Last Updated: March 2021
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.
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.
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.
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
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.
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.
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.
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 contact us.
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 provide an email with proof of EU residency. 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.
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.