Important information about your privacy
The Policy (the “California Residents Notice”) provides additional information for California residents, as required under the California Consumer Privacy Act of 2018 (“CCPA”). This section is effective January 1, 2020. We may update this section, our relevant data practices, or our processes for handling CCPA requests, in response to the final CCPA regulations or other CCPA legal developments.
Withers LLP (“we”, “us” and “our”) is the ‘data controller’ for the personal information you share with us.
If you have any specific concerns around the privacy of your personal information or require further information about how we manage your personal information, please get in touch with us directly:
CCPA Officer, Withers Bergman LLP, 505 Sansome Street, 2nd Floor, CA 94111
+1 415 872 3237
Privacy Information for California Residents (Supplemental)
This California Residents Notice applies to the personal information we collect, both online and offline, about California consumers, including personal information that we collect:
- from users of our Websites, including the services available via our Websites
- about clients and individuals that use or inquire about our legal and related services that we make available
- about individuals that attend events hosted or sponsored by us, reply to our emails or communications, visit our offices, or otherwise communicate or engage with us
- about individuals from clients and others related to the Services we provide
As used in this California Residents Notice, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household; it does not include publicly available information made lawfully available by state or federal governments or anonymised information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked directly or indirectly to a particular individual.
A list of what is defined under the CCPA as personal information includes:
- direct identifiers such as real name, alias, postal address, social security numbers, driver’s license, passport information and signature
- indirect identifiers such as cookies, beacons, pixel tags, telephone numbers, IP addresses, account names
- biometric data such as face, retina, fingerprints, DNA, voice recordings, health data
- geolocation data such as location history via devices
- internet activity such as browsing history, search history, data on interaction with a webpage, application or advertisement
- sensitive information such as personal characteristics, behaviour, religious or political convictions, sexual preferences, employment and education data, financial and medical information
Categories of personal information that we may collect and disclose
Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. Pursuant to the CCPA, we may collect and disclose for a business purpose the following categories of personal information (as defined by the CCPA).
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Protected classification characteristics under California or federal law
- Commercial information
- Biometric information
- Internet or other similar network activity
- Geolocation data
- Sensory data
- Professional or employment-related information
- Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
- Inferences drawn from other personal information
Sources of personal information
We may collect the above categories of personal information directly from you, automatically about your use of our Websites, and from third parties such as clients of our legal services, government and public entities, public records, data aggregators and resellers, parties and related parties in litigation matters and others.
Purposes for collecting, using and disclosing personal information
We use these categories of personal information we collect to provide our legal and other Services (See the ‘HOW WE USE YOUR PERSONAL INFORMATION’ section above for more information)
Rights of California residents under the CCPA
The California Consumer Privacy Act (CCPA) provides California residents with five core rights to data privacy and autonomy, and an additional private right of action of compensation in the event of data breaches:
Right to notice
We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
Right to deletion
California residents have the right to request, at no charge, deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.
Right to disclosure
California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.
Right to opt out / Do-not-sell (opt-out/opt-in)
California residents have the right to opt-out of our sale of their personal information. Further businesses may not knowingly sell personal information about minors under 16 years old without prior express consent.
Right to equal services and prices
We do not offer any such incentives at this time.
Not covered by this California Notice
This California Residents Notice does not address or apply to:
- our handling of personal information that is exempt under Section 1798.145 of the CCPA,
- personal information we collect about employees, contractors or job applicants or other individuals who are not California residents, or
- personal information we collect about individuals acting in their capacity as representatives (“B2B contacts”) of our clients, prospective clients, vendors and other businesses that we conduct business with, to the extent we use their personal information only in the context of conducting our business relationship with the respective business.
California residents may contact us directly using the information detailed in the table near the top of this page. We will respond to verifiable requests received from California residents as required by law.