Privacy Policy

ArentFox Schiff Privacy Policy

Last Updated: January 1, 2023

ArentFox Schiff LLP (“ArentFox Schiff,” “we,” “us,” or “our”) operates the www.afslaw.com website and other websites and services where this Privacy Policy is referenced (collectively, the “Service(s)”). We are committed to protecting your Personal Data and your right to privacy. If you have any questions or concerns about this Privacy Policy or our practices regarding your Personal Data, please contact us at consumerprivacy@afslaw.com or 1.888.414.8658.

In this Privacy Policy, we explain the information we collect, how we use it, and your rights. Please read through our Privacy Policy carefully. If there is anything in this Privacy Policy that you do not agree with, please discontinue use of the Services immediately and do not provide us with Personal Data.

By using our Services, or otherwise providing Personal Data to us, you signify your agreement to the collection and use of information in accordance with this Privacy Policy. We may update this Privacy Policy from time to time, as detailed below. You should not use the Services if you have any objections to our Privacy Policy, which is binding upon all users of the Services.

Notice at Collection and Table of Contents

We may collect or process various categories of Personal Data. The section titled “Information Collection and Use” contains information on the categories of Personal Data collected and our disclosure practices. As an overview, we collect identifiers; commercial data; characteristics of protected classifications; internet or other similar network activity; geolocation data; audio, visual, or similar data; and professional or employment-related data.

We collect this information to deliver requested information to you, such as sending you newsletters or legal alerts; process your request for employment; perform services for which we have been engaged; maintain our business relationship with you; respond to your comments or requests for information; enforce any contracts that we enter into with you or the business you represent; or for other business or commercial purposes listed in the “Use of Data” section. We do not sell or share Personal Data. We do not collect, use, or disclose Sensitive Personal Data; therefore, we do not offer a specific right to limit. We will retain the Personal Data listed above for as long as needed to fulfill the purpose for which it is collected and to comply with our legal obligations, resolve disputes, and enforce our agreements.

Scope
Information Collection and Use
Tracking and Cookies Data
Sources of Data
Use of Data
Disclosure of Data
Notice to California Job Applicants
Notice to California Businesses and Service Providers with whom we have Business Relationships
International Transfer of Data
Security of Data
Choice and Marketing
Links to Third Party Websites and External Pages
Bulletin Boards, Chat Rooms, and Blogs
Special Policy Regarding Information from Children
Your Individual Rights in the European Economic Area, the United Kingdom, and Switzerland
Your California and Virginia Privacy Rights
How We Respond to Do Not Track Signals
Material Changes to This Privacy Policy
Special Cases
Contact Us

Scope

This Privacy Policy describes the way that ArentFox Schiff collects and uses your Personal Data. This Privacy Policy applies to the Personal Data we collect related to our:

Services, including www.afslaw.com, and any other websites that display this Privacy Policy, and other services available through our Services
Events, marketing, and business development activities
Business communications and business interactions
Hiring activities

Additional or different privacy notices may apply to certain of our Services. If a different or supplemental privacy notice applies, it will be disclosed and in the event of a conflict between such provisions and this Privacy Policy, such different or supplemental terms shall control.

This Privacy Policy does not describe ArentFox Schiff’s use of information when a client relationship is in place because, as a law firm, client information is used in accordance with strict attorney ethical rules. Thus, this Privacy Policy does not apply to information that is exchanged as part of an attorney-client relationship.

Information Collection and Use

“Personal Data” means data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, device, or household; or is otherwise considered personal data or personal information under applicable privacy and/or data protection laws or regulations (“Applicable Law”). ArentFox Schiff has collected the following categories of Personal Data:

Category of Personal Data	Sources of Collection	Is this Information Sold, Shared, or Disclosed?	Categories of Third Parties to whom the Personal Data was Sold, Shared, and/or Disclosed
Identifiers, such as your name, address, online identifier, email address, Internet Protocol address, telephone number, and other contact information.	These are sourced directly from you or indirectly from you (e.g., from observing your actions on the Service).	Sold: No Shared: No Disclosed: Yes	Affiliates, agents, and service providers including without limitation companies that provide website analytics, hosting and cloud computing services, general IT services, software platforms and services for the legal profession, talent management and recruitment services, and other administrative services.
Commercial data, such as records of services provided.	We source this information directly from you.	Sold: No Shared: No Disclosed: Yes	Affiliates, agents, and service providers including without limitation companies that provide website and other forms of analytics, hosting and cloud computing services, general IT services, software platforms and services for the legal profession, and other administrative services.
Characteristics of protected classifications, such as age or gender. We may also collect health information, such as accessibility requirements and dietary restrictions for events.	We source this information directly or indirectly from you or our service providers.	Sold: No Shared: No Disclosed: Yes	Affiliates, agents, and service providers including without limitation talent management and recruitment agencies.
Internet or other similar network activity, including information about your use of our Services, access times, websites you visit before and after you visit ours, device type, device operating system, device identifiers, device settings, date and time you visit, information about your computer hardware and software, IP address, browser type, domain names, host information, and other Usage Information.	This information is sourced directly or indirectly from you (e.g., from observing your actions on our Services and from gathering information from our Analytics providers).	Sold: No Shared: No Disclosed: Yes	Affiliates, agents, and service providers including without limitation analytics providers.
Geolocation data	This information is sourced directly or indirectly from you (e.g., from observing your actions on our Services).	Sold: No Shared: No Disclosed: Yes	Affiliates, agents, and service providers including without limitation analytics providers.
Audio, visual, or similar data such as voicemail recordings of calls to our attorneys or personnel and CCTV video recorded at our facilities.	We source this information directly from you.	Sold: No Shared: No Disclosed: Yes	Affiliates, agents, and service providers including without limitation companies that provide general IT services and software platforms.
Professional or employment-related data such as employment history and professional licenses and memberships.	We may collect professional or employment-related Personal Data from you if you apply for a job via our Services. This information is sourced directly or indirectly from you or from our service providers. We also collect professional or employment-related Personal Data from third-party websites like LinkedIn.	Sold: No Shared: No Disclosed: Yes	Affiliates, agents, and service providers including without limitation talent management and recruitment agencies.

Retention: We will retain the Personal Data listed above for as long as needed to fulfill the purpose for which it is collected and to comply with our legal obligations, resolve disputes, and enforce our agreements.

You have choices about the Personal Data we collect. When you are asked to provide Personal Data, you may decline. Please note that, if you do not provide certain Personal Data we collect, we may not be able to accomplish some purposes outlined in this Privacy Policy and you may not be able to use or access certain Services.

Tracking and Cookies Data

We use, and allow certain third parties to use, cookies, tags/beacons and other similar technologies to provide our Services and to help collect data regarding your interaction with our Services. (“Usage Information”). Usage Information helps us better manage Services content and communications by informing us what content is effective and how it is used. These beacons (or other tracking technology) may also be included in or associated with emails or other communications that you receive from us (or our service providers) in order to help us track your response and interests and to deliver you relevant content and services.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. We, or third parties, may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device’s hard drive until you delete them or they expire. Different cookies are used to perform different functions, which we explain below:

Essential. Some cookies are essential in order to enable you to move around our Services and use their features, such as accessing secure areas of the Services. Without these cookies, we cannot enable appropriate content based on the type of device you are using.
Browsing and functionality. These cookies allow us to remember choices you make on the Services, such as your preferred language, and provide enhanced, more personalized features.
Performance and analytics. We use our own cookies and third-party cookies to see how you use our Services in order to enhance their performance and develop them according to your preferences. We use Google Analytics, for example, to track website usage and activity. You can opt-out of the Google Analytics Advertising Features we use by indicating your preference using the interest-based opt-out link here. Google also provides a complete privacy policy and instructions on opting-out of Google Analytics here.

There are several ways to manage cookies. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provides information on how to accept cookies, disable cookies, or to notify you when receiving a new cookie. The Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit www.networkadvertising.org to learn more. The Digital Advertising Alliance also has an opt-out tool available here. You can also use the mobile app to control interest-based advertising on apps on your mobile device, available on the Apple Store, Google Play, and Amazon’s Appstore. Mobile app guidance is available here.Please note, however, that by blocking or deleting cookies which are “strictly necessary,” you will not be able to access certain features of our Services. Note that opting-out from cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.

Sources of Data

We collect Personal Data in the following ways:

Directly from you when you enter information on our Services. For example, when you contact us, you provide your first name, last name, email, and phone number.

Directly or indirectly from you when you register for or attend an event or interact with us via social media sites or our attorneys or personnel, or in the application context, or when you interact with us in a business context.

Indirectly from you when you visit our Services. For example, our Services collect Usage Information through cookies and tags when you visit our websites. Please see our TRACKING AND COOKIES DATA section above for more information.

From publicly available sources.

From service providers. For example, we may use service providers who retrieve publicly available information about you and we may combine it with Personal Data we have about you.

Use of Data

1. Business or Commercial Purpose for Collection, Selling, Sharing, and/or Disclosing the Personal Data

ArentFox Schiff uses the Personal Data listed in categories A, B, C, D, E, F, and G primarily for the following business and commercial purposes:

Business Purposes:	Commercial Purposes:
To deliver requested information to you, such as sending you newsletters or legal alerts or information regarding educational seminars or other events that we believe may be of interest to you. To process your request for employment. To perform services for which we have been engaged. To maintain our business relationship with you. To respond to your comments or requests for information. To enforce any contracts that we enter into with you or the business you represent, or defend claims arising from such contracts. To operate, maintain, improve, administer and provide our Services, including customizing and optimizing user experience. For safety and security purposes, including where necessary to protect the rights, property or safety of us or others. For internal administration, data analysis, billing, and detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement. Where we are obligated, or permitted, to do so by applicable law, regulation or legal process, including disclosure to governmental authorities. To complete any other transaction or service requested by you. As described to you when collecting Personal Data. Monitoring our processes for compliance with regulatory requirements. To notify you about a material change to this Privacy Policy or the Terms of Use for our Services, if necessary.	To advertise, provide, and assess the effectiveness of our events, promotional campaigns, publications, and services. For marketing.

Business Purposes:

Commercial Purposes:

To deliver requested information to you, such as sending you newsletters or legal alerts or information regarding educational seminars or other events that we believe may be of interest to you.
To process your request for employment.
To perform services for which we have been engaged.
To maintain our business relationship with you.
To respond to your comments or requests for information.
To enforce any contracts that we enter into with you or the business you represent, or defend claims arising from such contracts.
To operate, maintain, improve, administer and provide our Services, including customizing and optimizing user experience.
For safety and security purposes, including where necessary to protect the rights, property or safety of us or others.
For internal administration, data analysis, billing, and detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement.
Where we are obligated, or permitted, to do so by applicable law, regulation or legal process, including disclosure to governmental authorities.
To complete any other transaction or service requested by you.
As described to you when collecting Personal Data.
Monitoring our processes for compliance with regulatory requirements.

To notify you about a material change to this Privacy Policy or the Terms of Use for our Services, if necessary.

To advertise, provide, and assess the effectiveness of our events, promotional campaigns, publications, and services.
For marketing.

If ArentFox Schiff collects your Personal Data for one of the purposes described above, it may store such information on its servers or in one (or more) of its databases. If you do not want ArentFox Schiff to use and store your Personal Data in accordance with this Privacy Policy, please do not submit any Personal Data to ArentFox Schiff or its attorneys or personnel. We may anonymize, pseudonymize, aggregate, depersonalize, or deidentify Personal Data to create non-personally identifiable information and use such anonymized data for our own statistical, marketing, and other business purposes. Once anonymized, pseudonymized, aggregated, depersonalized, or deidentified, we maintain the Personal Data in these forms.

2. Legal Bases for Processing

We base the above-mentioned processing activities of your Personal Data on the following legal bases:

Consent. Processing for the purpose of delivering requested information to you is based on your consent.
Performance of a Contract. Processing for the purposes of performance of a contract, such as handling requests for employment, completing a transaction requested by you, and notifying you about changes to our policies as necessary to establish and fulfill a contract with you and also based upon our legitimate interests.
Legitimate Interests. We may use your Personal Data for our legitimate interests to improve our Services, as well as the content on our Services. Consistent with our legitimate interests and any choices that we offer or consents that may be required under Applicable Law, we may use Personal Data for marketing purposes.
Legal Obligation. We may process Personal Data as necessary to comply with our legal obligations.

Disclosure of Data

ArentFox Schiff may transfer or disclose your Personal Data in the following instances:

With your consent. We may disclose Personal Data if you ask, direct, or authorize us to do so.
To fulfill a service to you. For example, if you choose to attend a webinar or other educational seminar advertised or promoted by ArentFox Schiff, we may disclose your Personal Data with a third-party service provider in order to provide that service to you.
To process a request made by you. For example, if you apply for a job via our Services, we may disclose your information with third parties in order to analyze and fulfill your request for employment.
To affiliates, strategic partners, and agents. We may disclose Personal Data to our affiliates, strategic partners, and agents.
To unaffiliated third-party service providers, agents, or independent contractors who help us maintain our Services and provide other administrative services to us (including, but not limited to, maintaining and analyzing data and sending customer communications on ArentFox Schiff s behalf). By agreement, we seek to ensure that these unaffiliated third parties will not use the Personal Data for any purpose other than to provide the services for which they are responsible. Because such third-party service providers that help us administer our Services will have access to users’ Personal Data, if you do not wish for our third-party service providers to have access to your information, please do not submit any Personal Data to us.
Reorganization. In the event of a direct or indirect reorganization process including, but not limited to, assignments, mergers, acquisitions, divestitures, bankruptcies, insolvencies, and sales of all or a part of our assets, we may disclose your Personal Data following completion of such transaction and/or during the assessment process pending transfer.
To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property, including the rights and property of ArentFox Schiff or act in urgent circumstances to protect the personal safety of our clients or end users.

Except as described in this Privacy Policy or at the time we request the information, we do not otherwise disclose your Personal Data to any third parties.

Notice to California Job Applicants

When you apply for a position with us, we will process your Personal Data as described in this Privacy Policy, and also as described below as it relates to you as a job applicant.

When you apply for a job with us, we ask you to provide Personal Data to evaluate your application. All information is provided on a voluntarily basis and you choose what Personal Data to provide. Please note, if you choose not to provide requested Personal Data, our ability to consider you for a position may be limited.

We may also get information about you from public sources or third parties. We may use such information, for example, to verify information in your application or conduct background screenings, as allowed by law. If you choose, you may provide us with Personal Data on third party sites like LinkedIn. If you choose to authorize us to access this Personal Data, you agree that we may collect, store, and use this information in accordance with this Privacy Policy.

How we use your Personal Data as a Job Applicant

We will use your Personal Data to process your application, including for the below purposes:

Recruitment, evaluation and selection of job candidates
General, human resources administration and management
Conducting satisfaction surveys (for example, to manage and improve the recruitment process)
Verifying your employment reference(s), conducting background checks, and related assessments
Compliance with legal and company requirements (for example, to monitor diversity)
Communicating with you regarding your application and interest in ArentFox Schiff
Use in connection with future job opportunities if you allow this use

How we Disclose your Personal Data as a Job Applicant

Your Personal Data is not sold or shared. Your Personal Data will only be disclosed with: ArentFox Schiff employees with a legitimate business need; third parties specific to job applicants, such as talent management and recruitment services, consultants, background service providers and attorneys. These entities may change over time. We always seek to ensure that third parties handling Personal Data do so in a manner consistent with this Privacy Policy and in accordance with the law.

Notice to California Businesses and Service Providers with whom we have Business Relationships

When you engage in a business relationship with us, we will collect and process your Personal Data as described in the “Information We Collect and Disclose” section of this Privacy Policy. We use this information for business purposes such as to perform and provide Services on behalf of the business. We do not sell or share the information you provide to us, but we may disclose such information to other service providers from time to time as necessary. This Privacy Policy does not override any specific contracts agreed to by the parties, and relationships may be governed by further privacy agreements. If you are engaging with us on behalf of others in your company or otherwise providing the Personal Data of others, by engaging with us, you acknowledge and agree that you have the consent of the data subject.

International Transfer of Data

If you choose to provide us with Personal Data, it may be may be transferred to, and stored on, computers located outside of your state, province, country, or other governmental jurisdiction where applicable data protection laws may differ than those from your jurisdiction. If you are visiting our Services from the European Economic Area or other regions with laws governing data collection and use, please note that your Personal Data may be transferred to the United States, and to other jurisdictions, which may not have the same data protection laws as the European Economic Area and may not afford many of the rights conferred upon data subjects in the European Economic Area. We primarily use European Union Commission Standard Contractual Clauses for data transfers from the European Union, the EEA, the UK and Switzerland to countries outside the EEA (including the UK). For transfers between other jurisdictions, we may rely on other legal mechanisms for international transfer, as appropriate under the relevant law. Please contact us for more information and to receive a copy of the standard contractual clauses we may utilize. By agreeing to this Privacy Policy, you acknowledge that you understand: (i) your Personal Data may be used for the uses identified above in accordance with this Privacy Policy; and (ii) your Personal Data may be transferred to the United States, or other jurisdictions as indicated above; and you consent to such use and transfer.

Security of Data

The security of your data is important to us, but remember that no method of data transmission over the Internet can be guaranteed to be 100% secure. You play a role in protecting your Personal Data as well. While we strive to use commercially acceptable means to protect your Personal Data, we cannot ensure or warrant the security of any information you transmit to us. Any information that you transfer to ArentFox Schiff is done at your own risk. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. We will comply with all privacy laws and make any legally required disclosures regarding breaches of the security, confidentiality, or integrity of Personal Data consistent with our ability to determine the scope of a breach and our obligations to law enforcement. By using the Services or providing Personal Data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. We may post a notice via the Services if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances.

Choice and Marketing

You have the right to ask us not to process your Personal Data for marketing purposes. When we collect contact information from you (for example, when you provide us with your business card, when you engage us for legal services, or when you subscribe to mailing lists via our Services), we may add your details to our contacts database and our mailing lists. If you register for an event we may send you follow-up information or newsletters regarding topics related to the event.

If you receive an email communication from ArentFox Schiff and you would prefer not to receive such an email communication, please either notify the sender of that email or follow the unsubscribe instructions in the email. ArentFox Schiff will take reasonable efforts to honor any such request. You may also indicate your desire to be removed from marketing communications by contacting us at consumerprivacy@afslaw.com.

Links to Third Party Websites and External Pages

This online Privacy Policy does not apply to the websites, services or platforms of other companies, individuals, or organizations to which we may provide links. These sites may have different policies relating to your privacy and the information they collect about you. Visitors should consult the privacy policies of linked sites, as we have no control over information that is submitted to, or controlled by, third parties. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites, platforms or services.

Bulletin Boards, Chat Rooms, and Blogs

From time to time, we may operate bulletin boards, chat rooms, and/or blogs in connection with the Services. Please exercise caution when disclosing any information in chat rooms, forums and other public posting areas. We are not responsible for the use by others of the information that you disclose in public posting areas.

Special Policy Regarding Information from Children

ArentFox Schiff and its Services are not targeted to children under the age of 16 and ArentFox Schiff does not knowingly collect Personal Data from any child under the age 16. If we become aware that such data has been collected, we will delete it.

Your Individual Rights in The European Economic Area, The United Kingdom, and Switzerland

For residents of the European Economic Area, the United Kingdom, and Switzerland, you may be entitled to ask us for a copy of your information, to correct it, erase or restrict its processing, or ask us to transfer some of this information to other organizations in a portable format. You may also have the right to object to some processing activities and, where we have asked for your consent to process your information, to withdraw this consent. You may also have the right to access our the service providers we use. For a list of our service providers, please contact us at consumerprivacy@afslaw.com. These rights may be limited in some situations, for example, where we can demonstrate that we have a legal requirement to process your information. In some instances, this may mean that we are able to retain your information even if you withdraw your consent.

We hope we can satisfy any queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt-out of receiving marketing communications, please contact us at consumerprivacy@afslaw.com.

For residents of the European Economic Area, the United Kingdom, and Switzerland in the event you have unresolved concerns, you also have the right to complain to a data protection authority.

Your California and Virginia Privacy Rights

If you are a resident of California or Virginia, you have the following rights. To the extent that these rights apply to you, the following rights are provided:

Right to know
You have the right to know and request information about the categories and specific pieces of information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we disclose such information. You also have the right to know if we have sold, shared, or disclosed your Personal Data. Again, we do not sell or share Personal Data. You may also request a copy of the Personal Data we have collected and, upon request, we will provide this information to you in electronic form.
Right to request deletion
You have the right to request the deletion of your Personal Data, subject to certain exceptions and our record retention policy.
Right to correct
You have the right to correct your Personal Data if inaccurate.
Right to opt-out of sale, sharing, and targeted advertising
We do not knowingly “sell” or “share” Personal Data, including the Personal Data of children under 16 years old. We also do not engage in targeted advertising.
Right to non-discrimination
You have the right to not be discriminated against for exercising any of these rights.

If you would like to exercise one or more of the rights above, please contact us by calling 1.888.414.8658 or consumerprivacy@afslaw.com. You may designate an authorized agent to make a request on your behalf. We will deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

We may need to confirm your verifiable consumer request before completing your request, and, for example, may ask for you to confirm data points we already have about you. We will only use Personal Data provided in a consumer request to verify the requestor’s identity or authority to make the request.

We do not sell or provide your Personal Data to any third party for such third party’s direct marketing purposes and therefore do not respond to requests under California’s “Shine the Light” law.

How We Respond to Do Not Track Signals

Certain web browsers and other programs may be used to signal your preferences about how or whether we or third parties may collect information about your online activities.

Material Changes to this Privacy Policy

ArentFox Schiff reserves the right to change this Privacy Policy from time to time. When we do, we will also revise the “Last Updated” date at the beginning of this Privacy Policy. For material updates, we will give notice and/or place a prominent notice on our Services.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. By continuing to use our Services or providing Personal Data to us, you are agreeing to be bound by any changes or revisions made to this Privacy Policy.

Special Cases

ArentFox Schiff reserves the right to disclose Personal Data in special cases, when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other ArentFox Schiff clients or Services users, or anyone else that could be harmed by such activities. We may disclose Personal Data without notice to you in response to a subpoena or when we believe in good faith that the law requires or permits it or to respond to an emergency situation.

Specific areas or pages of our Services may include additional or different provisions relating to collection and disclosure of Personal Data. In the event of a conflict between such provisions and this Privacy Policy, such specific terms shall control.

Contact Us

For questions about this policy and/or to contact us with any questions, please contact us at: consumerprivacy@afslaw.com or 1.888.414.8658.

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