Privacy

Introduction

1. Definitions
2. Responsibility for Your Personal Information
3. Categories of Individuals About Whom We Process Personal Information
4. Categories and Sources of Personal Information Processed
5. Sharing of Personal Information
6. Cross-Border Transfers of Personal Information
7. Data Retention Period
8. Updating Personal Information about You
9. Security of Personal Information
10. Policy for Confidentiality of Social Security Numbers
11. Personal Information about Others that You Provide to Us
12. U.S. State Law Privacy Rights
13. Changes to the Global Privacy Policy
14. How to Contact Us

Appendix 1: Summary of Privacy Rights under the GDPR (Regulation (EU) 2016/679) and the Data Protection Act 2018
Appendix 2: Privacy Policy for California Residents under the  California Consumer Privacy Act of 2018
Appendix 3: HIPAA Business Associate Privacy Policy
Appendix 4: Privacy Notice at Collection for California Residents
Appendix 5: Notice of Compliance with Connecticut Act Concerning the Confidentiality of Social Security Numbers
Appendix 6: Website Cookies Policy

Introduction

Locke Lord LLP and Locke Lord (UK) LLP (jointly “Locke Lord,” the “Firm” or “we”) understand how important your privacy and the protection of your personal data and information is to you. The following Global Privacy Policy explains how we use and protect personal data and information that we collect, store, transfer, and otherwise process.

If (i) our processing of your personal data is subject to the GDPR (as hereinafter defined) or (ii) you are a resident of California, and your personal information is subject to the privacy laws and regulations of California, the additional provisions of each of Appendix 1 (the “GDPR Privacy Rights Summary”) or Appendix 2 (the “CCPA Privacy Policy”) shall also apply, respectively.  To the extent the provisions of this Global Privacy Policy conflict or are inconsistent with the ‎provisions set out in the applicable Appendix, the provisions in that Appendix shall control.‎

If you have any questions regarding this Global Privacy Policy or do not feel that your concerns have been addressed, please direct your questions through the “How to Contact Us” section at the end of this Privacy Policy.

1. Definitions

“CCPA” means the California Consumer Privacy Act of 2018‎ and any regulations issued thereunder, as they may be amended from time to time, including by the California Privacy Rights Act of 2020.

“GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April ‎‎2016 on the protection of natural persons with regard to the Processing of personal data and on ‎the free movement of such data, and repealing Directive 95/46/EC and any law made under or ‎as a result of it and/or, as applicable, the UK GDPR as defined in The Data Protection, Privacy ‎and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019, including the ‎Data Protection Act 2018 and any law made under or as a result of it.‎

“Global Privacy Policy” means this Global Privacy Policy, as supplemented as applicable by the provisions set forth in ‎the GDPR Privacy Rights Summary, the CCPA Privacy Policy, the HIPAA Business Associate ‎Privacy Policy,‎ the Connecticut Policy,  and the Website Cookies Policy and which are set out ‎in Appendices 1-3 and 5-6, respectively.‎

“HIPAA” means the Health Insurance Portability and Accountability Act of 1996, as amended by the HITECH Act, and including all related regulations.

“HITECH Act” means the Health Information Technology for Economic and Clinical Health Act contained in Public Law 111-5, as amended.

“Personal Information” as used in this Global Privacy Policy means (i) “personal data” as defined in the GDPR and means any data that relates to an identified or identifiable natural person and (ii) “personal information” as defined under the CCPA, and means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

“Processing” means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction and "processed", "processing" and similar terms shall be interpreted accordingly.‎

“Protected Health Information” has the meaning under HIPAA.

“you” means any individual person identified or identifiable by Personal Information, as relevant for the context in which it is used in the Global Privacy Policy.

2. Responsibility for Your Personal Information

Locke Lord is responsible for its Processing of your Personal Information under this Global Privacy Policy ‎and is considered the "data controller" under the GDPR (as defined therein).  Locke Lord consists of the following two legal entities:

• Locke Lord LLP, 2200 Ross Avenue, Suite 2800, Dallas, Texas  75201, United States, T: +1-214-740-8000, and
• Locke Lord (UK) LLP, 201 Bishopsgate, London, EC2M 3AB DX 567, United Kingdom; T: +44 (0) 20 7861-9000

Unless stated otherwise, and generally speaking, Locke Lord LLP and Locke Lord (UK) LLP are ‎to be considered joint data controllers (also as defined under the GDPR).  ‎

You may contact the Firm regarding any questions or complaints as specified in the “How to Contact Us” section below.

3. Categories of Individuals About Whom We Process Personal Information

We process Personal Information from or about the following categories of individuals:

• Firm employees, partners, contractors, consultants, paid interns, job applicants, and temporary employees (“HR Data”);
• Current or former participants in the Firm’s retirement and/or welfare benefit plans or their beneficiaries (“Benefit Plan Data”);
• Users of the Firm Website (“Website Data”);
• Individuals who are, or are associated with, Firm clients, vendors, or other business contacts with whom we interact or seek to establish a relationship with (“Contact Data”);
• Individuals identified in data provided by or on behalf of clients in connection with representation by the Firm (“Client Sourced Data”); and
• Individuals who are, or are associated with, adverse parties, witnesses, or other third parties relevant to our legal representation of clients, such as information obtained during investigations or discovery in the context of litigation, arbitration, negotiations, or other aspects of client representation (“Other Party Data”)  
    

4. Categories and Sources of Personal Information Processed

We may collect and store various types of Personal Information about you, depending on the ‎category in which you fall and the reason for which the Personal Information is processed. The ‎following is a general summary of the Personal Information about you that we may process in ‎each category, the sources of such Personal Information, and the purposes of Processing.  If you are resident in the UK or EU please also refer to Appendix 1.‎

4.1 HR Data

When you apply for employment or engagement with the Firm (whether as an employee, partner, contractor, consultant, paid intern or temporary employee), when we evaluate your employment application and related materials (e.g., the results of pre-employment screenings), and thereafter throughout the course of your employment, contract or consulting arrangement, we obtain HR Data about you.

Categories of HR Data: The HR Data we collect and process varies by the roles and responsibilities that you undertake with the Firm, the location where you work, and our needs.  Such personal information may include:

• Individual Data: Your name, address, telephone and/or mobile telephone number, e-mail address, image, ‎gender, gender identity or gender expression, marital status, date of birth/age, ‎citizenship, race, national, or ethnic origin, foreign language skills, relevant tax ‎identification number(s), IP address, information on your passport, driver’s license or ‎other governmental identification, immigration status/visa information contained in a ‎governmental employment eligibility form, prior employers, education, qualifications, ‎prior employment history, results of criminal background screening, credit checks, ‎emergency contact information, name change information,  CVs, etc.;‎
  
  
• Job-Related Data: Recruitment records, application forms, equal opportunities monitoring forms, ‎assessment exercises or tests, interview records and notes and related decision making ‎records, information contained in your offer letter, contracts of employment or similar ‎contracts, your payroll and salary information, bank account information (to administer ‎direct deposit and/or expense reimbursements), overtime and working hours records, ‎timesheets, bonus information, benefits, insurances and pension information, dependent ‎and beneficiary information you provide, information about reimbursable expenses you ‎incur on our behalf, information about Firm-owned equipment assigned to you, P45, ‎P60, tax coding and tax records, tax and government reporting information, information ‎about your performance on the job, including reviews, appraisals, warnings, grievances, ‎resignation and termination records, individual and management development plans and ‎reviews, and information relating to promotions and position changes (including ‎requests), training records, information regarding your compliance with company ‎policies and certifications, annual leave records, statutory leave records and payments, ‎log-on and work station activity and web history information, information obtained from ‎outbound and inbound emails sent from Firm equipment‎, system usage, CCTV and building access control data;‎
  
  
• Special Categories of Personal information: Your race, national or ethnic origin, religion or creed, church affiliation (where ‎necessary for deducting church taxes from your income), political opinion, sex life, trade ‎union membership (e.g., where necessary for organizing social elections), geolocation data, data concerning health ‎‎(e.g., leave information, information on pregnancy or disabilities in order to comply ‎with legal requirements), accident records, health assessments and occupational health ‎reports, and media information you provide, physical or mental disability, veteran or ‎military status, or data that you voluntarily submit concerning your sexual orientation; ‎and
  
  
• Other Data About You: Any additional Personal Information that may be included on documents you submit or ‎we obtain as part of your employment application or throughout the course of your ‎employment, to the extent legally allowed, such as information contained on any ‎employment application or cover letter, curriculum vitae or resume, diploma, transcript, ‎license, professional qualifications and  regulatory status, statement of good behavior, ‎background screening, employment contract, any related documents, reference check, ‎identification card, request for leave, benefits, wage garnishment and other similar ‎court-ordered information, etc., and information collected from publicly available ‎resources, professional license databases, and credit agencies, where applicable. ‎Whenever you provide Personal Information about a dependent or beneficiary (e.g., in ‎connection with benefits we provide to you), it is your obligation to inform such ‎dependent or beneficiary of the fact that you have provided us with Personal Information ‎about him or her, and to inform such dependent or beneficiary of his or her rights under ‎the Global Privacy Policy.‎
    

Sources of HR Data: We obtain HR Data about you (i) directly from you or from inbound emails you receive, (ii) from our partners and employees at the Firm (e.g., performance reviews), and (iii) from third parties, such as government agencies, recruiters, educational establishments, employment agencies, screening companies, references that you provide to us, and may as well be obtained or provided from publicly available sources, such as publicly accessible websites, including social media, containing content you directly or indirectly control. 

While you have the ability to use facial or fingerprint biometrics  for authentication when signing on to Firm-issued equipment, using this is optional and other methods are available.  As you, rather than the Firm, chooses whether or not to utilize these facilities, the Firm does not determine the method of processing and so is not considered a data controller in this respect and it has no access to any such biometric data you may choose to utilize.

Purposes and Legal Basis for the Processing: Your HR Data is processed for the purpose of establishing and maintaining your employment ‎relationship with us (whether as an employee, partner, contractor, consultant or otherwise), as more fully ‎set out below. The legal basis for Processing each category of HR Data is as follows:

• Individual Data:
  • Reason for Processing: Your Individual Data is processed for the purposes of (a) making a decision about hiring you and determining the terms on which you work for us, (b) ensuring you have the necessary qualifications and entitled to work in the office for which you are being hired, and (c) checking your background, solvency and professional standing.
  • Legal Basis for Processing: The legal basis for Processing your individual data is that it is ‎(i) necessary for entering into and/or performing your employment relationship with the Firm, ‎‎(ii) necessary for compliance with one or more legal obligations to which you or the Firm is ‎subject (e.g., reporting to governmental, taxing, and law enforcement and judicial ‎authorities, including the respective bar authorities you are (applying to become) a member of), (iii) necessary for the purposes of the legitimate business interests pursued by the Firm‎ in recruiting and employing personnel in order to provide its services and/or (iv) processed with your consent. ‎
• Job-Related Data:
  • Reason for Processing: Your job-related data is processed for the purposes of‎ (a) recording the terms of your employment or engagement, pay and benefits, (b) paying you, deducting taxes and benefit co-pay amounts, making 401k or pension contributions and administering benefits, (c) reimbursing you for expenses you incurred on behalf of the Firm, (d) conducting performance ‎reviews, managing ‎performance and ‎determining performance ‎‎requirements, (e) making decisions about ‎salary reviews and ‎compensation., (f) assessing qualifications for ‎a particular job or task, ‎including decisions about ‎promotions and ‎terminations, (g) training and development ‎requirements, (h) assessing client complaints, (i) gathering evidence for ‎possible grievance or ‎disciplinary hearings against you, (j) dealing with legal disputes ‎involving you or others and ‎(k) protecting the Firm from data breaches and other cyber security risks.‎‎
  • Legal Basis for Processing: The legal basis for Processing your job-related data is that it is ‎(i) necessary for performing your employment relationship with the Firm, ‎‎(ii) necessary for compliance ‎with one or more legal obligations to which you or the Firm is ‎subject (e.g., reporting to ‎governmental, taxing, and law enforcement and judicial ‎authorities, including the respective ‎bar authorities you are (applying to become) a member of), ‎(iii) necessary for the ‎purposes of the legitimate business interests pursued by the Firm or its clients‎ in employing ‎personnel in order to provide its services and to protect client information, and/or (iv) processed with your consent.‎
• Special Categories of Personal Information:
  • Reason for Processing: Special categories of Personal Information is processed for the purposes of‎ ‎(a) in the case of race, national or ethnic origin, or data that you voluntarily submit concerning your sexual orientation, complying with client requests for diversity statistics or reporting to an independent diversity rating organization, (b) in the case of your religion or creed, ‎deducting church taxes or contributions made to a church from your pay, (c) uniquely identifying you or your location in the case of biometric data or geolocation data, (d) assessing our legal obligation to offer you statutory leave or a leave for medical reasons, or to accommodate medical needs and (e) in the case of veteran or military status, to ensure we do not discriminate against veterans during the recruiting process or during your employment, to make required filings with the government and to apply for applicable tax credits or other governmental benefits.
  • Legal Basis for Processing: The legal basis for Processing special categories of Personal Information is that it is ‎(i) necessary for performing your ‎employment relationship with the Firm, ‎‎(ii) necessary for compliance ‎with one or more legal ‎obligations to which you or the Firm is ‎subject, ‎(iii) necessary for the ‎purposes of the legitimate ‎business interests pursued by the Firm or its clients‎ in employing ‎personnel in order to provide its services and to protect client information, and/or (iv) processed with your consent.‎
• Other Data About You:
  • Reason for Processing: Other data about you is processed for the purposes of‎ ‎(a) making a decision about hiring you and determining the terms on which you ‎work for us, (b) ensuring you have the necessary qualifications and entitled to ‎work in the office for which you are being hired, (c) checking your ‎background, solvency and professional standing, (d) in the case of driving offenses, obtaining relevant insurance and (d) in the case of dependent information, in connection with benefits we provide to you. ‎
  • Legal Basis for Processing:‎The legal basis for Processing other data about you is that it is ‎(i) ‎necessary for performing your ‎employment relationship with the Firm where the nature of that information ‎is necessary to ‎‎comply with a legal obligation under your employment contract (i.e., for ‎insurance), or where ‎‎you have consented (i.e., DBS check)‎) ‎, ‎‎(ii) necessary for compliance ‎with one or more legal ‎‎obligations to which you or the Firm is ‎subject (i.e., reporting to ‎governmental, taxing, ‎and law ‎enforcement and judicial ‎authorities‎, including the respective ‎bar authorities you are (applying to become) a member of‎), ‎(iii) necessary for the ‎purposes of the legitimate ‎‎business interests pursued by the Firm in employing ‎personnel in order to provide its services ‎‎(i.e., complying with client requests for background checks on team members working for that ‎client) and/or (iv) processed with your consent.‎

Additional Protection for Certain Special Categories of Personal Information: Where we process your biometric or non-HIPAA health data only the following persons will have access such information: members of our HR team, office managers, personnel whose role includes disability discrimination, and personnel with responsibility for the health and safety of staff. For health data that is Benefit Plan Data, the Firm’s HIPAA policies will apply and only members of the Firm’s HIPAA workforce are permitted to have access to such Protected Health Information, as discussed in Section 4.2 below.

4.2 Benefit Plan Data

The Firm extends various retirement and welfare benefits to our employees and their eligible dependents and beneficiaries. The Firm generally outsources administration of the benefit plans, but as the plan sponsor of the plans, the Firm has certain responsibilities that require the direct collection and use of certain information for operational purposes. Information collected in connection with the benefit plans that are group health plans is subject to the plans’ HIPAA notices and policies. HIPAA and employment laws prohibit the Firm from using Protected Health Information to make employment related decisions. HIPAA also requires the Firm to designate a limited number of firm personnel who are allowed to have access to protected health information derived from the operation of the Firm’s benefit plans. All firm personnel who are so designated must undergo HIPAA training and comply with the plans’ HIPAA policies.

4.3 Website Data

You do not have to submit any Personal Information in order to use our Website (www.lockelord.com) and, as applicable for employees and Partners of the Firm, LNet, as well as outside contractors who maintain and update our Website and LNet (together the "Firm Website")

Categories of Website Data: When you visit the Firm Website, we may collect two types of data: (1) Personal Information about you that you voluntarily choose to provide to us, and (2) information related to your activities on the Firm Website that we automatically collect as you interact with the Firm Website (“Website Usage Information”).

• Information You Voluntarily Provide:  We collect Personal Information that you voluntarily provide in response to requests we may make at various places and through various mechanisms on the Firm Website. The Personal Information we collect is business-oriented data and is usually limited to contact information necessary for the relationship, such as name, company name, job title, and email address. We may collect such information, for example, when you fill out and submit a form, such as if you register for an event, register to receive a newsletter or email communications, when you submit an inquiry or request to us using a form or e-mail address link on the Firm Website, and when you send an email to a Firm address or Firm mail list that is listed on the Firm Website. In such case, we will collect whatever Personal Information you voluntarily provide in response to our request.

• Special Categories of Personal Information: In connection with the registration for and provision of access to an event or seminar, we may ask for information about your health for the purpose of identifying and accommodating any disabilities or special dietary requirements you may have. Any use of such information is based on your consent. If you do not provide any such information about disabilities or special dietary requirements, we will not be able to take any respective precautions.

• Website Usage Information and Cookies: The Firm Website uses cookies for analytical and functionality purposes that allow us to improve our Website based on visitor experience. Our cookies policy is set forth in Appendix 6.

• Links to Third Party Websites.  The Firm Website may contain links to other third-party websites (including but not limited to publications containing articles written by and about our attorneys and organizations where our attorneys are speaking and/or participating in community, service or bar activities), all of which are separate legal entities whose information practices may be different from ours. This Privacy Policy does not cover any such third-party websites. If you provide Personal Information to such third-party websites all information you disclose will be subject to the Privacy Policy and practices of such third parties. We are not responsible for the policies and practices of such third parties and, therefore, you should review the specific policies posted on those websites prior to submitting Personal Information to them.

• Information about Children. Neither the Firm Website nor any of our products or services are directed to children younger than age sixteen (16). We do not knowingly collect Personal Information from children under the age of sixteen (16) via the Firm Website and we will delete any such information later determined to be from a person younger than age sixteen (16).

• Third-Party Tracking and Do Not Track.  Third parties may use tracking technologies in connection with our Firm Website, which may include the collection of information about your online activities over time and across third-party websites. This Global Privacy Policy does not apply to these third-party technologies because we may not control them and we are not responsible for them. Do Not Track is a technology that enables users to opt out of tracking by websites they do not visit. Currently, we do not monitor or take any action with respect to Do Not Track technology.
     

Sources of Website Data: We obtain Website Data about you (i) directly from you if you voluntarily choose to enter Personal Information on the Firm Website, and (ii) from the data analytics software, cookies, and web beacons that we may use on the Firm Website.

Purposes and Legal Basis for the Processing:

We process Website Data as more fully set forth below for the purposes of building relationships with existing and potential clients and other interested parties, communicating with such parties, and analyzing and improving the Firm Website. This includes keeping such people informed of the latest updates about legal and regulatory developments and notifying them of seminars and hosted events. The legal basis for such Processing each category of Website Data is as follows:

• Information You Voluntarily Provide:
  • Reason for Processing:  Information you voluntarily provide is processed for the purposes of building relationships with existing and potential clients and other interested parties and ‎communicating with such parties‎.
  • Legal Basis for Processing:  The legal basis for Processing is that it is (i) necessary for the legitimate business interests of the Firm in marketing and providing our legal services and/or (ii) processed with your consent.
• Special Categories of Personal Information:
  • Reason for Processing:  Special categories of Personal Information that you voluntarily provide when you register for attendance at a seminar we sponsor is processed for the purposes of identifying and accommodating any disabilities or special dietary requirements you may ‎have‎.
  • Legal Basis for Processing:  The legal basis for Processing is that it is processed with your consent.‎
• Website Usage Information and Cookies:
  • Reason for Processing:  The Firm Website uses cookies for analytical and functionality purposes that allow us to improve our Website based on visitor experience. 

Legal Basis for Processing:  The legal basis for Processing is that it is (i) necessary for the legitimate business interests of the Firm in marketing ‎and providing our legal services, (ii) necessary for the legitimate business interests of the Firm in‎ maintaining the functionality of the Firm Website, and/or (ii) processed with your consent.‎

4.4 Contact Data

As any business, we collect, receive, and process Contact Data regarding our clients, potential clients, and other third parties (e.g., vendors, other attorneys, and other business and professional contacts) with whom we may interact from time to time.

Categories of Contact Data: The Contact Data that we collect and process typically consists of information such as name, title, position, employer, email address, other business contact data (e.g., business card data), and similar relationship type data. Such Contact Data may also include details of your visits to our offices.

Sources of Contact Data: We obtain Contact Data about you (i) directly from you, such as when you seek legal advice from us, attend a seminar or another event or sign up to receive newsletters, emails, or other information from us, or when you or your organization offer to provide or provide services to us, (ii) from others (e.g., referrals), (iii) from third parties, such as government agencies, compliance screening and credit reference agencies, and (iv) from publicly available sources, such as websites (e.g., LinkedIn, your business’ website, etc.).

Purposes and Legal Basis for the Processing:

We process Contact Data for the purposes described below. The legal basis for such Processing is also described below.

• Reason for Processing:Contact Data is processed for the purposes of (a) marketing and communicating to potential clients, including keeping such people informed of the latest updates ‎about legal and regulatory developments and ‎notifying them of seminars and hosted events,‎ (b) providing legal services to clients, building and managing relationships with existing and ‎potential clients and other interested parties, and communicating with such parties, including keeping such people informed of the latest updates ‎about legal and regulatory developments and ‎notifying them of seminars and hosted events,‎ (c) complying with our legal obligations (such as record-keeping obligations), compliance ‎screening for anti-money laundering and crime prevention and detection purposes or recording obligations, (d) managing risk to the Firm, such as when we do financial and credit checks and conduct diligence on ‎prospective or existing clients in order to decide whether to onboard them as clients or ‎keep them as clients, and (e) generally ‎operating the Firm’s business, including sending invoices to client.
• Legal Basis ‎for Processing:The legal basis for Processing Contact Data is that it is (i) necessary for the legitimate business interests of the Firm‎ in marketing ‎and providing our legal services, (ii) necessary to comply with our legal obligations and/or (iii) processed with your consent.

4.5 Client-Sourced Data

In the course of representing our clients, and providing legal services to them, we may receive certain Client-Sourced Data from such clients or from third parties providing such data on their behalf, as necessary or relevant to the legal services we are providing.

Categories of Client-Sourced Data: The scope and extent of the Client-Sourced Data that we collect and process is typically determined by the client and/or the nature and scope of the relationship and legal services involved. It will generally involve information on employees, representatives and ultimate beneficial owners of our Clients and may in some cases involve special categories of data or criminal data.

Sources of Client-Sourced Data: We obtain Client Sourced Data directly from our clients, and from third parties that provide such information on behalf of our clients, such as their professional advisors, attorneys, auditors, and accountants, consultants, and others.

Purposes and Legal Basis for the Processing:

• Reason for Processing:  We process Client-Sourced Data for the purposes of (a) managing risk to the Firm, such as when we do a financial and credit check and ‎conduct diligence on prospective or ‎existing clients in order to decide whether to ‎onboard them as clients or keep them as ‎clients and (b) providing legal services to our clients in connection with specific matters for a client on which we are engaged, such as performing ‎due diligence in connection with transactional matters (i.e., the sale or purchase of a client or ‎other company or assets relating to the clients or other company), representing a client in a ‎litigation matter (i.e., information about the client, the other party or employees, representatives ‎and ultimate beneficial owners of the client and such other parties and may in some cases ‎‎involve special categories of data or criminal history data in order to analyze issues in the ‎litigation and present issues to a court or other trier of fact in such litigation)‎.
• Legal Basis for Processing:  The legal basis for Processing Client-Sourced Data is that it is (i) necessary for the legitimate business interests of the Firm to assess risk of onboarding or keeping a client, (ii) necessary for the legitimate business interests of the Firm in providing our legal services, (iii) necessary for the performance of a contract to which the data subject is party, (iv) necessary to comply with a court order or our legal obligations and/or (v) processed with your consent. 

As a matter of Firm policy, Firm attorneys and staff may use or disseminate Client-Sourced Data only for the purpose of providing legal services consistent with our ethical obligations to our clients, including the duty of confidentiality under rules of professional responsibility applicable to our lawyers in our various jurisdictions .  The Firm believes in transparency with the client as to the collection, use, and dissemination of Client-Sourced Data, and the reasons therefor.

Additional Protection for Certain Client-Sourced Data: Where we process genetic, biometric, health data or data relating to crime, only the following persons will have access to such information: staff carrying out AML and other checks related to potential criminal activity and personnel having responsibility for the client.

Protected Health Information Under HIPAA. To the extent that any Client is considered to be a Covered Entity or Business Associate (as each is defined in HIPAA) under HIPAA, and the Client-Sourced Data includes Protected Health Information (as defined in HIPAA), or Protected Health Information is collected by us in our capacity as a Business Associate or sub-contractor Business Associate under HIPAA, the provisions of the HIPAA Business Associate Privacy Policy attached as Appendix 3 also shall apply.

4.6 Other Party Data

In the course of representing our clients, and providing legal services to them, we may seek, obtain, receive, or require, certain Other Party Data regarding adverse parties, witnesses, or other third parties relevant to our legal representation of the client.

Categories of Other Party Data: The scope and extent of the Other Party Data that we collect and process is typically determined by the applicable client, an adverse party, a court, and/or the nature and scope of the legal representation involved.

Sources of Other Party Data: We obtain Other Party Data about you from a variety of sources as necessary in the context of representing our clients, which may include directly from adverse parties (either voluntarily or through discovery in litigation or arbitration), from our own investigations in connection with representing our clients, and from other third parties providing such data.

Purposes and Legal Basis for the Processing:

• Reason for Processing: We process Other Party Data for the purposes of (a) managing risk to the Firm, such as when we ‎conduct ‎diligence on other parties involved in a matter in order to decide whether to ‎take on or terminate a particular matter and (b) providing legal services to our clients in connection with specific matters for a client on which we are engaged, such as performing ‎‎due diligence in connection with transactional matters (i.e., the sale or purchase by a client of an‎‎other company or assets relating to another company), representing a client in a ‎‎litigation matter (i.e., information about the other party or employees, representatives ‎‎and ultimate beneficial owners of the client and such other parties and may in some cases ‎‎‎involve special categories of data or criminal history data in order to analyze issues in the ‎‎litigation and present issues to a court or other trier of fact in such litigation)‎.
• Legal Basis for Processing:The legal basis for Processing Other Party Data is that it is (i) necessary for the legitimate business interests of the Firm to assess risk of opening or terminating a particular matter, (ii) necessary for the legitimate business interests of the Firm‎ in providing our legal services, (iii) necessary to comply with a court order or ourlegal obligations and (iv) processed with your consent.

5. Sharing of Personal Information

Subject in all cases to our ethical obligations as attorneys, we may share selected Personal Information about you with the following parties or in the following circumstances.  We do not sell Personal Information we collect about you, including as the term “sale” is used within the meaning of the CCPA or the Nevada Act Relating to Internet Privacy.

5.1       Intra-Firm

Locke Lord LLP and Locke Lord (UK) LLP may share Personal Information about you between them as necessary for the conduct of the Firm’s business.

5.2       Third Party Service Providers

We may share Personal Information about you with third parties who perform services for us or on our or our clients’ behalf, for the limited purpose of carrying out such services. This includes, without limitation, third parties that assist in managing our organization, hosting or administering the Firm Website or other systems, sending communications on our or our clients’ behalf, maintaining or analyzing our or our clients’ data, providing marketing assistance, conducting background checks, or in providing legal services to us or our clients. It also includes third parties providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference and background check agencies and regulatory bodies with whom such Personal Information is shared. The Firm also shares Personal Information with third parties in connection with the ‎provision of payroll, provisions of benefits, and occupational health and professional advisers ‎(life assurance trustees, auditors, insurers and brokers, accountants and ‎legal advisers etc.).

5.3       Clients and Other Parties

We may share selected Personal Information about you with clients, adverse parties, courts, regulators, legal counsel, experts, consultants, law enforcement personnel, and other persons or entities to the extent reasonably necessary or appropriate in the context of providing legal representation or other legal services for our clients.

5.4       Corporate Change

We reserve the right to disclose and transfer Personal Information about you in connection with a Firm merger, consolidation, restructuring, financing, sale of substantially all assets, or other organizational change.

5.5       Legal Requirements and Law Enforcement

We may disclose Personal Information about you when we believe in good faith that the law requires it; at the request of governmental authorities conducting an audit or investigation; pursuant to a court order, subpoena, or discovery request in litigation; to verify or enforce compliance with our agreements or policies and applicable laws, rules, and regulations; or whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of the Firm Website, its users, or other third parties. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.

5.6       Consent

We may also share Personal Information about you in accordance with any express consent you or your authorized agent give us which is specific to the purposes of the Processing which you will be informed about at the time we request such consent. You do not have to give such consent.  If you do give consent, you may withdraw it at any time by contacting us (see “How to Contact Us” section below), however please be aware that such withdrawal will not affect the lawfulness of Personal Information collected and processed prior to the date of your withdrawal of consent.

6. Cross-Border Transfers of Personal Information

Some Firm offices are located in different countries.  The Firm will transfer Personal Information from one country to another from time to time.  It will do so in compliance with applicable privacy and data protection law. For purposes of facilitating transfers of Personal Information from the UK or the EU to the U.S., Locke Lord LLP and Locke Lord (UK) LLP, have entered into Standard Contractual Clauses approved by the EU and the UK. You may request a copy of these Standard Contractual Clauses from the Firm at any time.  Where the Firm transfers Personal Information from the EU or UK to any third party outside the EEA where ‎there is no relevant adequacy decision, it will put in place EU Standard Contractual Clauses or, as appropriate, either an international data transfer agreement (“IDTA”) or an addendum to the EU Standard Contractual Clauses, with ‎such third party or confirm the implementation of a safeguard required by GDPR or in some instances it may rely upon derogations contained in Article 49 GDPR.

Personal data may be freely transferred by the Firm between the EEA and the UK in accordance ‎with the European Commission’s implementing decision of 28.6.21 on the adequate protection of ‎personal data by the United Kingdom.‎

7. Data Retention Period

All Personal Information retained by the Firm will be deleted when such Personal Information are no longer necessary for the purposes for which it was processed, unless applicable law requires a longer retention period. 

Client-Sourced and Other Party Data.  As set out in the Firm’s “Closing Matters and Client Document Retention” policy, the standard Retention Period for all client/matter ‎documents that contain Personal Information is five (5) years from the date the client/matter is ‎closed, or six (6) years in the case of files in the London office, except for documents to be retained for a shorter or longer period of time as ‎determined by the client’s guidelines or other agreement with the Firm or a member of the General ‎Counsel’s Office.

The following periods apply under the Firm’s policy “Document Retention—Accounting Records”:

• Time entries that may contain personal data are retained permanently;
• Accounts receivable records (excluding bills) and payroll records that may contain personal data are retained for the greater of (i) the required time periods under IRS regulations or (ii) seven years following the end of the year to which they relate.
    

The Firm retains vendor records/contracts with Personal Information during the duration of the contract and for seven years following the termination of the agreement or expiration of the ‎contract.

HR and Benefit Plan Data.

• The Firm follows state and federal guidelines for HR Data in the US.Employee files are retained while employment (or contract) continues and for seven years after the date of termination of employment;
• Form I-9 Employment Eligibility Verification forms are retained as required under federal law for three years after date of hire or one year after the date employment ends, whichever is later;
• Information in benefit and pension plans is retained as required under the Employee Retirement Income Security Act of 1974 or the various states where we have employees for a minimum of six years after filing returns or reports, unless an extension or other exception applies.

In respect of HR Data for the UK, please refer to Annex 1.

Website Data. We may use ‎third-party services, currently Google Analytics and Siteimprove, to ‎collect ‎standard internet log information and details of visitor behavior patterns.  Such data is retained for 14 months, which is the minimum length possible.

Contact Data.  The Firm removes information from its marketing lists if a person is not connected to a current lawyer of the Firm and has not interacted with the Firm’s email messages for a year.‎

8. Updating Personal Information about You

If any of the Personal Information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made of us, or if you become aware we have any inaccurate Personal Information about you, please contact us as specified in the “How to Contact Us” section below. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.

9. Security of Personal Information

We have implemented appropriate technical and organizational measures (i) to provide a level of security appropriate to the risks that are presented by the Firm’s Processing of Personal Information, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Information transmitted, stored or otherwise processed, and (ii) to protect the ongoing confidentiality, integrity, availability and resilience of processing systems and services for the personal information.’

10. Policy for Confidentiality of Social Security Numbers

It is the policy of the Firm to protect the confidentiality of Social Security numbers (or equivalent unique government identification numbers in other jurisdictions) in its ‎possession from misuse and improper disclosure by maintaining and enforcing policies and ‎physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure ‎of Social Security numbers is prohibited, and access to them is limited to Firm personnel who ‎need access to such information in order to perform their job functions at the Firm.‎

11. Personal Information about Others that You Provide to Us

If you provide Personal Information to us about someone else (such as one of your directors or ‎employees, or someone with whom you have business dealings) you must ensure that you are ‎entitled to disclose that Personal Information to us and that, without our taking any further ‎steps, we may collect, use and disclose that Personal Information as described in this Global ‎Privacy Policy. Depending upon your location and the location of any person about whom you ‎provide us with Personal Information, you may be required under applicable law to ensure the ‎individual concerned is aware of the various matters detailed in this Global Privacy Policy, as ‎those matters relate to that individual, including our identity, how to contact us, our purposes ‎for collection, our Personal Information disclosure practices (including disclosure to overseas ‎recipients), the individual’s right to obtain access to their Personal Information and make ‎complaints about the handling of their Personal Information (as well as other legal rights such ‎individual has, as explained in this Global Privacy Policy), and the consequences if the Personal ‎Information is not provided (such as our inability to provide services).‎

12. U.S. State Law Privacy Rights

If you are an individual residing in a jurisdiction of the U.S. with a state privacy law that applies to us (such as the Texas Data Privacy and Security Act), you may have privacy rights that apply to certain of your personal information, other than information we process in an employment or commercial context, and publicly available information, subject to other exceptions.

You may make a request to exercise your consumer privacy rights (i) to know and access your personal information, (ii) to obtain a copy of your personal information, (iii) to correct inaccuracies in your personal information, and (iv) to request that we delete your personal information.

If we deny your request, you may have the right to appeal.

To submit a consumer privacy rights request under applicable state law, or to appeal a denial of your request, please contact us as indicated below under the heading “How to Contact Us.”

13. Changes to the Global Privacy Policy

The Firm reserves the right to modify or amend the Global Privacy Policy at any time. The current version of the Global Privacy Policy will be published on our Website. Nothing contained in the Global Privacy Policy creates or is intended to create an attorney-client agreement between you and the Firm.  Please see our Legal Notices/Disclaimer on our Website for more information about attorney-client privilege.

14. How to Contact Us

For any questions about the Global Privacy Policy, to exercise any of your rights listed above or under the particular Appendix, or for any questions or complaints regarding the manner in which we handle or protect Personal Information, we can be contacted as follows:

By e-mail: Privacy@lockelord.com

By phone:US toll free: +1-888-558-5025

By postal mail:

Locke Lord LLP
Attn: Privacy Officer
2800 Financial Plaza
Providence, RI  02903

Additional rights afforded to California residents under the CCPA are set forth in the CCPA Privacy Policy under the section entitled “Contact Information.”

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Effective Date:           June 17, 2024
Geographic Scope:    Applies to all offices
Application:               Applies to all attorneys and team members as well as all persons from whom the Firm collects data

________________________________________

This policy is not a contract, and the Firm reserves the right to change, modify, suspend, interpret or cancel this policy in whole or in part, at any time, with or without prior notice.  Nothing in this policy is intended to change the traditional relationship of employment at will.

Retention periods for HR Data

We do not share personal information for the purpose of cross-context behavioral advertising. 

We do not sell personal information.  We do not sell or share the personal information of minors under 16 years of age.

We do not use or disclose sensitive personal information for purposes other than the following:

1. To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
2. To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
3. To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
4. To ensure the physical safety of natural persons.
5. For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
6. To perform services on behalf of the business.
7. To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business.
8. To collect or process sensitive personal information where the collection or processing is not for the purpose of inferring characteristics about a consumer.

Your Privacy Rights

Right to Notice

You have the right to receive notice at or before the point of collection about our collection and retention practices.  Please review the Firm’s “Privacy Notice at Collection for California Residents” at Appendix 4 for more information.

Right to Know and Access Your Information

You have the right to request that we disclose to you certain descriptions and categories of the personal information we collect, use, disclose, share, or sell about you.  For example, you may request the following:

‎(1) The categories of personal information we have collected about you.‎

‎(2) The categories of sources from which the personal information is collected.‎

‎(3) The business or commercial purpose for collecting, selling, or sharing personal information.‎

‎(4) The categories of third parties to whom we disclose the personal information.‎

‎(5) The specific pieces of personal information we have collected about you.‎

You may make up to two disclosure requests in any 12 month period.

Right to Request Deletion

You have the right to request that we delete your personal information (a “deletion request”). 

Only you, or someone legally authorized to act on your behalf, may make a deletion request ‎related to your personal information‎. You may also make a deletion request on behalf of your minor child.

You should be aware, however, that California law allows us to retain your personal information under certain conditions, even if you have asked us to delete it, such as when retaining your personal information is necessary for us to complete a transaction with you or provide you with a service you have requested.  We will notify you of any denial of your deletion request and the reason for such denial.

Right to Request Correction

You have the right to request that we correct your personal information. 

Exercising your California Consumer Privacy Rights

You may exercise the rights described above by making a “verifiable consumer request.”  To submit a verifiable consumer request (including a deletion request), please send an email to CCPAInquiries@lockelord.com.  You can also call 888-558-5025 to make the request.  You may make up to two requests in any 12 month period.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

Making a verifiable consumer request does not require you to create an account with us. ‎‎

Verifying your Identity

In making a verifiable consumer request, we will need to verify your identity.  To verify your identity, ‎we may ask you to provide personal information we have previously collected about you.  If ‎you are making the request for an entity, we will also ask that you provide some independent ‎evidence that you are a representative of that entity and are authorized to make such request.‎

We will only use personal information provided in a verifiable consumer request or request to delete, correct, or limit the use of, your personal information, to verify the ‎requestor's identity or authority to make the request.‎  We cannot respond to your request or provide you with personal information if we cannot verify ‎your identity or authority to make the request and confirm the personal information relates to ‎you.‎

Using an Authorized Agent

You may use an authorized agent to submit a verifiable consumer request.  To use an authorized agent, you will need to (i) provide written instruction to your agent and verify your identity to us, or (ii) provide a power of attorney pursuant to California Probate Code Sections 4000 to 4465.

Right to Non-Discrimination for Exercise of Consumer Privacy Rights

We will not discriminate against you because you have chosen to exercise any of your privacy rights provided by the CCPA.

Contact Information

If you have questions about the Global Privacy Policy or this CCPA Privacy Policy, please contact us at:

Phone:           ‎+1-‎888-558-5025‎

Website:         www.lockelord.com

Email:             CCPAInquiries@lockelord.com

Address:        2200 Ross Avenue
                       Suite 2800
                       Dallas, TX
                        Attn: CCPA Inquiries

Appendix 4
Privacy Notices at Collection for California Residents

Locke Lord LLP and Locke Lord (UK) LLP (jointly “Locke Lord,” the “Firm” or “we”) understand how important your privacy and the protection of your personal data and information is to you.  Protecting your privacy is important to the Firm.  This Privacy Notice at Collection applies to personal information of California residents to the extent the information is subject to the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020 (“CCPA”).  This Privacy Notice at Collection describes how the Firm may collect, use, disclose and safeguard the personal information you provide when you communicate or interact with the Firm, including as a client, as well as information you provide on the Firm’s websites and through or in connection with our mobile apps (the “Apps”) or other software- and Internet-enabled programs and services sponsored by the Firm.  This Notice at Collection does not apply to personal information collected pursuant to exemptions, including information collected subject to (i) the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act; (ii) HIPAA; or (iii) the Fair Credit Reporting Act.‎ ‎ ‎

Personal Information We Collect

We collect or use information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”).  Because the chart below includes information collected for various types of individuals, such as our ‎customers, employees, and others, not all of the categories of collected personal ‎information described may be applicable to you.‎ We may collect or use the following categories of your personal information in the following ways:   

We do not and will not sell personal information.  We do not share personal information for the purpose of cross-context behavioral advertising.  In the preceding 12 months we have shared personal information with third parties for business or commercial purposes as described above for each category of personal information.

We do not sell or share the personal information of minors under 16 years of age.  We do share cookies with third parties as described in our global privacy policy.‎ To opt-out of the sharing of information with third parties in this context, please review our global privacy policy for instructions or adjust your browser settings accordingly.

Further Information

Please visit our website, www.lockelord.com, for further information about personal information we collect, and your rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020 (at Appendix 2 of our Privacy Policy at Privacy | Locke Lord).

If you have questions about this notice or wish to contact us concerning your rights, please contact us at:

Phone:             ‎+1-‎888-558-5025‎

Website:          www.lockelord.com

Email:             CCPAInquiries@lockelord.com

Address:          2200 Ross Avenue
                        Suite 2800
                        Dallas, TX
                        Attn: CCPA Inquiries

Appendix 5
Notice of Compliance with Connecticut Act Concerning the Confidentiality of Social Security Numbers

Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly.  Locke Lord LLP has adopted a Global Privacy Policy that specifically includes a section on the protection of the confidentiality of social security numbers.  That section is Section 10.

Appendix 6
Website Cookies Policy

The Firm Website uses cookies for analytical and functionality purposes that allow us to improve our Website based on visitor experience.

Cookies are small text files placed on a computer hard drive to record a visitor's information such as user ID and browsing behavior. Our cookies do not collect your name or email address.

We use the following types of cookies:

(a) Necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable the Website to perform as intended and to access secure areas of our Website.

(b) Analytical/performance cookies. They allow us to recognize and count the number of visitors and repeat visitors, to see how visitors move around our Website when they are using it, to see which search engine is being used to access our Website, the region a visitor is browsing from, and the type of device a user is visiting from. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily. We may use third-party services, currently Google Analytics and Siteimprove, to collect standard internet log information and details of visitor behavior patterns. This information is only processed in a way that does not identify anyone. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. Individuals who have opted to browse websites in private or incognito mode will not be tracked by Siteimprove on our Website.

Third-Party Tracking and Do Not Track.  Third parties may use tracking technologies in connection with our Website, which may include the collection of information about your online activities over time and across third-party websites. Our Global Privacy Policy does not apply to these third-party technologies because we may not control them and we are not responsible for them. Do Not Track is a technology that enables users to opt out of tracking by websites they do not visit. Currently, we do not monitor or take any action with respect to Do Not Track technology.

If you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to change cookie settings you may not be able to use the full functionality of our Website. These settings will typically be found in the "options" or "preferences" menu of your browser. Further, most browsers permit individuals to decline cookies. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.