Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how Perkins Coie LLP and its affiliates, including Perkins Coie (International) LLP (“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 Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

Scope

Collection of Information

Use of Information

Disclosures of Personal Information

Data Retention

Your Choices

International Transfers

Additional Information for  Specific Jurisdictions

Contact Us

Scope

This Privacy Policy describes our practices in connection with personal information that we collect, use, and disclose:

• When you access or use our websites, applications, and other online services (collectively, the “Websites and Apps”);
• When you apply for a job with us (“Job Applicants”). If we hire you, information we collect in connection with your application will become part of your employment records and be used during the onboarding process and for other employment-related purposes in accordance with our internal Personnel Privacy Notice;
• In connection with our client onboarding process and disengagement, the information collected during the client relationship, and the information gathered from prospective clients (“Client Services”);
• About individuals who engage with Perkins Coie in a business capacity such as vendors, professional service providers, adverse parties, and expert witnesses; and
• When you visit our offices or attend our events.

Collectively, we refer to the above as the “Services.” Different or additional notices about the Firm’s privacy practices may be provided, in which case this Privacy Policy will not apply. For example, our internal Personnel Privacy Notice covers the processing of workforce personal information about Firm employees and attorneys, independent contractors, and other individuals who currently work or previously have worked for Perkins Coie. 

Collection of Information

The personal information we collect about you depends on how you interact with us or use our Services. In this section, we describe the categories of information we collect and the sources of this information.

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, provide information in conjunction with Client Services, or otherwise communicate with us. This personal information includes:

• Contact information, such as full name, email address, mailing address, and phone number;
• Professional and education information, such as educational degrees, educational institutions attended, language abilities, professional memberships, honors, and certifications; and board memberships; 
• Employment information, such as company name, office location, business unit/division, job status and title, employment history; tax-related information; and compensation structure and compensation history when legally permitted to be disclosed;
• Information for compliance and risk analysis, such as Job Applicants’ prior client engagements, their immediate family members employed in judicial or legal fields, and their involvement in claims, litigation, or regulatory inquiries; client-related investments or ownership; and information regarding clients with prominent public functions, including their family members and close associates; 
• 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 curriculum vitae/resume details, cover letter, references, employment application, information provided during an interview including recorded interviews, and background check information;
• Demographic information, related to Job Applicants or Client Services such as information about age, gender, race/ethnic origin, nationality, sexual orientation, political opinions, union membership, health information, and information about physical or mental disabilities;
• Information gathered from voluntary participation in marketing and other Firm initiatives, such as your choices regarding newsletters and responses to surveys; 
• Visitor and event information, such as travel and accommodation details, identification passes issued to access Firm premises, offices visited and time of entry and exit, audio and/or video recordings of online webinars and events, and other details specific to a particular event or conference that you share with us; and
• Additional Client Services-related information, such as username and password in connection with accessing Firm applications; commercial and financial information like client project numbers, invoices, payment information, bank account numbers, tax returns, and asset and net worth information; identity-related information such as birth certificate, residency status, visa information, and military status; information about owners and/or employees of clients that engage us; adverse parties and other individuals involved or in any way covered in each matter handled for a client; and other information provided in connection with Client Services. 

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, such as 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, such as 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; and
• Information collected by cookies and other tracking technologies, such as web beacons (or pixel tags), to collect information about your use of the Websites and Apps. These technologies help us improve our Services and marketing communications, personalize your experience, and analyze your interactions with us, including to see the popularity of areas and features of our Websites and Apps and count visits. For more information about removing or rejecting cookies, please see Your 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. The types of personal information we collect from other sources include:

• Social media information, such as profile pictures, social media account ID, and other public social media profile information;
• Anti-fraud information, such as share ownership structures, funding sources, and information that is available publicly and/or via third party sources like due diligence and screening databases (for example, court judgments and details on sanctions lists);
• Event photographs and videos, such as photos and videos taken at one of our events/conferences; and 
• CCTV and site security information, such as images or video footage captured or recorded by CCTV and other security measures on our premises.

If you are a Job Applicant, we also collect information such as notes about the conversations Job Applicants had with Firm personnel; feedback provided about Job Applicants including from references; and, to the extent permitted by applicable law, pre-employment background checks which may include criminal records checks, verification of qualifications and employment, and financial and other checks. For U.S. candidates, this will also include credit checks to the extent permitted by applicable law.

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 Websites and Apps.

Use of Information

We use the personal information we collect from and about you to provide our Services. We also use the information we collect 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;
• 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 seminars and other events, and to facilitate any continuing legal education credits earned;
• Facility access and security, such as to register and host you at our offices and 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; 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 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;
• Additional Client Services-related purposes, such as to conduct client due diligence and conflict checks; advise on current and prospective legal claims and compliance with legal obligations; provide personal or estate planning guidance; assist with due diligence and commercial deals; advise on mergers and acquisitions; and facilitate client intake, disengagement, and administration, including generating bills, invoices, disbursements and returning, transferring, or destroying documents;
• 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 for information;
• 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 to persons, groups, or entities as follows:

• Related entities, including to our affiliates, subsidiaries, and other companies under common control and ownership;
• 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 and due diligence 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-related 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, as necessary to allow them to render professional services to us;
• Third parties designated by you, to provide the services that you have requested;
• Client Services-related third parties, such as opposing counsel, court reporters, courts, mediators, arbitrators, 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;
• Law enforcement, public, regulatory and government authorities, courts, or tribunals, 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;
• To enforce agreements or policies, if we believe your actions are inconsistent with our agreements or policies, or to protect our rights, property, and safety or the safety of 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, the Firm considers numerous factors, including legal, ethical, contractual, 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 Choices

You have certain choices with respect to your personal information, as described below.

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 non-promotional communications, such as those about your account or our ongoing business relations.

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.

International Transfers

Perkins Coie LLP 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 information to countries outside of those jurisdictions by adhering to the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce (see Data Protection Framework).

Additional Information for Specific Jurisdictions

Individuals Residing in Certain U.S. States

Some U.S. states have enacted privacy laws that grant their residents certain rights and require specific disclosures (“State Privacy Laws”). If you reside in California, Texas, or Nebraska, this section may apply to you depending on the types of information we collect. This section also serves as our California notice at collection. 

Additional Disclosures

The Privacy Policy explains how the Firm collects, uses, and discloses information about you. As required by certain State Privacy Laws, we use the tables below to explain this same information.

In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

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.
• We collect information that is considered “sensitive” under State Privacy Laws in connection with Job Applicants and Client Services but do 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 this Privacy Policy.

Your Rights under State Privacy Laws

Access, Correction, and Deletion

You have the right to: (1) request to know more about and access your personal information, including in a portable format; (2) request deletion of your personal information: and (3) request correction of inaccurate personal information.

You may make these requests by calling 1.800.829.1177, emailing privacy@perkinscoie.com, or by visiting this page. 

Nondiscrimination

You have the right not to be discriminated against for exercising any of your privacy rights.

Authorized Agents

If you reside in California, you may also designate an authorized agent to submit an access, deletion, or correction request on your behalf. We may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the individual who is the subject of the request. In some cases, we may contact the individual who is the subject of the request to verify such individual’s own identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a California resident, please visit this page.

Perkins Coie (International) LLP and Individuals in the EEA, UK, or Switzerland

The Privacy Policy explains how the Firm collects, uses, and discloses information about you. 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 before entering into a contract (for example, 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 (for example, to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
• To comply with our legal obligations (for example, 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 (for example, 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, Job Applicants, or another natural person (for example, in the case of a medical emergency).

Data Subject Requests

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 data. 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. We may refuse a request for erasure in certain circumstances (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 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 interest (or those of a third party), you may challenge this. However, we may be entitled to continue processing your information when there are compelling legitimate grounds to do so. You also have the right to object where we process your personal information for direct marketing purposes.
• Consent: where we are processing personal data with consent, you can withdraw your consent.

You may make these requests by calling 1.800.829.1177, emailing privacy@perkinscoie.com, or by visiting this page. 

Data Retention

For details about the Firm’s data retention practices, see the Data Retention section of the Privacy Policy.

The Data Protection Framework

Perkins Coie U.S.-based entities comply with 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”) (together, the “DPF”) as set forth by the U.S. Department of Commerce.   

Perkins Coie U.S.-based entities have certified to the U.S. Department of Commerce that the entities adhere to the 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 U.S.-based entities have certified to the U.S. Department of Commerce that they adhere to the Swiss-U.S. DPF Principles with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. Each of these principles are collectively referred to as the “DPF Principles.” 

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 DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/s/.

Perkins Coie U.S.-based entities adhere 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 U.S.-Based Entities Internal Complaint Mechanism

In compliance with the DPF, Perkins Coie U.S.-based entities commit 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 DPF should first contact us at privacy@perkinscoie.com or visit Your Choices above.

Enforcement, Lawful Disclosures, and Onward Transfers

Perkins Coie U.S.-based entities are subject to the investigative and enforcement authority of the Federal Trade Commission (FTC). Perkins Coie U.S.-based entities may be required to disclose personal information in response to lawful requests by public authorities. Perkins Coie U.S.-based entities have 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 DPF, Perkins Coie U.S.-based entities commit to refer unresolved complaints concerning our handling of personal information received in reliance on the 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, 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 links below:

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

Individuals in the People’s Republic of China

The Privacy Policy explains how the Firm collects, uses, and discloses information about you. If you are a resident of China, in addition to the relevant sections of this Privacy Policy, the following China-specific provisions apply to our processing of your personal information.

Data Subject Rights

Individuals located in mainland China have the right to:

• Access their personal information held by us and request a copy of the information.
• Request us to update or correct your personal information if it is inaccurate or incomplete.
• Request us to delete your personal information if you no longer use our products or services or under other statutory circumstances, unless we have a legal or regulatory obligation to retain the information.
• Object to or withdraw your consent to our processing of your personal information.
• Request us to transfer your personal information to another person provided that such request complies with the conditions prescribed by the competent government authorities.

In special circumstances, the individual’s next of kin has the right to access, correct and delete the personal information of the deceased in accordance with the law. You may make these requests by calling 1.800.829.1177, emailing privacy@perkinscoie.com, or by visiting this page. 

Contact Us

If you have any questions or comments about this Privacy Policy, you may email us at privacy@perkinscoie.com.