WENDEL ROSEN LLP WEBSITE PRIVACY POLICY
Effective Date: 12/31/19

Wendel Rosen (the “Firm,” “We,” “Us,” or “Our”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.wendel.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by the Firm or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Throughout this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy, below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@wendel.com. California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights, below, for more information.

Information We Collect About You and How We Collect It

In most cases, we collect Personal Information directly from you. Below are descriptions of the different types of Personal Information we process and the sources from which we obtain them:

• Clients. If you are a client of our firm, we collect your name, contact details, payment information, and any other information you provide to us or we otherwise obtain from third parties (e.g., from public bodies, from the opposing party etc.) when providing legal services to you. The type of information we collect from our clients varies depending on the matter and may include information about our client’s employer, employee(s), customer(s), and vendor(s) (e.g., name, contact details), communications with our client, information provided by our client, and any other information that may be relevant for the matter we are representing you in.
• Events. We collect Personal Information about you if you choose to register for an event sponsored by our firm. This Personal Information may include your name, address, title, company, phone number, and email address, as well as specific information relevant to the event for which you are registering.
• Client Emails/Alerts/Newsletters. We offer a wide selection of blogs, newsletters, client alerts, and programs on topics of interest to our clients and others focusing on key legal, regulatory, and industry trends. If you sign up to receive such information or accept our invitations to informational programs and networking events, we will ask you to provide your first and last name, company, email address, and possibly the practice areas and industries that you are interested in.
• Communications. If you choose to contact us for any purpose, we will collect your contact details, your name, and the content, date and time of your message, as well as our reply and any follow up action we take in relation to your inquiry.
• Other sources. We may receive Personal Information about you from other sources, including third parties that help us update, expand, and analyze our records, identify new customers, or prevent or detect fraud. We may also receive information about you from social media platforms, for example when you interact with us on those platforms or access our social media content. The information we may receive is governed by the privacy settings, policies, and/or procedures of the relevant social media platform, and we encourage you to review them.

However, we may also obtain several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline;
• If you apply for a job with us via our website, you may be asked to enter or upload your first, middle and last name, address, phone, email address, resume and transcripts, law school, graduation year, desired position , reference(s), a cover letter, writing sample(s), deal sheet and/or additional work product samples.
• About your internet connection, the equipment you use to access our Website, and/or usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
• From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

• Records and copies of your correspondence (including email addresses), if you contact us.
• Your search queries on the Website.
• Information as it relates to applying for employment at Wendel Rosen.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website such as our blogs, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including [traffic data,] [location data,] [ISPs,] and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

The following shows the function of each of those cookies:

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

• To present our Website and its contents to you.
• To provide you with information or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To manage our business relationships with clients, vendors and suppliers, business partners, cooperating law firms and other contractors, including processing invoices and sending service-related communications.
• For recruitment purposes, including to evaluate job applications, invite you for a job interview, and to communicate with you and respond to your inquiries.
• For marketing purposes, including to send client alerts, newsletters and other communications to our clients and business contacts. We may also use your Personal Information to register you for, and confirm your attendance at, events; furnish biographical details to other attendees or co-presenting/sponsoring business partners; and assess the effectiveness of our events, promotional campaigns, and publications.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose Personal Information that we collect or you provide as described in this privacy policy:

• To contractors, service providers, and other third parties we use to support our business e.g., accountants, insurance companies, banks, auditors, Wendel Rosen’s network of external legal counsel and other professional experts, advisors and/or consultants engaged by Wendel Rosen).
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of assets, stock or membership interests, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about you is relevant to the assets, stock or membership interests transferred.
• To fulfill the purpose for which you provide it (e.g., legal representation, billing, client alerts/newsletters/event invitations, engagement with us through social media).
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Wendel Rosen, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

Additionally, we take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. For example, we keep client records for the length of the client relationship and for maximum of ten (10) years after we close the matter. When determining the retention period, we take into account various criteria, such as the nature and length of our relationship with you, mandatory retention periods provided by law and the statute of limitations, the type of legal services requested by or provided to you, the possible ongoing relationship of you with our firm, and the impact on our legal services if we delete some information from or about you.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. The date the privacy policy was last revised is identified at the top of the page. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

If you have any questions or comments about this privacy policy, the ways in which we collect and use your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 510.834.6600
Website: www.wendel.com
Email: privacy@wendel.com

Postal Address:
Wendel Rosen LLP
Attn: Ms. Ginger Wilson
1111 Broadway, 24^th Fl
Oakland, CA 94607

 

Wendel Rosen LLP Privacy Notice for California Residents
Effective Date: December 31, 2019

This Privacy Notice for California Residents supplements the information contained Wendel Rosen LLP’s general privacy policy and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, Wendel Rosen LLP’s website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A name, email address, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, telephone number, education or employment. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (18 years or older) and gender.	Yes
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location.	Yes
H. Sensory data.	Electronic or thermal information.	Yes
I. Professional or employment-related information.	Current or past job history.	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

‌Personal information does not include:

• Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

‌Wendel Rosen LLP obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete with regard to service inquiries or employment inquiries.
• Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and business development, including to develop and improve our Website and services.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Wendel Rosen LLP will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Wendel Rosen may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

• Service providers.
• Consultants and/or expert witnesses.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Wendel Rosen has not disclosed personal information for a business purpose.

Sales of Personal Information

In the preceding twelve (12) months, Wendel Rosen has not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Wendel Rosen LLP disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Wendel Rosen LLP delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

• Calling us at 510.834.6600
• Emailing privacy@wendel.com
• Writing us at Wendel Rosen LLP, Attn: Ms. Ginger Wilson, 1111 Broadway, 24th Fl, Oakland, CA 94607

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. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.

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

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

‌Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@wendel.com or write us at: 1111 Broadway, 24th Fl, Oakland, CA 94607.

Changes to Our Privacy Notice

Wendel Rosen LLP reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Wendel Rosen LLP collects and uses your information described below [and in the Privacy], your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 510.834.6600
Website: www.wendel.com
Email: privacy@wendel.com

Postal Address:
Wendel Rosen LLP
Attn: Ms. Ginger Wilson
1111 Broadway, 24th Fl
Oakland, CA 94607