PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy (the “Policy”) is effective as of May 25, 2018.

Cadwalader, Wickersham & Taft LLP (“Cadwalader”, “we” or the “Firm”) is committed to protecting individuals’ privacy rights, which is why the Firm has developed and implemented this Policy.

This Policy explains:

• the types of personal information we collect about you;
• the means by which we obtain your personal information;
• the ways in which we use your personal information;
• the bases on which we use your personal information;
• who we share your personal information with;
• the length of time for which we keep your personal information;
• how we protect your personal information; and
• where and why we transfer your personal information outside of the EU.

We may collect your personal information in your capacity as a client, potential client, alumnus, job applicant and/or as a visitor or subscriber to our website(s), including www.cadwalader.com, the alumni website www.cadwaladeralumni.com, and the Cabinet website www.findknowdo.com (collectively, “Cadwalader Sites”).

2. DATA CONTROLLER AND RESPONSIBLE OFFICER

Cadwalader, a New York limited liability partnership located at 200 Liberty Street, New York, NY 10281, is the Data Controller responsible for the implementation of this Policy.

Should you have any questions about this Policy or how Cadwalader handles your personal information, please contact Beth Taylor, General Counsel, at [email protected].

3. THE TYPES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect your personal information when conducting our business, including when you contact us, seek information from us, use one of our websites or engage us to provide our legal or other services. We may also collect your personal information for recruiting purposes.

The personal information that we process includes:

• personal identifying information, such as your name (including your name prefix or title);
• employment information, including your employer, your title and your job description;
• background check information to enable us to assess a prospective employee’s suitability for employment;
• contact details, including your postal address, email address and telephone numbers;
• personal information required to satisfy legal requirements, such as your anti-money laundering requirements (for example, passport details);
• financial information (for example, your bank account details);
• technical information (for example, the number of visits you make to our websites, or your receipt and use of materials and communications we send to you electronically);
• personal information you provide to us in advance of and during meetings and events, including your physical access and dietary requirements;
• personal information we receive by or on behalf of our clients, or created by us when providing services to our clients, which may include special categories of data; and
• any other information relating to you that you may provide to us.

4. HOW WE RECEIVE YOUR PERSONAL INFORMATION

We come into possession of your personal information in many ways, including:

• during the monitoring of our technology, including the Cadwalader Sites and email communications sent to and from Cadwalader;
• as part of our business onboarding processes and during the course of our providing legal services;
• when you provide information to us, or during your interactions with us directly, including face‑to‑face interactions with our staff and online interactions using the Cadwalader Sites or email; and
• from third-party sources (including, for example, LinkedIn and other social media).

5. HOW WE USE YOUR PERSONAL INFORMATION

We collect and process your personal information in a variety of ways, including when you use the Cadwalader Sites and when we provide our services to you. When we collect and process personal information, we do this:

• to manage and administer our relationship with clients, vendors and other third parties in the conduct of Cadwalader’s business;
• to market our services, including sending publications and the details of events to our clients and friends;
• to conduct recruitment;
• to administer our websites, including our monitoring of their use;
• to deliver and enhance our services, which may include handling personal information on behalf of our clients;
• to make available information requested by you; and
• to meet any of our legal, regulatory and risk management obligations.

A. Legal and other services

When we provide services to our clients, we may collect, develop, retain and use personal information.

We process personal identification information in order to process new clients and conduct our business acceptance processes, including anti-money laundering, conflict, reputational and financial checks, and as part of our finance, administration and marketing processes.

We will process personal information that our clients, or third parties on behalf of our clients, provide to us for the purposes of providing our services. To the extent reasonably necessary in connection with our services, we may need to share personal information with third parties. Please also see sections 7 and 9 below.

B. Marketing and other emails

If you receive our marketing materials, we may use your personal information to try to understand:

• whether you open our emails or other materials, including Clients & Friends Memos, either by downloading images in the emails or clicking links;
• whether you click on the web links, unsubscribe links or event RSVP links included in our emails and marketing materials;
• whether and how you visit our websites after you click on links we have shared with you, both immediately and on future visits. We do this by using software that places a cookie on your device that tracks this activity and records it against your email address. Please see our Cookie Policies, which are posted on our websites, for more information on how to manage and remove cookies. Refusal of this cookie will not affect your experience on the Cadwalader Sites.

We may also use a relationship management tool, where permitted by applicable local law, to assess the strength of the relationship between individuals in Cadwalader and our clients or potential clients based on the frequency of email contact between them. We use that information in order to assess, analyze and improve the services that we provide.

If you receive marketing communications from us and no longer wish to do so, you may unsubscribe at any time by emailing [email protected].

C. Meetings, events and seminars

When you attend meetings and events organized by Cadwalader or one of its business partners or contractors, we may collect and process personal information about you in relation to your attendance, including your contact information, name and employer. We also may collect special categories of personal information, including dietary requirements, allergies or access requirements, so that we can appropriately cater to your needs and meet any other legal or regulatory obligations we may have. We may share your information with our business partners and contractors who are involved in organizing or hosting the relevant events.

D. Using Cadwalader's websites

When you use the Cadwalader Sites, you may be asked to provide us with personal information; for example, when you sign up to our Cabinet news resource, you will be asked to provide your name and contact information. When you provide us with personal information in this way, we only use it for the purposes stated to you at the time we collect that information.

We also use cookies on the Cadwalader Sites. Please see our Cookie Policies, which are posted on our websites, for more information on how to manage and remove cookies.

6. THE BASES ON WHICH WE USE YOUR PERSONAL INFORMATION

We use your personal information on the following bases:

• the performance of contractual obligations, including the provision of legal and other professional services;
• legitimate business purposes, which are described more fully above in section 5;
• your explicit consent;
• in order to comply with legal and regulatory obligations; and
• the establishment, exercise or defense of legal claims and proceedings.

7. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We are a law firm headquartered in New York, with offices in Charlotte, Washington D.C., London and Brussels. Information that you provide to us may be shared with and processed by any of the Cadwalader offices.

If Cadwalader’s business structure changes in the future, we may transfer your information to new Cadwalader offices or to third parties for the purpose of carrying out Cadwalader’s business.

We may share your personal information with third parties in accordance with the contractual arrangements we have put in place with them, including with:

• our professional advisers and auditors;
• third‑party suppliers we engage to conduct certain services on our behalf, including translators and document reviewers, meeting planners, event organizers and IT service providers; and
• other third parties we engage when providing services to our clients, including local counsel, barristers, experts, data room providers, transcript and case management service providers.

We also may share personal information with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies where such disclosure is necessary to comply with legal or regulatory requirements. Unless we are restricted from doing so by law, we will use reasonable endeavors to notify you before we make any such disclosure.

We do not allow personal information to be made commercially available to any third party unless we have first obtained your prior permission.

8. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We retain your personal information for as long as necessary to comply with our legal, regulatory and professional obligations.

9. TRANSFERRING YOUR PERSONAL INFORMATION TO OTHER COUNTRIES

When providing our services, we may need to transfer your personal information outside of the country in which you are located for the purposes set out in this Policy. This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA to a location within the EEA. Please see section 7 for more detail on how the information may be shared with Cadwalader offices and third‑party service providers.

The level of information protection in countries outside the EEA may be less than that which is offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. Where our third‑party service providers process personal information outside the EEA in the course of providing services to us, appropriate measures, usually standard contractual clauses, will be included in our written agreement for the service provision.

10. HOW WE PROTECT YOUR PERSONAL INFORMATION

Consistent with applicable data protection laws, we utilize technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, alteration or destruction.

Cadwalader holds the internationally recognized security standard BS ISO/IEC 27001:2013 in respect of its document management and email systems and the supporting infrastructure for Cadwalader’s offices globally. This is an independently verified certification that information security is managed in line with international best practice.

11. RIGHTS OF EUROPEAN UNION RESIDENTS REGARDING YOUR PERSONAL INFORMATION

Pursuant to the European Union’s General Data Protection Regulation and other applicable data protection laws, data subjects within the European Union have certain rights that we are obliged to protect.

You are entitled to request details of the information we hold about you and how we process it.

In certain circumstances, you also may have the right to have the information that we hold about you rectified or deleted, restrict our processing of that information, request that we stop unauthorized transfers of your personal information to a third party, and request that we do not transfer information relating to you to another organization. You also may have the right to lodge a complaint in relation to Cadwalader’s processing of your personal information with a local supervisory authority.

Where you object to our processing of your personal information, or where you withdraw consent previously given, we may not be able to achieve the purposes set out above in section 5 or you may not be able to use our services and products.

Where you object to our processing of your personal information, or where you withdraw consent previously given, it is important to understand that we may be able to continue to process your personal information to the extent required or otherwise permitted by law, particularly in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

Please inform us of any changes to your information by emailing us at [email protected] so that we can keep your information up to date.

12. MAKING A COMPLAINT

We strive to meet the highest standards when handling your personal information and deal seriously with any complaints we receive.

If you think that our collection or use of information is unfair, misleading or inappropriate, please bring it to our attention by contacting our General Counsel whose details are set out in section 2 of this Policy. We also welcome suggestions for improving our procedures.

If you are located within the European Union and are not content with our response to your complaint, you may request that the UK Information Commissioner’s Office investigate the matter further by contacting:

Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone: (UK) 0303 123 1113 / (abroad) 44 1625 545 700.

13. CHANGES TO OUR PRIVACY POLICY

Cadwalader reserves the right to change this Policy from time to time as needed.

CADWALADER CABINET COOKIE POLICY

INFORMATION ABOUT OUR USE OF COOKIES

What are cookies?

Cookies are small text files that are stored in your computer’s memory and hard drive when you visit certain web pages. They are used to enable website to function or to provide information to the owners of a website. A cookie cannot read data from your hard disk or read cookie files created by other site.

Why do we use cookies?

Our website (www.findknowdo.com) uses cookies to distinguish you from other site users. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

In broad terms, we use the following cookies:

• Session management cookies. The software that runs our site uses cookies for technical purposes needed by the internal workings of our servers and applications. For instance, we use cookies to keep track of information about a user’s session and determine which options or pages to display in order for the site to function.

• Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, such as (if applicable to you) the Cadwalader Alumni Network.

• Analytical/performance cookies. These cookies allow us to recognize and count site visitors and to see how visitors move around our site when they are using them. This helps us to improve the way our website work, for example, by ensuring that users are finding what they are looking for easily. For these purposes, we may store the following information:

  • your browser type

  • the name of the domain from which you accessed the internet

  • the date and time you accessed our site

  • the advert or internet address of the site from which you linked directly to our site

  • the pages you accessed while visiting our site and the links you followed

  • the device from which you accessed our site

  • the location from which you accessed our site

  • the search terms you used

In addition, we use third party service providers to provide certain analytics services to us in connection with the operation of the site, including (without limitation) the collection and tracking of the data and information listed above. We may disclose visitor data, including personal data, to enable those third party service providers to provide their services. This data may be sent to those third party service providers and their local overseas suppliers, where the standard of data protection may be lower than the country in which you reside.

• Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We use this information to make our site and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose. For example, if you click through to one of our site from one of our emails or landing pages, we use cookies to connect the marketing you have received with your website journey. This helps us to provide you with the best user experience and relevant content.
• Functionality cookies. These cookies are used to recognize you when you return to our site and enable us to remember the choices you make when using our site.
• Subscribers: The information collected is supplied by the user or the company who signed them up. This info includes at present:
  First and Last name
  Professional Field
  Company Name
  Department
  Job Title

  Subscribers may also set bookmarks to pages on our site or subscribe to a weekly alerts bulletin. These opt-in choices are also stored on our website.
  Subscribers' web browsing logs are kept for up to 6 months and include the user's IP address as well as their username and the pages they've visited.

Third party cookies

Please note that, when you visit our site, you may also receive cookies set by third parties (including, for example, advertising networks and providers of external services such as web traffic analysis services). We have no control over these cookies; however, they are likely to be analytical/performance cookies or targeting cookies.

Amending cookie preferences

If you prefer not to receive cookies through our site, you may set your browser to warn you before accepting cookies and refuse the cookies when your browser alerts you to their presence. You may also delete cookies that have already been placed on your device or refuse all future cookies by turning them off in your browser. Cookies are required to access some pages within our site at www.findknowdo.com.

The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. But you may find further guidance, together with more information on cookies, at: www.allaboutcookies.org.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cadwalader reserves the right to change this policy from time to time as needed.