Last Updated: 03.12.2024
This Privacy Policy (“Policy”) explains how Perkins Coie LLP and its affiliates (“Perkins Coie,” the “Firm”, “we,” or “us”) collect, store, use, and disclose personal information about you when you interact with us as set out in the Scope section.
We may change this Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Policy,and in some cases, we may provide you with additional notice (such as by adding a statement to our website homepage). Weencourage you to review this Policy frequently to stay informed about our information practices and the choices available to you.
CONTENTS
- Scope
- Collection of Personal Information
- Use of Personal Information
- Disclosures of Personal Information
- Data Retention
- Your Privacy Rights and Choices
- Links to Other Websites and Third-Party Content
- Data Transfers
- Additional Information for Individuals in California
- Individuals in the EEA, UK, or Switzerland
- Contact Us
SCOPE
This Policy describes our practices in connection with personal information that we collect, use, and disclose:
- When you access or use our websites, mobile applications, and other online services (collectively, the “Websites and Apps”);
- When you apply for a job with us (“Job Applicants”);
- In connection with our client onboarding process and disengagement, the information collected during the client relationship, andthe information gathered from prospective clients (“Client Services”);
- About individuals who communicate with Perkins Coie in a business capacity such as vendors, professional service providers, adverse parties, and expert witnesses;
- When you visit our offices or attend our events; and
- Through any other business interactions you may have with us.
Collectively, we refer to the above as the “Services.”
COLLECTION OF PERSONAL INFORMATION
The personal information we collect about you depends on how you interact with us or use our Services. We describe below the categories of personal information we collect and the sources of this information.
Personal Information You Provide to Us
We collect personal information you provide directly to us including when you subscribe to receive our emails, access or use any collaboration tools, participate in any interactive features of the Websites and Apps, send us an email, fill out a form, respond to a survey, comment on a blog, register for or participate in a webinar or event, apply for a job with us, interact with us on social media, enter a promotional drawing, participate in a contractual arrangement for Client Services, provide information in conjunction with Client Services, or otherwise communicate with us.
The types of personal information we may collect include:
- Contact information, such as name, email address, postal address, phone number, and social media profiles;
- Education information, such as educational degrees, languages, professional memberships, qualifications, and certifications;
- Employment information, such as business unit/division, company name, job status and title, employment history, office location, and LinkedIn profile information;
- Health and health-related information, such as accessibility requirements, dietary restrictions, and, where necessary and appropriate to protect the health and safety of our personnel and others, information related to symptoms of, or risk of exposure to, certain illnesses;
- Government-issued identification numbers such as social security number, driver’s license number, alien number, or state-issued identification number in connection with Job Applicants or to provide Client Services;
- Recruitment information, such as your resume, cover letter, references, employment application, recorded interviews, information provided to us during an interview, interview notes, background check information, and assessment of recruitment information
- Photos, videos, and audio files that contain images or voice recordings;
- Demographic information, which may include information about protected classifications, such as age, gender, race/ethnic origin, and nationality;
- Information necessary to provide Client Services including:
- commercial and financial information, such as invoices, payment information, bank account statements, tax returns, and asset and net worth information;
- identity-related information such as birth certificate, residency status, visa information, and military status;
- demographic information including sexual orientation, political opinions, union membership, health information, and information about physical or mental disability; and
- other information provided in connection with making and defending legal claims and providing legal advice.
- Any other information you choose to provide in connection with the Services.
Personal Information We Collect Automatically
We automatically collect personal information when you access or use the Websites and Apps. The types of personal information we collect may include:
- Log Information: We collect log information about your use of the Websites and Apps, including your browser type and language, app version, access times, pages viewed, Internet Protocol (“IP”) address, links clicked, approximate geographic location, and the webpage you visited before navigating to the Websites and Apps.
- Device Information: We collect information about the mobile device you use to access the Websites and Apps, which may include the hardware model, operating system and version, unique device identifiers, and mobile network information.
- Location Information: In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Privacy Rights and Choices section below for details).
- Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information about your use of the Websites and Apps and other websites and applications, including cookies and web beacons (or pixel tags). Cookies are small data files stored on your hard drive or in device memory that help us to, among other things, improve the Websites and Apps and your experience, see which areas and features of the Websites and Apps are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used on the Websites and Apps or in our emails and help deliver cookies, count visits, understand usage and campaign effectiveness, and determine if an email has been opened and acted upon. For more information about removing or rejecting cookies, please see Your Privacy Rights and Choices section below.
Personal Information We Collect From Other Sources
We may also collect personal information about you from other sources, including publicly available databases, and combine that with information we collect through the Services. For example, we may use information from LinkedIn to update information about you in our contact database.
Personal Information We Derive
We may derive information or draw inferences about you based on other types of personal information we collect. For example, we may infer your location based on your IP address, or that you are interested in employment or participating in an event based on your browsing behavior on our Services.
USE OF PERSONAL INFORMATION
We use the personal information we collect from and about you for the following business purposes:
- Service improvement and analytics, such as to personalize and improve your experience on the Websites and Apps; monitor and analyze usage, trends, and activities related to the Websites and Apps, and identify, report, and repair errors that impair the functionality of the Websites and Apps;
- Contractual purposes, such as to enter into or carry out contracts;
- Marketing, such as to send newsletters, updates, and other communications we think will be of interest to you, including about our services, programming, and events unless you have opted out of such communications (see Opting Out of Marketing Communications for more information) and to administer surveys and promotional drawings;
- Firm-sponsored events, such as to fulfill your event registration requests and provide services, including the provision of seminars and other events, and to facilitate any continuing legal education credits earned;
- Facility access and security, such as using personal information to register and host you at our offices, as well as to ensure the security of our physical offices;
- To manage our hiring and recruiting activities, such as to assess your skills, qualifications, and suitability for a particular role or opportunity, communicate with you about the recruitment and hiring process, respond to your requests, inquiries, and comments, verify your information, complete your reference and/or background checks (where applicable) if we offer you a position or other opportunity with us, and improve our recruitment and hiring process more generally;
- Communication purposes, such as communicating with you about professional services you provide to the Firm and the Client Services we provide, responding to your questions, comments, and requests when you contact us, and providing information or services you request and sending you related information;
- Client Services, including to:
- advise on current, prospective, or potential legal claims, provide personal or estate planning guidance; ensure compliance with legal obligations; assist with due diligence and commercial deals; advise on mergers and acquisitions; and various other legal activities; and
- facilitate client intake and administration, including generating bills, invoices, and disbursements;
- Legal and compliance purposes, such as to implement internal policies, detect, investigate, and respond to suspected fraud, security incidents, or other activity that is illegal or violates our policies, exercise a legal claim, cooperate with law enforcement investigations, and comply with applicable laws, regulations, legal processes, or governmental requests;
- As necessary and appropriate to provide reasonable accommodations;
- To protect the health, safety, and vital interests of the Firm, personnel, applicants, or another natural person; and
- To enable solely internal uses in a lawful manner that are reasonably aligned with your expectations based on our interactions with you and that are compatible with the context in which the information was provided to us.
DISCLOSURES OF PERSONAL INFORMATION
We may disclose your personal information as follows or as otherwise described in this Policy:
- Related entities, including to our affiliates, subsidiaries, and other companies under common control and ownership;
- State bar associations, in connection with an application for continuing legal education credit;
- Service providers and contractors, that provide services on our behalf or help operate the Services such as information technology and software services, mailing services, marketing services, event management services, background check providers, and cyber and physical security services. These service providers and contractors may also include our legal support vendors, such as e-discovery providers, deposition services, and litigation support vendors, as well as experts, consultants, and other professionals that assist in connection with Client Services;
- Professional advisors, such as lawyers, auditors, bankers, and insurers, in the course of the professional services that they render to us;
- Third parties designated by you, to provide the services that you have requested;
- Third parties relating to providing Client Services, such as opposing counsel, court reporters, courts, mediators, regulators, and other legal authorities;
- Business and marketing co-sponsors, such as third parties with whom we co-sponsor events;
- Business transferees, such as in connection with, or during negotiations of, any merger, financing, divestiture, restructuring, reorganization, dissolution, or other sale of Perkins Coie’s assets or acquisition of all or a portion of our business to another company;
- Authorities and others, when we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
- Disclosures to our enforce agreements or policies if we believe your actions are inconsistent with our agreements or policies, or to protect the rights, property, and safety of us or any third party; and
- With your consent or at your direction, including if we notify you that your personal information will be disclosed in a particular manner and you provide such personal information.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. Perkins Coie processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.
DATA RETENTION
To determine the length of time the Firm retains personal information period, the Firm considers numerous factors, including legal, ethical, and regulatory obligations or whether retention of personal information is needed to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes, and/or enforce agreements.
YOUR PRIVACY RIGHTS AND CHOICES
You have certain choices with respect to your personal information, as described below.
Data Subject Requests
Depending on where you reside, you may have the right to: (1) know more about and access the personal information we collect, use, and disclose about you and to receive your data in a portable format, (2) delete your personal information, (3) correct inaccurate personal information, and (4) object to, or request that we restrict, certain processing. You may make these requests by calling 1.800.829.1177, emailing privacy@perkinscoie.com, or by visiting this page. We will verify your request by asking you to provide information sufficient to confirm your identity, such as your name, email address, and information about your interactions with us. If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney, or that the agent otherwise has valid signed authority to submit requests on your behalf, and ask that you verify your identity directly with us.
Opting Out of Marketing Communications
You may opt out of receiving promotional communications from us or request changes to your communication preferences by following the instructions in those communications or visiting our unsubscribe page. If you opt out, we may still send you nonpromotional communications, such as those about your account or our ongoing business relations.
Location Data
When you first launch any of our mobile applications that collect precise location information, you will be asked to consent to the application’s collection of location information. If you initially consent to our collection of this information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. You may also stop our collection of this location information by following the standard uninstall process to remove our mobile apps from your device. If you do so, our mobile applications, or certain features thereof, may no longer function properly.
Mobile Push Notifications/Alerts
With your consent, we may send push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. For European Economic Area (“EEA”) and UK residents, you can also change your cookie settings at any time by using the cookie icon in the lower left-hand corner of the page.
LINKS TO OTHER WEBSITES AND THIRD-PARTY CONTENT
We may provide links to or embed videos hosted by third-party websites, services, and applications, such as YouTube, that Perkins Coie does not operate or control. This Policy does not apply to third-party services, and we cannot take responsibility for the content, privacy policies, or practices of third-party services. We encourage you to review the privacy policies of any third-party service before providing any information to or through them.
DATA TRANSFERS
Perkins Coie is headquartered in the United States and we have operations and vendors in the United States and other countries. Therefore, we and those who perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. While in another jurisdiction for processing, the courts, law enforcement, and national security authorities of that jurisdiction may access your personal information.
If you are in the EEA, Switzerland, or the UK, we provide adequate protection for the transfer of personal data to countries outside of those jurisdictions by adhering to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the US Department of Commerce (see Data Protection Framework).
ADDITIONAL INFORMATION FOR INDIVIDUALS IN CALIFORNIA
The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020, (collectively, the “CCPA”) requires us to explain some information using definitions and categories set out under the CCPA. If you are a California resident, this section applies to you.
Categories of Personal Information Collected and Disclosed
We collect, and in the preceding 12 months, we have collected, the following categories of personal information: identifiers (such as your name, email address, and IP address), characteristics of protected classifications under California or federal law (such as your age), commercial information (such as events attended), internet and electronic network activity information (such as browsing history, search history, information about your activities on our Websites and Apps), geolocation data (such as the Firm offices visited), audio, electronic, visual, and similar information (such as recordings of selected events, conferences, or meetings), and professional or employment-related information (such as job title and employment history). For more information on the precise datapoints we collect, please see the Collection of Personal Information section above.
In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:
Categories of Personal Information | Categories of Recipients |
Identifiers | Cloud service providers, marketing service providers, event management software and event service providers, visitor management software providers, data analytics providers, software development providers, search firms and headhunters, recruiting software providers, internet service providers, data storage providers, other users of our Websites and Apps, background check providers, state bar associations, legal support vendors, opposing counsel, witnesses and potential witnesses, court reporters, regulators, courts, mediators, and legal authorities. |
Characteristics of protected classifications under California or US law (such as your age). | Cloud service providers, event management software and event service providers, data analytics providers, software development providers, search firms and headhunters, recruiting software, law schools, background check providers, legal support vendors, opposing counsel, witnesses and potential witnesses, mediators, court reporters, regulators, courts, and legal authorities. |
Commercial information. | Cloud service providers, marketing service providers, event management software and event service providers, data analytics providers, internet service providers, data storage providers, and operating systems and platforms. |
Internet and electronic network activity information. | Cloud service providers, marketing service providers, software development providers, data analytics providers, internet service providers, data storage providers, and operating systems and platforms. |
Geolocation data. | Cloud service providers, marketing service providers, software development providers, data analytics providers, data storage providers, and operating systems and platforms. |
Audio, electronic, visual, and similar information. | Cloud service providers, data analytics providers, data storage providers, operating systems and platforms, legal support vendors, opposing counsel, witnesses and potential witnesses, court reporters, regulators, courts, mediators, and legal authorities. |
Professional or employment related information. | Cloud service providers, marketing service providers, event management software and event service providers, data analytics providers, software development providers, search firms and headhunters, recruiting software, internet service providers, data storage providers, background check providers, state bar associations, legal support vendors, opposing counsel, witnesses and potential witnesses, court reporters, regulators, courts, mediators, and legal authorities. |
Privacy Rights
Please see the “Your Privacy Rights and Choices” section above for more information about your privacy rights and how to exercise them (including as an authorized agent of someone else), and how we will verify requesters. We will not discriminate against you if you choose to exercise your rights under the CCPA.
Other Details About Our Information Practices
- We do not “sell” or “share” and have not “sold” or “shared” personal information in the preceding 12 months under the laws applicable to you.
- The Firm does not knowingly sell or share personal information about individuals under the age of 16.
- The Firm does not use or disclose sensitive personal information for the purpose of inferring characteristics about you.
- For details about the Firm’s data retention practices, see the Data Retention section of our Policy.
INDIVIDUALS IN THE EEA, UK, OR SWITZERLAND
If you are located in the EEA, the UK, or Switzerland, you have certain rights and protections under applicable laws regarding the processing of your personal data, and this section applies to you.
Legal Basis for Processing
When we process your personal data, we will do so in reliance on the following lawful bases:
- To perform our responsibilities under our contract with you or to take steps at the request of the data subject prior to entering into a contract (e.g., processing payments for and providing the products and services you requested).
- When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
- To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
- When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing of your personal data, you may withdraw such consent at any time.
- When processing is necessary to protect the vital interests of the Firm, personnel, applicants, or another natural person (e.g., in the case of a medical emergency).
Privacy Rights
Subject to certain limitations, you have the following privacy rights:
- Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information. This enables you to receive a copy of the personal information we hold about you and certain other information about it.
- Correction: you are entitled to request that any incomplete or inaccurate information we hold about you be corrected.
- Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
- Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Portability: you may ask us to help you transfer certain of your personal information to another party.
- Objection: where we are processing your personal data based on a legitimate interests (or those of a third party), you may challenge this. However, we may be entitled to continue processing your information in case there are compelling legitimate grounds to do so. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
- Consent: where we are processing personal data with consent, you can withdraw your consent.
If you would like to exercise any of these rights, please contact us at privacy@perkinscoie.com or visit Your Privacy Rights and Choices above.
Data Retention
For details about the Firm’s data retention practices, see the Data Retention section of our Policy.
The Data Protection Framework
Perkins Coie complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and theSwiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) (together, the DPF) as set forth by the US Department of Commerce.
Perkins Coie has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles(EU-U.S. DPF Principles) with regard to the processing of personal information or personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Perkins Coie has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.
If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles shall govern.
To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Perkins Coie adheres to the DPF Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.
Perkins Coie Internal Complaint Mechanism
In compliance with the EU-US DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Perkins Coie commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact us at privacy@perkinscoie.com or visit Your Privacy Rights and Choices above.
Enforcement, Lawful Disclosures, and Onward Transfers
Perkins Coie is subject to the investigative and enforcement authority of the Federal Trade Commission (FTC). Perkins Coie may be required to disclose personal information in response to lawful requests by public authorities. Perkins Coie has liability for onward transfers to third parties unless we can prove we were not a party to the events giving rise to the damages.
Alternate Dispute Resolution Body
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Perkins Coie commits to refer unresolved complaints concerning our handling of personal information received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to the JAMS Data Privacy Framework (DPF) Dispute Resolution,. an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit the JAMS Data Privacy Framework (DPF) Dispute Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Right to Invoke Binding Arbitration
For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.
Supervisory Authorities and Right to Lodge a Complaint
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the linksbelow:
For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
CONTACT US
If you have any questions or comments about this Privacy Policy, you may email us at privacy@perkinscoie.com.