Brown & Blaier, PC / Business law

Privacy policy counsel.
Disclosures grounded in your practices.

Brown & Blaier helps businesses draft and review privacy policies for websites, applications, and online services. We begin with the information you collect, how it moves through your business, and the people and markets you serve.

Inquiries open our firm’s MyCase contact form.

Data, audience, and operations

Do websites need
privacy policies?

Many businesses have legal obligations to disclose their personal-information practices. The answer depends on the data, users, business activities, and jurisdictions involved. A policy should describe the actual practices of the business, including the tools and service providers supporting its website or app.

Health, financial, and children’s information can raise additional requirements. International operations may also matter. For example, the GDPR’s reach is not based simply on a user’s citizenship; establishment, offering goods or services to people in the EU, and monitoring their behavior can affect applicability.

Posting a policy is one part of privacy work. The business also needs to consider whether its collection, use, sharing, security practices, and handling of requests align with its disclosures and applicable obligations.

Make the disclosures match the service

What should a privacy-policy
review consider?

Information collected

Account and contact details, purchase information, device or browsing data, and information collected through cookies, analytics, advertising tools, or other integrations.

Use and sharing

The purposes for collecting information, the service providers and other recipients, and any advertising or other activities that require additional analysis.

Choices, rights, and contact methods

Applicable notice and request processes, user choices, and how individuals can contact the business. A published process should match what the business can actually carry out.

Security, retention, and change

Statements about safeguards and retention should be accurate. New tools, data uses, audiences, or business arrangements can require updates to the policy and related practices.

Different laws address different practices

Relevant state laws:
selected examples.

The following examples illustrate different kinds of obligations. They are not a complete list of U.S. privacy laws, and a four-state review is not sufficient to determine all requirements for a business. Comprehensive state privacy laws, sector rules, and other requirements may also apply.

California

The California Online Privacy Protection Act requires covered commercial website and online-service operators collecting personally identifiable information about California consumers to make a privacy policy available. Its disclosures include information categories, sharing, policy changes, and certain tracking practices. Cal. Bus. & Prof. Code § 22575.

Connecticut

A business collecting Social Security numbers must address the privacy-protection policy requirements in Conn. Gen. Stat. § 42-471. The policy must be published or publicly displayed; website posting is one method. The section also addresses safeguards for personal information. Other Connecticut privacy requirements may apply.

Delaware

Covered commercial online operators collecting personally identifiable information about Delaware users must make their privacy policy conspicuously available. Required disclosures address collection, sharing, changes, and specified tracking practices. 6 Del. C. § 1205C.

New York

The SHIELD Act’s security provisions require covered businesses holding computerized private information of New York residents to maintain reasonable safeguards. A qualifying small business’s safeguards are evaluated in light of its size, activities, and information sensitivity. This is a security obligation, not simply a website-policy requirement. N.Y. Gen. Bus. Law § 899-bb.

Prepare for the review

Start with a picture
of your data practices.

Identify your website and app functions, forms, payment tools, analytics, advertising technologies, major vendors, and where users are located. Note whether children, health information, financial information, or other sensitive data are involved.

We use that context to discuss the legal work needed, including drafting, review of an existing policy, and coordination with website terms or technology agreements. A general policy template cannot establish which laws apply to the business.

Before you get started

Questions we hear.

Does every website follow the same privacy rules?

No. Coverage depends on the law and the facts, including location, business activities, data, audience, and applicable thresholds or exemptions.

Is a privacy policy enough to comply?

No. Required notices need to match actual practices. Security, consent, consumer requests, contracts, and other operational duties may need separate attention.

When should we update an existing policy?

Review it when data practices, vendors, advertising tools, products, users, or legal requirements change. A policy can become inaccurate even if the website design stays the same.

Explore the firm

Related legal services.

Your next step

Discuss your privacy-policy
drafting or review.

Tell us about your business, the legal support you need, and any relevant timing.

Start an inquiry

Continue to our firm’s MyCase contact form.

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