The following definitions apply to the Terms and Conditions, all Legal Disclaimers, and Privacy Notices on this website and blog: 

“Website” refers to the WelcomePath Legal website, accessible from https://www.welcomepathlegal.com, or from a third-party site linked to WelcomePath Legal's website. “Website” includes all content contained throughout the WelcomePath Legal website as well as content contained in all blog posts published by WelcomePath Legal. 

“Visitor” means an individual who browses our Website. 

“Subscriber” means an individual who has registered with us to use, receive, or purchase one of our products or services through this Website. 

“User(s)” collectively refers to Visitor(s) and/or Subscriber(s).

"You" and "Your" refer to any person accessing, using, or reading information published on this Website, as well as your agents and representatives. 

"Company", "We", "Our", “Ourselves,” and "Us", refer to WelcomePath Legal, a division of DigitalSpeak Law, LLC, 5425 Wisconsin Avenue, Suite 600, Chevy Chase, MD 20815.

Any use of the above terminology or other words in the singular, plural, capitalization and/or he/she or they, are taken as interchangeable and therefore as referring to same.

This Website collects certain types of information from Users.
In order to tailor our products, materials, and services, as well as to provide an optimal browsing experience to Users, this Website may collect various types of information.  Some information, discussed below, may identify you as an individual. You may choose to provide personal information but are not required to provide it in order to use this Website. Other information is not intended to identify you as a specific user but, rather, provides analytical information in the aggregate about site traffic. As discussed below, this Website uses cookies and other tools to collect certain types of information relevant to the usage of the site.

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Please read below to learn the types of information this Website may collect and how it may be used.

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This Website is not directed at and does not knowingly collect personal information from Users who are under 13 years old.
While the content on this Website may be appropriate for most audiences, we do not knowingly market our Website, blog, services, or materials to minors under the age of thirteen (13) years old. In compliance with the Children’s Online Privacy Protection Act (COPPA), we do not knowingly or intentionally collect or use the personal information of minors under the age of thirteen (13) years old. If you are under the age of 13, please do not provide personally identifiable information of any kind. To learn more about protecting children’s privacy online, please visit the Federal Trade Commission’s website, www.OnGuardOnline.gov.

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By visiting and using this Website, you represent and warrant that you are at least 13 years old.

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Information You Provide
Some information (“personally identifiable information”) may identify you as an individual. The Federal Trade Commission considers data personally identifiable when it can be reasonably linked to a particular person, computer, or device. Such information includes but is not limited to your name, email address, contact information, date of birth, and biometric data. Under some laws, your Internet Protocol (IP) address, which is a number that is automatically assigned to your computing device whenever you access the Internet, may also be considered personally identifiable information.

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“Personally Identifiable Information” is information that identifies a specific user, such as your first and last name, home address, email address, telephone number, date of birth, gender, and other information.  Generally, it is not required that you provide Personally Identifiable Information in order to use this Website. However, when you request information from us, contact us, subscribe, register for an event or service, or engage in certain activities on this Website, we may ask you to provide certain Personally Identifiable Information about yourself.  

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We may use your Personally Identifiable Information to send you publications, information about events that may interest you, administrative information about the operation of our Site, or services that we may provide.  

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You are not required to provide any personal information when using this Website.  However, you may voluntarily provide certain personal information when doing one or more of the following:

•    downloading published materials
•    subscribing to our email newsletter or other updates
•    completing a form through this Website
•    submitting a contact request

 

If you choose to provide personal information, we may keep a record of this information and use it to:

•    send you our newsletters periodically
•    manage contacts and send messages
•    provide you with information, products, or services which may be of interest to you
•    contact you in response to a request

 

If you contact us via email through this Website, we may keep a record of your email address and correspondence and use such information to respond to you.  If you decide you do not wish to receive communications from us, simply follow the opt-out or unsubscribe instructions contained in one of our communications.

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Other Information Collected
This Website gathers certain types of information about our site traffic for administrative and analytical purposes. Generally, this is “Non-Personally Identifiable Information” that does not identify a specific user. This type of information may include but is not limited to your device type, Internet Protocol (IP) address, operating system, browser type, plugin details, dates and times of page views, language preference, time zone, and Uniform Resource Locator (“URL”) of the website you visited just before or just after visiting this Website. We may automatically collect this information when you visit our Website through the use of electronic tools like cookies, web beacons, or pixel tags.

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We may save "cookies" to your computer. “Cookies” are small pieces of code that web servers use to place information on a user’s browser in order to retrieve the information later. When you allow your browser to accept cookies, small data files are transferred to your device. Cookies automatically identify your browser to our Website whenever you visit and save your preferences or other information. Accepting cookies allows you to personalize your experience on this Website. If you prefer to browse this Website without accepting cookies, you may do so and should not notice a significant difference in your browsing experience on this Website. If you choose to disable cookies, the most effective way to do so is through your browser’s settings.

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Cookies may allow our Website to present personalized advertising to you. Cookies may also provide anonymized tracking data to third-party applications such as Google Universal Analytics. You can opt-out of Google Analytics by selecting “OPT-OUT” here or by using the tool linked here.

Third-party companies or advertisers may place separate cookies on your computer. We do not control the practices of third parties, nor does this Privacy Notice cover the use of cookies or other practices by third parties.

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Pixel tags and web beacons are tiny graphic images placed on certain pages on our Website or in our emails that allow us to determine whether you have performed a specific action. Pixel tags are typically single pixel, transparent images on a web page that allow that site’s server to read and record the cookie with the unique identifier and information it needs to record. Site tags hold JavaScript code that contains one or more pixel tags. These tags can control the information being converted into pixels in order to decide whether or not to show the pixel tag, which would trigger the host server to record an impression with the unique ID. When you access, open, or click content in these pages or emails, pixel tags and web beacons may generate a Non-Personally Identifiable notice of that action. Using pixel tags helps us measure and better understand visitor traffic on our Website. Some of our affiliates or partners may also use pixel tags and web beacons on our Website for the same purposes.

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We may collect IP addresses or click-stream data to improve our Website, report aggregate information internally, or optimize system administration. When you request pages from this Website, our host servers may identify and log your device’s IP address, as well as collect click-stream data. Click-stream data may include such information as the page your browser requested, the time and source of the request, the type of browser making the request, the page viewed immediately prior, and other non-personal information. This data may be analyzed to help us understand how visitors arrive to our Website, what type of content is of most interest to visitors, and aggregate information about the types of visitors who are interested in various types of content.

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Our Use of Your Information 
We do not sell or rent any of the personal information collected by this Website, and any personal information collected through this Website is used solely to deliver its services. We may share the collected information where required by law, specifically in response to a demand from government authorities where such demand meets the legal requirements.

Use of Your Information by Our Host and Host’s Service Partners
This Website is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to offer our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. Wix does not sell the Personal Information it collects or hosts.

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Wix has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement and data optimization services, content providers, and our legal and financial advisors. Wix’s service partners may receive or otherwise have access to our Visitors’ and Users’ Personal Information to facilitate and enhance our services, and may only use it for such purposes. 

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While our Website may contain links to other websites or services, we do not control and are not responsible for their privacy practices. As mentioned above, this Privacy Notice does not apply to linked third-party websites or services. Therefore, we encourage you to be aware when you leave our Website and read the privacy statements of each website you visit.

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Please visit Wix’s Privacy Policy at http://www.wix.com/about/privacy to learn more about our host’s privacy practices.

Third-Party Hosting and Storage of Information
This Website is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to offer our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall. 

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Users’ and Visitors’ Personal Information may be stored in Wix’s data centers located in the United States of America, Ireland, Japan and Israel. Wix may use other jurisdictions as necessary for the proper delivery of its Services and/or as may be required by law. Wix.com Ltd. is based in Israel, which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.

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Wix may retain the Personal Information it stores on Our behalf for as long as it continues to host this Website, or as otherwise needed to provide Us with services. If we make a request of Wix to remove any of our Users’ or Visitors’ Personal Information, Wix will respond to such requests in a timely manner upon verification and in accordance with applicable law (for example, thirty (30) days under the GDPR).

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Third-Party Security of Information Stored or Processed
Wix, its affiliates, and its Third-Party Service Providers that store or process your Personal Information on Wix’s behalf are contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.

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If you are located in the European Union, when Wix transfers your EU Personal Information to the United States or anywhere outside Europe, Wix will make sure that (i) there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Model Standard Contractual Clauses are in place. 

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Wix and its affiliates participate in and have certified their compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. To learn more about the Privacy Shield Framework, please visit the U.S. Department of Commerce’s Privacy Shield List, here. Wix is accountable for personal data that it receives under the Privacy Shield and subsequently transfers to a third party as described in the Privacy Shield Principles. In particular, Wix remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Wix proves that it is not responsible for the event giving rise to the damage.

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Wix has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, Wix offers HTTPS secure access to most areas on its Services; the transmission of sensitive payment information (such as a credit card number) through designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and Wix regularly maintains a PCI DSS (Payment Card Industry Data Security Standards) certification. Wix also regularly monitors its systems for possible vulnerabilities and attacks, and regularly seeks new ways and Third Party Services for further enhancing the security of its Services and protection of its Visitors’ and Users’ privacy.

Regardless of the measures and efforts Wix takes with respect to your data, neither We nor Wix can guarantee the absolute protection and security of your Personal Information or any other data you provide or share through this Website. We therefore encourage you to use strong security measures and encryption – including but not limited to network, device, account, and browser protections – and to avoid providing us with any sensitive information which you believe could cause you substantial or irreparable harm. 

Your Rights under the EU General Data Protection Regulation (GDPR)

When using our website and submitting personal data to us, you may have certain rights under the GDPR and other laws. Depending on the legal basis for processing your personal data, you may have some or all of the rights below.

 

Users based in the European Union have the right to do the following:

 

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their personal data;

• Object to processing of their data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent;

• Access their data. Users have the right to learn if data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing;

• Verify and seek rectification. Users have the right to verify the accuracy of their data and ask for it to be updated or corrected;

• Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, we will not process their data for any purpose other than storing it;

• Have their personal data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from us;

• Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any undue delay; and

• Lodge a complaint. Users have the right to bring a claim before their competent data protection supervisory authority.

 

You can exercise your right to prevent such processing by contacting us at contact@welcomepathlegal.com. These requests can be exercised free of charge and will be addressed by us as soon as possible and always within thirty (30) days.

 

Electronic Communications under the EU ePrivacy Regulation

In February 2021, the Council of the European Union adopted a consolidated version of the ePrivacy Regulation, which was welcomed by the European Data Protection Board in March 2021. The ePrivacy Regulation is intended to complement GDPR by focusing on ensuring an individual user’s privacy as it relates to electronic communications. The ePrivacy Regulation will replace the ePrivacy Directive (2002/58/EC) and will apply to users located in the EU, regardless of whether the processing of their data takes place outside the EU or the service provider is located in a non-EU jurisdiction. Organizations that offer direct marketing communications to EU residents or process electronic communications, metadata, or terminal equipment information of EU residents will be subject to the ePrivacy regulation.

 

EU residents will have, among others, the following rights under the ePrivacy Regulation:

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• Privacy for all electronic communications content as well as metadata (data that describes other data, such as author, date created and location). Electronic communications network and service providers must obtain prior consent from users before processing their electronic communications metadata, with certain exceptions.

• The use of cookies and other technologies involving the storage of information on, or collection of information from, a user’s device, will only be allowed if the user has provided GDPR-compliant specific consent, or for specific purposes outlined in the regulation. Users will also have more meaningful choices with respect to the use of cookies or similar technologies.

• No unsolicited electronic communications by email and SMS will be permitted, with protections and opt-out rights dictated by national laws.

 

 

Your Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you have certain rights with respect to your personal information, including:

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• The right to know about the personal information a business collects about you and how it is used and shared;

• The right to delete personal information collected from you (with some exceptions);

• The right to opt-out of the sale of your personal information; and

• The right to non-discrimination for exercising your CCPA rights.

 

Users who reside in California have the right to request any of the following from us: 

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• a disclosure of which personal information we have about you and what we do with that information, in a readily useable format that would allow you to transmit the information to another entity;

• deletion of your personal information;

• not to sell your personal information; and

• the right to be notified, before or at the point we collect your personal information, of the types of personal information we are collecting and what we may do with that information.

 

Under the CCPA, “sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. Under the CCPA, selling personal information includes disclosing information to a third party by using analytics tools, running ads, or having social media pixels and plugins installed.  

 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

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• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any financial incentive we offer will reasonably relate to the value of your personal information and will describe the material terms of the financial incentive program. Participation in any financial incentive program we offer requires your prior consent to opt in, which you may revoke at any time. We do not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.

 

Requests can be submitted by you or someone legally authorized to act on your behalf by email to contact@welcomepathlegal.com. These requests can be exercised free of charge and will be addressed by us as soon as possible and always within forty-five (45) days.

 

California Privacy Rights Act (CPRA) 

The California Privacy Rights Act (“CPRA”), passed in November 2020, will supersede the CCPA effective January 1, 2023. The CPRA expands and modifies certain provisions of the CCPA, as well as adds new requirements.

 

CPRA will modify or expand the following CCPA provisions:

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• In addition to having the right to request the categories of personal information about a consumer that a business sells, a consumer will also have to the right to know when their personal information is “shared” with a third party, and when information is otherwise disclosed for a business purpose, including disclosures to a service provider. This includes sharing through cookies and similar technologies used for online advertising. “Sharing” is defined as renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal Information by the business to a third party for cross-context behavioral advertising.

• In addition to opting out of the sale of information, a consumer will also have the right to opt-out of the “sharing” of their personal information with third parties, including through cookies and similar technologies. 

• Expanding the right to deletion, businesses will be required to notify service providers, contractors, and third parties to whom a consumer’s personal information was sold or “shared” that they must also delete that consumer’s personal information, except as allowed under limited circumstances.     

• Expanding the CCPA’s right to data portability, businesses will be required to both provide upon request consumers with their personal information in a readily useable format, and transfer that information directly to another entity at a consumer’s request.

• Expanding the rights of minors under 13 years of age, a business that uses cookies or behavioral technology to collect information will also have to obtain affirmative authorization before selling or sharing such information with a third party.

 

CPRA will add the following new rights for California consumers:

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• California residents will have the right to correct. A business will be required to use commercially reasonable efforts to correct inaccurate personal information about a consumer upon receiving a verified request from the consumer.

• California residents will have the right to limit sensitive personal information. A consumer has the right to direct a business that collects sensitive personal information about that consumer to limit its use of the consumer’s sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services. “Sensitive personal information” includes various data elements including social security or driver’s license number, account information or credit/debit card number when in combination with required security or access code, geolocation, racial or ethnic origin, religion, union membership, contents of a consumer’s mail, email or text messages and a consumer’s genetic data.

• California residents will have a private right of action to bring a lawsuit against a business if an email address in combination with a password or security question and answer is subjected to unauthorized access as a result of a business’s unreasonable security procedures.

 

Your Rights under the Virginia Consumer Data Protection Act (VCDPA)

The Virginia Consumer Data Protection Act (VCDPA) was passed in March 2021 and becomes effective January 1, 2023. The VCDPA will grant Virginia residents certain rights with respect to their personal information. These rights pertain to accessing, correcting, deleting, knowing, and opting-out of the sale and processing of their personal information for targeted advertising purposes.