WEBSITE PRIVACY STATEMENT AND SUMMARY

Brown Rudnick is committed to respecting and protecting your privacy. This privacy notice (together with any other documents referred to in it) sets out how we look after your personal data when you visit our website at www.brownrudnick.com, and tells you about your privacy rights and how certain laws may apply to you. If you have any queries about this policy or how we use your personal information, please contact us at dataprivacy@brownrudnick.com.

Your privacy is important to us. To protect your privacy and help you to make informed choices, we provide this notice explaining our information practices, how you can choose how we use your data, and your rights in relation to your data. In brief, we will only use your information:

  • • to optimize our website performance; or
  • • where you have consented to us doing so.

This is explained in more detail below.

Contents
  1. About us
  2. This privacy notice
  3. What personal data do we collect via the site?
  4. How we collect personal data
  5. How and why we use personal data
  6. How we share personal data
  7. International transfers
  8. Data security
  9. How long we keep personal data
  10. Third party links
  11. Your rights
  12. Changes to this policy or your data
  13. California Consumer Privacy Act


About Us

This website www.brownrudnick.com (our "site") is operated by Brown Rudnick LLP ("Brown Rudnick", also referred to in this notice as "the firm", "we", "us" and "our").

Brown Rudnick LLP is a limited liability partnership authorized and regulated by the Solicitors Regulation Authority, the Paris Bar, and registered in England & Wales with company number OC3000611 ("BR UK").

It is affiliated with Brown Rudnick LLP a limited liability partnership organized under the laws of the Commonwealth of Massachusetts (U.S.A.) ("BR-US"). BR-UK and BR-US are data controllers, and BR-UK is registered with the UK Information Commissioner's Office under registration number ZA073920.

The offices of BR-UK and BR-US are set out below:

BR-US

BR-UK

BOSTON

Brown Rudnick LLP

One Financial Center

Boston

MA 02111

Tel: +1 617 856 8200

LONDON

Brown Rudnick LLP

8 Clifford Street

London

W1S 2LQ

Tel: +44 (0)20 7851 6000

PROVIDENCE

Brown Rudnick LLP

10 Memorial Boulevard Providence, RI 02903

United States

Tel: +1.401.276.2600

PARIS

Brown Rudnick LLP

1, rue François 1er Paris 75008

France

Tel: +33(0)1 8556 8220

HARTFORD

Brown Rudnick LLP

185 Asylum Street Hartford, CT 06103

United States

Tel: +1.860.509.6500

WASHINGTON

Brown Rudnick LLP

601 Thirteenth Street NW Suite 600 Washington, DC 20005

United States

Tel: +1.202.536.1700

NEW YORK

Brown Rudnick LLP

7 Times Square New York, NY 10036

United States

Tel: +1.212.209.4800

ORANGE COUNTY

Brown Rudnick LLP

2211 Michelson Drive 7th Floor Irvine, CA 92612

United States

Tel:  +1.949.752.7100

You can contact us about any queries you have regarding this privacy notice at either our postal addresses above, or at GDPRcommunications@brownrudnick.com.


This privacy notice

This privacy notice describes how we collect and use information collected through your use of this site. Please read this privacy notice carefully.

This site is not intended to collect data of children under the age of 18.


What personal data do we collect via the site?

We collect different information depending on how you use the site and how you interact with us. 'Personal data' means any data which can be associated with you as an individual, either directly or indirectly.

The personal data we collect via the site may include:

  • • Identity information, such as your name, organization name and position.
  • • Contact data, such as your address and email and telephone details.
  • • Technical data, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the site.
  • • Usage data, which includes information about how you use the site, and any communications we may receive from you.
  • • Marketing and communications data, including your preferences in receiving marketing and other communications from us.

Our site is not intended for storing or transmitting 'special categories' of personal data, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, or criminal convictions and offences.


How we collect personal data

Different personal data is collected in different ways.

a) Personal data you provide to us

When you sign up to one of our mailing lists, you will provide us with your identity, contact information, IP address, and your marketing and communications preferences. This data is collected via direct solicitation as well as by the use of email tracking codes embedded in our marketing emails.  We do not embed tracking codes in our regular daily email correspondence. You will also provide us with personal data when you correspond with us, and if you apply for a position with the firm.

b) Personal data we collect automatically As you use the site, wwe will collect certain technical data including your browser type, the Internet Protocol (IP) address used to connect your computer to the internet, and your usage habits, patterns and preferences. We collect this data using cookies, beacons and similar technologies. We use Google Analytics to help us analyse user habits while visiting our site. The data gathered from cookies may be transmitted to Google servers in the United States. We employ IP address anonymization to ensure that there is no direct reporting of individual user IPs as part of this process. The information will be used by Google only for the purpose of evaluating website use, creating website activity reports, and other services relating to website activity and internet usage on behalf of Brown Rudnick. The IP address that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google.

We use the following cookies:

Cookie name What it is used for
Google Analytics website analytics and visitor tracking
Wordfence website security and access control
YouTube user viewing preferences

You can remove cookies from your computer through the settings on your browser, but be aware that this may impact your ability to make use of some features on this and other web sites. Management of cookie settings varies from one browser to another. The "Help" menu of your web browser will provide full instructions. For your convenience, you can follow these links for details on how to manage cookies in each of the major web browsers:


How and why we use personal data

We will only use your information where:

a) You have given us permission to do so If you sign up to our mailing lists, we will send you updates and marketing information that you have consented to receive. Likewise, we may need your contact, identity, technical and/or usage information to respond to a question you have asked us, or to register you for an event that you have requested to attend.

If you apply for a position with the firm, we treat any information you send to us as strictly private and confidential and will only use it in relation to application you have submitted.

b) We have a legitimate interest (reasonable business purpose) for doing so We will use your information for our legitimate business reasons where our doing so will not unduly affect your rights.

We will use your identity , contact and usage information to keep our records up to date.

We will use your technical information to:

  • • provide and make improvements to the site, system maintenance, support, reporting and hosting of data, and troubleshooting;
  • • ensure that the site is secure;
  • • analyse how users interact with the site; and
  • • address any issues you may experience with the site.

We may also use any or all of the information above to administer and manage our business in general. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should therefore stop processing your data, please let us know.

c) We need to comply with a legal or regulatory obligation In certain circumstances, we may need to retain or use your data to comply with regulations and/or the law.


How we share personal data

Personal information collected via this site is shared between BR-UK and BR-US.

We may share your information with our trusted third party service providers (including information technology providers such as website and mailing list hosts). When we share your information with our service providers, we will ensure that your data is kept secure and used only in accordance with this notice.

On rare occasions, we may share personal data when we believe it is necessary to comply with the law, regulation or legal request (including a court order or government inquiry); to enforce or apply our terms of use or other agreements; in the context of a firm reorganisation or restructuring exercise; or to protect the rights, property, or safety of the firm, our employees, our users, or others.


International transfers

This site is hosted on servers located in the US.

When we transfer your data outside of the EEA to a country which the European Commission does not deem to have adequate data privacy laws, we will ensure that such transfer(s) are in accordance with applicable data privacy laws. In respect of transfers between BR-UK and BR-US, we have executed a data transfer agreement giving effect to the Model Clauses pursuant to Commission decision 2004/915/EC.

In respect of transfers outside of the firm, we either implement the Model Clauses pursuant to Commission decision 2004/915/EC or 2010/87/EU (as appropriate) with the recipient of your personal data; and/or ensure that the recipient of your data is registered with the EU-US Privacy Shield.

You can obtain further information in this respect (including a copy of the Model Clauses) by contacting us.


Data security

The safety of your personal data is important to us, and we use various technical and organization measures to ensure that your data is secure.

Brown Rudnick employs encryption, data security, and intrusion prevention technologies to protect and secure all personal information in our possession. Our data environment is monitored 24/7 for malicious activity and/or anomalous behavior either of which triggers our incidence response. However, the transmission of information via the Internet is not completely secure. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee the security of your data.


How long we keep personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


Third party links

This site may contain links to other sites whose information practices may be different than ours. Please consult all third party sites' privacy notices as we have no control over information that is submitted to, or collected by, third parties.


Your rights

You have certain rights over your personal data. If the GDPR applies, you may:

  • • require us to rectify the personal data we hold about you, where that data is incorrect;
  • • require that we restrict the processing of your personal information in certain circumstances;
  • • request access to the personal data that we hold about you;
  • • require that, in certain circumstances, we delete the personal information we hold about you;
  • • require that we provide you with the information that we hold about you in a structured, commonly used and machine-readable format; and/or
  • • withdraw your consent to our using your data for marketing purposes at any time.

You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”), which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, be grateful if you would contact us in the first instance so we can endeavor to deal with your concerns direct.

If you wish to exercise any of these rights, please contact us at GDPRcommunications@brownrudnick.com.

To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.


Changes to this policy or your data

We may amend or modify this privacy notice from time to time. We will post any revised notice on this site. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


California Consumer Privacy Act

YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“California Privacy Notice”) supplements Brown Rudnick’s Website Privacy Statement and Summary. Brown Rudnick has adopted this notice to comply with the California Consumer Privacy Act (“CCPA”) and other California privacy laws. It applies only to visitors, users, clients, and other persons if they are California consumers, as defined in the CCPA. Any terms defined in the CCPA have the same meaning when used in this California Privacy Notice.

Please note that Brown Rudnick has not sold and does not sell your personal information, as those terms are defined in the CCPA.

Notice of information we collect Brown Rudnick collects personal information through our website(s), at our offices, and through the services that we provide. All of the categories of personal information that we collect about you (as set out in the table below) come from the following sources:

  • • You, including through your use of our services
  • • Your computer or other device, automatically, when you interact with our website(s) or applications
  • • Our affiliated partnership(s)
  • • Third parties, such as our clients

In particular, we have collected the following categories of personal information from California consumers within the last twelve (12) months:

Category Collected Purpose
A. Identifiers, such as such as name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name. Yes, such information is included in data provided by clients, suppliers, job applicants, and website users. It may also be collected from visitors to our office locations. To provide our services to clients. To respond to inquiries. To market to alumni of the firm and current and prospective clients. To process job applications and administer employment of staff. For security and fraud prevention purposes. To comply with legal requirements.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, contact information, education, employment, employment history, and financial information such as bank account number). Yes, such information may be included in data provided by clients or suppliers, and is collected from job applicants. To provide our services to clients. To respond to inquiries. To market to alumni of the firm and current and prospective clients. To process job applications and administer employment of staff. For security and fraud prevention purposes. To comply with legal requirements.
C. Protected Classification characteristics under California or federal law, such as age, citizenship, gender, marital status, physical illness, mental illness or disabilities, and veteran status. Yes, if voluntarily provided by job applicants or suppliers in connection with reporting to Equal Employment Opportunity Commission. Such information may also be included in client data if related to services provided by us. To comply with legal requirements.
D. Commercial information, such as records of personal property or transactions. Yes, such information may be included in data provided by clients or suppliers. To provide our services to clients.
E. Biometric information. NO
F. Internet or other similar network activity. Yes, such information is automatically collected from users of our website(s) or applications. Such information may also be contained in data supplied by clients. To provide, enhance and improve our website. To provide services to our clients. For marketing purposes.
G. Geolocation data, such as device location and IP location. Yes, such information is automatically collected from users of our website(s) or applications To provide, enhance and improve our website. To provide services to our clients. For marketing purposes.
H. Audio, electronic, visual, thermal, olfactory, or similar information, such as images and audio, video or call recordings created in the course of our communications and engagement. The buildings where our offices are located may have security cameras that take video for security purposes. We may also take photographs of staff, clients, and others with their permission. Clients and others may provide such information in connection with their communications with us, such as by leaving voicemail messages or participating in videoconferences. To provide our services to clients. For security and fraud prevention. For marketing purposes.
I. Professional or employment-related information, such as current or past job history. Yes, from job applicants and staff. Such information may also be included in data obtained from clients or others in the course of providing services. To process and evaluate job applicants. To provide our services to clients.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Yes, if job applicants provide school transcripts and records. Such information may also be included in data obtained from clients or others in the course of providing services. To process and evaluate job applicants. To provide our services to clients.
K. Inferences drawn from other personal information. Yes To provide our services to clients. For marketing purposes.

Your Rights Under the CCPA.

If you are a California consumer, you have the right to request that Brown Rudnick disclose to you:

  • (i) the categories of personal information that we collected about you and the categories of sources from which we collected such information;
  • (ii) the specific pieces of personal information we collected about you;
  • (iii) the business or commercial purpose for collecting personal information about you; and
  • (iv) the categories of personal information about you that we shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such information in the preceding 12 months.

California consumers also have the right to request that we delete personal information we collected from you, subject to certain exceptions.

To make such a request, contact us at dataprivacy@brownrudnick.com and indicate in the subject line of your message that you are making a CCPA request. You may be required to submit proof of your identity for these requests to be processed as a verifiable consumer request. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf, subject to proof of identity and authorization.

We will respond to your request consistent with the CCPA, which does not apply to certain information, such as information made available from government records, certain data subject to the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA) and certain other laws. Please note that we are only required to respond to two such requests per consumer each year.

You also have the right to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA. Brown Rudnick does not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information.

Changes to this California Privacy Notice.

Brown Rudnick may update its CCPA policies and practices from time to time. Any changes will be posted on this website at www.brownrudnick.com/privacy-policy with an updated revision date.

This privacy statement was last updated on January 03, 2020.


© Brown Rudnick LLP 2020