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California privacy notice

Last Updated: 1 July 2020

Freshfields Bruckhaus Deringer, (the “firm”, “we”, “us”, or “our”) takes its data protection and information security responsibilities very seriously. This California Privacy Notice supplements the information provided in our Privacy Notice and applies solely to natural persons who are residents of the State of California, United States of America, as defined by the California Consumer Privacy Act of 2018, as amended from time to time (CCPA).

PERSONAL INFORMATION WE COLLECT

Our Privacy Notice describes the categories of personal data that we may collect, the categories of sources from which we may collect personal data and the business purpose for such collection, by processing activity. Please review the “Description and purposes of the processing” section for the relevant processing activity identified under headings 2. to 7. of our Privacy Notice. To learn about the categories of personal data that we may disclose for a business purpose and the categories of third parties to whom we may have shared personal data, please review the “Recipients” description for the relevant processing activity identified under headings 2. to 7. of our Privacy Notice.

For the purpose of this California Privacy Notice only, “personal data” as used herein and in the Privacy Notice, shall mean “personal information” as defined in the CCPA.

YOUR RIGHTS

If you are a State of California resident, you may make certain requests regarding your personal data in our possession. We will fulfill each of these requests to the extent required by Applicable Laws, including the CCPA.

Your California rights

What do they mean for you?

The right to know

You have the right to know the categories of your personal data that a business has sold or shared with a third party for business purposes.

The right to access specific categories of information

You have the right to obtain a copy of the specific pieces of your personal data that a business holds about you.

The right to delete

Subject to certain exceptions, you have the right to request a business to delete your personal data.

The right to opt-out

You have the right to request that a business stop selling your personal data.

The right of non-discrimination

You have the right not to be discriminated against for exercising your CCPA rights.

More information on each of these requests is provided below.

Right to know

You have the right to request that we disclose the following to you: (1) the categories of personal data that we have collected about you; (2) the categories of sources from which we collect your personal data; (3) the business or commercial purpose for collecting or selling (if applicable) your personal data; and (4) the categories of third parties with whom we have shared your personal data. 

Right to Access

You have the right to obtain a copy of the specific pieces of personal data that we hold about you. If you make such a request, we will provide you with a copy of your personal data as permitted by the CCPA. Please be aware that the information provided may be limited to personal data for the last 12 months.

Right to Deletion

In certain circumstances, you have the right to request that we delete your personal data. Upon verifying your request, we will delete, deidentify, or aggregate covered personal data from our records, and instruct those service providers with whom we have shared your personal data to do the same. Please note that deletion requests are subject to certain limitations, for example, we may retain personal data as permitted by law, such as for tax or other record keeping purposes, and consistent with our professional responsibility obligations.

Right to Opt-Out of the Sale of Personal Information

We do not sell personal data within the meaning of the CCPA.

Right to not be Discriminated Against

If you exercise your CCPA rights, we will not deny you services, charge you different prices or rates, or provide you with a different quality or level of service. If you ask us to delete your data, however, please be aware that it may impact our ability to provide our services to you, including our legal advisory services.

EXERCISING YOUR RIGHTS

You may exercise any of your CCPA rights by emailing us at dataprivacy@freshfields.com or contacting us by telephone at +44 20 7716 4000.

Before we respond to a communication or request, we may take certain steps to verify the requestor’s identity and the authenticity of a request. Where we have reasonable doubts concerning the identity of the person making the request, or the authenticity of a request, we may request such additional information as we deem necessary to satisfy ourselves of their identity and authenticity of their request.

If we cannot satisfactorily verify the identity of a requestor and the authenticity of a request, we will not be able to take any action pursuant to the request.

In order to facilitate this process and to enable us to assist you, when you make a request to us, please specify the type of request you are making, and provide us with your name, e-mail and telephone number, and satisfactory evidence of your identity and residential address. We will use your information only to verify your request by attempting to match your information to our internal records. If you are a client, please also indicate the name(s) of the Freshfields Bruckhaus Deringer attorney(s) with whom you have worked, and we will seek to verify your information with the relevant attorney(s).

You may authorize another person (your “agent”) to submit a request on your behalf. You must provide your agent with a signed and dated permission, stating that your agent is authorized to exercise your CCPA rights and to submit a request to Freshfields Bruckhaus Deringer on your behalf. Your agent should submit a copy of your authorization to us at the time the request is made. Please note that we may contact you directly to verify your identity and to confirm that your agent has been properly authorized.

We will aim to complete all requests within 45 days of receipt. If it will take longer than that, we will let you know. Please note that if you are not a client, we will not provide any information from client files, because that information is confidential and/or covered by the attorney-client privilege.

There is generally no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested, or (b) refuse to act on the request.

DO NOT TRACK

We do not monitor or follow “Do Not Track” (DNT) signals because there is no standard interpretation or practice for DNT signals. We handle all personal data consistent with the Privacy Notice and, as applicable, this California Privacy Notice.

UPDATES TO THIS POLICY

We may periodically update this California Privacy Notice. Please reference the “Last Updated” date at the top of this page to see when it was last revised and posted. Any changes to this California Privacy Notice will become effective when posted.

CONTACTING US

If you have questions about our privacy practices or this California Privacy Notice, please contact us at:

The Data Protection Officer
(Legal Department)
Freshfields Bruckhaus Deringer LLP
65 Fleet Street, London EC4Y 1HS
Telephone: +44 20 7716 4000
Email: dataprivacy@freshfields.com