Privacy Policy

Privacy Policy

O’Hagan Meyer PLLC (“OM,” “we,” “us”) is an Illinois-based firm that takes privacy rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) seriously.  Included in your CCPA/CPRA rights is the right to notice of how we will be collecting, using, sharing, storing, and deleting your data, as well as rights that you have that attach to each case.  As a job applicant and/or potential recruit of OM in California or with California-protected data, you may have rights under the CCPA and/or CPRA.  If you have rights, they are described in this Policy.  In the context of your interaction(s) with OM, OM will have access to, use, store, potentially share, and delete your Personal Data, as described below.  Please read this Privacy Policy carefully and refer any questions to hr@nullohaganmeyer.com.  This Privacy Policy may be supplemented by other privacy policies for any third-party service, software, or platform that is used in your interactions with OM, including but not limited to third-party providers such as Workable Software Limited.

1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

Personal Information

  • Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household.

Sensitive personal information

  • Personal information revealing a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data,  biometric information, and citizenship or immigration status.

Biometric Information

  • An individual’s physiological, biological, or behavioral characteristics, including information about an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

2. Personal Information We Collect About You. In the preceding 12 months, we have collected the following categories and specific types of consumer personal information:

  • Identifiers
    • May include real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social profile URL
  • Customer records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))
    • May include name, signature, address, telephone number, employment history.
  • Internet or other electronic network activity information
    • Browsing history, search history, information interaction with the website or application.
  • Geolocation data
    • Physical location (calculated from IP address)
  • Professional or employment-related information
    • Current job title and employer, and resume
  •  Payment information
    • All information necessary to complete online payments, such as payment details, bank account information, billing information
  1. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text, or email, or through our third-party service providers and their agents/employees and/or web portals. However, we may also collect information from the following categories of sources:
  • Third party (e.g., sanctions screening providers, credit reporting agencies, customer due diligence providers, advertising networks, internet service providers, social networks, data analytics providers, government entities, and data brokers);
  • Cookies on our website;
  • Automated information collection; and
  • Our IT systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems.

Why We Use Your Personal Information. We collect your personal information for the following business purposes:

  • Debugging to identify and repair errors that impair existing intended functionality;
  • For employment-related purposes, including pre-employment and recruiting;
  • For our legitimate interests or those of a third party; or
  • Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for

  • For employment purposes
    • For all legitimate reasons related to recruiting, hiring, and/or development employment-related prospects
  • To prevent and detect fraud against you or OM
    • For our legitimate interests or those of a third party – i.e., to minimize fraud that could be damaging for us and for youGathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies
  • To comply with our legal and regulatory obligationsEnsuring business policy compliance
    • For our legitimate interests or those of a third party – i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
  • Operational reasons, such as improving efficiency, training, and quality control
    • For our legitimate interests or those of a third party – i.e., to be as efficient as we can so we can deliver the best service for you at the best price
  • Statistical analysis to help us manage our business
    • For our legitimate interests or those of a third party – i.e., to be as efficient as we can so we can deliver the best service for you at the best price

4. Sensitive personal informationCategories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

  • Identifiers;
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual;
  • Characteristics of protected classifications under California or federal law;
  • Internet or other electronic network activity information;
  • Geolocation data;
  • Professional or employment-related information; and
  • Sensitive personal information

5. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us in line of our federal and state record retention requirements and internal policies related to the retention of employee files, including this of job applicants and/or other recruits or prospects. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

6. Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

  • You have the right to know, and request disclosure of:
    • The categories of personal information we have collected about you, including sensitive personal information;
    • The categories of sources from which the personal information is collected;
    • Our business or commercial purpose for collecting, selling, or sharing personal information;
    • The categories of third parties to whom we disclose personal information, if any; and
    • The specific pieces of personal information we have collected about you.

Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

  • The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and
  • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.

You have the right to opt-out of the sale of your personal information or sharing of your personal information for targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.

Right to Limit Use of Sensitive Personal Information You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

  • Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
  • To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, if the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and
  • As authorized by further regulations.

You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.
Right to Deletion Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Direct any service providers or contractors to delete your personal information from their records.
  • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.
    Please note that we may not delete your personal information if it is reasonably necessary to:
  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right of Correction

If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Protection Against Retaliation

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

7. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you may also call us, or email/write to us.

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly by email, phone, or in writing, you will need to provide us with:

  • Enough information to identify you;
  • Proof of your identity and address; and
  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.