David Cohen (also known as Tech Attorney Cohort) (“TAC”) collects and uses information which may identify individuals (“personal data”), including visitors to this website: www.developlegalmindset.com (“you”, “your”).
TAC is aware of its responsibilities to handle your personal data with care, to keep it secure, and to comply with applicable privacy and data protection laws.
The purpose of this Privacy Policy (“Policy”) is to provide a clear explanation of when, why, and how TAC collects and uses personal data as a data controller, which is explained further below.
Please read this Policy carefully, as it explains how TAC uses personal data. TAC may change this Policy and, when it does, any changes will be posted on this page, so please check back frequently.
CONTENTS OF THIS POLICY
ABOUT TAC
PERSONAL DATA: COLLECTION, PURPOSES AND LAWFUL BASIS
DISCLOSURE OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
RETENTION OF YOUR PERSONAL DATA
YOUR RIGHTS AND HOW TO EXERCISE THEM
MARKETING
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
POLICY AMENDMENTS
CHILDREN'S INFORMATION
ANY QUESTIONS?
1. About TAC
TAC is the data controller for the personal data set out above in this Policy.
You can contact TAC by email at david@techattorneycohort.com.
2. Personal Data: collection, purposes and lawful basis
This Policy applies to the collection of and processing of your personal data by TAC.
TAC collects personal data from you directly:
through the "Contact Me" webpage;
if you register to view content prepared by TAC (e.g. guides, quizzes, white papers, webinars, courses, informational or educational documents etc.); or
if you purchase one of TAC's products or services.
TAC collects personal data during your use of this website via the cookies TAC use. For further details about TAC's use of cookies, please refer to TAC's Cookie Policy.
The type of personal data TAC process differs depending on how you engage with TAC. The table below provides this information including how TAC will use personal data and the context for which TAC uses your personal data:
Individuals that purchase TAC products and services
Types of Personal Data:
First name, surname, email address, address, phone number / mobile phone number, title, information about your professional expertise
Purpose:
For the provision of TAC's products and services, which includes processing orders, sending receipts, collecting payments and any other general contract administration.
To resolve any queries or complaints
To send marketing material, updates, newsletters, informational materials about TAC's products and services including online webinars and courses, and other related information, including, sending solicited information, and surveys and promotions.
Legal Basis:
The processing is necessary for performance of a contract.
TAC's legitimate interest to respond to any correspondence or queries you send TAC, and to send service information about TAC's products and/or services. In addition, responding to queries is necessary for fulfilling TAC's contractual obligations.
Where required by privacy laws, your consent or where information is solicited.
Otherwise, TAC's legitimate interest to send you communications related to the same or similar products or services to which you have previously purchased or expressed interest in, where permitted by privacy laws.
Please see section 7 (Marketing) of this Policy for more information.
Types of Personal Data:
First name, surname, email address, address, phone number / mobile phone number, title, information about your professional expertise
Information about your visits to TAC's website, your IP address, browser type, your operating system and device type, the number of times you visit TAC's website, your interactions with TAC's website, the pages you've visited on TAC's website, your display settings, session start / stop time, referral URL, time zone, and network connection type, your geo-location address, content information and preferences
Purpose:
To conduct data and usage analytics, sales and business performance analytics, improvement and optimization of products, service and business processes and operations, and for other internal business purposes.
Legal Basis:
TAC's legitimate interest to measure the use of TAC's products and/or services and interaction to inform and improve service/product direction and development, and business processes and operations.
Website Visitors
Types of Personal Data:
Name, email address, title, company name and website analytics (described below)
Purpose:
Provision of content and services, marketing and promotional purposes, participation in events, newsletter subscriptions, and responding to enquiries (including social media features) in response to you contacting TAC through TAC's Contract TAC page
Legal Basis:
Your consent (in relation to non-essential cookies – see below).
TAC's legitimate interest in providing you with information about TAC's products and services (where you indicate an interest) and developing TAC's relationship with you.
Please refer to TAC's Cookie Policy for further details about TAC's use of cookies
Types of Personal Data:
Information about your visits to TAC's website, your IP address, browser type, your operating system and device type, the number of times you visit TAC's website, your interactions with TAC's website, the pages you've visited on TAC's website, your display settings, session start / stop time, referral URL, time zone, and network connection type, your geo-location address, content information and preferences,
Purpose:
To keep TAC's website available and secure.
To improve your experience when you visit TAC's website. This includes: (a) for statistical analysis to improve, test and monitor the effectiveness of TAC's website; (b) to monitor metrics such as total number of visitors and traffic data (including demographic patterns); (c) to ensure content on TAC's website is presented in the most effective manner for you and to enhance your use of TAC's website; and (d) to optimize marketing campaigns.
Legal Basis:
TAC's legitimate interest to provide and maintain TAC's website through utilising cookies that are strictly necessary.
Your consent for cookies that are not strictly necessary, such as cookies relating to performance, functionality and target/advertising. Please refer to TAC's Cookie Policy for further details about TAC's use of cookies.
Marketing
Types of Personal Data:
Name, email address, telephone number, company and position information, location
Purpose:
Lead generation for marketing and promotion purposes through first and third party physical and web based events, conferences, roundtables, webinars and other interactive mediums.
Lead generation for use in marketing and promotion purposes through sourcing personal data via third party lead generation including affiliates and social media platforms.
Legal Basis:
Where required by privacy laws, your consent or where information is solicited.
Otherwise, TAC's legitimate interest to promote TAC's products or services.
All Data Subjects
Types of Personal Data:
All data above mentioned.
Purpose:
In connection with any merger, sale, transfer of TAC's assets, investment, acquisition, bankruptcy, or similar event or corporate transaction.
Legal Basis:
Necessary for TAC's legitimate interests to ensure TAC can protect and grow TAC's business.
Purpose:
To help TAC improve and optimise TAC's products and services.
Legal Basis:
Necessary for TAC's legitimate interests to maintain TAC's reputation as a leading provider of application security testing solutions to customers across the globe
Purpose:
To perform financial accounting functions including tax reporting to comply with applicable laws
Legal Basis:
Necessary to comply with relevant legal obligations (for example, relating to tax reporting).
Purpose:
To protect the rights of TAC and Data Subjects
Legal Basis:
Necessary to comply with relevant legal obligations (for example, applicable data protection/privacy laws).
Necessary for TAC's legitimate interests to act in, and protect, the interests of TAC's business.
Purpose:
To perform risk analysis, fraud/crime prevention and due diligence.
Legal Basis:
Necessary to comply with relevant legal obligations (for example, applicable anti-money laundering and anti-terrorist laws).
Necessary for TAC's legitimate interests to act in, and protect, the interests of TAC's business.
In limited circumstances TAC may process any of the personal data TAC holds to the extent necessary to defend, establish and exercise legal claims or to comply with legal or regulatory obligations, including, responding to requests and communications from competent authorities, courts or tribunals. Such processing is based on TAC's legitimate interests, which in this case are protecting TAC's services and data, exercising TAC's legal rights, and complying with TAC's legal obligations.
Where TAC needs to collect personal data due to a legal or regulatory obligation, or for performance of a contract, and you do not provide that data when requested, TAC may not be able to perform the contract TAC has or is trying to enter into with you (for example, to provide you with TAC's products/services). TAC will notify you of this at the time.
3. Disclosure of your Personal Data
Depending on your dealings with TAC, TAC may disclose some or all of the personal data TAC collects from and obtains about you to the following:
Internal Recipients:
Personnel: Personal data is shared internally on a need-to-know basis to TAC's staff and personnel.
External Recipients:
Service Providers and Data Processors: TAC engages third party vendors, from time to time, including:
IT service providers to help manage TAC's IT and back office systems
web services including web hosting, storage and web analytics
digital communication providers including online and instant messaging, chat and email providers
data, website, product and platform security providers
ordering, invoicing and payment platforms
analytics and search engine providers to help TAC improve and optimize TAC's products and services
providers of various services for improvement and optimization of TAC's products, service and business processes and operations, and for other internal business purposes including data and usage analytics, sales and business performance analytics and market research for statistical and survey purposes
professional advisors such as tax or legal advisors (for example, as necessary for the establishment, exercise or defence of legal claims or to protect the rights or safety of TAC)
agents, suppliers or sub-contractors and other associated organisations where they are engaged by TAC to help deliver a service or product that TAC have instructed them on or assist with customer management
event organizers, logistic and production companies in connection with events that you may attend.
Some of these service providers use 'cloud based' IT applications or systems, which means that your personal data will be hosted on their servers, but under TAC's control and direction.
Third parties in case of a legal requirement: TAC discloses your personal data if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process (including to law enforcement or competent authorities like the police and tax authorities).
TAC may also disclose personal data in case TAC believes, in good faith, that such disclosure is necessary in order to enforce TAC's policies, take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, protect the security or integrity of the service and protect TAC's rights and property.
Third parties in case of a corporate transaction: Information about TAC's customers, including personal data, may be disclosed as part of any merger, sale, transfer of TAC's assets, investment, acquisition, bankruptcy, or similar event, including while engaging with TAC's actual or potential investors.
4. International transfers of your Personal Data
Where the GDPR or the UK GDPR are applicable, and whenever TAC make transfers of your Personal Data, TAC implement appropriate safeguards and will only transfer or share your Personal Data to recipients:
pursuant to the EU Standard Contractual Clauses and additional measures to supplement such clauses as may be required in line with transfer impact assessments TAC carry out, to prevent interference by public authorities of third countries;
pursuant to the UK Addendum; and/or
in countries that have an adequacy decision by the European Commission and/or the UK Information Commissioner's Office; or
located in the EEA or in the UK.
Any requests for information TAC receives from law enforcement or regulators will be carefully checked before personal data is disclosed. If you would like to find out more about any such transfers or obtain a copy of safeguards, please contact TAC using the details set out in section 1
5. Retention of your Personal Data
TAC will not retain your personal data longer than it is necessary to carry out the purposes listed in section 2 of this Policy or than is required by law.
In some circumstances TAC may retain your personal data for longer periods of time, for instance where TAC is required to do so in accordance with legal, regulatory, tax or accounting requirements. In specific circumstances TAC may also retain your personal data for longer periods of time so that TAC has an accurate record of your dealings with TAC in the event of any complaints or challenges, or if TAC reasonably believe there is a prospect of litigation relating to your personal data or dealings.
Where your personal data is no longer required TAC will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.
6. Your rights and how to exercise them
Depending on your relationship with TAC, your jurisdiction and the applicable data protection laws that apply to you, you have several rights in relation to your personal data set out in this section. In certain circumstances these rights might not be absolute, as they depend on TAC's reason for processing your personal data. You are not required to pay any charge for exercising your rights, although TAC may charge a reasonable fee if your request is unfounded, repetitive or excessive.
EU Residents Rights: Right to know or access Personal Data collected by TAC
California Residents Rights: The right to know what personal data the business has collected.
Details: The right to know what personal data TAC collected, including the categories of personal data, the sources from which the personal data is collected, the business or commercial purpose for collecting, selling, or sharing personal data, the categories of third parties to whom TAC discloses personal data, and the specific pieces of personal data TAC collected about you.
EU Residents Rights: Deletion Rights
California Residents Rights: Deletion Rights
Details: The right to delete personal data that TAC collected from you, subject to certain exceptions.
EU Residents Rights: Correct Inaccurate Data
California Residents Rights: Correct Inaccurate Data
Details: The right to correct inaccurate personal data that TAC maintains about you
EU Residents Rights: N/A
California Residents Rights: Opt-Out of Sharing for Cross-Contextual Behavioural Advertising
Details: You have the right to opt-out of the "sharing" of your personal data for "cross-contextual behavioural advertising" (all as defined under the CCPA), often referred to as "interest-based advertising" or "targeted advertising".
EU Residents Rights: N/A
California Residents Rights: Opt-out from selling
Details: You have the right to opt-out of the "sharing" of your personal data for "cross-contextual behavioural advertising" (all as defined under the CCPA), often referred to as "interest-based advertising" or "targeted advertising".
EU Residents Rights: N/A
California Residents Rights: Opt-out from selling
Details: The right to opt-out of the "sale" or "sharing" (as defined under the CCPA) of personal data.
EU Residents Rights: N/A
California Residents Rights: Limit the Use or Disclosure of Sensitive personal data (SPI)
Details: You have the right to request to limit the collection of your SPI to that use which is necessary to maintain TAC's service,
EU Residents Rights: Opt-Out of the Use of Automated Decision Making
California Residents Rights: N/A
Details: In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your personal data.
EU Residents Rights: N/A
California Residents Rights: Non-Discrimination
Details: The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee's, applicants, or independent contractor's right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. TAC may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to TAC by your personal data.
EU Residents Rights: Data Portability
California Residents Rights: Data Portability
Details: You may request to receive a copy of your personal data, including specific pieces of personal data, including, where applicable, to obtain a copy of the personal data you provided to TAC in a portable format.
EU Residents Rights: Restriction or Objection to Processing
California Residents Rights: N/A
Details: You have the right to object the processing of your personal data, unless certain exceptions apply.
EU Residents Rights: Withdrawal of Consent
California Residents Rights: N/A
Details: If personal data is processes on the basis of your consent, you have the right to withdraw it at any time.
Your rights may be exercised by contacting TAC at: david@techattorneycohort.com. In case of rejection, the response TAC provide will explain the reasons for which TAC cannot comply with your request.
Responding times and format:
For EU residents: TAC has one month to respond to you (unless you have made a number of requests or your request is complex, in which case TAC may take up to an extra two months to respond).
Please note that, where TAC asks you for proof of identification, the one-month time limit does not begin until TAC has received this. If TAC requires any clarification and/or further information on the scope of the request, the one-month deadline is paused until TAC receives that information.
For California residents:
TAC's goal is to respond to a verifiable consumer request within 45 days of its receipt. If TAC requires more time, TAC will inform you of the reason and extension period in writing within the first 45 days period. TAC will deliver TAC's written response, by mail or electronically, at your option. Any disclosures TAC provides will cover only the 12-month period preceding the request. If reasonably possible, TAC will provide your personal data in a format that is readily useable and should allow you to transmit the information without hindrance. You may only request a copy of your data twice within a 12-month period.
The request must:
Provide sufficient information to allow TAC to reasonably verify you are the person about whom TAC collected personal data or an authorized representative.
Describe your request with sufficient details to allow TAC to properly understand, evaluate, and respond to it.
TAC cannot respond to your request or provide you with personal data if TAC cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require you to create an account with TAC. TAC will only use personal data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
7. Marketing
You may change your marketing preferences (for example whether you want to receive email, SMS and/or telephone marketing) at any time by contacting TAC.
In most cases TAC's processing of your personal data for marketing purposes is based on your consent (including where required by law), although in some cases it may be based on TAC's legitimate interest. Further information about TAC's legal basis for processing personal data for marketing purposes is set out in section 2 In particular, you can always opt-out of email marketing communications by clicking the "unsubscribe" link at the bottom of marketing emails, or by contacting the contact details provided in section 1.
When you choose to unsubscribe, your data is automatically moved to a suppression list to prevent your email address being accidentally added to TAC's database again. If you wish your data to be fully deleted from TAC's systems, TAC will do so at your request but, if your email address is at any point added back into TAC's database, by you or on your behalf, there will be no automated process in place to prevent marketing being emailed to you again. Please note that where TAC have another lawful basis for processing, TAC will continue to process personal data for other purposes – for example, TAC may process information based on contract necessity. You may also receive indirect marketing from TAC by way of general marketing communications (e.g. post or non-targeted adverts in the media etc).
8. Privacy Notice for U.S Residents
This part of the Policy addresses the specific disclosure requirements under the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., and the regulations enacted thereunder (collectively: "CCPA").
Collection, Disclosure and Sharing of Personal Information
In the preceding twelve (12) months, TAC has collected the following Personal Information:
Category of Personal Information Collected: Identifiers
Personal Information Collected: Full name, email address, social media identifier, IP address.
Category of Personal Information Collected: Personal information described in subdivision (e) California Code, Civil Code – CIV § 1798.80
Personal Information Collected: Full name, email address, social media identifier, IP address, phone/mobile phone number.
Category of Personal Information Collected: Commercial Information
Personal Information Collected: Records of products or services purchased
Category of Personal Information Collected: Professional or employment-related information
Personal Information Collected: Title and professional expertise of users, subscribers and TAC events' attendees'
Category of Personal Information Collected: Geolocation data
Personal Information Collected: IP address and device location data
Category of Personal Information Collected: Electronic network activity
Personal Information Collected: Information about users' visits to TAC's website, IP address, browser type, operating system and device type, number of visits on TAC's website, interactions with TAC's website, the pages visited on TAC's website, display settings, session start / stop time, referral URL, time zone, and network connection type, content information and preferences.
Sources of Personal Information:
Directly and indirectly from activity on TAC's website: For example, directly from forms you complete on website; or indirectly, TAC collects your usage data automatically from measurement tools.
Indirectly from you: TAC track your activities across the internet, for example, when you view or interact with certain content, web page or ad.
From third-parties: For example, from vendors who assist TAC in performing services for consumers, internet service providers, data analytics providers and social networks.
Business Purposes for Collection:
To provide you with and improve TAC's service.
To fulfil TAC's contractual obligations with you
To detect and prevent fraud or illegal activities.
To respond to your requests and inquiries and communicate with you.
Direct marketing purposes – TAC may use the contact details you provided TAC to send you promotional offers and other content.
To perform research, technical diagnostics, analytics or statistical purposes.
To charge you for services provided by TAC.
For marketing and promotion purposes.
To perform financial accounting functions.
In the preceding twelve (12) months TAC disclosed your Personal Information, as described below:
Categories of Recipients
Service Providers
Business and Commercial Purposes for Disclosure
The disclosure of such Personal Information will be as reasonably necessary and proportionate to achieve, inter alia, the following purposes:
To provide, operate, maintain, improve, and promote the website and services.
To enable you to access and use the website and services.
To process and complete transactions, and send you related information, including purchase confirmations and receipts.
To send transactional messages, including responses to your comments, questions, and requests.
To send marketing communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, quizzes and events.
To improve and optimize TAC's products, service and business processes and operations, and for other internal business purposes including data and usage analytics, and sales and business performance.
To obtain professional advice from external counsel (such as, lawyers, accountants and tax advisors).
To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
To organize TAC's events, where you attend a TAC event
To promote, market and sell TAC products and services.
To comply with legal obligations or requirements, and exercise TAC's rights.
TAC does not "Sell" or "Share" personal information, as these terms are defined under the CCPA.
Authorized Agents
"Authorized agents" may submit opt out requests on a consumer's behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer.
Usually, TAC will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent's state of residence, provided that the third party successfully completes the following qualification procedures:
When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:
Provide the authorized agent signed permission to do so or power of attorney.
Verify their own identity directly with the business.
Directly confirm with the business that they provided the authorized agent permission to submit the request.
TAC may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
Direct Marketing Requests
California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact TAC at david@techattorneycohort.com.
"Do Not Track" Settings: "Do Not Track" is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. Cal. Bus. And Prof. Code Section 22575 also requires TAC to notify you how TAC deal with the "Do Not Track" settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, TAC do not respond to the Do Not Track settings. For more details, including how to turn on Do Not Track, visit: www.donottrack.TAC.
Record Keeping
TAC will maintain records of consumer requests made pursuant to the CCPA and TAC's responses to said requests for minimum period of 24 months. Such information will be used for no other purpose other than records keeping requirements under the CCPA or other legal requirements such as law, court order, subpoena, warrant or other legal judicial process.
9. Policy Amendments
TAC reserves the right to change this Policy at any time, so please re-visit this page frequently. All changes to this Policy are effective as stated "Last Updated" date, and your continued use of the services after the Last Update date will constitute acceptance of, and agreement to be bound by, those changes. As required by the CCPA, TAC will review this Privacy Policy every twelve (12) months and amend it as necessary.
10. Children's Information
TAC's Services are not intended for, and TAC will not knowingly collect personal data from, minors below the age of sixteen (16) years, or otherwise below the legal age for providing consent that is not subject to authorization by the holder of parental responsibility, in accordance with the laws in the jurisdiction you reside ("Age of Majority"). If TAC becomes aware that personal data of a user under the Age of Majority, TAC will remove such information from TAC's files immediately. TAC reserves the right to request proof of age at any stage so that TAC can verify that children are not using the Services.
11. Any Questions?
TAC hopes this Policy has been helpful in setting out the way TAC handles your personal data and your rights to control it. If you have any questions that have not been covered, please contact TAC's Data Privacy Team who will be pleased to help you via email at david@techattorneycohort.com. If you have a complaint or concern about how TAC use your personal data, please contact TAC in the first instance and TAC will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.
This Policy was last updated on August 1, 2024.