THE ORACLE LEGAL GROUP PRIVACY POLICY

1. Our Site provides a comprehensive overview of our law firm and the services we offer. In addition to introducing our team and practice areas, we offer a range of resources, including FAQs, blog posts, newsletters, firm news, and event announcements. Visitors can also access our contact information and use the integrated chat feature to ask general questions or be directed to relevant information. All content on this site is for general informational purposes only and does not constitute legal advice or create an attorney–client relationship.

2. Information We Collect or Receive.

We may collect Personal Information (as defined below) about you directly from you and from third parties, as well as automatically through your use of our Site. In the course of operating the Site, we will collect and/or receive the following types of information:

1. Personal Information. We only receive or collect information that identifies you personally (“Personal Information”) if you choose to provide such personally identifiable information to us via registration, email, or other means. When you sign up to become a user or contact us, you will be required to provide us with Personal Information about yourself. This Personal Information may include your name, date of birth, physical address, and e-mail address. You will also have the option to voluntarily provide us with other Personal Information, including but not limited to, those you choose to disclose to explain the services you might seek. We do not collect any of your Personal Information when you use the Site unless you voluntarily provide us with the information. You may also provide protected health information and other medical-related information through the Site. We are not responsible for any medical or any personal protected health information you provide.
2. Geolocational Information. Certain features and functionalities of the Site are based on your location. In order to provide these features and functionalities while you are using your mobile device and/or computer, we may, with your consent, automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers (collectively, “Geolocational Information”). Collection of your Geolocational Information occurs only when the Site is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.
3. Survey Data. To help us assist you more effectively, we may invite you to complete survey questions and, where applicable, request that you upload names and email addresses. This information may be used to distribute surveys either directly by you or on your behalf by us.
4. Appointment Information. When scheduling an appointment or consultation through our online services, we may collect the information necessary to process your request. This may include details about the appointment itself and, if you choose to provide it, health or legal information that may be associated with your request.
5. Third-Party Analytics. We and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which we work use third-party analytics services (e.g., Google Analytics, Google reCAPTCHA, and Google G Suite for Email) to evaluate your use of the Site, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Site and mobile and Internet usage. These third parties may use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. The operator of Google Analytics is Google LLC, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States. Our third-party technology providers may utilize Google Analytics and Google reCAPTCHA. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Without limiting the generality of the foregoing, Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the sites, compile reports on the sites’ activity, and provide other services related to sites activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor and any referring website. The information generated by Google Analytics may be transmitted to and stored by Google and will be subject to Google’s privacy policy: https://policies.google.com/?hl=en. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google click here: https://policies.google.com/technologies/partner-sites. For more information on Google Analytics, and how it collects and processes data, go to the site “How Google uses data when you use our partners’ site or apps”, which may be located at the website google.com/policies/privacy/partners/, or any other URL Google may provide from time to time. For more information on these third parties, including how to opt out from certain data collection, please go to section 10 “Information Collected by or Through Third-Party Companies.” Please be advised that if you opt out of any such service, you may not be able to use the full functionality of the Site.
6. Other Information. In addition to the Personal Information and Geolocational Information, we may automatically collect or receive additional information regarding you and your use of the Site; your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the Site. Such other information may include:
   
   1. From You. Additional information about yourself that you voluntarily provide to us, such as a username, password, your physical address, and your product and service preferences.
   2. From Your Activity. We may collect or receive information regarding: your IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device; browser type and language; how you encountered the Site; referring and exit pages and URLs; date and time of your activity; and details regarding your activity on the Site, such as search queries and other performance and usage data.
   3. About Your Mobile Device. We may collect or receive information regarding: the type of mobile device you are using; advertising Identifier (“IDFA” or “AdID”); the operating system and version (e.g., iOS, Android, or Windows); your carrier; and the network type being utilized (Wi-Fi, 3G, 4G, 5G, LTE).

3. How We Collect Your Data.

You directly provide us with most of the data we collect. We collect data and process data when you:

1. If you contact us directly, we will collect your name, email address, phone number, contact details, the content, date, and time of your message and any attachments thereto, and other information you may directly provide to us. You may choose to submit your email address and phone number on our Site to receive updates. If you reach out to us with inquires or requests, we will keep a record of how your inquiry or request was handled.
2. Online Usage Data. We may automatically collect the following information about your use of our Site through: cookies, web beacons, and similar technologies; your domain name; browser type; operating system type, name and version; page views; links you click; your IP address; location information; the length of time you visit or use our Site; referring URL; access date and time; mobile device ID; language information; device name and model; and other information about your activities within the services and communications that we send you. Please see the sections listed under the “Cookies” topic and the section labeled “Information Collected by or Through Third-Party Advertisers” below for more information. Where required under applicable law, we will only perform such data collection with your consent.

4. How Information is Used.

We collect your data so that we can: (a) Provide our services and enable you to access and use the Site; (b) Improve our overall Site, and your experience with our Site (such as making suggestions, and ranking search results); (c) Process and confirm your purchase, and to manage your account; (d) Email you with information on services we think you might want to utilize and administer to our programs; (e) Provide you with customer services; and (f) Comply with our legal obligations and ensure compliance with Oracle Policies (such as verifying information or identifications provided by you, resolve disputes, enforce our Terms of Use and other policies, conduct security investigations and risk assessments, and detecting or preventing fraud and other harmful activity). We will provide third parties with your Personal Information when you purchase products, or with your request. In this instance, Oracle will provide information to these persons who would use the information to bill you, or provide you with the products.

5. How Information is Shared.

1. In order to provide our services and administer our programs, we may share your information with our third-party partners, including, without limitation, businesses participating in our various programs. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
2. We engage third-party companies and individuals to perform functions on our behalf. Examples include providing product fulfilment, technical assistance, payment processing, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the information only as necessary to perform their functions and to the extent permitted by law.
3. In an ongoing effort to better understand our users, the Site, and our products and services, we analyze certain information in anonymized and aggregate form to operate, maintain, manage, and improve the Site, and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the Site, and these products and services to current and prospective business partners and investors, and to other third parties for other lawful purposes.
4. We may share some or all of your information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
5. As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the information may be part of the transferred assets.
6. To the extent permitted by law, we may also disclose the information:
   
   1. when required by law, court order, or other government or law enforcement authority or regulatory agency; or
   2. whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

6. What Are Cookies?

Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our Site, we may collect information from you automatically through cookies or similar technology.

For further information, visit www.allaboutcookies.org.

7. How We Use Cookies.

We use cookies in a range of ways to improve your experience on our Site, including: keeping you signed in; understanding how your use our Site and to personalize your experience with the Site; identifying the type of device you are using; analyzing which portions of the Site are visited and used most frequently; measuring and optimizing advertising and promotional effectiveness; and to understand and tailor the user experience.

8. Types of Cookies We Use.

There are a number of different types of cookies, however, our Site uses the cookies listed below.

We use session cookies, which expire once you close the Site, and persistent cookies, which stay on your mobile device or computer until you delete them and other technologies to help us collect data and to enhance your experience with the Site.

We use functionality cookies so that we recognize you on our Site and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

We use advertising cookies to collect information about your visit to our Site, the content you viewed, the links you followed and information about your browser, device, and your IP address. We sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our Site.

9. How to Manage Cookies.

If you do not want us to deploy cookies in the Site, you can opt out by setting your mobile device or computer to reject cookies. You can still use the Site if you choose to disable cookies, although your ability to use some of the features may be affected.

10. Information Collected by or Through Third-Party Companies.

We may share information about your activity on the Site with third parties for Site optimization. These third parties may use cookies, and/or other technologies to collect information for such purposes. In addition, we may receive information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data.

We do not “sell” or “share” your Sensitive Personal Information. Sensitive Personal Information may include (1) personal information that reveals (A) a social security, driver’s license, state identification card, or passport number; (B) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) precise geolocation; (D) racial or ethnic origin, immigration status, religious or philosophical beliefs, or union membership; (E) the contents of mail, email, and text messages except where we are the intended recipient of the communication; (F) genetic data; (2) the processing of biometric or genetic information for the purpose of uniquely identifying a consumer; (3) personal information collected and analyzed concerning a consumer’s health or diagnosis; (4) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation; and (5) personal information collected from a known child.

11. Communication Preferences.

Our sites and services may allow us or other users to communicate with you or other users through our in-product instant messaging services, service-branded emails, SMS, and other electronic communication channels.

• 11.1. Text Messaging. We may make available text messaging services in which you can receive messages from us and send messages to us on your mobile phone.
• 11.2. Opting Out of Requested Communications. Requested communications include, for instance, email newsletters and software updates that may be expressly requested by you or which you consented to receive. After you request such communications, you may “opt-out” of receiving them by using one of the following methods: i) selecting the email “opt-out” or “unsubscribe” link, or following the opt-out instructions included in each email communication; ii) returning to the web page(s) where you originally registered your preferences and following the opt-out instructions; or emailing clients@dev.theoraclelegalgroup.com.
• 11.3. Opting Out of Transactional or Relationship Communications. Communications that are sent by or on behalf of a user are indicated as being from that user. Communications that are sent by us are indicated as being from us or one of our account or support specialists. Either type of communication may be “real time” communications or communications triggered automatically upon the occurrence of certain events or dates, such as appointment reminders. Email communications received from users and our administrative announcements are often transactional or relationship messages, such as appointment requests, reminders, and cancellations. You may not be able to opt-out of receiving certain email messages, although our services may provide a means to modify the frequency of receiving them.
• 11.4. Opting Out of General or Promotional Communications. General communications provide information about products, services, and/or support and may include special offers, new product information, or invitations to participate in market research. You may opt-out of receiving these general communications by using one of the following methods: i) selecting the email “opt-out” or “unsubscribe” link, or following the opt-out instructions included in each email communication; or ii) emailing clients@dev.theoraclelegalgroup.com.

12. How We Protect Your Information.

We take commercially reasonable steps to protect your data and information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These steps include a combination of process, technology, and physical security controls. When you submit your information through the Site, that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the top or bottom of your web browser or looking for “https” at the beginning of the URL address of the web page. We have internal policies and processes directed toward limiting access to your information to those employees, contractors, and agents of Oracle who need to know such data to perform their jobs and develop or improve our websites, products, and services.

We securely store your data with a cloud host. All of our servers are encrypted, with a standard process for data deletion. Our third-party provider utilizes a number of proprietary methods to safeguard information. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that your information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mails and messages sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail or other messaging programs. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as consistent with i) the legitimate needs of law enforcement or ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

13. External Websites.

The Site may contain links to third-party websites including, but not limited to social media sites, and google. We have no control over the privacy practices or the content of these third-party websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

14. Protected Health Information (PHI) and HIPAA Compliance.

While our firm is not a healthcare provider, in the course of providing legal services—particularly when representing clients in the healthcare industry—we may receive, store, use, or disclose Protected Health Information (“PHI”) as defined under the Health Insurance Portability and Accountability Act (“HIPAA”). In such cases, our handling of PHI is governed by applicable law, including HIPAA, and any Business Associate Agreements (“BAAs”) we enter into with covered entities.

15. Use and Disclosure of PHI in the Course of Representation.

If we are engaged by a covered entity and receive PHI as a Business Associate, we will use and disclose that information solely in accordance with the terms of the governing Business Associate Agreement and applicable HIPAA regulations. This means we may use PHI only to provide legal services on behalf of the covered entity, or as otherwise permitted under HIPAA, such as:

• For our firm’s internal legal compliance and risk management purposes;
• To carry out our obligations under law, including court orders or regulatory requirements;
• To perform limited data aggregation services, where applicable and authorized;
• To subcontract services, provided that such subcontractors agree in writing to comply with the same HIPAA obligations applicable to us under the BAA.

Where permitted, we may also de-identify PHI in accordance with HIPAA standards and treat such de-identified information as non-PHI, subject to the terms of our Privacy Policy. Please note that this section is intended to explain how we may handle PHI in a professional capacity and does not create any private rights or remedies for individuals under this Privacy Policy, HIPAA, or any other regulation.

16. Children’s Privacy.

The Site is not directed to children under the age of 18. We adhere to the Children’s Online Privacy Protection Act (“COPPA”) and will not knowingly collect Personal Information from any child as determined in the applicable jurisdiction. We ask that minors not use the Site. If a child has provided us with Personal Information, a parent or guardian of that child may contact us at clients@dev.theoraclelegalgroup.com and request that such information be deleted from our records. For more information about the Children’s Online Privacy Protection Act, please visit www.ftc.gov.

17. How We Handle Do Not Track Signals.

Some web browsers and operating systems include a Do-Not-Track (“DNT”) setting that you can activate to signal your preference not to have information about your online activities monitored. There is currently no uniform standard for recognizing and implementing DNT signals. As a result, our Site does not respond to DNT signals. If a standard for recognizing DNT signals is adopted in the future and we follow that standard, we will inform you about our approach in an update to this Privacy Policy.

18. California Privacy Rights.

Under the California Consumer Privacy Act, California residents who have an established business relationship with us may choose to opt out of our sharing their contact information and other Personal Information with third parties for direct marketing purposes, or for limited purposes, such as providing you with the services you request. If you are a California resident and you wish to opt out, please send an e-mail to clients@dev.theoraclelegalgroup.com. California residents who are our users in California now have the right to see a report summarizing all of their personal data that we have collected and to request the removal of their data from our computer systems.

California law permits members who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those third parties.

The California Consumer Privacy Act, as amended (“CCPA”), allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ Personal Information correct inaccurate information a business has on you and to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of Personal Information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes or collecting the information, and the categories of third parties with which the information was shared.

California residents also have the right to submit a request for deletion of information under certain circumstances. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete a transaction for which we collected the personal information, provide something that you requested, take actions reasonably anticipated within the context of our ongoing relationship with you, or fulfill any legal obligations we may have.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
6. 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

Notice to California Minors. If you are a California resident under 18 years old and a registered user, you can request that we remove content or information that you have posted to our Site or other online services. Note that fulfillment of the request may not ensure complete or comprehensive removal (e.g. if the content has been reposted by another user). To request removal of content or information, please email clients@dev.theoraclelegalgroup.com.

19. Nevada Privacy Rights.

Oracle does not sell your Personal Information. However, we believe it is important that you are aware you have the right to opt-out of the sale of your Personal Information. Access requests may be made directly toclients@dev.theoraclelegalgroup.com.

20. Important Notices to Non-U.S. Residents.

The Site and its servers are operated in the United States. If you are located outside of the United States, please be aware that your information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Site, you hereby consent to such transfer, processing, and use in the United States and elsewhere.

This Site is not marketed to users outside the United States. If you are located in the European Economic Area (“EEA”) you should not use the Site.

21. Your Data Protection Rights.

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access. You have the right to request copies of your personal data.
• The right to rectification. You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we complete information you believe is incomplete.
• The right to erasure. You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing. You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing. You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability. You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please don’t hesitate to contact us.

22. Changes to This Privacy Policy.

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the Site. By accessing the Site after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

23. How to Contact Us.

If you have questions about this Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us. If you choose to e-mail us, please write “Privacy Policy” in the subject line. You may contact us through the following: