Greenberg Traurig Privacy Notice

Updated: May 24, 2018

Greenberg Traurig and our affiliates worldwide (“GT”, “we” or “us”) respect your right to privacy. (collectively the “Service”). This Privacy Notice explains how GT, as a data controller, may collect, share, use and process information about you, and how you can exercise your privacy rights. It applies to all individuals who access our website (www.gtlaw.com), mobile apps and in connection with our blogs, alerts, newsletters, social media sites or programs and other communication services provided on or through the Internet, and any data received from clients in relation to our legal services (the “Services”).

If you have any concerns or questions about your privacy or use of our Services, please contact us via email at privacyoffice@gtlaw.com, or via postal mail at the relevant location listed in the “How to Contact Us” section below.

Changes to this Privacy Notice

We may update this Privacy Notice from time to time. The effective date of the current Privacy Notice is noted at the top of this page.

If we make any material changes to the way we collect, use, share or process the personal information that you have provided, we will notify you by posting a notice of the changes in a clear and conspicuous manner on the GT website. To the extent required by applicable data protection laws, we will obtain your consent to any material Privacy Notice changes.

Information We May Collect

When you use our Services, we collect personal information about your use of our Services and information that you send us.Throughout this policy, we use the term "personal information" to describe information that identifies you or makes you identifiable. Information that has been anonymized so that it does not identify a specific individual is not “personal information.”

We may collect and store the following information when running the Service:

  • Information You Provide Voluntarily.

We collect information that you voluntarily provide to us, including: when you communicate via email or other channels; when you sign up for news, publications and marketing communications and events; when you seek career information; when you register for alumni communications newsletters, alerts, or other materials; when you submit an application for a position with us; when you sign up for a webinar or event; when you respond to our communications or requests for information; or when you retain us for legal services.  The information you provide may include your name, contact information, title, and information about the organization with which you are affiliated. In relation to career information, the information you provide may also include employment history and qualifications. We only collect the personal information we need to allow us to respond to your request and/or provide the particular service you have sought.

Unless specifically requested and you use the method that we identify for such purpose, we request that you not send us any confidential or sensitive information such as credit card numbers, national ID numbers, social security numbers, health insurance number, or license numbers.

  • Information We Collect Automatically.

Device Information. We may collect information about devices you use to access the Services and how you use the Services, such as your Internet Protocol (“IP”) address and which websites you visited before accessing our Services.

Performance and Log Data. Our servers automatically record information created by your use of our Services, which may include information such as, but not limited to, your IP address, browser type, operating system, command line information, diagnostic information related to the Services (i.e., crash activity reports), the referring web page, pages visited, location, your mobile carrier, device and application IDs, and search terms. For instance, when we send you an email, we may collect certain information including the nature of the email, whether you opened our email, action you took upon receipt of our email (e.g. whether you opened it or deleted it), or your name and contact information.

Cookies. We use cookies to display information more effectively, store, on a user’s computer or device information about the user’s preferences and settings, gather statistical information about the use of our Service to improve our design and functionality, and for security purposes. Please review also our Cookie Notice for more information. 

Please note that we do not currently respond to web browser “do not track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Privacy Policy.

When you engage us to provide you with legal services, we collect and use personal information which is necessary for the performance of those services, which is usually information you voluntarily provide to us. This can include: your name, email address, contact information the company you work for, your position; identification and background information, financial information, such as payment related information, information about third parties that you provide to us, and other personal information as is relevant to our representation of you.

How and Why We Use Your Information

  • To Provide Our Services to You. We process your personal information to inform you about our Services, new legal and policy developments, relevant information in the industries we serve, and our marketing events. Without your personal information, we cannot provide our Services to you.
  • To Respond to Your Inquiries. We process your personal information when you contact us, such as with questions, concerns, feedback, disputes or issues. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
  • To Enforce Our Terms or Agreements. We process your personal information to actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services; investigate, prevent, or mitigate violations of our terms, agreements or policies; and enforce our agreements with third parties and partners. We cannot perform our Services in accordance with our terms, agreements or policies without processing your personal information for such purposes.
  • To Ensure the Security of the Service. We are committed to ensuring your safety and continued enjoyment of our Services. To do so, we process your personal information to: combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not access your account with us. We cannot ensure the security of our Services if we do not process your personal information for security purposes.
  • To Personalize Your Experience on the Services. We provide you with Third-Party Services, plugins, and many other options to personalize your experience on our Services. In addition, we also use cookies and similar tracking technology for such purposes – please see our Cookie Notice for more information. By personalizing the Services, you get to enjoy our Services even more because we keep track of your preferences (e.g. your language selection, your time zone, etc.). Without processing your personal information for such purposes, you may not be able to access or personalize part or all of our Services.
  • For Research and Development Purposes. To continue to provide you with our innovative Services, we collect information about the way you use and interact with our Services for research and development purposes. Research and development help us improve our Services, and build new Services and customized features or Services. We take additional security measures when processing your personal information for such purposes, by de-identifying or pseudonymizing your information, limiting access to personnel that may conduct research and development, and applying other technical, physical, and administrative security measures.
  • For Potential Employment. We process your personal information when you seek employment with us to evaluate you as a candidate for the position. Without your personal information, we cannot evaluate your qualifications for employment.
  • To Engage in Marketing Activities. We want to share information our Services with you, and to do so we may process your contact information or information about your interactions on our Services to: send you marketing communications; provide you with information about events, webinars, or other materials; deliver targeted marketing to you (please see our Cookie Policy for more information about interest-based advertising); and, keep you updated about our products and Services. You can opt-out of our marketing activities at any time and free of charge.

If, in the future, we use your personal information in any way that is not described in this Privacy Notice, we will disclose this to you. At that time, you can choose not to allow us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your consent. If you choose to limit the ways we can use your personal information, some or all of the Services may not be available to you.

Information Sharing and Disclosure

We do not sell, exchange, transfer, or give your personal information to any other company or individual for any reason except as set forth below:

  • GT Affiliated Entities. Since GT is a global organization and provides a global service, we may share users’ information with our offices and data centers throughout the world, for example, in the United States. Europe, Latin America, Middle East, and Asia.
  • Our Service Providers. We share information with our service providers, suppliers, subcontractors, and similar third parties who provide services to us, or act on our behalf so that they can assist us with the maintenance of our Service. Our contracts with these service providers prohibit them from using or sharing with others, for other purposes than as directed by us, the information that we provide to them, or that they collect directly from our users.
  • Corporate Reorganization. We may transfer information to a third party in case of the reorganization, sale, merger, joint venture, assignment, transfer or other disposition of all or any portion of our business, asset or stocks, including in the event of corporate restructuring. We reserve the right, as part of this transaction, to transfer or assign information we have collected from users of the Services to these third parties. Except as otherwise provided by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to policies that are consistent with the policies described in this Privacy Notice. However, any information that a user submits or that is collected after that transfer may be subject to a new privacy policy adopted by the successor entity.
  • Law Enforcement Requests. We may use, share, or disclose information about users in order to address legal concerns or liabilities, especially when we believe, in our sole discretion, that (a) a user has misused the Service such as to gain unauthorized access to any system, engaged in spamming, denial of service attacks, or similar attack; (b) disclosure is reasonably necessary to enforce our Terms of Use to respond to suspected illegal or fraudulent activity; to protect legal rights or defend against legal claims; to allow us to pursue available remedies or limit the damages that we may sustain.
  • Your Consent. We will disclose your information to a person you have given us your consent to disclose to.

Links to Third Party Services

Our Service may include links to third party services where you might be able to post comments, reviews, or view third party information. The use of these third party services may result in the collection and sharing of information about you by these third party services.

This Privacy Notice does not address the information practices of any third party, unless as specified otherwise. Please note, the inclusion of a link on our Service to a third party’s service does not imply endorsement of the third party’s data handling practices, and does not imply that the third party’s practices are covered by this Privacy Notice. We are not responsible for the privacy practices of these entities.

We encourage you to be aware when you leave our Service, and to read the privacy statements of each website or app on which you land after you click on a link or social networking button.

Access to Your Information

You may access and update your personal information that we hold by contacting us directly at privacyoffice@gtlaw.com. For your protection, we may need to verify your identity before implementing your request. We will try to implement your request as soon as reasonably practicable.

In your request, please make clear what information you would like to have changed, whether you would like to have your personal information suppressed from our database, or other limitations you would like to put on our use of your personal information. We may only implement requests with respect to personal information that is associated with the particular email address that you use to send your request.

However, please note that we reserve the right to refuse to act on a request that is manifestly unfounded or excessive (for example because it is repetitive) and/or to charge a fee that takes into account the administrative costs for providing the information or taking the action requested.

For individuals located in the European Economic Area, Switzerland or the United Kingdom during data collection, please refer to the Notice to Individual in the European Economic Area and Switzerland section below for more information about access, correction and deletion.

How We Keep Your Information Secure

We seek to use reasonable technical, organizational, and administrative measures to protect user information within our organization against unauthorized or unlawful access or processing, and against accidental loss, destruction, or damage. We believe that these measures are reasonably adapted to the nature of the information in our custody.

However, even though GT makes reasonable efforts to protect information in its custody, no data storage or transmission over the Internet and no security system is fully secure. Thus, we cannot guarantee the security of any information we may have collected or received from you or transmitted to you.

If you believe your information is not secure due to a problem in our systems, please immediately notify us of the problem at the address provided in the “How to Contact Us” section.

Retention

We retain information about users for as long as necessary to perform the activities described in this Privacy Notice, or where we have an ongoing legitimate business need to do so, such as for legal, regulatory, accounting or reporting requirements.

When our legitimate interest for retaining your personal information ceases to exist, we will either delete or anonymize your information so that it can no longer be attributed to a particular individual. To the extent residual information remains within our databases, back-ups or other records and we are unable to anonymize it we will isolate such information from further processing until deletion is possible. If you have any questions, please feel free to contact us.

Children’s Information

We do not knowingly collect any personal information from children under 16. If we become aware that an individual under 16 is submitting information, we will delete the information as soon as possible from our database.

International Transfers of Personal Information

Greenberg Traurig, P.A. complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield.  Greenberg Traurig, P.A has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this Privacy Notice and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

If you are not located in the United States or any of the countries noted above, and you access or use our Services or provide your information to us, your personal information may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.

Notice to Individuals in the European Economic Area and Switzerland

This section only applies to individuals using or accessing our Service while located in the European Economic Area, United Kingdom and/or Switzerland (collectively, the “Designated Countries”) at the time of data collection.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in the Designated Countries.

Legal Basis. In the sections above entitled “How and Why We Use Your Information” and “Information Sharing and Disclosure” we explain various ways we process your information. We will process your personal information only (1) with your consent; (2) to perform a contract between you and us; (3) to comply with a legal obligation or (4) where we have a legitimate interest to do so, balancing this interest against your interests and fundamental rights. Below is a chart indicating the legal bases we rely in processing personal information.

Purposes of Processing

Legal Basis for Processing

  • To Provide the Services
  • To Respond to Your Inquiries
  • To Enforce our Terms and Agreements
  • Provide Customer Support
  • To Ensure the Security of the Service.
  • Share with GT Affiliated Entities
  • Share with Our Service Providers, Business Partners and Others

Processing is based on our contract obligations or to take steps at the request of the individual prior to entering into a contract.

  • To Personalize Your Experience on the Services
  • For Research and Development Purposes
  • Sharing Due to Corporate Reorganization

Processing is based on our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services.

  • To Ensure the Security of the Service.
  • Share Due to Law Enforcement Requests
  • To Enforce our Terms and Agreements

Processing is necessary for compliance with our legal obligations, the public interest, or in your vital interests. 

Marketing. We will only contact individuals located in the Designated Countries by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law, or the individual’s consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.

If you do not want us to use your personal information in this way please click an unsubscribe link in your emails or send us an email at privacyoffice@gtlaw.com. You can object to direct marketing at any time and free of charge.

Individual Rights. We provide you with the rights described below when you use our Services. We may limit your individual rights requests (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other's privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or burdensome.

We may seek to verify your identity when we receive an individual rights request from you to ensure the security of your personal information.

  • Access, Correct, Delete. You have the right to access, correct, update or request deletion of your personal information under certain circumstances.
  • Object to Processing. You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
  • Right to Withdraw Consent. For any consent-based processing of your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

If you would like to exercise your rights under applicable law, please contact us at privacyoffice@gtlaw.com, indicating “EEA Individual Rights Request” in the subject line of the email.

Right to Lodge Complaint. If you believe we have infringed or violated your privacy rights, please contact us at privacyoffice@gtlaw.com so that we may resolve your dispute directly. If you are a European data subject with an unresolved complaint or dispute with Greenberg Traurig, P.A., arising under the requirements of the Privacy Shield Framework, we agree to refer your complaint under the Framework to an independent dispute resolution mechanism. See Privacy Shield Policy for more information. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

Special Requirements Under California Law

GT is comprised of several separate legal entities that may be considered “third party affiliated entities” for purposes of California Civil Code Section 1798.83. California law requires us to inform California residents who have provided us with personal information that they may request of us information about our disclosures to third parties (including GT Affiliated entities) for their direct marketing purposes. To do so, contact us at privacyoffice@gtlaw.com and indicate in the subject line “California Privacy Rights”.

How to Contact Us

You can contact us via email at privacyoffice@gtlaw.com. If you prefer to contact us by postal mail, and you are in the United States or in any country other than the countries listed in the chart below, please contact us at: Office of the General Counsel, Greenberg Traurig, MetLife Building, 200 Park Avenue, New York, NY 10166.

Please use the following addresses based on your location:

China

Greenberg Traurig, LLP
Huai Hai Zhong Lu 381
Shanghai 200020
China

Germany

Greenberg Traurig Germany, LLP
Potsdamer Platz 1
Berlin, Germany 10785

Italy

GT Strategic Alliance
Largo Toscanini 1
20122
Milan

Japan

14F, Meiji Yasuda Seimei Building
2-1-1 Marunouchi
Chiyoda-ku
Tokyo 100-0005

Mexico

Greenberg Traurig, S.C.
Paseo de la Reforma No. 265 PH1
Colonia Cuauhtemoc
Mexico, D.F. C.P. 06500
Mexico City

Netherlands

Greenberg Traurig, LLP
Hirsch Building
Leidseplein 29
1017 PS
Amsterdam, The Netherlands

Poland

Greenberg Traurig Grzesiak sp. k.
ul Książęca 4
Warsaw, 00498

South Korea

23F, Seoul Finance Center
136, Sejong-daero
Jung-gu
Seoul, Korea

United Kingdom

Greenberg Traurig LLP
The Shard, Level 8
32 London Bridge Street
London, SE1 9SG