Privacy Policy

1. Introduction

Welcome to Savvy Esquires ("Firm," "we," "us," or "our"). We are committed to protecting the privacy and security of individuals who visit our website, www.savvyesquires.com (the "Website"), and interact with our services.

This Privacy Policy ("Policy") explains how we collect, use, disclose, and safeguard your Personal Information when you visit our Website, including any other media form, media channel, mobile website, or mobile application related or connected thereto. It also describes your rights regarding your Personal Information and how you can contact us.

Please read this Privacy Policy carefully. By accessing or using the Website, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with the practices described in this Policy, please do not access or use our Website.

We may update this Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of the Website after any such changes constitutes your acceptance of the new Privacy Policy.

2. Information We Collect

We may collect Personal Information about you in a variety of ways. "Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

A. Personally Identifiable Information (PII) You Provide to Us

We collect PII that you voluntarily provide to us when you:

• Fill out a contact form (e.g., providing your name, email address such as info@savvyesquires.com, phone number like +16462562484, company name, and details about your inquiry).
• Schedule a consultation (e.g., providing your name, email address, phone number, and information relevant to the consultation).
• Take our Needs Assessment Quiz (e.g., providing your name, email, and responses related to your business or legal needs).
• Communicate with us via email or other channels (e.g., any PII you include in your communications).
• Subscribe to our newsletter or other marketing communications (if applicable, and with your consent).
• [Miakel: Review and add any other specific PII you collect directly, for instance, if you have client portals, event registrations, or other interactive features.]

B. Information Collected Automatically (Derivative Data)

When you access and use our Website, our servers (which may be hosted by third-party service providers) may automatically collect information, including:

• Log File Information: Your Internet Protocol (IP) address, browser type and version, operating system, internet service provider (ISP), referring/exit pages, date/time stamps, and clickstream data.
• Device Information: Information about the computer or mobile device you use to access the Website, such as the device type, unique device identifiers (if applicable), and mobile network information.
• Usage Data: Information about how you use the Website, such as the pages you view, the links you click, the time you spend on pages, and other actions you take on the Website.

[Miakel: Confirm if you use analytics tools like Google Analytics. If so, be specific about the data collected by these tools. For example, Google Analytics may collect demographic and interest data if enabled. You should also disclose your use of such tools clearly.]

C. Cookies and Other Tracking Technologies

We and our third-party service providers may use cookies, web beacons (also known as pixel tags or clear GIFs), and other similar tracking technologies to collect information automatically as you navigate the Website and interact with our communications.

• Cookies: Small text files placed on your device that store information. We may use session cookies (which expire when you close your browser) and persistent cookies (which stay on your device until you delete them or they expire). Cookies help us to improve our Website, understand user activity, and personalize your experience.
• Web Beacons: Tiny graphics with a unique identifier, similar in function to cookies, that are embedded invisibly on web pages or in emails. We may use web beacons to track whether emails have been opened and for other analytics.

You can control the use of cookies at the individual browser level. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Website.

For more detailed information on the cookies we use, their purpose, and how you can manage them, please refer to our [Link to Cookie Policy, if you create a separate one. If not, detail it more here]. We recommend implementing a cookie consent banner, especially to comply with regulations like GDPR and ePrivacy Directive for non-essential cookies.

[Miakel: Detail your specific cookie usage. List categories (e.g., Strictly Necessary, Analytics/Performance, Functional). Identify third-party cookies (e.g., from Google Analytics). Explain how users can opt-out of non-essential cookies beyond browser settings, e.g., through a consent management tool or links to third-party opt-out pages.]

3. How We Use Your Information

We use the Personal Information we collect for various purposes, grounded in legitimate business interests, the fulfillment of our potential or actual contractual obligations to you, compliance with our legal obligations, and/or your consent. These purposes include:

• To Provide and Manage Our Services:
  • Respond to your inquiries, comments, and questions.
  • Schedule and manage consultations and appointments (e.g., using Microsoft Bookings).
  • Provide you with information about our services.
  • Process information you provide through our Needs Assessment Quiz to understand your needs and prepare for consultations.
• To Operate and Improve Our Website:
  • Administer, maintain, and improve the Website's functionality, performance, and user experience.
  • Analyze trends, usage, and activities in connection with our Website for marketing or advertising purposes (e.g., using aggregated or de-identified data).
  • Monitor and analyze the effectiveness of our communications.
• To Communicate With You:
  • Send you administrative information, such as updates to our terms, conditions, and policies.
  • Send you newsletters, marketing or promotional materials, and other information that may be of interest to you, where you have provided your consent to receive such communications. You may opt-out of receiving any, or all, of these marketing communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us directly.
• For Security and Legal Compliance:
  • Prevent fraudulent activity and enhance the security of our Website and services.
  • Comply with applicable legal or ethical obligations, regulatory requirements, court orders, or other legal process.
  • Protect our rights, privacy, safety, or property, and/or that of you or others.
  • Enforce our terms and conditions.

[Miakel: Add any other specific uses. For example, if quiz data is used to generate automated reports for the user, mention that. Be specific about the legal basis for each processing activity if targeting individuals in jurisdictions like the EU (GDPR).]

4. How We Share Your Information

We do not sell your Personal Information. We may share your Personal Information in the following circumstances:

• With Third-Party Service Providers: We may share your Personal Information with trusted third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include:
  • Website hosting and maintenance providers.
  • Email service providers.
  • Scheduling and calendar management tools (e.g., Microsoft Bookings).
  • Document management and e-signature platforms (e.g., Dropbox Sign, SignWell).
  • Payment processing providers (e.g., Stripe).
  • Data analytics providers (e.g., Google Analytics).
  • Cloud storage providers.
  • IT support services.
  These third parties are contractually obligated to maintain the confidentiality and security of your Personal Information and are restricted from using your Personal Information for any purpose other than to provide services for us. We will enter into data processing agreements (DPAs) with these providers where required by applicable law (e.g., GDPR).

  [Miakel: CRITICAL - Create an exhaustive list of ALL categories of third-party service providers. Ensure you have appropriate agreements, including DPAs where necessary, with each one.]

• As Required by Law or to Protect Rights: We may disclose your Personal Information if we are required to do so by law or in the good faith belief that such action is necessary to:
  • Comply with a legal obligation, subpoena, court order, or other legal process.
  • Respond to lawful requests from public authorities, including to meet national security or law enforcement requirements.
  • Protect and defend our rights, property, or safety, or that of our users or the public.
  • Prevent or investigate possible wrongdoing in connection with the Website or our services.
• During Business Transfers: We may share or transfer your Personal Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. We will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.
• With Your Consent: We may disclose your Personal Information for any other purpose with your explicit consent.

5. Data Security

We implement reasonable administrative, technical, and physical security measures designed to protect your Personal Information from unauthorized access, use, alteration, and disclosure. These measures include, for example:

• Using Secure Sockets Layer (SSL) technology (HTTPS) for our Website.
• Implementing access controls to limit access to Personal Information to authorized personnel.
• Regularly reviewing our information collection, storage, and processing practices.

[Miakel: You can add more general categories of security measures if appropriate and safe to disclose, e.g., "encryption of data at rest and in transit where feasible," "staff training on data protection." Avoid overly specific details that could be exploited.]

However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of Personal Information is at your own risk.

6. Data Retention

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal or ethical requirements applicable to law firms).

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you or provide services to you.
• Whether there is a legal or ethical obligation to which we are subject (e.g., rules of professional conduct for client records, statutes of limitation).
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

For PII provided through inquiries that do not result in an attorney-client relationship, we will retain the information for a reasonable period to address the inquiry and for follow-up, after which it will be securely deleted or anonymized.

Information from our Needs Assessment Quiz will be retained for [Define a specific period or link it to inquiry retention/client file retention].

Derivative data and analytics information (often aggregated or anonymized) may be retained for longer periods for trend analysis and Website improvement.

[Miakel: Define retention periods more specifically where possible, or the criteria used to determine them. This requires careful consideration of your firm's specific legal and ethical obligations.]

When we no longer need to retain your Personal Information for the purposes outlined in this Policy, we will securely delete or anonymize it.

7. Your Rights Regarding Your Personal Information

Depending on your jurisdiction (e.g., California under the CCPA/CPRA, the European Economic Area under GDPR), you may have certain rights regarding your Personal Information. These rights may include:

• Right to Access: The right to request access to the Personal Information we hold about you and to receive a copy of that information.
• Right to Rectification (Correction): The right to request that we correct any inaccurate or incomplete Personal Information we hold about you.
• Right to Erasure (Deletion / "Right to be Forgotten"): The right to request that we delete your Personal Information, subject to certain exceptions (e.g., where retention is necessary for us to comply with a legal obligation or for the establishment, exercise, or defense of legal claims).
• Right to Restrict Processing: The right to request that we restrict the processing of your Personal Information in certain circumstances.
• Right to Data Portability: The right to receive your Personal Information in a structured, commonly used, and machine-readable format and to have it transmitted to another controller, where technically feasible.
• Right to Object: The right to object to the processing of your Personal Information in certain circumstances, such as for direct marketing purposes.
• Right to Withdraw Consent: If we are processing your Personal Information based on your consent, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
• Right to Lodge a Complaint: The right to lodge a complaint with a data protection supervisory authority in your jurisdiction if you believe that our processing of your Personal Information infringes applicable data protection laws.
• Right to Non-Discrimination (e.g., under CCPA/CPRA): We will not discriminate against you for exercising any of your privacy rights.

Exercising Your Rights:

To exercise any of these rights, please contact us using the contact details provided in Section 11 ("Contact Us") below. Please clearly state your request and provide sufficient information to allow us to verify your identity (we may request additional information for this purpose). We will respond to your request within the timeframes required by applicable law.

Specific Information for California Residents (CCPA/CPRA):

If you are a California resident, you have specific rights regarding your Personal Information under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). This includes the rights listed above. We do not "sell" your Personal Information as that term is traditionally defined. You also have the right to request information about the categories and specific pieces of Personal Information we have collected about you, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, and the categories of third parties to whom we disclose Personal Information. [Miakel: Review CPRA's definition of "sharing" for cross-context behavioral advertising if you engage in such activities. If so, a "Do Not Sell or Share My Personal Information" link and process would be needed.]

[Miakel: CRITICAL - This section MUST accurately reflect all rights afforded by NY, NJ, CA (CCPA/CPRA), and GDPR if applicable. Provide clear, actionable instructions. Consider if a toll-free number or dedicated web form is needed for CCPA requests depending on your firm's data processing volume.]

8. Children's Privacy

Our Website is not intended for or directed at individuals under the age of 16. We do not knowingly collect Personal Information from children under 16. If we become aware that we have inadvertently collected Personal Information from a child under the age of 16 without parental consent, we will take steps to delete such information from our files as soon as possible. If you are a parent or guardian and believe that your child under 16 has provided Personal Information to us, please contact us using the details in Section 11.

[Miakel: Verify age thresholds. COPPA (US) is 13. GDPR default is 16, but member states can lower to 13. Using 16 is generally a safer approach if there's any ambiguity or potential international reach.]

9. Links to Other Websites

Our Website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We strongly advise you to review the privacy policy of every site you visit.

10. International Data Transfers (If Applicable)

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there. Our service providers may also be located in the United States or other jurisdictions.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and that appropriate safeguards are in place before transferring your Personal Information, such as by using Standard Contractual Clauses where required.

[Miakel: Review if you target or knowingly collect data from individuals outside the U.S., particularly the EEA/UK. If so, this section is important and needs to be robust regarding transfer mechanisms like SCCs.]

11. Contact Us

If you have any questions, concerns, or comments about this Privacy Policy or our data practices, or if you wish to exercise your rights regarding your Personal Information, please contact us at:

Savvy Esquires LLC
Attn: Miakel D. Williams, J.D., LL.M. (Data Privacy Contact)
10 W 122nd Street
New York, NY 10027
Email: info@savvyesquires.com
Phone: +1 (646) 256-2484
Website: www.savvyesquires.com