Effective Date: January 26, 2017.

  1. Introduction and Overview.

This Privacy Policy describes how Frankfurt Kurnit Klein & Selz PC (“Company,” “we,” “our,” or “us”) collects, uses, and shares information about you and applies to your use of the blog located at www.focusonthedata.com and all features, content, and other services that we own, control and make available through such online service location (collectively, the “Service”). This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection).

  1. Information Collection.

                 A.   Information You Provide.

We and our Service Providers (defined below) may collect information you provide directly via the Service. For example, we collect information when you register an account, access our content, or otherwise communicate or transact with us through the Service.

The information we collect may include Personal Information. “Personal Information” is information that identifies you personally (whether alone or in combination), such as your first and last name, e-mail address, phone number, and postal address. You may choose to voluntarily submit certain other information to us through the Service, including Personal Information, but you are solely responsible for your own Personal Information in instances where we have not requested that you submit such information to us.

Personal Information once “de-identified” is not subject to this Privacy Policy and we and our Service Providers may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.

             B.   Information Collected Automatically.

We and our Service Providers may automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, data regarding network connected hardware, and information about your use of the Service. To the extent that we combine Usage Information with your Personal Information, we will treat the combined information as Personal Information under this Privacy Policy.

The methods that may be used on the Service to collect Usage Information include:

  • Log Information: Log information is data about your use of the Service, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
  • Information Collected by Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about your interactions with the Service or e-mails, including information about your browsing and activity behavior.                                         

                       Cookies: A cookie is a small text file that is stored on a user’s device, which may be a session ID cookie or tracking cookie. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies help in understanding how you use the Service, and remain longer. The Service may associate  some or all of these types of cookies with your devices. Cookies may remain on your device for extended periods of time.

                       Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.

                       Embedded Scripts: An embedded script is programming code designed to collect information about your   interactions with the Service. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Service, and deleted or deactivated thereafter.

Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies.

For further information on Tracking Technologies and your choices regarding them, please see “Third Party Services, Social Features, and Analytics” and “Your Choices” below.

     C.   Information from Other Sources.

 We may obtain information about you from other sources, including Service Providers and Third Party Services, and combine such information with information we have collected about you. To the extent we combine such third party sourced information with Personal Information we have collected about you on the Service, we will treat the combined information as Personal Information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.

  1.  Use of Information.

We may use information about you, including your Personal Information, for any purposes consistent with our statements under this Privacy Policy or as permitted by applicable law, including to:

  • Manage our Service, including your registration and account;
  • Respond to your comments, questions, and requests, and provide customer service;
  • Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
  • Prevent and address fraud, breach of policies or terms, and threats or harm;
  • Monitor and analyse trends, usage, and activities;
  • Improve the Service or other Company websites, applications, marketing efforts, products and services;
  • Send you advertisements and communicate with you regarding our products, services, offers, and events we think you may be interested in (for information about how to manage these communications and marketing efforts, please see “Your Choices” below); and
  • Fulfill any other purpose disclosed at the time you provide Personal Information.
  1. Sharing of Information.

 Our agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including Personal Information and Usage Information, in connection with their work on our behalf. These Service Providers are prohibited from using your Personal Information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.

We may also share information about you with third parties for any purposes consistent with our statements under this Privacy Policy or as permitted by applicable law, including as follows:

  • To comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements;
  • To protect the rights, property, life, health, security and safety of us, the Service or any third party;
  • In connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company;
  • For purposes disclosed at the time you provide Personal Information; and
  • With your consent or at your direction.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.

  1. Third Party Services, Social Features, and Analytics.

Our Service includes hyperlinks to websites, locations, platforms, or services operated by third parties (“Third Party Service(s)“). These Third Party Services may use Tracking Technologies to independently collect information about you and may solicit Personal Information from you.

Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third Party Services, such as third party social networks (“Social Features”).

Examples of Social Features include “liking” or “sharing” our content and otherwise connecting our Service to a Third Party Service. If you use Social Features, and potentially other Third Party Services, information you post or provide access to may be publicly displayed on our Service or by the Third Party Service that you use. Similarly, if you post information on a Third Party Service that references our Service (e.g., by using a hashtag associated with Company in a tweet or status update), your post may be used on or in connection with our Service. Also, both Company and the third party may have access to certain information about you and your use of our Service and the Third Party Service.

We use Google Analytics and other Service Providers for analytics services. These analytics services may use Tracking Technologies to help Company analyze Service users and how they use the Service. Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service’s activity, and providing other services relating to Service activity and other internet usage.

To the extent we combine information from Third Party Services with Personal Information we collect directly from you on the Service, we will treat the combined information as Personal Information under this Privacy Policy. Otherwise, the information collected and stored by third parties remains subject to their policies and practices, including whether they continue to share information with us, the types of information shared, and your choices on what is visible to others on Third Party Services. We are not responsible for and make no representations regarding the policies or business practices of any third parties or Third Party Services and encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on Tracking Technologies and your choices regarding them, please see “Information Collected Automatically” above and “Your Choices” below.

 6.  Your Choices.

            A.    Accessing Your Information

You may access, update, or remove certain account information that you have voluntarily submitted to us by sending us an e-mail at focusonthedata@fkks.com. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

           B.  Tracking Technologies Generally.

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings.  Browsers offer different functionalities and options so you may need to set them separately. With respect to our mobile apps, you can stop all collection of information via the app by uninstalling the app.  Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device.

Please be aware that if you disable or remove these technologies some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit.  Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

        C.  Analytics Tracking Technologies.

 You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

You can opt out of receiving certain promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link or by sending us an e-mail at focusonthedata@fkks.com with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that your opt out is limited to the e-mail address used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing, or Company’s ongoing business relations.

Your California Privacy Rights.

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.

Company will not share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please e-mail us at focusonthedata@fkks.com or send us a letter to Tanya Forsheit, Frankfurt Kurnit Klein & Selz PC, 2029 Century Park East, Suite 1060, Los Angeles, CA 90067. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Company is not required to respond to requests made by means other than through the provided e-mail address or mail address.

  1. Children.

The Service is intended for a general audience and not directed to children less than thirteen (13) years of age. Company does not intend to collect personal information as defined by the U.S. Children’s  Online Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe Company has collected such information in a manner not permitted by COPPA, please e-mail us at focusonthedata@fkks.com or send us a letter to Tanya Forsheit, Frankfurt Kurnit Klein & Selz PC, 2029 Century Park East, Suite 1060, Los Angeles, CA 90067, and we will remove such data to the extent required by COPPA.

  1. Data Security.

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information collected through our Service.

  1. International Transfer.

We are based in the U.S. and the information we and our Service Providers collect is governed by U.S. law.  If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored and used in the U.S.  Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Policy.

  1. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice, to your e-mail address.

  1. Contact Us.

If you have any questions or comments about this policy, please e-mail us  at focusonthedata@fkks.com or send us a letter to Tanya Forsheit, Frankfurt Kurnit Klein & Selz PC, 2029 Century Park East, Suite 1060, Los Angeles, CA 90067.