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California Privacy Notice

Last Updated: 17 November 2021

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).

CATEGORIES OF PERSONAL INFORMATION COLLECTED AND DISCLOSED

The following table identifies the categories of personal information, as listed in the CCPA, that we plan to collect and that we have collected and disclosed for business purposes during the preceding 12 months:

Category

Collected?

Disclosed?

A. Identifiers such as name, postal address, online identifier, IP address, and email address 

Yes

Yes, to affiliates, service providers, and other vendors

B. Personal information as defined in the California customer records law, such as name, signature, and contact information

Yes

Yes, to affiliates, service providers, and other vendors

C. Characteristics of protected classifications under California or federal law

Yes

Yes, to affiliates, service providers, and other vendors

D. Commercial information, including records of services obtained, financial details and payment information.

Yes

Yes, to affiliates, service providers, and other vendors

E. Biometric information

No

No

F. Internet or other electronic network activity information, such as browsing history on our website and other interactions with our website, applications, and email communications.

Yes

Yes, to affiliates, service providers, and other vendors

G. Geolocation data, such as approximate location derived from IP address

Yes

Yes, to affiliates, service providers, and other vendors

H. Audio, electronic, visual, or similar information, such as office security footage or recordings of select events, conferences, or meetings

Yes

Yes, to affiliates, service providers, and other vendors

I. Professional or employment-related information

Yes

No

J. Education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec 1232g; 34 C.F.R. Part 99)

Yes

Yes, to affiliates, service providers, and other vendors

K. Inferences drawn from any of the personal information listed above to create a profile of an individual’s preferences, characteristics, behavior, intelligence, or abilities.

No

Yes, to affiliates, service providers, and other vendors

We collect this personal information from the following types of sources:  our clients, public registers and databases, court and public records, communication with third parties and other advisors involved in client matters, commercial databases, and event sponsors.  As described in further detail in our Privacy Notice, we use this personal information for our business and operational purposes, such as providing legal services to our clients; complying with our applicable legal and regulatory obligations in the jurisdictions where we practice; performing business functions (e.g., record keeping, accounting, billing and tax compliance, auditing, business development, research, and data analysis); administering, optimizing, and protecting our website and other Solutions (as defined in our Privacy Notice); communicating with clients and prospective clients; and exercising and defending legal claims.

We do not “sell,” and have not “sold,” personal information in the preceding 12 months, within the meaning of “sale” under the CCPA. For example, and without limiting the foregoing, we do not sell personal information of minors under the age of 16.

CCPA RIGHTS

If you are a State of California resident, you may make certain requests under the CCPA, as described below:

Right to Know

You may request the following information covering the 12 months preceding our receipt of your request: (1) the categories of personal information we collected about you, and the categories of sources from which we collected your personal information; (2) the specific pieces of personal information we collected about you; (3) the business or commercial purposes for collecting personal information about you; (4) the categories of personal information that we disclosed about you, and the categories of third parties to whom the personal information was disclosed; and (5) the business or commercial purpose for our collection of your personal information.

Right to Deletion

You may request that we delete your personal information. Please note that deletion requests are subject to certain limitations; for example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, and consistent with our professional responsibility obligations.

Right to Non-Discrimination

If you exercise your CCPA rights, we will not unlawfully 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 personal information, 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 1 (833) 699-1579.

Before we respond to a communication or request, we may take certain steps to verify the requestor’s identity and/or the authenticity of their 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 their request, we may not be able to take action pursuant to the request.

In order to facilitate this process and to enable us to assist you, please ensure that you include in your request the type of request you are making; 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. We may ask your agent to provide proof of their status as an authorized agent by submitting (1) proof of the agent’s registration with the California Secretary of State to conduct business in California; and/or (2) a power of attorney that you have provided to the agent pursuant to Probate Code sections 4000 to 4465. Please note that we may also contact you directly to verify your identity and to confirm that your agent has been properly authorized, where we have not received such a power of attorney authorizing the agent to act on your behalf.

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 CCPA 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 based on 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.

UPDATES TO THIS NOTICE

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 dataprivacy@freshfields.com.