This Privacy Policy (the “Policy”) explains how Pullman & Comley, LLC (collectively, “we,” “us,” or the “Firm”) collects, uses, discloses, and protects personal information in the course of operating our websites, delivering legal and related professional services, conducting events and marketing and managing our business and client relationships. It also describes your rights and choices.
Categories of Personal Information We Collect
We collect information directly from you, automatically when you interact with our websites or communications, when you contact us or otherwise correspond with us, or when we provide services to you or receive services from you. The categories of personal information we may collect include:
- Data that you provide to us (e.g., where you contact us via email, telephone, or by any other means).
- Identifiers and contact information, such as name, employer, title, postal address, email address, phone number, and unique identifiers.
- Professional and business information, such as role, practice area or industry focus, relationship history, preferences, and communications with us.
- Client and matter information, including details necessary to provide legal services, manage engagements, conduct conflicts checks, and maintain privileged communications.
- Compliance and onboarding information, such as government identifiers.
- Financial and transaction data, such as invoicing details, payment information, and records of transactions with the Firm.
- Event and marketing data, such as registrations, attendance, subscription preferences, and your interactions with our newsletters and alerts.
- Device and usage data, such as IP address, device identifiers, browser type, operating system, referral URLs, pages viewed, links clicked, and interactions with our websites, emails, and online services collected via cookies, pixels, and similar technologies.
- Audio, visual, and security data, such as voicemail, webinar recordings, and photographs from Firm events.
Where we collect or process sensitive personal information (such as government identifiers, financial account information, health or disability data for event accessibility, diversity data, or criminal history for regulated checks), we do so only where necessary and permitted by law, and subject to appropriate safeguards.
Sources of Personal Information
We obtain personal information from:
- You directly, including through our websites, email, phone, in person, and at events, or when you make personal information public.
- When you visit our website.
- When you register to use any of our services.
- Public and private databases, regulators, and screening providers.
- Referrals, recruiters, job platforms, and background screening vendors for recruitment.
- Marketing, analytics, and communications service providers that support our websites and campaigns.
Purposes for Processing
We use personal information for the following purposes:
- Providing and administering legal and professional services, including managing engagements, client communications, billing, collections, and dispute resolution.
- Client onboarding, conflicts checks and other compliance activities required by law or regulation.
- Marketing and business development, including sending legal updates, event invitations, and newsletters, and organizing events and webinars.
- Vendor and contractor management, including due diligence, engagement, and performance monitoring.
- Complying with law, responding to lawful requests, and protecting rights, property, confidentiality, privilege, and safety.
- Analytics and website functionality, including security, troubleshooting, and improving our sites and communications.
Where we rely on consent, you may withdraw it at any time.
Disclosures of Personal Information
We may disclose personal information, as relevant and appropriate, to:
- Service providers acting on our behalf, such as IT hosting and support, communications platforms, screening providers, marketing and analytics vendors, payment processors, and professional advisers. We require service providers to use personal information only on our instructions and to implement appropriate confidentiality and security measures.
- Clients, counterparties, experts, courts, tribunals, regulators, and law enforcement, where necessary to provide services or comply with law and professional obligations.
- Transaction or corporate restructuring participants, including prospective buyers, investors, or counterparties, in connection with an actual or potential merger, acquisition, joint venture, or other corporate transaction, subject to confidentiality protections.
- Other third parties as required or permitted by law, to protect rights, property, confidentiality, privilege, safety, or to investigate suspected wrongdoing.
We do not sell or share personal information for cross-context behavioral advertising as those terms are defined under applicable U.S. state privacy laws.
Data Subject Rights Under Applicable Privacy Laws
Depending on where you reside, you may have rights under applicable data privacy laws, including the Connecticut Data Privacy Act (CTDPA) and other applicable privacy legislation. We may also choose to provide you these rights even if we are not required to do so. Subject to certain exemptions and verification requirements, you may have the following rights with respect to your personal information:
- Right to Know What Happens to Your Personal Information. This is sometimes called the right to be informed. You have the right to obtain information regarding our data processing activities that concern you, such as how we collect and use your personal information, how long we will keep it, and with whom it will be shared. We are informing you of how we process your personal information with this Privacy Policy.
- Right to Access Your Personal Information. This right allows you to confirm whether we are processing your personal information and, if so, to access that personal information. Once we receive and verify your request, we will provide you with: a copy of the specific personal information we have collected about you in a portable and readily usable format; the categories of personal information we process; the categories of sources from which we collected your personal information; our purposes for processing your personal information; the inferences about you derived from personal data; whether your personal information is being used for profiling that produces legal or similarly significant effects; and the third parties with whom we share your personal information.
- Right to Correct Your Personal Information. You have the right to request that we correct inaccurate personal information we have about you and to complete any incomplete personal information. If we deny your correction request, we will inform you of the reason for the denial.
- Right to Delete Your Personal Information. You have the right to request that we delete your personal information. In some cases, we may not be able to delete your information for technical or legal reasons. If that is the case, we will consider whether we can limit how we use it. We will inform you of our reason for denying your deletion request.
- Right to Data Portability. You have the right to request and receive a portable copy of your personal information that you have provided to us or that you have generated by using our services. We will provide your personal information in a structured, commonly used, and machine-readable format.
- Right to Opt Out. You have the right to opt out of: (1) the sale of your personal information; (2) the processing of your personal information for targeted advertising; (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; and (4) the collection, use, or sale of your personal information for the purpose of training artificial intelligence systems or large language models. To exercise your opt-out rights, you may enable an opt-out preference signal or Global Privacy Control on your browser or device, which we will recognize as a valid opt-out request, or you may submit an opt-out request using the contact methods listed in the “Contact Us” section.
- Right to Withdraw Consent. Where we process your personal information based on your consent, you have the right to withdraw your consent at any time. Please note that withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal.
- Right to Non-Discrimination. We will not discriminate against you for exercising any of your privacy rights. We will not deny you goods or services, charge you different prices or rates, provide you a different level or quality of services, or suggest that you may receive a different price or rate or level or quality of services as a result of exercising your privacy rights.
- Right to Appeal. If we decline to take action on your request, you have the right to appeal our decision. To submit an appeal, please contact us using the methods listed in the “Contact Us” section. We will respond to your appeal within the timeframe required by applicable law, explaining any actions taken or not taken and the reasons for our decision. If your appeal is denied, we will provide you with information on how to contact the appropriate regulatory authority, such as the Connecticut Attorney General for Connecticut residents, to submit a complaint.
- Limitations on Data Subject Rights. Your data subject rights are subject to certain limitations and exemptions under applicable law. In particular, these rights may be limited where necessary for the Firm to comply with its professional, ethical, and legal obligations, including obligations arising from attorney-client privilege, work product doctrine, professional secrecy, and duties of confidentiality owed to our clients. For example, you may not use data subject rights to request access to or deletion of personal information contained in privileged client communications, litigation files, deposition transcripts, discovery materials, court filings, or other documents related to legal proceedings in which you are a party or witness. We may also retain personal information where necessary to establish, exercise, or defend legal claims; to comply with document retention requirements under professional conduct rules, court orders, or regulatory obligations; or where deletion would impair the rights of our clients or third parties. Where we limit or deny a data subject rights request based on these exemptions, we will inform you of the basis for our decision. For sensitive data, including precise geolocation, certain financial or government identifiers, health data, biometric data, racial or ethnic origin, religious beliefs, or personal data of a known child, we will process such data only as permitted by applicable law and, where required, with your consent. Nothing in this Privacy Policy is intended to waive or limit the protections afforded to attorney-client communications, attorney work product, or information subject to professional secrecy or duties of confidentiality. This Privacy Policy does not create an attorney-client relationship, and our provision of information in response to privacy rights requests does not constitute legal advice.
To exercise your privacy rights, please contact us using the methods listed in the “Contact Us” section. Please indicate the nature of your request and your place of residence so we can route it appropriately. You may also designate an authorized agent to make a request on your behalf by providing written authorization to your agent and having your agent submit the request with proof of such authorization. We will acknowledge receipt of your request and respond within the timeframe required by applicable law. If we require additional time, we will notify you of the extension and the reason for it. In order to respond to your request, we may need to verify your identity. We may require additional information to verify your identity, and if you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from that person.
Data Security
We implement administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction, appropriate to the nature of the information and the risks involved. While we maintain robust security measures, transmission of information via the internet and email is not completely secure, and we cannot guarantee absolute security.
Data Accuracy, Minimization, and Retention
We take reasonable steps to keep personal information accurate and up to date and to limit processing to what is reasonably necessary and proportionate for the purposes described in this Policy. We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide services, comply with legal and regulatory obligations, maintain records consistent with our retention schedules, resolve disputes, and enforce agreements. Where appropriate, we may anonymize or aggregate information so that it no longer identifies you, in which case we may retain and use such information for legitimate business purposes.
Cookies and Similar Technologies
We use cookies, pixels, and similar technologies to operate our websites, enhance functionality, conduct analytics, and understand engagement with our communications. Where required by law, we obtain your consent for non-essential cookies. You may manage cookies through your browser settings or our cookie management tools. Our websites may not respond to Do-Not-Track signals, as there is no consistent industry standard.
For more information, please visit our Manage Cookies page accessible through a footer link on each page of our website, www.pullcom.com.
Children’s Information
Our services are not directed to children, and we do not knowingly collect personal information from children under 16 (or a higher age where required by local law). If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to delete it.
In compliance with applicable state privacy laws, including Connecticut’s minor data provisions, we do not process personal data for targeted advertising purposes when we have actual knowledge, or willfully disregard, that the individual is under 18 years of age. We do not sell minors’ personal data. We process minors’ personal data only where reasonably necessary for the services provided.
Third-Party Links and Services
Our websites may include links to third-party websites, plug-ins, and applications. We are not responsible for the privacy practices of third parties, and we encourage you to review their privacy policies.
You may interact with our Firm through third-party platforms, such as LinkedIn or other professional networking services. When you interact with us on these platforms, the third party’s privacy policy governs the collection of your personal information by that platform. We encourage you to review the privacy policies of any third-party platforms you use to interact with us.
Changes to This Policy
We may update this Privacy Policy from time to time. The “Effective Date” indicates when this Policy was last revised. Material changes will be communicated as appropriate. Your continued use of our services after an update constitutes acceptance of the revised Policy.
Contact Us
If you have questions about this Privacy Policy, our privacy practices, or wish to exercise your rights, please contact us at:
Privacy Office
Pullman & Comley, LLC
850 Main Street, Bridgeport, CT 06604
Email: info@pullcom.com
Telephone: (203) 330-2000
If you are not satisfied with our response, you may contact the appropriate regulatory authority.