Effective Date: May 25, 2018

Kelley Drye & Warren LLP (“Kelley Drye”) respects your privacy and is committed to protecting your data.  This Website Privacy Policy describes the types of data that Kelley Drye collects from and about you when you visit our website, www.kelleydrye.com, and any and all other sites on the Internet operated by Kelley Drye (each a “Site” and collectively, the “Sites”). This Website Privacy Policy also explains how we may use and disclose such data, as well as your rights and choices with respect to your personal data.

This Website Privacy Policy does not apply to personal data that you provide when you become a client or employee of Kelley Drye, which may be subject to a separate privacy notice.

 

   QUICK GUIDE TO CONTENTS

  1. Who We Are and Important Information
  2. Data That We Collect
  3. Data Use and Our Legal Basis
  4. Data That We Share
  5. Data Retention
  6. Your Rights and Choices
  7. Your California Privacy Rights
  8. Third-Party Content, Links, and Plug-Ins
  9. Securing Your Data
  10. International Transfers
  11. Revisions to this Website Privacy Policy
  12. How to Contact Us

Please also see the Disclaimer that applies to this website and states that the data contained on this site is not intended to convey or constitute legal advice.

  1. WHO WE ARE AND OTHER IMPORTANT INFORMATION

Who We Are

Kelley Drye is a nationally renowned law firm that has provided legal counsel carefully connected to our client’s business strategies for more than 180 years. Kelley Drye is a firm of more than 350 lawyers and other professionals practicing in New York, New York; Washington, D.C.; Los Angeles, California; Chicago, Illinois; Stamford, Connecticut; Parsippany, New Jersey; and Houston, Texas.  Outside of the U.S., the firm has an office in Brussels, Belgium.

Data Controller

For residents from the European Economic Area (EEA), the Brussels office of Kelley Drye & Warren LLP, located at 52 Rue Marie de Bourgogne, 1000 Brussels  (BE 544.236.415) is the data controller responsible for your personal data.

Important Information

It is important that you read this Website Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data from or about you so that you are fully aware of how and why we are using your data.

This website is not intended for children and we do not knowingly collect information from children.

  1. DATA THAT WE COLLECT

There are several ways that we may obtain data about you, including what you provide to us directly, data that we automatically collect, and data received from third parties.  This includes data that identifies you personally whether directly (i.e., your name) or indirectly (i.e., data about your online use of the Sites).

Data That You Provide

Kelley Drye collects data from you through the Sites when you choose to share it with us.  This may include when you sign up for one or more of our newsletters or our email list, register for one of our events, request information from us, or otherwise communicate with or contact us.

The data we collect from you on the Sites generally falls into the following categories:

  • Contact Details: We collect your contact information, such as first and last name, email and postal address, and telephone number.
  • Business Information: We collect data about your company or business, including company name, your job title, and business telephone number or mailing address.
  • Marketing Preferences: We collect data concerning your preferences in receiving marketing, other targeted information from us, and your contact preferences.
  • Other Communications: If you choose to send us an email message, we may retain the content of the email, including any attachments, your email address, and our response.

You may also provide us with certain data in connection with applying for a job on the Sites.  This data may include your contact details, and information contained in your cover letter and resume.

Data That We Collect Automatically
Whenever you visit or interact with the Sites, we may use cookies, pixel tags, or other technologies to automatically or passively collect data about your online activity.  The data we collect automatically on the Sites generally falls within the following categories:

  • Computer or Device: We may automatically collect your IP address or other unique identifier or information from the computer, mobile device, tablet, or other device you use to access the Site, including Internet browser type, device type, operating system, software version, hardware model, and the domain name from which you accessed the Sites.
  • Usage Information:  We may collect data about your use of the Sites, including the date and time you visit the Sites, the areas or pages of the Sites that you visit, the amount of time you spend viewing or using the Sites, the number of times you return to the Sites, other click-stream or site usage data, emails that you open, forward or click-through to our Sites, and other sites that you may visit.

Data Received from Third Parties

We may receive data about you from various third parties and public sources as set out below:

  • Third Party Analytic Technologies.  We may use third parties’ analytics tools to better understand who is using the Site, how people are using the Site, and how to improve the effectiveness of the Sites and related content. These tools may use technology such as cookies, web beacons, pixel tags, log files, or other technologies to automatically collect and store certain data. They may also combine data that they collect from your interaction with the Site with data they collect from other sources. We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.
  • Our Social Media Pages: We may receive data about you when you connect with us through one of Kelley Drye’s social media pages. When you do, we may automatically receive certain data about you based on your registration and privacy settings on those third party services. This may include, but may not be limited to, name, user name, demographic information, updated address or contact information, location, interests, and publicly-observed data, such as from social media and online activity.

Combination of Data

We may combine the Data we receive from and about you, including data you provide to us and data that we automatically collect through the Sites, as well as data collected from third-party sources.

  1. DATA USE AND OUR LEGAL BASIS

Kelley Drye is committed to protecting and maintaining the privacy of your data. Therefore, we will process your data only in accordance with applicable data protection law and this Website Privacy Policy.

We will have a lawful basis for processing your data if:

  • We need to process your data to provide you with the service you have requested or to enter into a contract;
  • You have consented to such processing;
  • We have a legitimate interest in processing your data, and your interests and fundamental rights do not override those interests – e.g., for network and information systems security; data analytics; enhancing modifying, or improving our services; identifying usage trends; determining the effectiveness of our marketing; and/or
  • We are legally obliged to process it.

We may use the data that we collect from and about you for any of the following
purposes.

  • To respond to your inquiries, and contact and communicate with you when requested;
  • To review the usage and operations of our Site, and conduct analysis to enhance or improve our content or services;
  • To contact you with information and promotional materials from Kelley Drye or on behalf of our affiliates;
  • To address problems with the Site or our business, and to protect the security or integrity of the Site and our business; and
  • For other purposes disclosed at the time you provide your information or otherwise with your consent.

If you apply for a job through the Site, we will use the data as part of the recruitment process to evaluate your qualifications, skills, and experience.

  1. DATA THAT WE SHARE

Except as provided in this Website Privacy Policy, Kelley Drye does not disclose, sell, rent, or exchange any personal data to or with unrelated third parties. Kelley Drye may share the data that we collect from or about you in the following ways:

  • Among Kelley Drye Affiliates: We may share your data with affiliates of Kelley Drye, including Georgetown Economic Services, for business, operational, and marketing purposes.  These affiliates are bound by this Website Privacy Policy.
  • With our Service Providers: We may share your data with third-party service providers that provide business, professional, or technical support functions for us, help us operate our business and the Sites, or administer activities on our behalf.
  • Legal Obligations; Safety: We may access and disclose your data to respond to subpoenas, judicial processes, or government requests and investigations, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law. We may disclose your data to protect the security of our Sites, servers, network systems, and databases. We also may disclose your data as necessary, if we believe that there has been a violation of any legal document or contract related to our services, or the rights of any third party.
  • Sale or Transfer of Business or Assets: We may sell or purchase assets during the normal course of our business.  If another entity acquires us or any of our assets, information that we have collected about you may be transferred to such entity.  In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such data may be considered an asset of ours and may be sold or transferred to third parties.  Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal data provided through this Site in a manner that is consistent with this Website Privacy Policy.

 

  1. DATA RETENTION

We will keep your personal data for as long as we need it to fulfill the purpose it is being processed for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

  1. YOUR RIGHTS AND CHOICES

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  Further information and advice about your rights can be obtained from the data protection authority in your country. For example:

  • Right to be informed. You have the right to be provided with clear, transparent, and easily understandable information about how we use your information and your rights. This is why we are providing you with this Website Privacy Policy.
  • Right of Access.  You have the right to obtain access to your data (if we are processing it), and certain other information (similar to that provided in this Website Privacy Policy).  This is so you are aware and can check that we are using your data in accordance with data protection law.
  • Right to Rectification.  You are entitled to have your data corrected if it is inaccurate or incomplete.
  • Right to Erasure.  This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your data where there is no compelling reason for us to keep it.  This is not a general right; there are exceptions.
  • Right to Restrict Processing.  You have certain rights to ‘block’ or suppress further use of your data. When processing is restricted, we can still store your data, but may not use it further.  We keep lists of people who have asked for further use of their datato be ‘blocked’ to make sure the restriction is respected in future.
  • Right to Object to Processing.  You have the right to object to certain types of processing, including processing for direct marketing (i.e., if you no longer want to be contacted with potential opportunities).
  • Right to Lodge a Complaint.  You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection authority.
  • Right to Withdraw Consent.  If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us for use of your personal data for marketing purposes.

If you have these rights under your data protection laws, you can exercise your rights by using the details set out in the ‘How to Contact Us’ section below.
Pursuant to applicable data protection law, we may be entitled to refuse to act on the request. You can exercise the above rights by contacting us as specified in the ‘How to Contact Us’ section.

Opt Out Preferences

If you no longer wish to receive our marketing materials, you may opt-out of receiving them at any time by: (1) unsubscribing from our email communications by following the instructions contained within the email; or (2) by sending us an e-mail at marketing@kelleydrye.com.

Cookies and California Do Not Track Disclosures

For California Residents: Certain parts of our Sites require cookies. You are free to set your browser or operating system settings to decline cookies, but by doing so, you may not be able to use certain features on the Site. Please refer to your Web browser’s or operating system’s website or “Help” section for more information on how to delete or disable your browser or operating system from receiving cookies or controlling your tracking preferences.

Our system may not respond to Do Not Track requests or headers from some or all browsers.

  1. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may request information about our disclosure of personal data to affiliated companies for their direct marketing purposes. To make such a request, please contact us at marketing@kelleydrye.com. Please include the statement “Your California Privacy Rights” in the subject field. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

  1. THIRD-PARTY CONTENT, LINKS, AND PLUG-INS

The Sites may provide links to third-party websites for your convenience. Please be aware that this Website Privacy Policy applies only to websites operated by Kelley Drye & Warren LLP. We recommend that you review the privacy and security policies of each website you visit before providing any personal data.

The Site may also offer you the ability to interact with social plugins from social media sites, which may allow us and the social media site to receive data from or about you. In some cases, we may know that you clicked on a social plugin, such as a Twitter Follow button, or receive other information from the social media sites. Similarly, if you have previously provided personal data to a third party operating a plug-in on this Site, then such third party may recognize you on this Site. Your use of social network plugins is subject to each social media site’s privacy policy, which may be different from ours, so please read these policies carefully to understand their policies and your options. As with linked sites, we have no control over the information that is collected, stored, or used by social network plugins, and are not responsible for the practices of such sites.

  1. SECURING YOUR DATA

We have taken certain physical, administrative, and technical steps to safeguard the data we collect from and about our Site visitors. Although Kelley Drye uses security that it believes to be appropriate to protect the personal data received through the Sites, Kelley Drye does not guarantee that its security precautions will protect against any loss, misuse, or alteration of any such data.

  1. INTERNATIONAL TRANSFERS

Kelley Drye is a global business and it, or its service providers, may process, transfer, and store information about our users on servers located in numerous countries, including the United States.  In some of these locations, data protection laws may be less stringent than in the EEA. To ensure that your data is adequately protected, we transfer your data subject to suitable safeguards being in place.

In particular, where we transfer your information outside the EEA, we rely on EU Standard Contractual Clauses approved by the European Commission and we transfer the information in accordance with applicable laws and using adequate and appropriate safeguards.  To find out more about how we safeguard your data (including obtaining a copy of such safeguards) in relation to transfers outside the EEA, please contact us via the details provided in the ‘How to Contact Us’ section.

  1. REVISIONS TO THIS WEBSITE PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. Continuing to access any of our Sites constitutes your acceptance of any modification to this Privacy Policy in effect at the time of your access. No modification or attempted modification of this Privacy Policy by you shall be binding on Kelley Drye.

  1. HOW TO CONTACT US

If you have any questions, you may contact us at
marketing@kelleydrye.com or by mail to:

KELLEY DRYE & WARREN LLP
101 Park Avenue
New York, NY  10178

KELLEY DRYE & WARREN LLP
Rue Marie de Bourgogne 52
Maria van Bourgondiëstraat 52
B-1000 Brussels Belgium