Overview of Our Privacy Policy
At Pellegrino, LLC, we understand that privacy and the protection of private information are top priorities for legal asset managers and investment management companies. This Privacy Policy describes the manner in which our law firm – a boutique law firm focused exclusively on the investment management industry – collects, utilizes, shares, and protects an individual’s or entity’s information and related data. Our commitment to privacy is not only required by law but is important in embodying the values of trustworthiness, transparency, and professionalism that we strive to embrace. We ask you to please read this policy carefully to review how we handle your information, and please reach out to us if you have questions.
About Pellegrino, LLC
Pellegrino, LLC is a boutique law firm in Wenonah, New Jersey that serves the investment management industry in the United States. Under the leadership of Mr. Michael Pellegrino, the firm provides legal and regulatory services for investment advisers, money managers, investment companies, independent directors/trustees, and providers of financial services. Contract drafting, regulatory filings, compliance reviews, and support for a broad array of investment products are among the firm’s legal and compliance services. The firm has a practical, responsive, and client-centered approach, accommodating specific client needs within the framework of a strong commitment to privacy and confidentiality practices.
Scope and Applicability of Our Privacy Policy
This Privacy Policy applies to any and all personal information obtained by Pellegrino, LLC through our website, communications, and the provision of professional legal services, including information provided by clients, potential clients, business partners, prospective employees, and visitors to the site. This policy relates to the management of data in electronic, written, and/or verbal form. It does not apply to websites or third-party services that may be linked to or referenced on this site. Users are encouraged to review the privacy policies of third parties separately.
Categories of Information We May Collect
Pellegrino, LLC gathers personal and non-personal information required to conduct our legal practice and provide our services. Categories of information that we may collect include:
- Contact information (such as name, email address, phone number, mailing address)
- Professional information (such as position, employer, business contacts)
- Transactional information (such as legal inquiries, referrals for or provision of services, charges and payment information)
- Technical information (such as IP address, browser type, operating system, website usage information)
- Communications (e.g., emails, telephone calls, other messages, notes of meetings)
- Regulatory and compliance (such as identity documentation and background screening as required by law)
Depending on the services you request, we may hold additional data that you voluntarily supply to us (for example, when you fill out a contact page and provide your name and contact information, or submit an application for employment).
How We Collect Personal Information
We gather personal information in several ways, including:
- Direct interactions: When you communicate with us by phone, email, fax, or via our website contact form at 4 East Cherry Street, Wenonah, N.J. 08090, or by telephone 856-292-8331.
- Automated technologies: When you visit our sites or use services we provide, we use cookies, server logs, and other similar technologies to help us gather technical and usage data.
- Third parties: We receive information from business partners, public databases, joint marketing partners, or other outside sources, or as part of our due diligence and compliance efforts.
- Engagements and transactions: When you retain us for legal services, attend one of our events, or otherwise interact with the firm.
Our Purposes for the Collection and Processing of Information
- Rendering legal advice and services
- Communicating with clients, prospective clients, and business counterparties
- Fulfilling contractual obligations and other compliance requirements
- Billing, invoicing, and operating an account
- Enhancing the website, services, and client experience
- Complying with laws and regulations (including AML/KYC)
- Protecting the Company’s operations and integrity
- Reviewing, evaluating, and responding to employment inquiries
Basis for Processing of Personal Information
Our use of personal information is based on one or more of the following legal grounds for processing, depending on the relevant activity:
- Performance of a contract: Where processing is necessary for the provision of legal services to you by us.
- Legal obligation: Where we have to comply with a legal or regulatory obligation in the UK or elsewhere.
- Legitimate interests: The processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest examples include the use of your personal information for internal business or governance purposes (e.g., audit), fraud prevention, protection against cyberattack, and protection against criminal behaviour.
- Consent: Where you have provided consent for us to process your personal information in a particular way (for example, where you subscribe to receive client alerts).
How We Use Your Personal Information
The personal information we obtain is used only in accordance with this Privacy Policy and applicable law. Common uses include:
- Communications with you regarding your legal matters, status updates, and responses to inquiries
- Drafting, negotiating, and executing documents, contracts, and other legal instruments
- Regulatory filing and compliance reviews
- Managing client files, accounts, and billing correspondence
- Information regarding our services, events, or other legal updates (with your permission)
- Conflict checks, standard background checks, and due diligence exercises that are mandated by law
- Providing greater levels of security for the Firm’s website and IT infrastructure
- Analyzing website use or use of services in order to tailor offerings to serve your needs
To Whom We May Disclose Personal Information
Pellegrino, LLC respects the confidentiality and privacy of its clients and users. We do not sell and we don’t rent your personal information to third parties. We may share information as follows, in limited circumstances:
- With service providers and vendors who perform services to us in support of the operation of our practice (e.g., IT support, secure cloud storage, processors of online billing); subject always to appropriate confidentiality requirements
- As necessary to cooperate with law- or regulatory-enforcement agencies, subpoenas, court orders, or other legal processes; including during the course of audits or investigations by those entities
- With co-counsel, consultants, or experts retained in support of a client matter; subject always to appropriate confidentiality requirements
- In the event of a business reorganization or corporate acquisition or merger; subject always to appropriate privacy protections
- With your express consent, or as otherwise allowed by applicable law
Data Integrity and Security Measures
We take your privacy and the security of any personal information you provide very seriously. We employ a variety of technical, administrative, and physical standard safeguards to protect data against unauthorized access, disclosure, alteration, or destruction, including:
- Locking offices and limiting access to confidential files
- Using secure electronic communications and storage for notes
- Providing training for our staff on privacy and data security
- Relying on firewalls, anti-virus, and secure back-up systems
- Reviewing and testing our security programs and procedures periodically
However, it should be noted that no means of transmission or storage of information via the Internet or other method is completely secure. We advise you to exercise caution if submitting sensitive information to our firm electronically.
Retention, Transfer and Disposal of Personal Information
Pellegrino, LLC will retain Personal Information only for as long as is necessary for the purposes set forth in this Privacy Policy, or as required to meet our obligations under any applicable contract, by law, or applicable professional standards. The retention periods may vary according to the nature of the Personal Information and any applicable laws. Where Personal Information is no longer required, such information will be securely destroyed by shredding, deleting, or anonymizing (as appropriate).
Your Privacy Choice and Rights
You may be able to:
- Request access to personal data we hold about you
- Request that we rectify or erase your personal data
- Request that we restrict our processing of your personal data, subject to operational and legal constraints
- Withdraw consent when processing is on the basis of consent
- Object to processing for direct marketing purposes
To exercise your rights or if you have any questions regarding your data, please contact 4 East Cherry Street, Wenonah, N.J. 08090 or call 856-292-8331.
Use of Cookies and Electronic Tracking Tools on Our Sites
Our site may use cookies and similar technology to track use and improve features. Cookies are text files placed on your computer or device that help us recognize you by remembering information about your preferences. You have the option to turn off cookies using your browser settings, although this may impact the functionality of our site. We do not use cookies to target advertising or to collect sensitive personal information.
Links and Social Media Features
You may find links to third-party websites, resources, products, and services on our website for your convenience or reference. Pellegrino, LLC has no control over and no responsibility for the privacy practices, content, services, or security of these third-party websites. We encourage you to review the privacy policy related to any third-party website you might visit, since they may not follow similar practices.
Trans border Data Transfers
While Pellegrino, LLC primarily partners with clients in the United States, information may be transferred to or accessed from other jurisdictions. Where such transfer or access occurs, Pellegrino takes measures to ensure information is handled appropriately by applicable privacy laws and the legal profession’s rules of professional conduct. Clients located outside the United States who contact us should expect that their information may also be accessed in the United States, where different privacy laws may apply.
Children Under Age 13
Our products and websites are not aimed at children under the age of 16, and we do not knowingly collect personal information from a child. If we learn we have collected information from a child, we will take steps to delete the information as soon as possible.
Legal Obligations of Confidentiality and Privilege
As a law firm, Pellegrino, LLC is subject to professional obligations regarding confidentiality and privilege. Whether information is given to us in connection with seeking legal advice or otherwise provided to us, we take our obligations seriously and utilize our best efforts to maintain client information in confidence as required under the professional rules of conduct and applicable law. Our internal policies and procedures are designed to support that obligation at every step in the process.
Modifications to This Privacy Policy
This Privacy Policy may be updated from time to time to reflect changes in our practices, technology, or legal requirements. Changes will be posted on this page with an updated effective date. Please check back periodically to see if our practices have changed. If the changes are material, we may attempt to notify you directly or obtain your consent if necessary under applicable law.
How to Address Privacy Concerns with Pellegrino, LLC
If you have any questions, concerns, or requests with regard to this Privacy Policy or our use of your personal information, please contact us at:
- Address: 4 East Cherry Street, Wenonah, N.J. 08090
- Telephone: 856-292-8331
- Fax: 856-504-0202
You may also contact our office regarding your privacy rights or to file a privacy complaint against us. All privacy complaints will be taken seriously and responded to promptly in compliance with our legal and ethical responsibilities.
State Specific Privacy Rights Under California Law
Residents of California and certain other states may have additional privacy rights under state laws, such as the California Consumer Privacy Act. For example, these rights may include:
- The right to know what categories of personal information we collect, use, and disclose
- The right to request that we delete certain categories of personal information
- The right to opt out of the sale of certain personal information (Pellegrino, LLC does not sell personal information)
- The right not to be discriminated against for the exercise of privacy rights
To submit any requests in connection with such privacy rights, please contact Pellegrino, LLC via our contact information set forth above. We will verify your identity prior to processing any such requests, to the extent required by applicable law.
Data Breach Notification and Response
In the event of an actual or suspected security breach of your personal information, Pellegrino, LLC will promptly take measures to contain and investigate the breach. We will notify you and law enforcement as necessary and in accordance with applicable law, providing appropriate information regarding the nature of the breach, the data that was possibly compromised, and what you should do to safeguard yourself. We maintain incident response plans that are reviewed regularly to help ensure that we can implement an effective and timely response if this kind of situation arises.
Retention of Client Information in File and Records
Client files (including client documents and correspondence) are kept for the period required by professional rules, guidelines, and best practices, generally a minimum of five to seven years from the end of a matter, unless another retention period is required by law. At the end of the retention period, records are shredded for confidentiality. During the retention period, clients may request copies of their files at any time by contacting our office.
Marketing, Promotions and Your Choices
We may from time to time send notices, newsletters, or event invitations by email to clients and other contacts who have consented to receiving such materials or have otherwise indicated an interest in our legal services. Recipients of such mailings may opt out of future mailings at any time in the manner described in the email or by contacting us directly. We do not send unsolicited marketing emails and we do not share email addresses or other information with any third parties for marketing purposes.
Prohibited Professional Conduct and Privacy
Pellegrino, LLC strives to ensure that we practice at the highest possible levels of professional standards and ethics while handling personal and/or confidential information. Our privacy policy is governed not only by applicable laws and professional and ethical rules, but also by our commitment to earn and keep the trust of our clients and those about whom we may be entrusted with private information. We regularly scrutinize our privacy policies and make appropriate adjustments to account for changes in applicable industry standards and rules.
Disputes and Questions
If you have a complaint or dispute with our information privacy practices, we encourage you to contact us and we will make every effort to fairly and amicably address your concerns. If you are not satisfied with how we have addressed your concern, you may have a right to file a complaint with a government data protection authority or bar association in the applicable jurisdiction. We will make every effort to fairly and amicably resolve privacy disputes.
Availability, Scope and Applicability of This Privacy Policy
We attempt to make our Privacy Policy as easy as possible to read and understand for all visitors, regardless of ability. If you wish to obtain this Privacy Policy in an alternate format or have questions about our policy, please contact our office at (856) 292-8331. We want all clients and visitors to receive all information about our privacy practices in a clear, unambiguous manner.
Engaging Pellegrino, LLC for Legal Services
If you’re seeking legal assistance on matters related to the investment management industry, please contact Pellegrino, LLC today for a confidential consultation. We’re available to provide you with answers pertaining to your concerns in terms of privacy, compliance, and other areas of representation. Pellegrino, LLC can be reached at our physical address of 4 East Cherry Street, Wenonah, N.J. 08090, or via telephone at 856-292-8331. Potential clients are invited to study Mr. Michael Pellegrino’s CV to find out more about the backgrounds and qualifications of our lawyers.
Effective Date and Policy Acknowledgement
Our Privacy Policy is effective as of June 1, 2024. By using our website or engaging the legal services of Pellegrino, LLC, the policy terms and requirements are agreed to. You agree that we may collect, use, and protect your information as set forth in this Privacy Policy based on your continued use of our services. Thank you for putting your confidence in us and allowing us to be of service to you. We are here to protect your privacy throughout the process and every step of the way.