Colin Farnsworth

Attorney

Prior to joining Siri & Glimstad, Mr. Farnsworth worked for a law firm that focused exclusively on matters involving the Freedom of Information Act (FOIA). He has experience facilitating FOIA actions against a wide range of federal agencies, including the NIH, CMS, FDA, IRS, FBI, ICE, Army, and the DOJ. Mr. Farnsworth is dedicated and passionate about promoting government transparency and getting clients – and the public – the records they’re entitled to receive. Prior to becoming an attorney, Mr. Farnsworth worked for nearly a decade as a certified social studies and language arts teacher in Oregon’s public schools.

Admissions

Oregon
U.S. District Court for the District of Columbia

Contact Us

Siri & Glimstad LLP (“SG”, “we”, “us” or “our”) welcomes you as a visitor to and user of our websites (“user”, “you” or “your”). SG operates several websites (the or our “websites”), the following Notices and Full Disclaimer (“Notices”), Terms and Conditions (the “Agreement”), and Privacy Policy (“Policy”) apply to all the websites operated by SG that link to this document. In order to use any of the websites, you must accept all the terms of the Notices, Agreement and Policy. By continuing to use any of the websites, you agree that you accept the terms of this Notices, Agreement and Policy and agree to abide by same in all your interactions with the websites. If you do not understand or have questions about the Notices, Agreement, or Policy, immediately stop all use of the websites and contact itaccounts@sirillp.comIf you do not contact us, we will assume that you understand the Notices, Agreement, and Policy and have no questions about same.

The Notices, Agreement, or Policy may periodically change without notice, so you should check the Notices, Agreement, and Policy before every attempt to use the websites. When the Notices, Agreement, or Policy is changed, the date of the latest revision will appear at the top of the Notices, Agreement, or Policy. By continuing to access or use the websites on or after the date the revised Notices, Agreement, or Policy are made available here, you agree to be bound by the revised Notices, Agreement, and Policy.

No one under 18 is allowed to use or access the websites. By using the websites, you state that:

You are at least 18 years old and over the minimum age required by the laws of your country of residence to access and use the websites;
You can form a binding contract with SG;
You are not barred from using the websites under any applicable laws; and
You have not been permanently suspended or removed from the websites.

If you are accepting the Notices, Agreement and Policy on behalf of another legal entity, including a business or government entity, you represent that you have full legal authority to bind such entity to the Notices, Agreement and Policy.

Notices and Full Disclaimer

Last updated May 12, 2022

Attorney Advertising Disclaimer: The material on the websites, other than Your Content (as defined in the Agreement), has been prepared and is copyrighted by SG. The material is for informational purposes only and does not constitute legal advice. The material is not guaranteed to be correct, complete, or up to date. Information provided by or cited to by you or third parties does not necessarily reflect the opinions of SG or any of its attorneys or clients. Without limiting the generality of the foregoing, we are not responsible for any content, communications, information, or other materials posted, submitted, communicated, shared, discussed or otherwise generated by you or third-parties on our websites, nor do we guarantee its truthfulness, accuracy or completeness.

Disclaimer On Contract Or Attorney-Client Relationship Formation: Your receipt of the information on, use of, or submission to the websites is not intended to create, and does not constitute, a contract for representation by SG nor does it create an attorney-client relationship between you and SG. This information is not intended to substitute for obtaining legal advice from an attorney. No person should act or rely on any information in the websites without seeking the advice of an attorney. Also, please be aware that the sending of an e-mail message to SG does not contractually obligate SG to represent you as your attorney. SG cannot serve as your counsel in any matter unless you and our firm expressly agree, in writing, that we will serve as your attorney.

Statute Of Limitations Notice: You should be aware that the Statute of Limitations (the deadline imposed by law within which you may bring a lawsuit) may severely limit the time remaining for you to file any potential claims you may have.

This Is An Advertisement: The websites may be considered advertising in some jurisdictions under the applicable law and ethical rules. The determination of the need for legal services and the choice of a lawyer are extremely important decisions and should not be based solely upon advertisements or self-proclaimed expertise. No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers.

Independent Investigation: All potential clients are urged to make their own independent investigation and evaluation of any lawyer’s credentials and ability being considered, and not rely upon advertisements or self-proclaimed expertise. Our attorneys are not certified as specialists in any particular field of law.

SG Does Not Offer Any Guarantees Of Case Results: Every legal matter is different. The outcome of each legal case depends upon many factors, including the facts of the case, and no attorney can guarantee a positive result in any case. Any testimonial or endorsement does not constitute a guarantee, warranty, or prediction regarding the outcome of your legal matter. Prior results do not guarantee a similar outcome.

Jurisdictions In Which Our Attorneys Are Licensed To Practice: Members of the firm practice in federal district courts throughout the United States. SG attorneys are licensed to practice in the state(s) enumerated on their individual attorney profiles.

Notice On Contingent Fees: SG represents clients in certain cases on a contingent fee basis. In such cases, no fee will be charged in the absence of recovery. However, in the event of an adverse verdict or decision, the contingent fee litigant may be responsible for court costs.

Statement Of Client’s Rights: The Appellate Divisions of the State of New York have enacted a Statement of Client’s Rights and Statement of Client’s Responsibilities which are available at www.nysba.org If you have any questions about the content of either of these documents, please let us know.

The Websites Do Not Provide Medical Diagnosis or Advice: The content provided on the website, such as documents, text, graphics, images, videos, news alerts, pharmaceutical drug recalls, prescription medication history, or information on litigation concerning the foregoing topics, or other materials, is for informational purposes only. Links to other websites are provided for information only. Use of trade names is for identification only and does not constitute endorsement by SG.

Without limiting the generality of the foregoing, the website may present information about pharmaceutical drug recalls, which is for information purposes only. Such information is not necessarily the most current information on subject and may or may not be updated based on the last information concerning such recalls.

Image Notice: No persons pictured on the websites are clients of SG.

Copyright Policy: SG respects the intellectual property rights of others. If you believe your work has been copied in a way that constitutes copyright infringement or are aware of any infringing material on the websites, please contact us at itaccounts@sirillp.com and provide us with the following information: an electronic or physical signature of the person authorized to act on behalf of the owner of the copyright interest; a description of the copyrighted work that you claim has been infringed; a description of where the material that you claim is infringing is located on the websites; your address, telephone number, and email address; a written statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; a statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf.

Nature of the Firm: SG is a registered limited liability partnership under the laws of the State of New York. The personal liability of our partners is limited to the extent provided in such laws. Additional information is available upon request made to our office in New York.

Terms and Conditions

Last updated May 12, 2022

1. Limited License: Subject to your complete and ongoing compliance with and acceptance of the Notices, Agreement and Policy, SG grants you a personal, non-transferable, non-exclusive, revocable, limited license to access and use the websites. We reserve all rights not expressly granted to you by the Notices, Agreement, or Policy.

Unless such a restriction is impermissible under applicable law, you may not, without our written agreement:

license, sell, transfer, assign, distribute, host, or otherwise commercially exploit the websites;
modify, prepare derivative works of, disassemble, decompile, or reverse engineer any part of the websites;
access the websites in order to build a similar or competitive website, product, or service; or
access or use the websites for any purpose that is in violation of law or that results in a violation of law;
harvest, collect or otherwise use contact information made available on the websites for the purpose of sending unsolicited improper communications, including without limitation, unsolicited bulk email (collectively, spam) and that you will not use any SG communications facility to deliver or attempt to deliver spam;
attempt to gain unauthorized access to the websites or the servers and network associated with the websites;
circumvent or attempt to circumvent any security or access control technology implemented on the websites, or the servers and network associated with the websites
use the websites in any manner designed to degrade the performance or functioning of the websites, including, without limitation, launching Denial-of-Service (DoS) attacks against the websites.

To the fullest extent permitted by applicable law, we reserve the right, at any time and for any reason we choose, at our sole discretion, to revoke the limited license granted herein and to refuse you access to or use of the websites.

The following sections will survive any termination of this Agreement or of your Account: 3, 5, 6, and 7.

2. Privacy Policy: The below Policy explains how and why we collect, use, and share information about you when you access or use our websites. You understand and agree that through your use of the websites, you are consenting to the collection and use of this information as set forth in the Policy.

3. Your Content:The websites may contain information, text, links, graphics, photos, videos, audio, streams, or other materials (“Content”), including Content created with or submitted to the websites by you or through your Account (“Your Content”). We take no responsibility for and we do not expressly or implicitly endorse, support, or guarantee the completeness, truthfulness, accuracy, or reliability of any of Your Content.

By submitting Your Content to the websites, you represent and warrant that you have all rights, power, and authority necessary to grant the rights to Your Content contained within the Notices, Agreement and Policy. Because you alone are responsible for Your Content, you may expose yourself to liability if you post or share Content without all necessary rights.

You retain any ownership rights you have in Your Content, but you grant SG the following license to use that Content:

When Your Content is created with or submitted to the websites, you grant us a worldwide, royalty-free, perpetual, irrevocable, non-exclusive, transferable, and sublicensable license to use, copy, modify, adapt, prepare derivative works of, distribute, store, perform, and display Your Content and any name, username, voice, or likeness provided in connection with Your Content in all media formats anywhere in the world. This license includes the right for us to make Your Content available for syndication, broadcast, distribution, or publication by other companies, organizations, or individuals who partner with SG, unless doing so is otherwise prohibited by the terms of the Notice, Agreement, or Policy. You also agree that we may remove metadata associated with Your Content, and you irrevocably waive any claims and assertions of moral rights or attribution with respect to Your Content.

Any ideas, suggestions, and feedback about the websites, SG, or any business opportunity or idea that you provide to us are entirely voluntary, and you agree that SG may use such ideas, suggestions, and feedback without compensation or obligation to you.

Although we have no obligation to screen, edit, monitor, delete or remove Your Content (unless required by law), we may, in our sole discretion, edit, delete or remove Your Content at any time and for any reason, including but not limited to, for violating the Notice, Agreement, or Policy, or if you otherwise create or are likely to create liability for us.

4. Third Party Content or Links: If you use any links on the websites to websites not maintained by SG, you will leave our websites. The linked sites are not under the control of SG and SG is not responsible for the contents of any linked site or any link contained on a linked site. We provide these links to you only as a convenience and the inclusion of any link does not imply recommendation, approval or endorsement by SG of the site.

5. Limitation on Liability: SG assumes no liability for the use or interpretation of information contained on the websites. This publication is provided “AS IS” WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT.

UNLESS OTHERWISE PROHIBITED BY RELEVANT LAW OR ATTORNEY ETHICS OBLIGATION: IN NO EVENT WILL SG, ITS OFFICERS, PARTNERS, ASSOCIATES, EMPLOYEES, REPRESENTATIVES, AGENTS, OR AFFILIATES (THE “SG ENTITIES”) BE LIABLE TO YOU FOR ANY INDIRECT, CONSEQUENTIAL, EXEMPLARY, INCIDENTAL, SPECIAL, OR PUNITIVE DAMAGES, OR LOST PROFITS ARISING FROM OR RELATING TO THE NOTICES, AGREEMENT, OR POLICY, OR THE USE OF THE WEBSITES, INCLUDING THOSE ARISING FROM OR RELATING TO CONTENT MADE AVAILABLE ON THE WEBSITES THAT IS ALLEGED TO BE DEFAMATORY, OFFENSIVE, OR ILLEGAL. ACCESS TO, AND USE OF, THE WEBSITES IS AT YOUR OWN RISK, AND YOU ARE EXCLUSIVELY RESPONSIBLE FOR ANY DAMAGE TO YOUR DEVICE, NETWORK, OR COMPUTER SYSTEM, OR RESULTING LOSS OF DATA. IN NO EVENT WILL THE AGGREGATE LIABILITY OF THE SG ENTITIES EXCEED THE GREATER OF ONE THOUSAND U.S. DOLLARS ($1,000) FOR ANY DAMAGES OR INJURY ARISING FROM OR RELATING TO THE NOTICES, AGREEMENT, OR POLICY, OR THE USE OF THE WEBSITES. THE LIMITATIONS OF THIS SECTION WILL APPLY TO ANY THEORY OF LIABILITY, INCLUDING THOSE BASED ON WARRANTY, CONTRACT, STATUTE, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE, EVEN IF THE SG ENTITIES HAVE BEEN ADVISED OF THE POSSIBILITY OF ANY SUCH DAMAGE, AND EVEN IF ANY REMEDY SET FORTH IN THESE TERMS IS FOUND TO HAVE FAILED ITS ESSENTIAL PURPOSE. NOTHING HEREIN SHALL EFFECT ANY CLAIMS THAT ARISE EXCLUSIVELY FROM SG’S LEGAL REPRESENTATION OF YOU THAT RESULTED FROM A WRITTEN AGREEMENT REFLECTING AN ATTORNEY-CLIENT RELATIONSHIP BETWEEN YOU AND SG.

6. Arbitration: Any and all claims by you arising out of or related to the websites, your use thereof, or arising out of or related to the Notice, Agreement, or Policy may be resolved only through a binding arbitration proceeding to be conducted under the auspices of the Commercial Arbitration Rules of the American Arbitration Association in New York, New York, and any conflict between the rules of the the American Arbitration Association and this Agreement shall be resolved in favor of this Agreement. The arbitration shall be governed by the laws of the State of New York. Both your agreement to arbitrate all controversies, disputes and claims, and the results and awards rendered through the arbitration, will be final and binding on you and may be entered in, or specifically enforced by, legal proceedings in court. Arbitration will be the sole means of resolving the controversies, disputes and claims referenced in the first sentence hereof, and you waive your rights to resolve such controversies, disputes and claims by court proceedings or any other means. You agree that judgment may be entered on the award in any court of competent jurisdiction and, therefore, any award rendered shall be binding. THE ARBITRATOR MAY NOT CONSOLIDATE MORE THAN ONE PERSON’S CLAIMS, AND MAY NOT OTHERWISE PRESIDE OVER ANY FORM OF A REPRESENTATIVE OR CLASS PROCEEDING. YOU UNDERSTAND THAT BY AGREEING TO ARBITRATION AS A MECHANISM TO RESOLVE ALL CONTROVERSIES, DISPUTES AND CLAIMS BETWEEN US, YOU ARE WAIVING CERTAIN RIGHTS, INCLUDING THE RIGHT TO BRING AN ACTION IN COURT, THE RIGHT TO A JURY TRIAL, THE RIGHT TO BROAD DISCOVERY, AND THE RIGHT TO AN APPEAL. YOU UNDERSTAND THAT IN THE CONTEXT OF ARBITRATION, A CASE IS DECIDED BY AN ARBITRATOR (ONE OR MORE), NOT BY A JUDGE OR A JURY. IN THE EVENT THAT ANY DISPUTES BETWEEN YOU AND SG ARE DECIDED BEFORE A COURT, YOU AND SG AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND THAT YOU ARE YOU ARE GIVING UP YOUR RIGHT TO PARTICIPATE AS A CLASS REPRESENTATIVE OR MEMBER ON ANY CLASS CLAIM YOU MAY HAVE AGAINST US. For the purposes of any legal proceeding commenced in any court in accordance with this paragraph, you irrevocably submit to the jurisdiction of the state and federal courts located in the County of New York in the State of New York for such proposes.

7. Miscellaneous: This Agreement, together with Notices and Policy and any other agreements expressly incorporated by reference into this Agreement, constitute the entire agreement between you and us regarding your access to and use of the websites. If you agree to retain SG and SG agrees to represent you and enters into a written agreement with you to that extent (the “Retention Agreement”), then the terms of the Notices, Agreement, and Policy shall continue to the extent there is no conflict between the Notices, Agreement, and Policy and that Retention Agreement, and in the event of a conflict, that Retention Agreement shall control. The Notices, Agreement and Policy shall be governed, interpreted and enforced in accordance with the laws of the State of New York, without giving effect to the conflicts of laws principals therein. Our failure to exercise or enforce any right or provision of this Agreement will not operate as a waiver. If any part of this Agreement is held to be invalid or unenforceable, the unenforceable part will be given effect to the greatest extent possible, and the remaining parts will remain in full force and effect. You may not assign or transfer any of your rights or obligations under this Agreement without our consent. We may freely assign any of our rights and obligations under this Agreement to the extent permitted by law.

This Agreement is a legally-binding agreement between you and SG.

Privacy Notice

Last updated May 12, 2022

Thank you for choosing to be part of our community at the SG websites. SG respects your privacy and is committed to collecting, maintaining and using personal information about you responsibly. This Policy is intended to supplement, and not supplant, any legal or attorney ethics obligations we may have if SG agrees in writing to represent you. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at itaccounts@sirillp.com.

This privacy notice describes how we might use your information if you:

Visit, use, or submit information to our websites
Engage with us in other related ways ― including any sales, marketing, or events

In this privacy notice, if we refer to:

"Website," we are referring to any of our websites that references or links to this policy
"Services," we are referring to our Website, and other related services, including any sales, marketing, or events

The purpose of this privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. The terms herein are intended to govern information we collect on the Website. We may collect additional information from you as part of an attorney-client relationship between you and SG, and our obligations and use of that information shall be governed by our written Retention Agreement, or our legal and attorney ethics obligations and not this Policy.

Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect.

1. WHAT INFORMATION DO WE COLLECT?Personal information you disclose to us

In Short: We collect on the websites personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; job titles; contact preferences; contact or authentication data; and other similar information.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at itaccounts@sirillp.com and be sure to include your name, testimonial location, and contact information.
Request feedback. We may use your information to request feedback and to contact you about your use of our Website.
To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below).
Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold, provided doing so does not violate any relevant legal or attorney ethics obligations, based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of SG assets, financing, or acquisition of all or a portion of our business to another company.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law or applicable ethics rule.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required by law (such as tax, accounting or other legal requirements) or relevant ethics rules. No purpose in this Policy will require us keeping your personal information for longer than 2 years unless a longer retention period is required by law or relevant ethics rules.

When we have no ongoing legitimate business need or ethical obligation to process or retain your personal information, we may either delete or anonymize such information, or, if this is not possible or advisable (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

6. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at itaccounts@sirillp.com.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name	YES
B. Personal information categories listed in the California Customer Records statute	Name, contact information, education, employment, employment history and financial information	YES
C. Protected classification characteristics under California or federal law	Gender and date of birth	YES
D. Commercial information	Transaction information, purchase history, financial details and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements	NO
G. Geolocation data	Device location	YES
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us	YES
J. Education Information	Student records and directory information	NO
K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by visiting https://www.sirillp.com/contact/, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

SG has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. SG will not sell personal information in the future belonging to you or other consumers.

Your rights with respect to your personal data

Right to request deletion of the data - Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be Informed - Request to Know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification Process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other Privacy Rights

you may object to the processing of your personal data
you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

To exercise these rights, you can contact us by visiting https://www.sirillp.com/contact/, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time without notice. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification, but unless obligated by law, we are not required to provide such notice. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at itaccounts@sirillp.com or by post to:

Siri & Glimstad LLP
200 Park Avenue
17th Floor
New York, NY 10166
United States

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here.

Colin Farnsworth

Attorney

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