Last modified: May 15, 2019

Gulovsen Law Office (the “Firm”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy (this “Policy”).

This Policy describes the types of information the Firm may collect from you or that you may provide when you  access the website located at https://gulovsen.io, any of its subdomains, and any other content, functionality, products or services provided by the Firm (collectively the “Services”). It also explains the Firm’s practices for collecting, using, maintaining, protecting, and disclosing that information.

Note that Gulovsen Law Office is the entity that acts as the controller of your information.

This Policy applies to information the Firm collects:

  • through the Services.
  • via email, text or other electronic messaging or communication service or app.
  • when you interact with the Firm’s advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

This Policy does not apply to information collected by:

  • us offline or through any other means not listed above.
  • any third party, including through any application or content (including advertising) that may link to or be accessible on or via the Services.

Acceptance of Privacy Policy

Please read this Policy carefully to understand how the Firm collects, uses, discloses, and processes your information. If you do not agree with or you are not comfortable with any aspect of this Policy, you should immediately discontinue access or use of the Services. By accessing or using the Services, you agree to this Policy. This Policy may change from time to time (see Changes to This Policy). Your continued use of the Services after the Firm makes changes shows your acceptance of those changes, so please check this Policy periodically for updates.

What Information the Firm Collects and How the Firm Collects it

The Firm collects several types of information from and about users of the Services, including information:

  • by which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline (“Personal Information”).
  • that is about you but individually does not identify you, such as basic analytics and log-in information when you use the Services, some of which may be collected from third-party providers like Facebook or Google Analytics.
  • about your Internet connection, the equipment you use to access the Services, language information and usage details.

The Firm collects this information:

  • directly from you when you provide it to us.
  • automatically as you navigate through the site, which may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • from third parties, such as the Firm’s business partners.

Information You Provide to Us

The information the Firm collects on or through the Services may include:

  • information that you provide by filling in forms on the Services, including information provided at the time of registering to use or subscribing to the Services or requesting support.
  • records and copies of your correspondence (including email addresses), if you contact us.
  • details of transactions you carry out through the Services (which may include financial information that the Firm collects as needed to process any orders you place through the Services).
  • your search queries on the Services.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Services or transmitted to other users of the Services or third parties (collectively, “User Contributions”). Your User Contributions (e.g., comments on blog posts, testimonials, etc.) are posted on and transmitted to others at your own risk. Although the Firm limits access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, the Firm cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, the Firm cannot and does not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information the Firm Collects Through Automatic Data Collection Technologies

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

  • details of your visits to the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Services.
  • information about your computer and Internet connection, including your IP address, operating system, and browser type.

The information the Firm collects automatically may include Personal Information or the Firm may maintain it or associate it with Personal Information the Firm collects in other ways or receive from third parties. This helps the Firm improve the Services and to deliver a better and more personalized service, including by enabling it to:

  • estimate the Firm’s audience size and usage patterns.
  • store information about your preferences, allowing the Firm to customize the Services according to your individual interests.
  • speed up your searches.
  • recognize you when you return to the Services.

The technologies the Firm uses 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 the Services. Unless you have adjusted your browser setting so that it will refuse cookies, the Firm’s system will issue cookies when you direct your browser to the Services.
  • Flash Cookies. Certain features of the Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How the Firm Uses and Discloses Your Information.
  • Web Beacons. Pages of the Services and the Firm’s emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. 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 the Services. 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.

The Firm does 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 the Firm Uses and Discloses Your Information.

Information the Firm Will Never Collect

The Firm never asks for your private keys, cannot access your private keys, and do not maintain custody of any private keys on your behalf. You should never disclose your private keys to anybody under any circumstances. Because the Firm does not have access to nor maintain your private keys, you are solely responsible for maintaining the security of your private keys. You must keep your private key access information secure. Failure to do so may result in the complete loss of access to those Services that require private key access.

Children Under the Age of 13

The Services are not intended for children under 13 years of age. No one under age 13 may provide any information using the Services. The Firm does not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on the Services. If the Firm learns that it has collected or received Personal Information from a child under 13, the Firm will delete that information. If you believe the Firm might have any information from or about a child under 13, please contact the Firm using our Contact Page or send an email to info@gulovsen.io.

Why the Firm Collects and How the Firm uses Your Information

The Firm uses information that it collects about you or that you provide, including any Personal Information, to do the following:

  • present the Services and its contents to you.
  • provide you with information, products, or services that you request from us.
  • provide you with notices about your account, including expiration and renewal notices.
  • conduct the Firm’s obligations and enforce its rights arising from any contracts entered into between you and the Firm, including for billing and collection.
  • let you know about changes to the Services or any products or services the Firm offers or provide though it.
  • Allow you to participate in interactive features on the Services.
  • Fulfill any other specific purpose for which you provide the information with your consent.

The Firm may also use your information to contact you about its services that may be of interest to you. If you do not want your information used in this way, please adjust any account-related settings on the Services or with any relevant third-party services provider. For more information, see Choices About How the Firm Uses and Discloses Your Information.

Disclosure of Your Information

The Firm may disclose aggregated information about the its users, and information that does not identify any individual (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.), without restriction.

The Firm may disclose Personal Information that it collects, or you provide, as described in this Policy:

  • to the Firm’s subsidiaries and affiliates.
  • to contractors, service providers, and other third parties the Firm uses to support its business.
  • to fulfill the purpose for which you provide it.
  • for any other purpose disclosed by the Firm when you provide the information.
  • with your consent.

Legal Basis for Using and Disclosing Your Information

The Firm may also disclose your Personal Information:

  • to follow any court order, law, or legal process, including to respond to any government or regulatory request.
  • to enforce or apply the Firm’s terms of use and other agreements, including for billing and collection purposes.
  • to investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • to protect the rights, property, or safety of the Firm, its clients, or others.
  • for the purposes of compliance, fraud protection and credit risk reduction.

Choices About How the Firm Uses and Discloses Your Information

The Firm strives to provide you with choices regarding the Personal Information you provide to us. It has 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. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote the Firm’s own services, you can opt out by using our Contact Page or sending an email to info@gulovsen.io . If the Firm has sent you a promotional email, you may send the Firm a return email asking to be omitted from future email distributions.

The Firm does 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’s website, available at http://optout.networkadvertising.org.

Storage and Processing

Your Information May Be Stored and Processed Anywhere in the World

The Company maintains (and requires its service providers to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the Personal Information you entrust to us. This information may be stored and processed in the United States, Europe, Africa, or anywhere else in the world in which the Firm or its subsidiaries, affiliates or service providers maintain facilities. You acknowledge that, as part of making the Services available to you, the Firm may transfer your information to or maintain your information on computers 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. You agree that the Firm has the right to transfer your information to any jurisdiction in the world in which the Firm or its subsidiaries, affiliates or service providers maintain facilities and by using the Services, or by otherwise providing any information to the Firm, you consent to the processing and transfer of that information in any jurisdiction.

Important Privacy-Related Information Regarding Blockchain Technology

In addition to any information that is stored on computers which the Company or its subsidiaries, affiliates or service providers maintain, the Services may also record data on various distributed public blockchain networks which are replicated over tens of thousands of computer systems across the globe. Given the nature of blockchain technology, once a transaction has been added to the blockchain ledger and verified, it is impossible for you, the Firm, or anyone to delete or modify that data, and it will remain on the blockchain ledger forever. In using the Services, you acknowledge that you understand and accept the fact that your data may be permanently recorded on one or more public blockchains and that it will not be possible to modify or delete that data even though the privacy laws of your jurisdiction might otherwise require such data to be modified or deleted.

How the Firm Protects and Secures Your Information

The Firm takes safeguarding your information seriously. The Firm will take reasonable administrative, physical, and electronic measures to help protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration or destruction. All that said, no method of transmitting or storing information over the Internet is completely secure. With that in mind, the Firm cannot guarantee the absolute security of your information. The Firm is not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of the Firm’s digital services.

The Firm retains information it collects as long as it is necessary and relevant to fulfill the purposes outlined in this Policy. In addition, the Firm retains Personal Information to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce its Terms of Use, and other actions permitted by law. To determine the appropriate retention period for Personal Information, the Firm considers the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which it processes your Personal Information and whether the Firm can achieve those purposes through other means, and the applicable legal requirements.

In those cases where the Firm aggregates information about its users (so that it cannot be associated with you or any other individual), and collect information that does not identify any individual (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) the Firm may store and use this information indefinitely without further notice to you.

Accessing, Correcting and Deleting Your Information

The Company makes every effort to comply with the directives appearing in the European Union General Data Processing Regulation (“GDPR”) regarding the following:

  • the right to access, correct and delete your personal data the Firm collects.
  • the right to restrict or prohibit the Firm’s use of your personal data that it collects.
  • the right to download and transfer your personal data that it collects.

In order to accomplish any of the foregoing, please use our Contact Page or send an email to info@gulovsen.io and the Firm will use best efforts to assist you unless it believes doing so would violate any law or legal requirement or cause the information to violate its own terms of use.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of the Services that are California residents to request certain information regarding the Firm’s disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use our Contact Page or send an email to info@gulovsen.io .

Changes to This Policy

The Firm reserves the right to modify this Policy at any time and will post any changes it makes on this page with a notice that the Policy has been updated at https://gulovsen.io. If the Firm makes material changes to how it treats its users’ Personal Information, the Firm will notify you by email to the primary email address specified in your account and/or through a notice at https://gulovsen.io. The date this Policy was last revised is identified at the top of this page. You are responsible for ensuring the Firm has an up-to-date active and deliverable email address for you, and for periodically visiting the Services and this Policy to check for any changes.

Contact Information

To ask questions or comment about this Policy and the Firm’s privacy practices, you may contact the Firm using the contact information appearing in the sidebar (in the top right on a full-size browser or below on a mobile device).

You may also use the Contact Page or send an email to info@gulovsen.io.