Privacy Policy

PRIVACY POLICY

Last Updated: March 2021

Spiritus Law, LLC. (“Spiritus” or “We”) respects your privacy and is committed to protecting it through our compliance with this privacy policy (“Privacy Policy”).

You understand that by using the Service, You consent and agree to the collection and use of certain information about You and Your use of the Service in accordance with our Privacy Policy and Terms of Use.

Please read this policy carefully for information about how We collect, use, maintain, and disclose information about you collected or received through the Spiritus website located at www.spirituslaw.com (“Website”), marketing emails, and subscription emails and other electronic messages between you and the Website. This Privacy Policy does not apply to information collected by Spiritus offline or through any other means, including on any other website operated by Spiritus or any third party (including our affiliates and subsidiaries).  All transmission of personal or confidential information is governed by the Rules and Regulations of The Florida Bar.  However, use of our website does not create any attorney/client relationship and the information contained on this website or any collateral information related thereto should not be construed or used as legal advice.  Neither Spiritus Law nor any of its employees or consultants represents any individual or business until a formal engagement agreement is consummated in writing and acknowledged by both you and Spiritus. 

This privacy statement (together with our Terms of Use and any additional data privacy notices on our websites or in targeted e-mails) explains how SPIRITUS LAW, LLC. collects and uses the personal data of our app users, website visitors, clients, and business contacts. Any changes we may make to our privacy statement in the future will be posted on this page. SPIRITUS LAW, LLC is interested in maintaining your privacy while creating valuable, robust applications, platforms, and websites, giving you the best user experience possible, and in some cases developing a personal relationship with you to provide you with customized services, products, and information. If you have any questions now or during your visit, please contact us using our Contact Us form.

BY ACCESSING OR VIEWING THE WEBSITE, MARKETING EMAILS, OR SUBSCRIPTION EMAILS YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND YOU EXPRESSLY CONSENT TO THE COLLECTION, USE, MAINTENANCE, AND DISCLOSURE OF INFORMATION ABOUT YOU, INCLUDING PERSONAL INFORMATION (AS DEFINED IN SECTION 1.1 BELOW), IN ACCORDANCE WITH THIS PRIVACY POLICY. If you do not agree with our policies and practices in this Privacy Policy, do not use the Website or view marketing emails or subscription emails.

1. Types of Information. We collect both Personal Information and Anonymous Information, each as defined below, in connection with your use of the Website, Spiritus marketing emails, and Spiritus subscription emails.

1.1. Personal Information. “Personal Information” is information which may be used to identify or contact an individual, such as your name, mailing address, phone number, email address, and any other information which identifies you or allows Spiritus to contact you.

1.2. Anonymous Information. “Anonymous Information” is information We collect that is not associated with, or linked to, Personal Information about you and which, on its own, does not individually identify you.

Examples of the information we collect and analyze include the Internet protocol (IP) address used to connect your phone or computer to the Internet; login; e-mail address; computer and connection information such as browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platform; purchase history; the full Uniform Resource Locator (URL) clickstream through, and from our Web site, including date and time; cookie number; products you viewed or searched for; and the phone number you used to call our  number. We may also use browser data such as cookies, Flash cookies (also known as Flash Local Shared Objects), or similar data on certain parts of our Web site for fraud prevention and other purposes. During some visits we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes.

1.3. Client Information.  If you apply to be a client, we will collect the information you provide in your application, including your name, email address, phone number, birth date, physical address, government identification number (such as social security number), and driver’s license information, if required. We collect the payment information you provide us, including your credit card, bank routing numbers, and tax information if needed. We may need additional information from you at some point after you become a client, including information to confirm your identity (like a photo, or a copy of your identification document showing your age).

2. How We Collect and Use Information.

2.1. Information You Provide. You may provide Spiritus Personal Information when you send Spiritus a message through the “CONTACT US” form. We may use or share the Personal Information you provide through these contact options to communicate with you or perform some action you have requested. We may also internally use or combine Personal Information about you with other information to maintain and improve our services, and for marketing such as announcements, newsletters, and other forms of marketing. In some cases, you may provide Anonymous Information on the Website. If We do not associate this information with Personal Information about you, then We may use this information at our discretion and for any purpose. If this Anonymous Information is associated with you, then We will use it consistent with how We use Personal Information in this section.

2.2. Information Collected Automatically When Visiting the Website. We use “cookies” to collect Personal Information and Anonymous Information about visitors to the Website. We may use both session cookies and persistent cookies to identify visitors to the Website and to determine how and when visitors interact with the Website. If these cookies provide Personal Information, or We associate this information with Personal Information about you, then We may use this information to customize the Website for individual visitors, maintain and improve our services, and for marketing consistent with this Privacy Policy. We may use, transfer, and disclose Anonymous Information gathered from cookies for any purpose.

When you use the Services, the following information is created and automatically logged in our systems:

Log data: Information (“log data”) that the Apps automatically send when you use them.

Device information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.

Usage Information: We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, the other users you interact with and the time, frequency and duration of your activities.

2.3. Web Beacons. Pages within the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs). Web beacons permit Spiritus, for example, to count users who have visited those pages or opened an email and for other related email or Website statistics (for example, recording the popularity of certain content and verifying system and server integrity). This information is used to enable more accurate reporting, improve the effectiveness of our marketing, and maintain and improve our email and the Website.

2.4. Anonymous Information Generally. We may create Anonymous Information records from Personal Information by excluding information (such as your name) that would otherwise make such data personally identifiable to you. We may use Anonymous Information at our discretion and for any purpose.

3. How We Share Information.

3.1. Our Service Providers. We employ third-party companies and individuals to administer and provide services on our behalf (including, but not limited to hosting providers, recruitment agencies, IT providers, software providers, marketing database providers, accountants, HR system providers) who may need Personal Information to provide services for Spiritus In order to obtain these services. These third-party service providers are restricted from using Personal Information for any purpose other than to provide the services we request.

3.2 Affiliated firms and advisors. we share your information with our affiliated firms and advisors as necessary to carry out the purposes for which the information was supplied or collected.

3.3. Social media networks: SPIRITUS LAW, LLC uses social sharing and other “widgets” to enable interaction with social media networks. Some of these social media networks track your visit to our Sites (or any other website that uses the widgets) because when you visit those websites, they may place personally identifiable “cookies” in your browser which are then transmitted back to the social network when you visit other sites that happen to use that network’s social sharing widgets (even if you don’t “click” on or interact with the widget).

3.4 At Your Request or With Your Consent. We may disclose information about you to fulfill the purpose for which you provide it, disclose it at your request or with your consent, and for any other purpose disclosed by Spiritus when you provide the information.

3.5. Other Disclosures. Regardless of any choices you make regarding Personal Information, We may disclose Personal Information: (i) to respond to subpoenas, warrants, court orders, lawful requests, or legal process, (ii) to establish or exercise our legal rights or defend against legal claims, or protect other users, or (iii) in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, or as otherwise required by law.  All transmission of personal or confidential information if governed by the Rules and Regulations of The Florida Bar. 

3.6. Business Transfers. We may transfer Personal Information about you in the event of a merger, acquisition, reorganization, sale of assets, or in the event of bankruptcy. We may also share Personal Information about you with subsidiaries, joint ventures, or other companies under common control that We may have now, or in the future, in which case We will require them to honor the terms of this Privacy Policy. All transmission of personal or confidential information if governed by the Rules and Regulations of The Florida Bar.

4. Choices About How We Use and Disclose Information. We strive to provide you with choices regarding the Personal Information you provide to Spiritus.

4.1. Browser Settings. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies.

4.2. How We Respond to Do Not Track. This Website does not respond to Do Not Track browser signals.

5. Children Under the Age of 18. The Website is not intended for children under 18 years of age. No one under age 18 should provide any information to or on the Website. We do not knowingly collect Personal Information from children under 18. If We learn We have collected or received Personal Information from a child under 18 without verification of parental consent, We will delete that information. If you believe we might have any information from or about a child under 18, please contact Spiritus at:

Spiritus Law, LLC
Attn: Office Manager/Managing Partner
2525 Ponce de Leon Blvd., Suite 1080
Coral Gables, FL 33134
305-224-1003

6. Third-Parties. Any third-party websites, products and services (collectively “Third-Party Services”) are managed by those third-parties. The presence of a link to Third-Party Services does not constitute an endorsement, authorization, or representation that We are affiliated with the Third-Party Services. We do not exercise control over Third-Party Services and Third-Party Services are governed by their own privacy policy. We encourage you to read the privacy policy and terms of use for these Third-Party Services before you choose to utilize them.

7. Protection of Personal Information. Your privacy is important to Spiritus. We do not generally seek to collect sensitive personal data through this site. We take reasonable administrative and technical precautions to protect Personal Information. However, no method of transmission over the internet, or method of electronic storage, is completely secure. Spiritus cannot completely eliminate the risks associated with handling information over the internet. YOU ACKNOWLEDGE AND AGREE THAT YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK. WE ARE NOT LIABLE FOR THIRD PARTY CIRCUMVENTION OF ANY PRIVACY SETTING OR ANY OF OUR SECURITY MEASURES.

If you choose to provide us with unsolicited sensitive personal data, you consent to our using the data, subject to applicable law as described in this privacy policy. The term “sensitive personal data” refers to the various categories of personal data identified by privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent.

We take appropriate steps to maintain the security of personal data collected via Spiritus Law, LLC’s website. You should understand that the open nature of the Internet is such that information and personal data may flow over networks connecting you to our systems without security measures and may be accessed and used by people other than those for whom the data is intended.

8. Data Protection for Users in Europe. For purposes of the General Data Protection Regulation (“GDPR”), Spiritus is the controller of your personal data. The GDPR defines personal data as any information relating to an identified or identifiable natural person.

8.1. Processing Your Data. If you provide Spiritus personal data to determine the suitability of services referenced on the Website, then We will lawfully process your personal data to perform a contract with you or take steps at your request prior to entering into a contract. We internally process your personal data for our legitimate business interests, like improving Spiritus services, in a manner that does not outweigh your fundamental rights and freedoms. If you provide your personal data to receive a subscription email, then we will process your information to provide you with the requested subscription. If you would like to withdraw your consent to receiving a subscription email, then you may complete the unsubscribe process within the subscription email. In some cases, We will use your personal data for direct marketing, in which case you have the right to object to direct marketing.

8.2. Cookies and Web Beacons. Spiritus has legitimate business interests in providing Website functionality, understanding how visitors and customers use the Website, marketing emails, and subscription emails, and improving our services. Spiritus uses cookies and web beacons to provide functionality and to personalize the Website, marketing emails, and subscription emails. Spiritus also uses cookies and web beacons to capture information about internet protocol (IP) addresses, browser types, and access times to learn more about Website, marketing email, and subscription email traffic patterns and to perform maintenance. You have choices with regards to the management of cookies on your computer. For more information about cookies and web beacons, please see section 5 of this Privacy Policy.

Parts of the Service may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our website people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non-Personal Data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Data by local law, we also treat these identifiers as Personal Data.

“Cookies" are small bits of electronic information that a website sends to a visitor's browser and are stored on the visitor's hard drive. Like many websites, we employ cookies and other technologies in certain areas of the Service to allow us to provide information to make Your online experience more convenient. For example, when You return to the Service after logging in, cookies provide information to the Service so that the Service will remember who You are on subsequent visits, speeding up or enhancing Your experience of the Service by, for instance, tailoring content to You. Spiritus Law, LLC and our partners also use cookies and other technologies to remember Personal Data when You use our Service.

Some of our content is stored by and through third party servers, and we limit access to our control panel. We may use Google Analytics to understand how our users use the Services and Clear Company in connection with job applications. We communicate with our users and the general public via Instagram, Facebook, Twitter and third-party advertising networks including Google Ads.

You may be able to disable cookies on Your web browser through Your browser settings – please consult Your browser’s help menu for assistance. Please note that certain parts of the Service will not be available or usable if cookies are disabled. In some of our email messages, advertisements or social media posts, we may opt to use a “click-through URL” linked to content on the Service. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics or products, and measure the effectiveness of our customer communications. If You prefer not to be tracked in this way, You should not click text or graphic links in our posts and/or messages.

A pixel tag or web beacon is an often-transparent graphic image, usually no larger than 1 pixel by 1 pixel, that is placed on a website or in an email that is used to monitor the behavior of the user visiting the website or sending the email.  We may use web beacons and/or pixel tags for many purposes, including site usage analytics, advertising, user management, auditing and reporting, and content and advertising personalization.

Our website may, from time to time, contain links to and from the websites of our advertisers and affiliates, including social media networks. If you follow a link to any of these websites, please note that these websites have their own privacy policies, and Spiritus Law, LLC does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

8.3. Categories of Recipients of Your Personal Data. We employ third-party service providers to administer and provide services on our behalf (including, but not limited to, a cloud service provider) who may need your personal data to provide services for Spiritus. These third-party service providers are restricted from using your personal data for any purpose other than to provide the services requested.

8.4. Data Subject Rights. The GDPR provides certain rights for individuals. You may request information about: the purpose of processing; the categories of personal data concerned; third parties that may have received your personal data from Spiritus; the source of your personal data (if you didn’t provide it directly to Spiritus); and how long your personal data will be stored. You have a right to correct your personal data record maintained by Spiritus if it is inaccurate. Subject to certain exceptions, you may request that Spiritus erase your personal data or cease processing your personal data. You have the right to receive, or transmit to another controller, personal data concerning you that you have submitted to Spiritus. Spiritus will provide reasonable access to your personal data at no cost, upon request, and if access cannot be provided within a reasonable time frame, Spiritus will provide you with a date when the information will be provided. If for some reason access is denied, Spiritus will provide an explanation as to why access has been denied. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Spiritus processes your personal data. To exercise these rights, please email spiritus@spirituslaw.com.

You are entitled to know whether we hold personal data about you and, if we do, to have access to that personal data and require it to be corrected if it is inaccurate. You can do this by using our Contact Us form. You can exercise your right to prevent marketing communications to you by utilizing opt-out mechanisms in e-mails we send to you. You can also exercise the right to discontinue marketing communications to you, or to have your personal data removed from our customer relationship management (CRM) databases at any time by using our Contact Us form.

If you withdraw your consent for the use or disclosure of your personal information for purposes set out in this Privacy Notice you may not have access to all our Services and we might not be able to provide you all of the Services and customer support offered to our users and authorized under this Privacy Notice and our User Agreement.

8.5. Transferring Personal Data from the EU to the United States. We exclusively market and sell our Services to United States-based organizations and individuals. Even though we do not intentionally collect information about residents of the European Union ("EU"), some EU residents' data may be inadvertently collected through marketing channels or by virtue of our customers’ legitimate use of our Services. Collection and storage of any EU resident's data by us is minimal and incidental. No such data is used for marketing or any other purpose.

The information Spiritus collects from you is processed in the United States. The United States has not sought, nor received, a finding of “adequacy” from the European Union under Article 45 of the GDPR. Spiritus relies on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, Spiritus collects and transfers to the U.S. personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Spiritus when your rights and freedoms are not overriding.

Notwithstanding the foregoing, if you are a EU resident and would like to request that your data be securely removed from our systems, however collected, please send an email with proof of EU residency to spiritus@spirituslaw.com spiritus@spirituslaw.com . We will remove all relevant data, so long as that removal is technically feasible, does not impact the legitimate accounting or business practices of our customers, and does not violate other regulatory or legal standards with which we must comply. We will also cooperate with our customers in good faith to address any requests they receive or that may impact them directly.

8.6. Data Storage and Retention. We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer. Your personal data is stored by Spiritus on cloud-based database management services located in the United States. Spiritus retains data for the duration of your business relationship with Spiritus and for a period of time thereafter to satisfy legal requirements.

9. Changes to This Privacy Policy. We may update this Privacy Policy from time to time to reflect changes or updates to our technology, data practices, service methods, or other factors. If We make material changes to this Privacy Policy, We will notify you by posting the revised Privacy Policy on our Website. Changes to the Privacy Policy will become effective immediately, unless otherwise noted. Your continued use of the Website, marketing emails, or subscription emails following the effective date of these changes indicates your consent to the revised policies and practices. You are expected to check this page frequently, so you are aware of any changes, as they are binding on you. If you object to any revisions, you should immediately cease using the Website or viewing marketing emails or subscription emails.

10. California Consumer Privacy Compliance

If you are a California resident as defined by CCPA and §17014 of Title 18 of the California Code of Regulations and reasonably believe SPIRITUS LAW, LLC maintains personal information related to you, and would like to exercise your right to request:

the categories of personal information SPIRITUS LAW, LLC maintains related to you; or

a copy of the personal information SPIRITUS LAW, LLC maintains related to you; or

SPIRITUS LAW, LLC to remove all instances of your personal information from our records,

please click on the Contact US form found at: https://spirituslaw.com/contact/ssi

If you are a California resident and wish to make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing to us at the address provided herein.  Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state and ZIP code.  Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this address.

Information shared for purposes other than direct marketing will not necessarily be included in our response to such request. We reserve the right to request and confirm proof of identity as we determine necessary in our sole discretion.

11. Applicable Law. This Privacy Policy shall be governed in all respects by the laws of the State of Florida without giving effect to its conflicts of law provisions. Both parties submit to the personal jurisdiction of and venue in the state and federal courts in the State of Florida, in the judicial district that includes Miami, Florida. The parties further agree that any cause of action arising under this Privacy Policy shall exclusively be brought in such courts. If any provision of these Terms is held to be invalid or unenforceable, such provision shall be struck and the remaining provisions shall be enforced. Headings are for reference purposes only and in no way define, limit, construe, or describe the scope or extent of such section. SPIRITUS LAW, LLC's failure to act with respect to a breach by you or others does not waive the Firm's right to act with respect to subsequent or similar breaches. This agreement and Privacy Policy contained herein set forth the entire understanding and agreement between SPIRITUS LAW, LLC and you with respect to the subject matter hereof and supersede any prior or contemporaneous understanding, whether written or oral.

12. Indemnity You agree to defend, indemnify, and hold SPIRITUS LAW, LLC and its subsidiaries, affiliates, officers, directors, agents, and employees harmless from any liability to third parties, including reasonable attorneys' fees, arising from or related to your breach of this Privacy Policy.

13. Questions. If you have questions related to this Privacy Policy, please contact Spiritus at

Spiritus Law, LLC
Attn: Office Manager/Managing Partner
2525 Ponce de Leon Blvd., Suite 1080
Coral Gables, FL 33134
305-224-1003