California Consumer Privacy Notice

简介

Last updated: November 2023

This California Consumer Privacy Notice (this “California Notice”) supplements Shearman & Sterling’s main Privacy Notice in order to provide information that is required under the California Consumer Privacy Act of 2018 and its implementing regulations (“CCPA”). This California Consumer Privacy Notice applies solely to California residents and uses certain terms that are defined under the CCPA.

In this California Notice, references to “Shearman & Sterling”, the “Firm”, “we” and “us” are references to Shearman & Sterling LLP together with its affiliated entities, including Shearman & Sterling (London) LLP, a limited liability partnership through which we practice in the United Kingdom, and Shearman & Sterling, a partnership through which we practice in Hong Kong. Shearman & Sterling LLP also practices in Saudi Arabia in association with a Saudi firm, Dr. Sultan Almasoud & Partners, and in Italy in association with Studio Legale Associato Shearman & Sterling LLP. 

For additional information about our data practices: Please see our main Privacy Notice.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT 

The Personal Information that we may collect (and may have collected from you in the past 12 months)—with reference to the statutory categories of Personal Information defined under CCPA—include the following:

  • Identifiers, including your name, addresses, telephone numbers and email addresses, social security, passport, driver's licence or other national or state identification number, user names and login credentials for our systems, IP address and other unique personal identifiers;
  • Additional Personal Information described in Section 1798.80(e) of the California Civil Code, including your signature, physical characteristics or description, financial account number, credit or debit card number, insurance policy number, education, employment, employment history, medical information and health insurance information;
  • Characteristics of protected classifications under federal or California law, including race, gender, age, national origin, religion, mental or physical disability, citizenship status, sexual orientation, gender identity or gender expression and medical conditions;
  • Commercial information, including records of personal property and purchasing information about products or services;
  • Biometric information;
  • Internet or Other Electronic Network Activity Information, including system and application access and activity logs, internet browsing history, and interactions with our or others’ websites and applications;
  • Geolocation data, such as city, state or geographic area, but generally not precise geolocation data unless that relates to accessing our office premises or is relevant to a client matter;
  • Audio, electronic, visual and similar information, including photographs and video and audio recordings used in connection with our business activities;
  • Professional or employment related information, including information provided in connection with legal services we provide to our clients, in presenter bios collected for events or presentations or if you apply for employment with the Firm;
  • Education information, as defined under the Family Educational Rights and Privacy Act; and
  • Inferences, which may be drawn from the Personal Information described above to create an individual profile.
SOURCES OF PERSONAL INFORMATION 

As a law firm, we regularly receive Personal Information as part of our professional activities. We may collect Personal Information:

  • As part of our business intake procedures;
  • When you or your organization seek legal advice or representation from us;
  • In the course of representing and counseling our clients;
  • When you or your organization offer or provide services as our vendor;
  • When you apply for employment or other roles with the firm;
  • When you browse or interact with our website(s), use any of our online services; or
  • When you email us or provide such data to us in other circumstances, such as when you request details about or attend a firm-sponsored event, or when you engage with the alumni or careers portal.

Ordinarily, you will provide any such personal data to us directly. In some cases, we may collect data about you from your organization, public records or third parties, such as government or credit reporting agencies, or via service providers that we may engage as part of the work we perform for our clients.

“Do not track” requests

We do not currently respond to “do not track” requests made through browser settings.

PURPOSES FOR WHICH YOUR PERSONAL INFORMATION WILL BE USED 

We use the Personal Information we have collected for some or all of the following business and commercial purposes:

  • Providing legal advice, representation or other services to our clients;
  • Managing our business relationship with you or your organization, including in connection with services we provide to you;
  • Recruiting for roles with the firm;
  • Complying with legal, regulatory and professional obligations, including court orders and anti-money laundering and sanctions checks;
  • Managing and securing access to our offices and facilities, as well as our systems, online platforms and other technology;
  • Communicating with you with about legal and business developments, firm announcements and other news and events of interest to you, or to improve the quality of our communications and interaction with you;
  • Processing that is otherwise necessary for purposes of the legitimate interests of the firm or third parties; and
  • For any other purpose described at the time you provide us with personal data, or for other purposes that are compatible with the original purpose for which we collected your personal data, with your consent, or as otherwise described in this California Notice or our Privacy Notice.
DISCLOSURES OF PERSONAL INFORMATION 

For each category of Personal Information described above in this California Notice, in order to meet the business and commercial purposes described above, we may have shared such Personal Information during the past 12 months with any of the following categories of third parties:

  • Clients and other parties involved in client matters or those other parties’ counsel;
  • Courts, government agencies and industry regulators;
  • Vendors, service providers and consulting experts;
  • New Shearman & Sterling entities or third parties through which the business of Shearman & Sterling will be carried out in the future.

Additionally, we may have shared any of the described categories of Personal Information with third parties during the past 12 months as necessary in the following circumstances:

  • To comply with our legal or professional obligations, a court order or other governmental or legally enforceable demand;
  • To establish or protect our legal rights, property or safety, or the rights, property or safety of others, or to defend against legal claims; or
  • In the event of any reorganization, merger or similar organizational event or transaction involving the firm.

Sharing Personal Information within Shearman & Sterling

In addition to disclosures to third parties, we may share Personal Information among the Shearman & Sterling offices in order to provide services to our clients or for our business operations. A list of our offices is available at https://www.shearman.com/contact-us.

No disclosures for others’ direct marketing or sale of data

It is our policy not to provide your personal data to third parties for those third parties' direct marketing purposes without your consent.

No “sales” of Personal Information

We do not “sell” Personal Information, as “selling” is defined under CCPA.

RIGHTS OF CALIFORNIA RESIDENTS 

Where applicable and with certain exceptions, California residents have the following privacy rights under the CCPA:

  • The right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used and disclosed about you during the past 12 months;
  • The right to request access, or a copy of the specific pieces of Personal Information we have collected about you;
  • The right to request that we delete Personal Information we collected from you;
  • The right to not be discriminated against for exercising any of your rights under the CCPA.

How to Exercise CCPA Rights

If you are a California resident and wish to exercise any of your rights under the CCPA, please send a request to data.privacy@shearman.com, or you may call 866-408-9293.

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you would like to designate an agent, please send an email from your own address to data.privacy@shearman.com indicating the name and email address of your agent. If you request access to or deletion of your personal information, we may require you to provide any of the following information:

  • verification via a password protected account you maintain with the firm; or
  • an email from your email address that is associated with the information we maintain; and at least one further data point (not including your name) relevant to your relationship with us, which we will specify.

In addition, if you ask us to provide you with specific pieces of personal information, we will also require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. 

If a request is made on your behalf by an agent, we will take appropriate steps to confirm that the agent is properly authorized to make such a request.

Please also understand that we are not obliged to provide you with a copy of Personal Information more than twice in a 12-month period.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

UPDATES TO THIS NOTICE 

We may update this California Consumer Privacy Notice from time to time to reflect changes in legal requirements or our processing practices. Any such changes will be posted on this website, with the date at the top of the privacy notice providing the date it was last updated. Changes to this California Notice will be effective upon posting.

HOW TO CONTACT US 

If you have any questions or comments about this California Consumer Privacy Notice, or our collection and handling of your Personal Information, please email us at data.privacy@shearman.com, or you may write to us via postal mail at:

Shearman & Sterling
Attn: Director of Data Privacy
9 Appold Street
London EC2A 2AP
United Kingdom