We respect your privacy and are committed to protecting it through  our compliance with this privacy policy (“Policy”). This Policy  describes the types of information we may collect from you or that you  may provide (“Personal Information”) on this website (“Website” or  “Service”) and any of its related products and services (collectively,  “Services”), and our practices for collecting, using, maintaining,  protecting, and disclosing that Personal Information. It also describes  the choices available to you regarding our use of your Personal  Information and how you can access and update it.

This Policy is a legally binding agreement between you (“User”, “you”  or “your”) and this Website operator (“Operator”, “we”, “us” or “our”).  If you are entering into this agreement on behalf of a business or  other legal entity, you represent that you have the authority to bind  such entity to this agreement, in which case the terms “User”, “you” or  “your” shall refer to such entity. If you do not have such authority, or  if you do not agree with the terms of this agreement, you must not  accept this agreement and may not access and use the Website and  Services. By accessing and using the Website and Services, you  acknowledge that you have read, understood, and agree to be bound by the  terms of this Policy. This Policy does not apply to the practices of  companies that we do not own or control, or to individuals that we do  not employ or manage.

Our top priority is customer data security and, as such, we exercise  the no logs policy. We may process only minimal user data, only as much  as it is absolutely necessary to maintain the Website and Services.  Information collected automatically is used only to identify potential  cases of abuse and establish statistical information regarding the usage  and traffic of the Website and Services. This statistical information  is not otherwise aggregated in such a way that would identify any  particular user of the system.

We do not knowingly collect any Personal Information from children  under the age of 18. If you are under the age of 18, please do not  submit any Personal Information through the Website and Services. If you  have reason to believe that a child under the age of 18 has provided  Personal Information to us through the Website and Services, please  contact us to request that we delete that child’s Personal Information  from our Services.

We encourage parents and legal guardians to monitor their children’s  Internet usage and to help enforce this Policy by instructing their  children never to provide Personal Information through the Website and  Services without their permission. We also ask that all parents and  legal guardians overseeing the care of children take the necessary  precautions to ensure that their children are instructed to never give  out Personal Information when online without their permission.

We act as a data controller and a data processor when handling  Personal Information, unless we have entered into a data processing  agreement with you in which case you would be the data controller and we  would be the data processor.

Our role may also differ depending on the specific situation  involving Personal Information. We act in the capacity of a data  controller when we ask you to submit your Personal Information that is  necessary to ensure your access and use of the Website and Services. In  such instances, we are a data controller because we determine the  purposes and means of the processing of Personal Information.

We act in the capacity of a data processor in situations when you  submit Personal Information through the Website and Services. We do not  own, control, or make decisions about the submitted Personal  Information, and such Personal Information is processed only in  accordance with your instructions. In such instances, the User providing  Personal Information acts as a data controller.

In order to make the Website and Services available to you, or to  meet a legal obligation, we may need to collect and use certain Personal  Information. If you do not provide the information that we request, we  may not be able to provide you with the requested products or services.  Any of the information we collect from you may be used to help us run  and operate the Website and Services.

Processing your Personal Information depends on how you interact with  the Website and Services, where you are located in the world and if one  of the following applies: (i) you have given your consent for one or  more specific purposes; (ii) provision of information is necessary for  the performance of an agreement with you and/or for any pre-contractual  obligations thereof; (iii) processing is necessary for compliance with a  legal obligation to which you are subject; (iv) processing is related  to a task that is carried out in the public interest or in the exercise  of official authority vested in us; (v) processing is necessary for the  purposes of the legitimate interests pursued by us or by a third party.

Note that under some legislations we may be allowed to process  information until you object to such processing by opting out, without  having to rely on consent or any other of the legal bases. In any case,  we will be happy to clarify the specific legal basis that applies to the  processing, and in particular whether the provision of Personal  Information is a statutory or contractual requirement, or a requirement  necessary to enter into a contract.

To maintain the highest level of privacy and to protect your Personal  Information to the full extent, we do not share your Personal  Information with any third parties.

However, we may also disclose any Personal Information we collect,  use or receive if required or permitted by law, such as to comply with a  subpoena or similar legal process, and when we believe in good faith  that disclosure is necessary to protect our rights, protect your safety  or the safety of others, investigate fraud, or respond to a government  request.

We will retain and use your Personal Information for the period  necessary to comply with our legal obligations, to enforce our  agreements, resolve disputes, and unless a longer retention period is  required or permitted by law.

We may use any aggregated data derived from or incorporating your  Personal Information after you update or delete it, but not in a manner  that would identify you personally. Once the retention period expires,  Personal Information shall be deleted. Therefore, the right to access,  the right to erasure, the right to rectification, and the right to data  portability cannot be enforced after the expiration of the retention  period.

Some browsers incorporate a Do Not Track feature that signals to  websites you visit that you do not want to have your online activity  tracked. Tracking is not the same as using or collecting information in  connection with a website. For these purposes, tracking refers to  collecting personally identifiable information from consumers who use or  visit a website or online service as they move across different  websites over time. The Website and Services do not track its visitors  over time and across third-party websites. However, some third-party  websites may keep track of your browsing activities when they serve you  content, which enables them to tailor what they present to you.

The Website and Services contain links to other resources that are  not owned or controlled by us. Please be aware that we are not  responsible for the privacy practices of such other resources or third  parties. We encourage you to be aware when you leave the Website and  Services and to read the privacy statements of each and every resource  that may collect Personal Information.

We secure information you provide on computer servers in a  controlled, secure environment, protected from unauthorized access, use,  or disclosure. We maintain reasonable administrative, technical, and  physical safeguards in an effort to protect against unauthorized access,  use, modification, and disclosure of Personal Information in our  control and custody. However, no data transmission over the Internet or  wireless network can be guaranteed.

Therefore, while we strive to protect your Personal Information, you  acknowledge that (i) there are security and privacy limitations of the  Internet which are beyond our control; (ii) the security, integrity, and  privacy of any and all information and data exchanged between you and  the Website and Services cannot be guaranteed; and (iii) any such  information and data may be viewed or tampered with in transit by a  third party, despite best efforts.

In the event we become aware that the security of the Website and  Services has been compromised or Users’ Personal Information has been  disclosed to unrelated third parties as a result of external activity,  including, but not limited to, security attacks or fraud, we reserve the  right to take reasonably appropriate measures, including, but not  limited to, investigation and reporting, as well as notification to and  cooperation with law enforcement authorities. In the event of a data  breach, we will make reasonable efforts to notify affected individuals  if we believe that there is a reasonable risk of harm to the User as a  result of the breach or if notice is otherwise required by law. When we  do, we will post a notice on the Website.

We reserve the right to modify this Policy or its terms related to  the Website and Services at any time at our discretion. When we do, we  will revise the updated date at the bottom of this page. We may also  provide notice to you in other ways at our discretion, such as through  the contact information you have provided.

An updated version of this Policy will be effective immediately upon  the posting of the revised Policy unless otherwise specified. Your  continued use of the Website and Services after the effective date of  the revised Policy (or such other act specified at that time) will  constitute your consent to those changes. However, we will not, without  your consent, use your Personal Information in a manner materially  different than what was stated at the time your Personal Information was  collected.

You acknowledge that you have read this Policy and agree to all its  terms and conditions. By accessing and using the Website and Services  and submitting your information you agree to be bound by this Policy. If  you do not agree to abide by the terms of this Policy, you are not  authorized to access or use the Website and Services.

If you have any questions, concerns, or complaints regarding this  Policy, the information we hold about you, or if you wish to exercise  your rights, we encourage you to contact us using the details below:  info@waterflylaw.com PO Box 117, St. Joseph, MN 56374

We will attempt to resolve complaints and disputes and make every  reasonable effort to honor your wish to exercise your rights as quickly  as possible and in any event, within the timescales provided by  applicable data protection laws.

This document was last updated on March 1, 2025.