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    California Consumer Privacy Act - Privacy Policy Applicable to Client-Related Personal Information

    Effective date: 1 January 2020

     

    California Consumer Privacy Act - Privacy Policy Applicable to Client-Related Personal Information

    This Privacy Policy (“Policy”) describes how Squire Patton Boggs (US) LLP (“SPB,” “we,” “us,” “ours”) handles the personal information of California residents (“you,” “your,” “yours”) to the extent that: (1) we collect and process such information in the context of the provision of legal services (“client-related personal information”); and (2) the obligations imposed by the California Consumer Privacy Act of 2018 ("CCPA") apply to such data. This Policy also notifies you of our collection practices regarding client-related personal information, and describes your rights under the CCPA. 

    Our Global Website Privacy Notice and Cookie Notice address other privacy-related requirements under California law and generally describe how we collect and handle personal information about visitors to our website. Our CCPA Applicant Privacy Notice describes the personal information that we collect about California job applicants.

    The terms used in this Policy are as defined in the CCPA unless otherwise indicated.

    1. Collection and sharing practices regarding client-related personal information during the past 12 months
    2. We do not sell your personal information to third parties, nor do we share it with them for their marketing purposes without your consent.

      Given the diverse types of legal issues that our clients engage us to address, we may potentially collect and process many different kinds of personal information as lawyers acting on behalf of our clients. The table below describes our collection and sharing practices during 2019 for each category of personal information identified in the CCPA.

      For each such category, we may share the personal information collected for the following purposes:

      • For the business purpose for which we collected it, as described in the table below, or for other purposes compatible with the context in which we collected the information;
      • At your request; or
      • Pursuant to an exception recognized by CCPA.

      CCPA Personal Information Category

      Collection Sources:

      Collection Purpose:
      (see definitions below)

      We May Share With:

      Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

      • Prospective clients
      • Our clients or individuals associated with our clients or adverse parties
      • Third parties such as credit rating agencies (e.g., credit history to perform credit checks), legal directories (e.g., records of individuals related or adverse to our clients to conduct conflict checks)
      • Public sources (e.g., records of litigation from public sources.)
      • Providing services
      • Auditing and compliance
      • Quality/Safety maintenance
      • Service providers (e.g., credit vetting agencies and background check firms)
      • Other members of the SPB group
      • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others)
      • Local Counsel, co-counsel, opposing counsel, courts and arbitration panels
      • Other third parties as necessary to provide legal services to our clients

      Other records, including personal information that identifies, relates to, describes, or is capable of being associated with you protected by Cal. Civ. Code 1798.80(e) and not already described under one of the other categories listed in this table

      • Prospective clients
      • Our clients or individuals associated with our clients or adverse parties
      • Public sources (e.g., public registers and publicly available internet sites)
      • Third parties (e.g., credit vetting agencies and third-party subscription services such as legal directories)
      • Providing services
      • Auditing and compliance
      • Security
      • Service providers (e.g., document review service providers)
      • Other members of the SPB group
      • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others)
      • Local counsel, co-counsel, opposing counsel, courts and arbitration panels
      • Other third parties as necessary to provide legal services to our clients

      Characteristics of protected classifications under California or Federal Law, such as age (if 40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, gender (including gender, gender identity, gender expression), pregnancy or childbirth and related medical conditions, sexual orientation, veteran or military status, genetic information (including familial genetic information)

      • Our clients or individuals associated with our clients or adverse parties where relevant to the issues involved (e.g., in connection with immigration proceedings or labor and employment matters)
      • Providing services
      • Service providers (e.g., data room administrators, document review service providers)
      • Other members of the SPB group
      • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others)
      • Local counsel, co-counsel, opposing counsel, courts and arbitration panels
      • Other third parties as necessary to provide legal services to our clients

      Commercial information, including records of personal property, product or services purchased, obtained or considered from us, or other purchasing or consumer history related to our services.

      • Our clients or individuals associated with our clients or adverse parties (e.g., bank account details and related data necessary for us to make or receive payments)
      • Third parties (e.g., third-party marketing and event management platforms and other solutions, which may collect data on our behalf as service providers)
      • Providing services
      • Auditing and compliance
      • Quality/Safety maintenance
      • Service providers (e.g., e-billing and matter management platform service providers)
      • Other members of the SPB group
      • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others)
      • Local counsel, co-counsel, opposing counsel, courts and arbitration panels
      • Other third parties as necessary to provide legal services to our clients

      Biometric information, such as individual physiological, biological, or behavioral characteristics that can be used alone or in combination with others, to establish an individual’s identity; e.g., hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data

      • Our clients or individuals associated with our clients or adverse parties where relevant to the legal issues involved (e.g., in connection with health and safety regulations or labor and employment matters).
      • Providing services
      • Service providers (e.g., data room administrators, document review service providers)
      • Other members of the SPB group
      • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others)
      • Local counsel, co-counsel, opposing counsel, courts and arbitration panels
      • Other third parties as necessary to provide legal services to our clients

      Internet or other electronic network activity information, including, but not limited to, browsing history, search history and information regarding a consumer’s interaction with an internet website, application or advertisement (excluding identifiers as described in “identifier” category above e.g. IP Addresses)

      • You when you visit our site or interact with us online. For more information see our Global Website Privacy Notice and Cookie Notice.
      • Our clients or individuals associated with our clients or adverse parties where relevant to the legal issues involved (e.g., as part of discovery in a case we are litigating)
      • Providing services
      • Security
      • Quality/Safety maintenance
      • Repairing errors
      • Short-term use
      • Service providers (e.g., IT service providers, data room administrators)
      • Other members of the SPB group
      • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others)
      • Local counsel, co-counsel, opposing counsel, courts and arbitration panels
      • Other third parties as necessary to provide legal services to our clients

      Geolocation (i.e., approximate location of a device or equipment based on geographical coordinates and measurements)

      • Our clients or individuals associated with our clients or adverse parties where relevant to the legal issues involved (e.g., as part of discovery in a case we are litigating)
      • Providing services
      • Service providers (e.g., document review service providers)
      • Other members of the SPB group
      • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others)
      • Local counsel, co-counsel, opposing counsel, courts and arbitration panels
      • Other third parties as necessary to provide legal services to our clients

      Audio, electronic, visual, thermal, olfactory, or similar information (e.g. video recordings)

      • Prospective clients (e.g., we may record a conference call or an event where you participate).
      • Our clients or individuals associated with our clients or adverse parties where relevant to the legal issues involved (e.g., as part of discovery in a case we are litigating).
      • Providing services
      • Auditing and compliance
      • Quality/Safety maintenance
      • Service providers (e.g., telecommunications operators)
      • Other members of the SPB group
      • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others)
      • Local counsel, co-counsel, opposing counsel, courts and arbitration panels
      • Other third parties as necessary to provide legal services to our clients

      Professional or employment-related information (e.g., business contact details, title or position, company affiliation, company address)

      • Prospective clients
      • Our clients or individuals associated with our clients or adverse parties (e.g., your business contact information when you request copies of our newsletters, client alerts or blogs, or register to attend seminars, online webinars and similar events offered by us)
      • Third parties (e.g., business contact details of our vendor’s individual account representatives)
      • Providing services
      • Auditing and compliance
      • Security
      • Service providers (e.g., marketing and event management platforms)
      • Other members of the SPB group
      • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others)
      • Local counsel, co-counsel, opposing counsel, courts and arbitration panels
      • Other third parties as necessary to provide legal services to our clients

      Educational records (i.e., files, documents, and other materials which (i) contain information directly related to a student; and (ii) are maintained by an educational agency or institution or by a person acting for such agency or institution)

      • Our clients or individuals associated with our clients or adverse parties where relevant to the legal issues involved (e.g., in connection with litigation matters involving an educational institution)
      • Providing services
      • Service providers (e.g., data room administrators, document review service providers)
      • Other members of the SPB group
      • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others)
      • Local counsel, co-counsel, opposing counsel, courts and arbitration panels
      • Other third parties as necessary to provide legal services to our clients

      Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

      We may draw inferences from information that we have received (such as, we may draw inferences from evidence received from or on behalf of our clients in legal proceedings; we may conclude that you are interested in receiving updates from us on developments in particular areas if you have attended firm-sponsored events; or we may conclude that applicable laws prohibit us from engaging with a prospective client based on information obtain through our Know-Your-Client compliance procedures)

      • Providing services
      • Auditing and compliance
      • Service providers (e.g., IT service providers)
      • Other members of the SPB group
      • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others)
      • Local counsel, co-counsel, opposing counsel, courts and arbitration panels
      • Other third parties as necessary to provide legal services to our clients

       

      Description of purposes

      • Providing services: Providing legal services to our clients under the terms of our engagement, including communications in relation to our provision of legal services; verifying client information and evaluating the creditworthiness of potential clients; receiving or paying out transaction completion monies or other transaction-related funds such as disbursements; paying court fees; invoicing our clients and receiving payment; communicating and conducting business with our vendors; and providing advertising or marketing services.
      • Auditing and compliance: Auditing and compliance related to interactions with clients including compliance with Know-Your-Customer legislation such as laws on anti-money laundering (“AML”), anti-terrorism, anti-bribery, anti-corruption, international sanctions.
      • Security: Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
      • Repairing errors: Debugging to identify and repair errors that impair existing intended functionality.
      • Short-term use: Short-term use without disclosing to third parties.
      • Quality/safety maintenance: Maintaining the quality and safety of our services, including undertaking activities to verify or maintain the quality or safety of a service or device and to improve, upgrade, or enhance the service or device.

       

    3. Your rights
    4. If you are a resident of the State of California, you have the following rights in relation to the categories of personal information described above, as provided under California law:

      • Right to know: You have the right to request that we disclose to you: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information collected or shared; (3) the purposes for which we collected or shared your personal information; (4) the categories of third parties to whom we have disclosed personal information about you. Prior to disclosing the information, we are required to verify that the individual making the request is indeed the individual to whom the information relates. Once we receive a verifiable request, we must disclose to you the information requested for the twelve months preceding your request. The law gives us 45 days to provide the information to you. Information on how to submit a request to us is provided below. Please note that if the information you are requesting reveals details directly or indirectly about another person, we will need to seek consent of that person before we can disclose that information to you. In certain circumstances, where disclosure of part or all of the information you have requested would adversely affect the rights of others, we may not be able to disclose the information to you, in which case we will inform you promptly and give you the reasons for our decision. Please further note that information covered by an evidentiary privilege recognized under California Law (including attorney-client communications privilege and work product privilege) cannot be disclosed.
      • Right to delete: You have the right to request deletion of the personal information about you that we have received from you. Prior to deleting the information, we are required to verify that the individual making the request is indeed the individual to whom the information relates. Once we receive a verifiable request, the law gives us 45 days to respond. As a general rule, we must delete the information at your request and require our vendors to do so as well. However, the law provides certain exceptions that allow us to retain the information even if you have requested that it be deleted. If we do not erase the information pursuant to one of those exceptions we must inform you of that fact and of any rights you may have to appeal our decision. Information on how to submit a request to us is provided below.
      • Right to opt-out of sales (opt-in for minors): Not applicable since, as indicated above, we do not sell your personal information.
      • Right against discrimination: California residents have the right to not be discriminated against for exercising their rights under the CCPA. 

      Please note that your CCPA rights are subject to certain conditions and exceptions, such as limitations on your right to know based on our compliance with evidentiary privileges recognized under California Law (including attorney-client privilege) and exceptions to your right to erase under Cal. Civ. Code Sec. 1798.105(d).

       

    5. How to submit a request
    6. In order to exercise your right to know or your right to delete, please email us at DataSubjectRequests@squirepb.com and include “Request under CCPA” in the subject line.
      Note: An online form to submit your CCPA requests will be made available soon.

      Please include in your request:

      • Your full name and address
      • Former names (if applicable)
      • Former addresses (including dates of change) (if applicable)
      • Date of birth
      • Contact information (Phone number or email address)
      • Your relationship to us (e.g. former or existing client)

      Please indicate if you are acting as a representative of another individual. If that is the case, include the identification information both for yourself and for the individual you represent and a copy of the written authorization you have received.

      To ensure that we are releasing data to the right person, please provide sufficient proof of identity to confirm that you are entitled to the information requested. The nature of the identification required will depend on the nature of your request and your relationship to us. Any identification documents transmitted to us should be transmitted through secure means of communication and should be photocopies or scanned images (do not send the originals).

      To help us respond to your request please identify your relationship to us in your request (e.g., former client, existing client).

      We will endeavor to respond promptly and in any event within the period permitted by law described above.

      As a general rule, we are not allowed to charge you a fee when you exercise your rights, but if your requests are manifestly unfounded or excessive, we are allowed to charge a reasonable fee or refuse to act on the request.

       

    7. How can individuals with disabilities access these disclosures?
    8. Individuals who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this notice.

       

    9. How to contact us
    10. For general questions about this Policy, please contact us in one of the following ways:

      By mail:
      Assistant General Counsel - CCPA
      Squire Patton Boggs (US) LLP
      2550 M Street, NW
      Washington, DC 20037

      Or

      By email:
      Privacy@squirepb.com

      Or

      By phone:
      [A toll free number will be made available soon.]