Privacy Policy

Tonkon Torp Website Privacy Policy

Last Updated: July 28, 2024

Tonkon Torp LLP (“Tonkon Torp, “we,” or “us”) respects your privacy and is committed to protecting it through our compliance with this Privacy Notice (this “Notice”).

This Notice describes the types of information we may collect from you or that you may provide when you visit the website www.tonkon.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Notice applies to information we collect:

On this Website.
In email, text, and other electronic messages between you and Tonkon Torp.
In connection with newsletters, invitations, or other announcements we send you.

Our Website, together with the content and services we provide, are collectively referred to herein as our “Services.”

It does not apply to information collected by:

Us offline or through any other means, including on any other website or any third party; or
Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.
Us in the course of our representation of clients in legal matters and information collected about or from third parties who are involved in legal matters with our clients. These materials are retained in client files consistent with our contractual and ethical obligations and applicable court orders.

Please read this Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using our Website, you agree to this Notice. This Notice may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check this Notice periodically for updates.

Children Under the Age of 18

Our Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or on our Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@tonkon.com.

Information We Collect & How We Collect It

We collect information from and about users of our Website:

Directly from you when you provide it to us, such as, for example, when you fill a newsletter sign-up form.
Automatically from you when you use our Services, such as, for example, your device’s operating system and other usage details (see Automatic Information Collection).
From third parties, for example, our business partners and service providers.

This information includes:

Information that you provide by filling in forms on or through our Website. This includes information provided when you request further information or Services. We may also ask you for information when you report a problem with our Website.
Records and copies of your correspondence (including email addresses and phone numbers) if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Your search queries on our Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on our Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). However, information collected in this way is always anonymized and aggregated to reflect totals, not individual users.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways. The information we collect helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Click Tracking. Click tracking is an analytical feature that measures and reports where users click or tap on our Website. Every time you click on our Website, we record the event and log your user session for future analysis. We use this information only to improve our Services. Click tracking only collects the IP address assigned to you on the date when you visit our Services, rather than your name or other identifying information. Please note, however, that when you fill out a contact or subscription form on our Website the information may be matched with your IP address.
Analytics. We collect analytics information from our web services provider and various third-party service providers. We only use the information we get from analytics to improve our Website. For example, we use Google Analytics to collect information about use of our Website. Google Analytics collects information such as how often users visit our Website, what pages they visit when they do so, and what other sites they used prior to coming to our Website. We use the information we get from Google Analytics only to improve our Website. Google Analytics collects only the IP address assigned to you on the date you visit our Website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our Website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by Google Analytics’ Terms of Use and Google’s Privacy Policy. For more information on how to opt-out of Google Analytics, see Changes to Our Privacy Policy.

Third-Party Use of Cookies & Other Tracking Technologies

Our Website may provide third-party links. When you click a third-party link, the result may take you outside of our Website in which case these third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. 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 websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use & Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with information or services that you request from us.
To fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or services we offer or provide through it.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

We may also use your information to contact you about our services and events that may be of interest to you. If you do not want us to use your information in this way, please see Choices About How We Use & Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect, or you provide as described in this Notice:

To contractors, service providers, and other third parties we use to support our business, including but not limited to:
- Our hosting provider.
- Our Website creator.
- Data analytics providers and internet cookie data recipients, like Google Analytics.
- Operation systems and platforms.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Tonkon Torp’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Tonkon Torp about our Website users is among the assets transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including responding to government or regulatory requests.
To enforce or apply our Terms of Use, and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Tonkon Torp, our customers, or others.

Choices About How We Use & Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website may then be inaccessible or not function properly. Other ways to opt-out of specific data collection technologies that we utilize include:
- Google Analytics. Google has a browser add-on for opting out of Google Analytics which can be found here: https://tools.google.com/dlpage/gaoptout.
Promotional Offers from Tonkon Torp. If you do not wish to have your email address/contact information used by us to promote our own Services or events, you can opt-out here and follow the instructions to unsubscribe or, if we have sent you a promotional email, by clicking unsubscribe in the email. This opt-out applies to such promotional offers only does not apply to information provided to us as a result of a transaction or in connection with our work on any on-going legal matter.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI website at https://thenai.org/opt-out/.

Accessing & Correcting Your Information

You can review and change your personal information. Please email privacy@tonkon.com to request access to, correct, or delete any personal information that you have provided to us pursuant to this Notice. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Oregon, Texas, Virginia, and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Correct inaccuracies in their personal information, taking into account the information’s nature and processing purpose (excluding Iowa and Utah).
Data portability.
Opt-out of personal information processing for:
- Targeted advertising (excluding Iowa);
- Sales; or
- Profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
Either limit (opt out of) or require consent to process sensitive personal information.

The exact scope of these rights may vary by state.

Nevada provides its residents with a limited right to opt out of certain personal information sales. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

If you are a resident of California, Oregon, or Texas, please see the corresponding section below for more information on your state-specific rights.

To exercise any of your state-specific privacy rights, or to appeal a decision regarding a consumer rights request, please send us an email at privacy@tonkon.com or fill out our electronic contact form at www.tonkon.com/about/contact/.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Personal information that you provide to us is encrypted and stored behind firewalls.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website.

Changes to Our Privacy Policy

It is our Notice to post any changes we make to this Notice on this page. The date this Notice was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Notice to check for any changes, as they are binding on you.

Contact Information

If you have any questions or concerns regarding this Notice or need to access this Notice in an alternative format due to having a disability, please email us at privacy@tonkon.com.

TONKON TORP SUPPLEMENTAL STATE PRIVACY NOTICE

Last Updated on: July 28, 2024

CALIFORNIA

We adopt this section of this Notice to comply with the required “Notice at Collection” disclosures under California Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California Privacy Rights Act of 2020 (the “CPRA”) and its implementing regulations (together, the “California Privacy Laws”). This section applies to California consumers, including employees, job applicants, and contractors (“you”). Any terms defined in the California Privacy Laws have the same meaning when used in this California section of this Notice.

Categories of Personal Information We Collect

We may collect or receive (and may have collected or received during the 12-month period prior to the Last Updated date of this Notice) the categories of personal information listed in the table below. Not all categories will be collected or received for every individual.

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	YES
B. California Customer Records personal information, as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information. *Some personal information included in this category may overlap with other categories.	NO; client payments are collected through LawPay, not our Website. We do not collect your data from LawPay.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website or application.	YES
G. Geolocation data.	Physical location.	YES; however, this information is collected anonymously and only includes city and state information. No addresses are collected.
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES, but only for job applicants.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES, but only for job applicants.
K. Inferences drawn from other personal information.	Profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L. Sensitive Personal Information	Government-issued identifiers including social security number, driver’s license, state identification card, or passport number), account log-in and financial information (such as payment card details), and precise geolocation.	NO

We may obtain and combine personal information from different sources, as described in the Information We Collect & How We Collect It section of this Notice. As further described in the How We Use Your Information section of this Notice, we generally collect and use the above-listed categories of personal information to present our Website and its contents to you, provide requested information or services, fulfill purposes for which you provide the information, carry out contractual obligations, notify you about changes, and for any other purpose described at the time of collection or with your consent.

Sharing Personal Information

We do not rent, sell, or use for targeted advertising, the personal information we collect. We may disclose your personal information to our third-party service providers for a business purpose as described in the Disclosure of Your Information section of this Notice. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal data confidential, and prohibit using the disclosed information for any purpose except performing the contract.

In the preceding twelve (12) months, Tonkon Torp has disclosed personal information for a business purpose to the following categories of third parties:

Our hosting provider.
Our Website creator.
Data analytics providers and internet cookie data recipients, like Google Analytics.
Third-party software-as-a-solution providers, like Salesforce Pardot which we use to automate and streamline marketing and sales processes.
Operation systems and platforms.

Data Retention

We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in the How We Use Your Information, section of this Notice, including to satisfy legal or reporting requirements. What this means in practice will vary for different types of information, but the criteria assessed in the data retention analysis consider ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.

Your California Privacy Rights

If you are a California resident, you can make certain requests regarding your personal information. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial. Your rights include:

Right to Know. You have the right to request that we disclose to you the categories of personal information we have collected about you, as well as the sources of such personal information, the purposes, and the categories of third parties with whom such personal information is shared.
Right to Access. You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.
Right to Delete. You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.
Right to Opt Out of Sale or Sharing of Personal Information. You have the right to “opt out” of the “sale” or “sharing” of your “personal information” to or with “third parties” (as those terms are defined by California Privacy Laws). Please note that we do not use your personal information in this way.
Right Not to Receive Discriminatory Treatment. You have the right not to receive discriminatory treatment for the exercise of your privacy rights. If you choose to exercise any of these rights, you will not receive different prices or quality of services unless permitted by applicable law, including if those differences are reasonably related to your information. For example, if you exercise your right to opt out of “sale” or “sharing” of your ”personal information,” the ads you view may not be tailored to your interests.

Exercising Your California Privacy Rights

Making Requests to Know, Access, Delete, or Correct Your Personal Information. To exercise your rights to know, access, delete, or correct your personal information, please submit a request by either emailing us at privacy@tonkon.com or filling out our contact form at tonkon.com/about/contact/. Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may only submit a request to know twice within a 12-month period. 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. We will only use personal information provided in a request to review and comply with the request. You do not need to create an account with us to submit a request to know or delete. We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. 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. We will delete or de-identify personal information not subject to a legal exception from our records and will direct our service providers to take similar action. 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.
Instructions for Using an Authorized Agent to Make Requests. You may use an authorized agent to submit a request to know or access, deletion, correction, or opt-out requests on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity. Authorized agents may submit requests by emailing us at privacy@tonkon.com.

Contact Information

If you have any questions or comments about this California section of our Notice, or wish to exercise your California privacy rights, please do not hesitate to email us at privacy@tonkon.com.

OREGON

We adopt this section of this Notice to give Oregon residents (“you”) additional information required by the Oregon Consumer Privacy Act (the “OCPA”). This Oregon section applies to you when you are acting in an individual or household context, but not when you are acting in a commercial or employment context, including as a job applicant. Any terms defined in the OCPA have the same meaning when used in this Oregon section of this Notice.

Categories of Personal Data We Collect

We may collect or receive (and may have collected or received during the 12-month period prior to the Last Updated date of this Notice) the categories of personal data listed below. Not all categories will be collected or received for every individual. For more information on the categories of personal data we collect, please see the Information We Collect & How We Collect It section of this Notice.

Personal identifiers, such as name, telephone number, physical address, email address, or other similar identifiers.
Device Information and Online Activity. Device and online identifiers, keystroke patterns indicative of human or bot website usage, mobile and web network activity and related information (such as Mac address, IP address, cookie IDs, browser activity, and other information associated with your browsing history), and social media information (if you engage with us on social media platforms).
Commercial Information. Commercial information and service testimonials.
Communication details (such as the content of emails, text messages, or other communications), call logs, and calendar information where we are a party to the exchange.
Anonymized geolocation data, showing only city and state.

We do not collect sensitive personal data.

Collection, Use, and Sharing of Your Personal Data

We do not rent, sell, or use for targeted advertising, the personal data we collect. We may disclose your personal data to our third-party service providers for a business purpose as described in the Disclosure of Your Information section of this Notice. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal data confidential, and prohibit using the disclosed information for any purpose except performing the contract.

In the preceding twelve (12) months, Tonkon Torp has disclosed personal data for a business purpose to the following categories of third parties:

Our hosting provider.
Our Website creator.
Data analytics providers and internet cookie data recipients, like Google Analytics.
Third-party software-as-a-solution providers, like Salesforce Pardot which we use to automate and streamline marketing and sales processes.
Operation systems and platforms.

Data Retention

We retain each category of personal data that we collect for as long as necessary to fulfill the purposes described in the How We Use Your Information section of this Notice, including to satisfy legal or reporting requirements. What this means in practice will vary for different types of information, but the criteria assessed in the data retention analysis consider ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.

Your Oregon Privacy Rights

If you are an Oregon resident, you can make certain requests regarding your personal data. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the data applies. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial. Your rights include:

Right to Know. You have the right to know whether we control the collection of your personal data.
Right to Access. You have the right see what personal data we have collected about you in a usable format.
Right to Delete. You have the right to request that we delete personal data that we collect from you, subject to applicable legal exceptions.
Right to Correct. You have the right to request that we correct inaccurate personal data.
Right to Opt Out of Sale of Personal Data and Targeted Advertising. You have the right to “opt out” of “targeted advertising,” certain types of profiling, and the “sale” of your “personal data” (as defined in the OCPA). Please note that we do not use your personal data in this way.

Exercising Your Oregon Privacy Rights

Making Requests to Know, Access, Delete, or Correct Your Personal Information. To exercise your rights to know, access, delete, or correct your personal information, please submit a request by either emailing us at privacy@tonkon.com or filling out our contact form at tonkon.com/about/contact/. Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. 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. We will only use personal information provided in a request to review and comply with the request. You do not need to create an account with us to submit a request to know or delete. We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. 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. We will delete or de-identify personal information not subject to a legal exception from our records and will direct our service providers to take similar action. 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.
Instructions for Using an Authorized Agent to Make Requests. You may use an authorized agent to submit a request to know or access, deletion, correction, or opt-out requests on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity. Authorized agents may submit requests by emailing us at privacy@tonkon.com.

How to Submit an Appeal

To appeal our decision regarding a request to these rights, you may email us at privacy@tonkon.com.

Contact Information

If you have any questions or comments about this Oregon section of our Notice, or wish to exercise your Oregon privacy rights, please do not hesitate to email us at privacy@tonkon.com.

TEXAS

We adopt this section of this Notice to give Texas residents (“you”) additional information required by the Texas Data Privacy and Security Act (the “TXDPSA”). This Texas section applies to you when you are acting in an individual or household context, but not when you are acting in a commercial or employment context, including as a job applicant. Any terms defined in the TXDPSA have the same meaning when used in this Texas section of this Notice.

Collection, Use, and Sharing of Your Personal Data

We do not collect sensitive personal data, nor do we rent, sell, or use for targeted advertising, the personal data we collect.

We may disclose your personal data to our third-party service providers for a business purpose as described in the Disclosure of Your Information section of this Notice. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal data confidential, and prohibit using the disclosed information for any purpose except performing the contract.

Your Texas Privacy Rights

If you are a Texas resident, you can make certain requests regarding your personal data. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the data applies. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial. Your rights include:

Right to Know. You have the right to know whether we control the collection of your personal data.
Right to Access. You have the right see what personal data we have collected about you in a usable format.
Right to Delete. You have the right to request that we delete personal data that we collect from you, subject to applicable legal exceptions.
Right to Correct. You have the right to request that we correct inaccurate personal data.
Right to Opt Out of Sale of Personal Data and Targeted Advertising. You have the right to “opt out” of “targeted advertising,” certain types of profiling, and the “sale” of your “personal data” (as defined in the TXDPSA). Please note that we do not use your personal data in this way.

Exercising Your Texas Privacy Rights

Making Requests to Know, Access, or Delete Your Personal Information. To exercise your rights to know, access, delete, or correct your personal data, please submit a request by emailing us at privacy@tonkon.com or by filling our electronic contact form at www.tonkon.com/about/contact/. Only you, or someone legally authorized to act on your behalf, may make a request related to your personal data. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. We will only use personal data provided in a request to review and comply with the request. You do not need to create an account with us to submit a request to know or delete. We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. 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. We will delete or de-identify personal data not subject to a legal exception from our records and will direct our service providers to take similar action. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the data from one entity to another entity without hindrance.
Instructions for Using an Authorized Agent to Make Requests. You may use an authorized agent to submit a request to know or access, deletion, correction, or opt-out requests on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity. Authorized agents may submit requests by email us at privacy@tonkon.com.

How to Submit an Appeal

To appeal our decision regarding a request to these rights, you may email us at privacy@tonkon.com.

Contact Information

If you have any questions or comments about this Texas section of our Notice, or wish to exercise your Texas privacy rights, please do not hesitate to email us at privacy@tonkon.com.