Privacy Policy

7. How Information Is Used

Cochran & Co. may use information received through website-directed contact or related communications to:

• respond to questions and consultation requests;
• communicate with the person who contacted the firm;
• understand the general nature and objective of a prospective matter;
• conduct conflict, lawful-purpose, suitability, capability, jurisdiction, and case-acceptance review;
• maintain prospective-matter and business-administration records;
• if a matter is accepted, establish and administer the client relationship and perform authorized investigative work;
• protect client, case, company, system, and information security;
• detect or prevent misuse, fraud, harassment, stalking, intimidation, unlawful access requests, or other improper activity;
• comply with legal, regulatory, licensing, insurance, professional, recordkeeping, and valid legal-process obligations;
• establish, exercise, or defend legal or professional rights; and
• maintain website reliability, security, and business operations.

Contacting Cochran & Co. does not by itself create an investigator-client relationship or mean that the firm has accepted a matter.

8. Marketing Communications

Cochran & Co. does not currently operate a marketing mailing list and does not automatically add a person to a promotional email list merely because that person contacts the firm about an investigation or other matter.

If Cochran & Co. later begins sending promotional or marketing email campaigns, the firm will evaluate and implement applicable notice, consent, identification, and opt-out requirements and update this policy when appropriate.

Service, case, billing, administrative, or other non-promotional communications may continue when appropriate even if a person has opted out of marketing communications.

9. Disclosure of Information

Cochran & Co. does not sell personal information collected through the website or an initial inquiry.

Information may be disclosed when reasonably necessary and lawful, including to:

• Carrd and other website, hosting, domain/DNS, security, or internet-infrastructure providers needed to operate and deliver the website;
• Google Workspace / Gmail and other communications providers used to send, receive, store, secure, or administer business communications;
• Google Fonts infrastructure needed to deliver the website's current typefaces;
• qualified investigators, contractors, vendors, or specialists when reasonably necessary for an authorized business or investigative purpose and subject to applicable confidentiality and security controls;
• a client's attorney, authorized representative, or other person when the client has authorized the communication and disclosure is lawful and appropriate;
• legal counsel, insurers, auditors, accountants, or other professional advisors when reasonably necessary for legitimate business, legal, insurance, or compliance purposes;
• courts, regulatory or licensing authorities, law enforcement, government agencies, or other persons when disclosure is required or permitted by applicable law or valid legal process; and
• other persons when reasonably necessary to address an immediate safety concern, prevent unlawful misuse, or protect the rights and security of Cochran & Co., its clients, personnel, or others, consistent with applicable law.

Cochran & Co. does not disclose client or investigative information to a subject or other third party merely because that person requests it.

10. Investigative and Third-Party Information

An inquiry may contain information about people other than the person contacting Cochran & Co., including subjects, witnesses, family members, attorneys, employees, businesses, or other related persons.

The person making an inquiry should avoid sending unnecessary sensitive information about any person during initial contact.

If a matter is accepted, case information is handled according to the applicable engagement, professional obligations, lawful client instructions, confidentiality requirements, investigative needs, records controls, and applicable law.

The fact that information is available to or held by Cochran & Co. does not make that information public or freely disclosable.

11. Retention and Destruction

Cochran & Co. retains information according to the nature of the record and the legitimate purpose for which it is maintained.

Prospective-matter information may be retained for intake administration, conflict screening, suitability and acceptance review, follow-up, professional accountability, legal or regulatory compliance, security, and defense of potential claims.

If a matter is accepted, applicable information becomes part of the associated client or case record and is retained under Cochran & Co.'s case-file and records-retention controls.

Legal Holds, subpoenas, complaints, insurance matters, regulatory inquiries, litigation, or other preservation obligations may require information to be retained longer than an ordinary retention period.

When destruction is authorized, Cochran & Co. applies secure-destruction requirements appropriate to the information and storage medium.

12. Information Security and Email

Cochran & Co. treats prospective-client, client, investigative, and other sensitive information according to applicable professional obligations and company confidentiality and information-security controls.

Cochran & Co. uses administrative, technical, and physical safeguards intended to protect confidential and personal information in a manner proportionate to the sensitivity of the information and the operational risk.

No method of internet transmission, email communication, electronic storage, or security control can guarantee absolute security.

Ordinary email is appropriate for general initial contact, but prospective clients should not transmit highly sensitive records or evidence solely because an email address appears on the website.

If sensitive or large materials are needed, an appropriate method of transmission can be discussed after initial contact.