Privacy

Privacy Policy

Last Updated Date: May 31, 2024

Willkie Farr & Gallagher LLP (“Willkie,” “we,” “our” or “us”) is committed to protecting your privacy and the data you share with us. This Privacy Policy describes how Willkie may collect, use and disclose personal information, including in association with the operation of our website (www.willkie.com), Willkie-operated pages on social media sites (e.g., LinkedIn) and any HTML-formatted emails or communications from Willkie that link to this Privacy Policy (collectively, the “Willkie Digital Services”), as well as personal information we collect and process in connection with our relationship with clients, prospective clients, prospective employees, vendors, suppliers, and other individuals about whom we collect personal information.

This Privacy Policy describes how Willkie collects, uses, shares, and otherwise processes personal information as a data controller under applicable laws, including the European Union General Data Protection Regulation (GDPR) and the UK GDPR. 

What personal information do we collect?
We collect personal information that you provide to us. For example, certain portions of our website, such as the “Contact Us” page, allow you to provide certain personal information on a voluntary basis, including your name, e-mail address, company information and other contact information. Likewise, your contact information may be added to email lists for our client alert emails and other resources when you provide your contact information to one of our attorneys.

We may automatically collect personal information when you access or use Willkie Digital Services. For example, when you are visiting our website, Willkie and third parties with whom we work (e.g., service providers, business partners) may place, view and/or use “cookies” or similar technologies to collect certain information about your use of this website. This may include information about the IP address of your computer and mobile device, browser type, language, operating system, geo-location data, the state or country from which you accessed this website, the web pages visited, the date and the time of a visit and the websites you visited immediately before visiting this website.

The Willkie Digital Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from individuals under 18. 

Whose personal information is covered?
The personal information covered by this Privacy Policy concerns the following categories of persons:

  • Employees, associates and partners of Willkie;
  • Willkie clients, as well as prospective and former clients and their affiliated entities (including their respective employees, agents, consultants, directors, officers, temporary, casual workers and direct and indirect shareholders, beneficial owners and the person(s) controlling them);
  • Opponents and counterparties, and prospective opponents and counterparties, of clients and their affiliated entities (including their respective employees, agents, consultants, directors, officers, temporary, casual workers and direct and indirect shareholders, beneficial owners and the person(s) controlling them);
  • Professional and personal contacts of Willkie partners, associates and other employees;
  • Suppliers (including their employees, agents, consultants, directors, officers, temporary, casual workers and direct and indirect shareholders, beneficial owners and the person(s) controlling them);
  • Advisors, consultants, witnesses, other professionals and professional experts (including their respective employees, agents, consultants, directors, officers, temporary, casual workers and direct and indirect shareholders, beneficial owners and the person(s) controlling them);
  • Other persons involved in providing legal services; 
  • Persons registering for or attending our events or signing-up for our newsletters, alerts, and similar publications; and
  • Dependents, associates and correspondents of the above persons affected by the data transfer.

How will the information you provide be used?
We may use the information you provide us for a number of different purposes. Specifically, we may use the information to respond to any requests you have submitted. Likewise, we may use your contact information to send you Willkie memoranda, announcements, alerts, news, invitations or other information about Willkie events and services that we believe may be of interest to you.

Other potential uses of this data include:

  • To comply with the law or in response to a subpoena, court order, law enforcement or government request or other legal process;
  • To produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigation or other legal or administrative proceedings;
  • To protect the interests, rights, safety or property of Willkie, our clients, users of this website or others;
  • In connection with internal organizational matters;
  • To combat fraud or other criminal activity;
  • To disclose or transfer information as an asset that is party of reorganization or other transaction; 
  • For any other purpose disclosed by us when you provide the information; and
  • As otherwise required or permitted by law.

How may we disclose the information we collect?
Willkie is a global provider of legal and other services. Our offices share information with each other for business purposes such as internal administration, billing, informing you about our events and services and providing you or your organization with legal services. In order to provide the information and services described in this Privacy Policy, we may provide your personal information and other information between our offices or with vendors that perform services on our behalf.

What is our legal basis for processing your personal information?
We rely on the following legal grounds to process your personal information:

  • Performance of a contract – To the extent you are a client of Willkie or wish to become one, we may need to collect and use your personal information to perform the services for which you have contracted with us. For example, we may use your personal information to respond to requests you make via our website and provide you with such services. 
  • Consent – Some of the personal information collected by Willkie is provided by you voluntarily (for example, when you sign up to join a mailing list or register for an event), and is therefore collected and used with your permission. To withdraw your consent to such use, you can contact us at [email protected].
  • Legitimate interests – We may use your personal information for our legitimate interests, such as to improve our products and services, and for the content on the Willkie Digital Services. We may also use your contact information to keep you and others who have provided us with their contact information up-to-date on legal developments of interest. If you wish us to stop using your contact information in this manner, you can contact us at [email protected].
  • Compliance with legal obligations – We may use your personal information to comply with legal obligations that are applicable to us. 

Is your data transferred to third countries and how is it protected?
The information we collect from and about you through this website, including your personal information, may be transferred to countries other than the one in which you reside. Any information transferred to a third country will be secured in the same manner as it would be in your own and will be done pursuant to all applicable laws. 

How do we secure your personal information?
We use reasonable administrative, technical and physical security measures to protect your personal information from unauthorized access and use. This may include, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide a level of protection equivalent to that adopted by Willkie.

However, no system of transmission or storage of data can be 100% secure. As such, we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet.

How long do we hold your personal information?
We retain the information we collect no longer than as reasonably necessary to fulfill the purposes for which we collect the information and to comply with our legal obligations.

Do we use “Do Not Track” signals? 
Some web browsers allow “Do Not Track” signals or settings, which may allow you to request that you do not want certain information about your web page visits tracked and collected across websites. At this time, this website does not respond to “Do Not Track” signals or settings. 

What are your rights?
If you no longer wish to receive communications from us – such as about events being promoted or hosted by Willkie or insight from Willkie attorneys on recent legal developments – you can let us know by contacting us at [email protected].

Depending on applicable law or the jurisdiction in which you reside, you may have certain rights regarding your personal information, which may include the right to:

  • Access or know about the personal information Willkie has about you and process;
  • Correct inaccurate personal information we maintain about you; 
  • Delete your personal information, subject to certain exceptions under applicable laws; 
  • Object to the processing of your personal information; or
  • Non-discrimination for exercising your rights. 

If you wish to exercise those rights, please contact us at [email protected]. If you are a California resident, you can also submit requests by calling toll-free at 1-833-381-8820 or through our “Privacy Inquiry” page. 

If you are a resident of the European Union, you have the right to complain to a Data Protection Authority if you believe that your personal information has been collected or used in violation of relevant privacy requirements. You may file such complaint with the Data Protection Authority in the country in which you are located. Alternatively, you may contact the Data Protection Authority (GBA) of Belgium online at https://www.dataprotectionauthority.be/citizen, by telephone at +32 (0)2 274 48 00, or at their physical address: Rue de la Presse 35, 1000 Brussels.

If you are located in the United Kingdom, you may contact the Office of the Information Commissioner in the United Kingdom at www.ico.org.uk, by telephone on +44 (0)303 123 1113 or by writing to this address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF United Kingdom.

Please note that to protect your information and the integrity of our services, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity. We are also prohibited by California law from disclosing certain information we may have under any circumstances. You may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf.

Additional information for California residents
This section supplements our Privacy Policy and provides additional information to California residents pursuant to the California Consumer Privacy Act of 2018, as amended, and its implementing regulations (collectively, the “CCPA”). 

The following explains the categories of personal information we have collected about California in the preceding 12 months: 

  • Identifiers, such as name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, Social Security number, driver’s license or other government ID number, passport number, employee ID number or other similar identifiers;
  • Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number or any other financial information, medical information or health insurance information;
  • Commercial information, such as records of personal property;
  • Characteristics of protected classifications under California or federal law, such as age, race, color, ancestry, national origin, immigration status, citizenship, marital status, medical condition, physical or mental disability, sex, gender, pregnancy or childbirth and related medical conditions or veteran or military status;
  • Audio, electronic, visual, or similar information, such as pictures, audio or video recordings;
  • Professional or employment-related information, such as current or past job history or performance evaluations, professional license information and bar standings, corporate expense information, salary information, drug screen results, fitness-for-duty or pre- employment physical exam results, tax rates, retirement fund information, compensation information, bonus information, benefits information or stock option information;
  • Education Information, such as schools attended, degrees and certificates awarded or in process, grades achieved in education courses, vocational trainings and certifications and transcript information;
  • Internet or other electronic network activity information, such as browsing history, search history and information regarding interaction with an internet website or application;
  • Geolocation data, such as information collected through GPS technology.

In the preceding 12 months, the categories of personal information listed above have been disclosed for business purposes to affiliates and service providers. 

We do not “sell” or “share” your personal information to third parties as the terms are defined in the CCPA and have not sold or shared your personal information in the preceding 12 months. We do not knowingly “sell” or “share” personal information about individuals under the age of 16.  We do not use or disclose your sensitive personal information for purposes other than those permitted by the CCPA. 

Changes to this Privacy Policy 
We may update this Privacy Policy from time to time, as required under the applicable laws or to incorporate changes to our privacy practices.  If you have any questions about this Privacy Policy or about our privacy practices, please contact us at [email protected].