‍Your Geolocation Information. When you access the Website, DLx Law may use cookies to discern your general geolocation information from the IP address associated with your computer or mobile device. DLx Law uses this information to support general analytics, business, and communications functions, and to help discern your location within or connection to any jurisdiction that is the subject of applicable sanctions or in which DLx Law or its partners may be prohibited from doing business. You may stop DLx Law’s collection of your geolocation information by rejecting analytics cookies using the Cookie Consent Manager (available at https://www.dlxlaw.com/cookie-manager), provided that you recognize this action may be disruptive to Website functionality and performance. As described above, unless DLx Law has your complete street address, DLx Law does not consider your city, state, ZIP code, or general geographic location to be your PII. DLx Law also reserves the right to block or restrict your access to the Website and may reject any request for legal services if DLx Law is unable to confirm your location.

• ‍Your Responses to Surveys and Emails. DLx Law may from time to time administer or work with a third party to administer surveys to its clients and Website visitors to help DLx Law better target its ideal online audience, better serve its clients, and improve the services, content, or features of the website. Additionally, if you are receiving emails in relation to the Website (such as in relation to a subscription to DLx Law’s Mailing List at https://www.dlxlaw.com/mailing-list) or other communications from DLx Law requesting information from you in connection with your Website use, then you may opt out of receiving these kinds of communications by selecting “unsubscribe” at the footer of those communications, or by requesting to opt out in writing by delivering an email to DLx Law at contact@dlxlaw.com.

• ‍Your Participation in Forums or Events. The Website may provide you with a variety of means for communicating with DLx Law, its network, and other Website visitors, such as when using any forum available through the Website, attending one of DLx Law’s events or discussions, adding or submitting information or other content through the Website, or interacting with content submitted by other Website visitors. For more information, including warnings regarding PII disclosure and communications practices, review the Terms and Conditions to which you have agreed (available at https://www.dlxlaw.com/terms-and-conditions) and which supplement this Policy.

• ‍Where is Your Information Held? The information handled by DLx Law, including your PII, is encrypted in transit and in storage (except in the event you deliver PII to DLx Law without encryption or without using designated means). This information may be held at DLx Law’s offices, by one of its attorneys or personnel, or in an encrypted database. DLx Law and some of its partners and suppliers are based outside the United Kingdom (U.K.) and European Economic Area (EEA). If you are a resident of the U.K. or EEA, please review the Europe Privacy Supplement (available at https://www.dlxlaw.com/europe-privacy-supplement).

• ‍How Long is Your Information Kept? If you register an account through the Website, subscribe to DLx Law’s Mailing List, or register for any other Website service or feature, then DLx Law will retain your PII for at least as long as you have the account or active registration. If you or your organization separately enter an attorney-client agreement to receive legal services, then DLx Law will retain your PII for at least as long as it is operating under an attorney-client relationship with you or your organization. If you close all your accounts, subscriptions, or registrations with DLx Law or its Website, or if the attorney-client relationship that DLx Law has with you (if any) has come to an end, then DLx Law will continue to hold records of your PII for as long as necessary to comply with applicable law, regulation, or internal policy. DLx Law may additionally hold your PII as necessary to adequately respond to any questions, complaints, or claims made by you, by your organization, or by someone else on your behalf, and to show that DLx Law treated you fairly. DLx Law will not keep your PII for longer than necessary for the purposes identified in this Policy and, at the end of the applicable retention period, will delete or anonymize your information. If you voluntarily publish or submit any of your PII or other information on any public space on the Website in any message, forum, publication, broadcast, or screening, then you do so at your own risk, and your information may persist online indefinitely if you do not remove that information or specifically ask DLx Law, in writing, to remove it. If DLx Law is separately under an active attorney-client relationship with you or your organization, then your information is additionally subject to the terms of your client agreement for DLx Law’s services (which control in the event of any conflict between that agreement and this Policy or any Supplement).

2. Information Collected Through Cookies

• What are Cookies? To ensure optimal performance and support your ability to use the Website and any services accessible through the Website as intended, DLx Law and its suppliers or other third parties install and use cookies. Cookies are small text files generated when you access the Website and used to collect your internet browsing information. All cookies that DLx Law uses are safe for your computer and only process the information stored on your browser. These cookies cannot execute code, do not contain malware or viruses, and cannot be used to access content stored on your computer. DLx Law uses four different types of cookies on the Website: (i) cookies that are strictly necessary for Website use (“essential cookies”); (ii) cookies that remember your settings (“functional cookies”); (iii) cookies that monitor your website use (“analytics cookies”); and (iv) cookies that assist with business strategy and communications (“tracking cookies”), the details of each of which are listed below, in Section 2.B through 2.E, respectively.

• ‍Essential Cookies. Essential cookies are cookies needed to ensure you can access the Website and browse securely. You are unable to opt out of these cookies because Website services require them to function. Essential cookies help protect DLx Law from fraudulent use of the Website or related services, verify that anyone using your registered account on the Website or any of its components is indeed you, and protect your data from unauthorized access and use. These cookies are installed, used, and owned by the following third-party services for the corresponding purposes listed:

1. 1. • Google Analytics
        • Source: Google Ireland Limited (Ireland)
        • Cookies or resources:  aec; sid; sidcc
        • Purpose: These essential cookies are used to confirm visitor authenticity and ensure that requests within any given browsing session on the Website are made by the visitor and not by other websites, thereby preventing unauthorized or fraudulent access or use of visitor data and preventing potentially malicious sites from acting on any visitor’s behalf without their knowledge.
        • Additional privacy information: policies.google.com/technologies/cookies
        • Expiration: 1 to 2 years
      • Google reCAPTCHA
        • Source: Google Ireland Limited (Ireland)
        • Cookies or resources: _grecaptcha
        • Purpose: This essential cookie is used to record anonymized visitor browsing device information to provide the Website with spam protection and enable the performance of ongoing risk analysis.
        • Additional privacy information: policies.google.com/technologies/cookies
        • Expiration: 6 months
      • Website Cookie Acceptance
        • Source: DLx Law
        • Cookies or resources: cookie_notice_accepted
        • Purpose: This essential cookie is used to record unique visitor acceptances of the cookies under this Privacy Policy via the Website’s cookies consent banner.
        • Additional privacy information: n/a (none)
        • Expiration: n/a (persistent)

• Functional Cookies. Functional cookies are cookies that gather data necessary to provide you with an interactive user experience. Functional cookies allow DLx Law to adapt the Website and Website services to your preferences, such as language and other interactive functionality. These cookies are installed, used, and owned by the following third-party services for the corresponding purposes listed:

1. 1. • YouTube
        • Source: Google Ireland Limited (Ireland)
        • Cookies or resources: nid
        • Purpose: This functional cookie is used to record an anonymized version of each unique visitor’s Google user ID to enable visitors to play YouTube videos embedded on any page of the Website.
        • Additional privacy information: policies.google.com/technologies/cookies
        • Expiration: 6 months

• ‍Analytics Cookies. Analytics cookies are cookies that when used together track, monitor, and analyze how you browse and interact with the Website and any Website services. Analytics cookies reveal trends in Website usage and allow DLx Law to customize the Website user experience for you. These cookies are installed, used, and owned by the following third-party services for the corresponding purposes listed:

1. 1. • Google Analytics
        • Source: Google Ireland Limited (Ireland)
        • Cookies or resources:  _ga; ga_qc9edtqb8g
        • Purpose: These analytics cookies are used to create unique visitor IDs to capture the pages on the Website visited by each unique visitor, as well as certain other websites visitors might visit and the time spent on each page or website.
        • Additional privacy information: policies.google.com/technologies/cookies
        • Expiration: 2 years
      • StatCounter
        • Source: Google Ireland Limited (Ireland)
        • Cookies or resources:  is_unique; sc_is_visitor_unique
        • Purpose: These analytics cookies are used to identify and record unique visitors and unique visitor visits to the Website.
        • Additional privacy information: https://statcounter.com/about/legal/
        • Expiration: 2 to 5 years

• Tracking Cookies. Tracking cookies are cookies that track, monitor, and analyze how you browse and interact with the Website and any Website services specifically as necessary to help DLx Law deploy, manage, and improve its web programs and strategies. Tracking cookies allow DLx Law to better understand Website user behavior, develop its audience, and improve business communications strategies. These cookies are installed, used, and owned by the following third-party services for the corresponding purposes listed:

1. • Google Ads
     • Source: Google Ireland Limited (Ireland)
     • Cookies or resources:  1p_jar; dv
     • Purpose: These tracking cookies are used to record an anonymized version of each unique visitor’s Google user ID to provide visitors with ad delivery or retargeting, and to allow Google DoubleClick to show personalized ads to visitors based on their past Website visits.
     • Additional privacy information: policies.google.com/technologies/cookies
     • Expiration: 1 month
   • YouTube & Google Maps
     • Source: Google Ireland Limited (Ireland)
     • Cookies or resources: apisid; hsid; sapisid; ssid
     • Purpose: These tracking cookies are used to record an anonymized version of each unique visitor’s Google user ID and enable Google to collect certain visitor information in connection with videos hosted by YouTube and maps integrated with Google Maps, and also to enable Google to display personalized advertisements on Google sites based on visitors’ recent searches and previous interactions with the Website.
     • Additional privacy information: policies.google.com/technologies/cookies
     • Expiration: 2 years

3. How You Can Control Cookies

• How Can You Manage Your Consent to Cookies? You may accept or reject cookies when you use the Website by setting your preferences using the Cookie Consent Manager (available at https://www.dlxlaw.com/cookie-manager), which is also linked from a notification banner each time you visit the Website. While you cannot reject essential cookies because they are necessary to provide you with access to the Website, you may select those of the other categories of cookies (i.e., functional cookies, analytics cookies, and tracking cookies) that you wish to accept or reject. You may still use the Website if you choose to reject any or all these categories of cookies, but access to certain Website services, features, or functionality may be restricted.

• ‍How Can You Block or Delete Cookies? If you would like to reject cookies without adjusting your preferences in the Cookie Consent Manager each time you visit the Website, or if you would like to remove the cookies to which you previously consented, then you can modify your browser settings to block or delete cookies. The means by which you may refuse cookies in your web browser settings may vary depending on the browser you use (see e.g., Instructions for Clearing and Managing Cookies in Google Chrome, available at https://support.google.com/chrome/answer/95647). See your web browser’s help menu for more information.

4. Information Collected Through Other Technologies

• Web Beacons. From time to time, the Website may use other tracking technologies similar to cookies called “web beacons” (or “tracking pixels” or “clear gifs”) to monitor traffic patterns of Website users from one page to another and deliver or communicate with cookies. Web beacons are small graphics that display a unique identifier that allow DLx Law to recognize when someone has visited the Website or opened an email from DLx Law. Web beacons help DLx Law improve Website performance and understand whether any particular visit to the Website is directed from certain external sources, like from a publication displayed on a third-party platform application or website or an email announcement or other content distribution. Web beacons are largely reliant on cookies to function properly, so blocking or rejecting cookies may impair web beacon functionality and, in turn, Website performance.

• ‍Local Shared Objects. From time to time, the Website may also use “Flash cookies” (also known as “local shared objects” or “LSOs”) to collect and store information about your use of the Website, and to prevent fraud, support other Website operations, and more. Flash cookies are stored locally on your computer and interact with your Adobe Flash Player, which is typically installed as a widget or add-on to your web browser. The Website uses Flash cookies to support the functionality of some Flash applications that may be used in connection with the Website or other online content. If you do not want the Website to use Flash cookies on your computer, then you can adjust your Flash Player settings to block Flash cookie storage. You can also use your Flash Player’s global storage settings panel to prevent Flash cookies from being placed on your computer without your explicit opt-in, or to block them unless being delivered by a website or webpage you are accessing at any given time (for more information about accessing and using your Flash Player settings manager, read the Adobe Help Page at macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html).

• ‍Targeted Advertising. Third-party companies may use cookies, web beacons, or other technologies in connection with your use of your computer or mobile device to send or display advertisements to you, but DLx Law does not enable targeted advertising on, through, or in connection with the Website. Importantly, DLx Law does not advertise its services to you or any Website visitors. For more information, view the Website Legal Disclaimer (available at https://www.dlxlaw.com/legal-disclaimer).

5. Children’s Privacy

The Website is directed at a general audience but not at children under the age of 16. DLx Law does not knowingly collect or solicit personal information from any person under the age of 16 or knowingly allow them to use or interact with Website services, features or content. If you are under 16, please do not visit or use the Website or participate in or attend any forum, discussion, or event in connection with DLx Law. If DLx Law obtains actual knowledge that the personal information of a child under age 16 was or is being collected through the Website, then DLx Law will delete that information as quickly as possible. If you believe the Website might have collected any information from or about a child under 16, then please contact DLx Law by email at contact@dlxlaw.com.