Privacy Policy

Last updated on February 17, 2026

1. Introduction and Overview.

Marble PC and its subsidiaries (“Marble Law”) have contracted with Themis-Tech Inc dba Flare (“Flare”) ( “we”, “our” or “us”) to provide services to Marble Law’s clients. Flare provides technological, marketing, and other services, and manages the entire user journey in relation to your case and your relationship with Marble Law.

This Privacy Policy describes how we collect, use, and share information about you as well as your rights and choices about that information. It applies to information collected through the Marble Law website at www.marble.co, our Marble Law apps available through iOS and Android, and any online location we operate that links to this Privacy Policy (the “Service”) or offline location that makes this Privacy Policy available to you. By using the Service or interacting with us offline, you agree to our Terms of Use and consent to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.

If you are a resident of Nevada or California, please see the additional disclosures at the end of this Privacy Policy. If you are located in the European Economic Area, United Kingdom, or Switzerland, please see Section 15 for additional disclosures. If you have any questions or want to exercise your rights and choices, please contact us as described in the “Contact Us” section.

Nothing in this Privacy Policy will violate applicable laws regulating the legal profession, including the attorney-client privilege and/or the attorney work product doctrine. Any sharing of information between Marble Law and Flare will follow the law. If you have signed a written agreement with Marble Law for legal services, additional terms and privacy provisions may apply. If you are a client of Marble Law and have questions about how we process your information, please contact us at privacyteam@themarbleway.com.

2. Information Collection.

A. Information You Provide.

We collect information about you when you use the Service or interact with us offline, including information you provide when you fill out a case assessment, access our content, make a purchase, or contact customer support. The types of information we collect and may have collected in the last 12 months:

When you hire Marble Law for legal services, you may submit information to us about your case or claim, including through our Client Portal. Your case or claim data and any other information we collect through the Client Portal may be protected by attorney-client privilege and other additional terms and privacy provisions. You may choose to provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

• Contact Data, including your first and last name, email address, city, postal address, and phone number.

• Account Credentials, including your username, password, password hints, and information for authentication and account access.

• Demographic Data, including your age, gender, and country.

• Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.

• Content, including content in any messages you send to us (such as feedback) or publicly posted on the Service (such as service reviews), any information you share through free text (such as to a chat bot), and any information shared by you or on your behalf as part of any onboarding or intake process.

• Financial Eligibility Data, including your self-reported credit score or creditworthiness information, which you may voluntarily provide in connection with evaluating eligibility for payment plans or financial arrangements.

B. Information Collected Automatically.

We automatically collect information when you use the Service. The categories of information we automatically collect and have collected in the last 12 months include:

We use various tracking technologies to automatically collect information when you use the Service, including the following:

For more information on how we use tracking technologies for analytics and advertising, and your rights and choices about them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

• Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, services you view, the time of day you browse, and your referring and exiting pages.

• Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.

• Location Data, including general location data (such as location based on an IP address or data that indicates a city or postal code level).

• Log Files, which are files that record events related to your use of the Service.

• Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to use our website and are deleted when you close your browser. Persistent cookies help personalize your experience, remembering your preferences, and supporting security features. Also, persistent cookies allow us to bring you advertising. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.

• Pixels (also known as web beacons), which are code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contain JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may allow us or a third party to drop or read cookies on your browser. Pixels are used with cookies to track activity by a browser on a device. We may use pixels from third parties that allow us to track our conversions, bring you advertising, and provide you with additional functionality.

• Device Fingerprinting, which looks at data from your browser - such as JavaScript objects and installed fonts - to create a "fingerprint" that identifies your browser and device.

• App Technologies, which are technologies in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include SDKs, which are code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising, and provide you with additional features.

C. Information from Other Sources.

We also collect information from other sources. The sources we collect and have collected information from in the last 12 months include:

• Social networks you use.

• Vendors and other parties who help bring users to our Service.

• Publicly-available sources, including data in the public domain.

• Affiliates.

3. Use of Information.

We collect and use information for business and commercial purposes as described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, include the following:

We may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

For information on your rights and choices about how we use information about you, please see the “Your Rights and Choices” section below.

• Operate and manage our Service.

• Training generative artificial intelligence and machine learning models. We may use your personal information to train models used for you. We may also use anonymized or de-identified information derived from client data to improve our models and services generally; such anonymized information cannot be used to identify you.

• Perform services requested by you, such as responding to your case assessment questionnaire and requests, and providing customer service.

• Check your eligibility for payment plans or other financial arrangements, including by reviewing financial information you choose to share (such as self-reported credit score or creditworthiness).

• Send you technical notices, updates, security alerts, information about changes to our policies, and support and administrative messages.

• Prevent and address fraud, breach of policies or terms, and threats or harm.

• Track trends, usage, and activities.

• Conduct research, including focus groups and surveys.

• Improve the Service or other Marble websites, apps, marketing efforts, products and services.

• Develop and send you advertising, direct marketing, and communications, including about our and other entities’ products, offers, promotions, rewards, events, and services.

• Complete any other business or commercial purposes with your consent.

4. Sharing of Information.

A. Information we share.

We share information we collect in accordance as described in this Privacy Policy. The types of parties we share and have shared information in the last 12 months, include the following:

For information on your rights and choices about how we share information about you, please see the “Your Rights and Choices” section below.

• Service Providers. We share information with Flare which provides technology, operations, case management, marketing, advertising, analytics, and AI-powered services on behalf of Marble. Flare uses its own service providers to deliver these services, including AI platforms, cloud hosting providers, and advertising platforms. We require by contract that our service providers not retain, use, or disclose information about you for any purpose other than doing the services for us. We do not allow third-party use or disclosure of your information, including de-identified, anonymized, or pseudonymized data, for any purpose other than providing services to us without your consent.

• Lawyers. We share information with lawyers we work with to determine whether we can provide you with legal help if so requested, and we also share information with lawyers we work with after we are retained in order to provide you with the legal help that has been mutually agreed upon in writing.

• Vendors and Other Parties. We share information with vendors and other parties for analytics and advertising purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.

• Affiliates. We share information with our related entities, including where they act as our service providers or for their own internal purposes.

• Business Colleagues. We share information with our non-attorney business colleagues in connection with offering co-branded services or engaging in joint marketing activities.

• Merger or Acquisition. If we are involved in a merger, sale, acquisition, or transfer of all or part of our business or assets, your personal information may be transferred to the acquiring entity. We will notify you before any transfer of your personal information to a new entity. You may request that we securely dispose of any health information we hold about you, transmit it to you, or provide it to you in a downloadable format.

• Security and Required Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.

• Facilitating Requests. We share information at your request or direction.

• Consent. We share information with notice to you and your consent. However, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law.

B. Risks, Benefits, and Limitations of Data Sharing.

Sharing your information with third parties provides certain benefits, including enabling us to deliver our services efficiently, improve our technology through AI and machine learning, process payments securely, and provide you with relevant information about our services. However, data sharing also carries risks, including the possibility that third parties may experience security incidents, that shared data could be accessed by unauthorized parties, or that data could be used in ways you did not anticipate. We implement contractual and technical safeguards to mitigate these risks, but we cannot guarantee that third parties will maintain the same level of security or privacy practices that we do. You have choices about certain data sharing as described in Section 7 below.

C. Impact of Data Sharing on Others

In connection with your legal matter, you may provide us with information about other individuals, such as family members, spouses, children, employers, or other parties. This information will be processed in accordance with this Privacy Policy. Before providing information about others, you should inform those individuals that their information will be shared with us and processed as described herein. You are responsible for ensuring you have the authority to share such information with us. Sharing information about family members or others may affect their privacy and could have implications for their own legal matters or personal circumstances.

5. Other Parties.

We offer parts of our Service through websites, platforms, and services run by third parties in parts of our Service. In addition, we integrate technologies operated or controlled by third parties into parts of our Service.

Please note that when you use other entities’ services, including when you leave our Service, those services may independently collect information about you and ask for information from you. The information collected and stored by those services is governed by their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to read their privacy policies and terms of use.

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6. Analytics and Advertising.

We use analytics services, such as Google Analytics and others, to help us understand how users access and use the Service. Also, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

We use tracking technologies on our Service (including our website and emails) and in our ads on other websites. Some of these tracking technologies track your activities across time and services to link the different devices you use, and deliver relevant ads and/or other content to you (“Interest-based Advertising”).

We also use audience matching services to reach people (or people similar to people) who have visited our Service or are listed in one or more of our databases (“Matched Ads”). We also engage in retargeting, which allows us to show you ads on other websites based on your previous visits to our Service. This works by uploading a customer list to a technology service or adding a pixel to our Service. The technology service then matches common factors between our data and theirs. For example, we use the Facebook pixel on our Service and may share your email address with Facebook for Custom Audiences.

As noted above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to read their privacy policies and terms of use.

For information on the types of tracking technologies we use on the Service and your rights and choices about analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

7. Your Rights and Choices.

A. Account Information.

You may access, update, remove, or request permanent deletion of certain information that you have provided to us through your account, or request closure of your account, by sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to allow us to confirm your identity. Deletion requests will be completed within 45 days. Please note that we will keep and use information about you as necessary to follow our legal duties, resolve disputes, and enforce our agreements.

B. Tracking Technology Choices.

Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies depends on your browser settings and limitations.

Global Privacy Control. We honor Global Privacy Control (GPC) signals as valid requests to opt out of the sale or sharing of your personal information. When we detect a GPC signal from your browser, we will treat it as a request to opt out of sale/sharing for that browser and device. For more information on GPC, visit https://globalprivacycontrol.org.

Apps. You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which allows you to limit the use of information collected about you. Please be aware that if you disable or remove tracking technologies some parts of the Service may not work correctly.

C. Analytics and Interest-Based Advertising.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb.

The companies we work with to provide you with targeted ads \- including retargeted or interest-based ads \- are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about these targeted ads and how to opt out, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices. Opting out only means that the selected companies should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

To opt out of us using your data for Matched Ads, please contact us as described in the “Contact Us” section below and say that you want to opt out of Matched Ads. We will remove your data from any lists shared with third parties for Matched Ads. Or you may directly contact the technology service to opt out. Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for any third party's opt-out tools or the accuracy of their claims about those tools.

D. Communications.

Emails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or Marble’s ongoing business relations.

Push Notifications. If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app. Please note that your opt out is limited to the email address or device used and will not affect subsequent subscriptions.

8. Children.

The Service is intended for a general audience, and is not directed at children under 18 years of age. We do not knowingly collect personal information (as defined by the U.S. Children’s Online Privacy Protection Act, or “COPPA”). If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at privacyteam@themarbleway.com. We will remove the data to the extent required by applicable laws. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors who are California residents.

9. Data Security.

We use reasonable security safeguards to help protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. However, no internet transmission is fully secure, and we cannot guarantee the security of your information. In the event of a data breach affecting your personal information, we will notify you and provide instructions for any actions you may take to protect yourself.

10. International Transfer.

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. By using the Service or giving us your information, you consent to the transfer, processing, and storage of your information in the U.S. and other jurisdictions as described in this Privacy Policy.

If you are located in the EEA, United Kingdom, or Switzerland, we will transfer your personal data to the U.S. and other countries that may not have equivalent data protection laws. When we do so, we rely on appropriate safeguards as permitted under applicable law, which may include the EU-US Data Privacy Framework, Standard Contractual Clauses, or other mechanisms. To obtain a copy of the safeguards we use, contact us as described in the "Contact Us" section.

11. Changes to this Privacy Policy.

We may update this Privacy Policy from time to time. For material changes, we will notify you and obtain your consent before the changes apply to you. We will notify you through the Service and provide a plain-language summary of what has changed.

12. Contact Us.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us: By email: privacyteam@themarbleway.com By mail: 9920 Pacific Heights Blvd., Ste. 150 San Diego, California 92121, United States of America

This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at https://www.marble.co/disability-contact-form.

13. Additional Disclosures for Nevada Residents.

Nevada law (NRS 603A.340) requires businesses to establish a request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. Under Nevada law, a "sale" means exchanging personal information for money so a third party can license or resell it. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at privacyteam@themarbleway.com.

14. Additional Disclosures for California Residents.

These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (collectively, "CCPA"), provides California residents with specific rights regarding their personal information.

A. Notice of Collection.

Categories of Personal Information Collected. In the past 12 months, we have collected the following categories of personal information:

Sources. We collect personal information from: (1) you directly; (2) automatically when you use our Service; and (3) third parties such as social networks, vendors, and publicly available sources.

Purposes. We collect and use personal information for the business purposes described in Section 3 of this Privacy Policy, including to provide legal services, process payments, communicate with you, improve our Service, and for marketing and advertising.

Retention. We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide legal services, comply with legal obligations (including attorney record-keeping requirements), resolve disputes, and enforce our agreements. Client matter files are generally retained for a minimum of seven (7) years following the conclusion of the matter, or longer as required by applicable law or professional responsibility rules. For accounts that are dormant (defined as no login, transaction, or other account activity for twenty-four (24) consecutive months), we will retain personal information for seven (7) years following the last account activity, after which such information will be securely deleted, unless retention is required by applicable law, professional responsibility rules, or pending legal matters.

• Identifiers, including name, email address, phone number, postal address, account name, IP address, and an ID or number assigned to your case or case assessment.

• Customer Records, including billing and shipping address, and credit or debit card information.

• Protected Classification Characteristics, such as age, gender, marital status, and other characteristics relevant to your legal matter.

• Commercial Information, including purchases and engagement with the Service.

• Internet or Network Activity, including your interactions with our Service, browsing history, and search history.

• Geolocation Data, including imprecise location derived from IP address.

• Audio or Visual Data, including pictures, videos, or call recordings.

• Professional or Employment Information, as relevant to your legal matter.

• Inferences, including information about your interests, preferences, and characteristics.

• Sensitive Personal Information, including Social Security number, driver's license number, passport number, financial account information, and information concerning your legal matters (which may include health information, sex life or sexual orientation, racial or ethnic origin, religious beliefs, or citizenship/immigration status, depending on the nature of your case). Personal information of consumers under 16 years of age is also treated as sensitive personal information.

B. Sale and Sharing of Personal Information.

We do not "sell" personal information for monetary consideration. However, like many companies, we use advertising technologies (such as cookies, pixels, and similar technologies) that may constitute "sharing" of personal information for cross-context behavioral advertising under the CCPA. The categories of personal information we may share for this purpose include: identifiers, internet or network activity, and inferences.

We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

C. Your California Privacy Rights.

California residents have the following rights:

• Right to Know. You have the right to request that we disclose: (1) the categories of personal information we collected about you; (2) the categories of sources from which we collected your personal information; (3) the business or commercial purpose for collecting, selling, or sharing your personal information; (4) the categories of third parties to whom we disclosed your personal information; and (5) the specific pieces of personal information we collected about you. If we maintain your personal information beyond the preceding 12 months, you may request access to information collected on or after January 1, 2022.

• Right to Delete. You have the right to request that we delete personal information we collected from you, subject to certain exceptions.

• Right to Correct. You have the right to request that we correct inaccurate personal information we maintain about you. If we received the inaccurate information from a third-party source, we will either inform you of that source or notify the source that the information is incorrect and must be corrected.

• Right to Opt-Out of Sale or Sharing. You have the right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising. To exercise this right, click the "Do Not Sell or Share My Personal Information" link in the footer of our website, submit a request through our online form at https://www.marble.co/do-not-sell-my-info, or email us at privacyteam@themarbleway.com.

• Right to Limit Use of Sensitive Personal Information. You have the right to limit our use of your sensitive personal information to only those uses necessary to provide the services you requested. However, we only use sensitive personal information for purposes permitted under the CCPA (such as providing legal services you requested), so this right may not apply to our processing activities.

• Right to Non-Discrimination. You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.

D. How to Submit a Request.

To exercise your rights to know, delete, or correct, you may:

We will confirm receipt of your request within 10 business days and respond within 45 calendar days. If we need additional time, we will notify you of the extension and the reason for it.

• Submit a request through our online form at https://www.marble.co/do-not-sell-my-info

• Call our toll-free number at (800) 297-1008

• Email us at privacyteam@themarbleway.com

E. Verification.

We will verify your identity before fulfilling your request. For requests to know categories of information or to delete, we will verify your identity to a reasonable degree of certainty by matching at least two data points you provide with information we maintain. For requests to know specific pieces of information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points and obtaining a signed declaration under penalty of perjury.

If we cannot verify your identity, we may deny your request.

F. Authorized Agents.

You may designate an authorized agent to submit requests on your behalf. We will require: (1) written authorization signed by you; and (2) verification of your identity directly, unless the agent provides a valid power of attorney.

G. Opt-Out Preference Signals and Confirmation.

We honor Global Privacy Control (GPC) signals as valid requests to opt out of the sale or sharing of personal information. When we detect a GPC signal from your browser, we will treat it as a request to opt out of sale/sharing for that browser and device. You may confirm the status of your opt-out request at any time by visiting our privacy preference center or contacting us.

H. Shine the Light.

California residents may request: (i) a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the preceding calendar year; and (ii) a list of such third parties. To make this request, email us at privacyteam@themarbleway.com with "California Shine the Light Request" in the subject line.

15. Additional Disclosures for EEA, UK, and Swiss Residents.

These additional disclosures apply to individuals located in the European Economic Area ("EEA"), United Kingdom ("UK"), or Switzerland. The General Data Protection Regulation ("GDPR") and equivalent UK and Swiss data protection laws provide you with rights regarding your personal data.

A. Data Controller.

Marble PC is the data controller for personal data collected in connection with our legal services and the Service. Flare acts as a data processor on behalf of Marble PC.

Contact details: Marble PC 9920 Pacific Heights Blvd., Ste. 150 San Diego, California 92121, United States of America Email: privacyteam@themarbleway.com

B. Legal Basis for Processing.

We process your personal data only where we have a valid legal basis to do so. The legal bases we rely on include:

• Contract. Processing necessary to perform our contract with you or to take steps at your request before entering into a contract, including providing legal services, processing payments, and communicating with you about your matter.

• Legitimate Interests. Processing necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights. Our legitimate interests include operating and improving our Service, marketing and advertising, fraud prevention, and ensuring network and information security.

• Legal Obligation. Processing necessary to comply with a legal obligation to which we are subject, including attorney record-keeping requirements, court orders, and regulatory obligations.

• Consent. Processing based on your consent, where we have obtained it. Where we rely on consent, you have the right to withdraw it at any time by contacting us at privacyteam@themarbleway.com. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

C. Your Rights Under the GDPR.

Subject to applicable law, you have the following rights regarding your personal data:

To exercise any of these rights, contact us at privacyteam@themarbleway.com. We will respond to your request within one month. If your request is complex or we receive a high volume of requests, we may extend this period by up to two additional months, and we will notify you of any extension within the initial one-month period.

• Right of Access. You have the right to request confirmation of whether we process your personal data and, if so, to request a copy of that data.

• Right to Rectification. You have the right to request that we correct inaccurate personal data or complete incomplete personal data.

• Right to Erasure. You have the right to request that we delete your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.

• Right to Restriction. You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data.

• Right to Data Portability. You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.

• Right to Object. You have the right to object to the processing of your personal data where we rely on legitimate interests as the legal basis, including for direct marketing purposes. Where you object to processing for direct marketing, we will stop processing your data for that purpose.

• Right to Withdraw Consent. Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

• Right to Lodge a Complaint. You have the right to lodge a complaint with your local data protection supervisory authority. A list of EEA supervisory authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

D. Retention.

We retain your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide legal services, comply with legal obligations (including attorney record-keeping requirements), resolve disputes, and enforce our agreements. Client matter files are generally retained for a minimum of seven (7) years following the conclusion of the matter, or longer as required by applicable law or professional responsibility rules. When personal data is no longer necessary for these purposes, we will delete or anonymize it. For accounts that are dormant (defined as no login, transaction, or other account activity for twenty-four (24) consecutive months), we will retain personal data for seven (7) years following the last account activity, after which such data will be securely deleted, unless retention is required by applicable law, professional responsibility rules, or pending legal matters.

E. Automated Decision-Making.

We do not use your personal data for automated decision-making, including profiling, that produces legal effects or similarly significant effects concerning you.

F. International Transfers.

Your personal data may be transferred to and processed in the United States and Israel. Our service provider, Flare, maintains operations in Israel. For more information on the safeguards we use for international transfers, see Section 10 of this Privacy Policy.

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