Last Updated: November 22, 2024

California Consumer Privacy Statement

This California Privacy Statement supplements the Privacy Notice. It applies solely to California residents, and addresses personal information we collect online and offline. This California Privacy Statement does not apply to Hunton Andrews Kurth LLP personnel.

This California Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).

1. Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the Last Updated date of this California Privacy Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Sensory Information: audio, electronic, visual and similar information
• Geolocation Data
• Employment Information: professional or employment-related information, such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)

We may use (and may have used during the 12-month period prior to the Last Updated date of this California Privacy Statement) the categories of personal information listed above for the purposes described in our Privacy Notice. In addition, we may use these categories of personal information for the following purposes, including the following business purposes specified in the CCPA:

• Performing services, including maintaining or servicing accounts, providing client service, processing or fulfilling orders and transactions, verifying client information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services
• Providing advertising and marketing services
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
• Short-term, transient use
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• Helping to ensure security and integrity
• Debugging to identify and repair errors that impair existing intended functionality
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them
• Managing career opportunities with us
• Managing our relationships with current or prospective clients, vendors and other business partner personnel

We do not use or disclose (and have not used or disclosed during the 12-month period prior to the Last Updated date of this California Privacy Statement) “sensitive personal information” (as defined under the CCPA) for any purpose other than those expressly permitted under the CCPA. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

2. Retention of Personal Information

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in the Privacy Notice and this California Privacy Statement, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

3. Sources of Personal Information

During the 12- month period prior to the Last Updated date of this California Privacy Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you visit our websites or register for an event we sponsor
• From your devices, such as when you visit our websites
• Your business colleagues, such as when they provide us with your contact information so we can send information that may interest you
• Our affiliates (such as our document management and e-discovery solutions affiliate)
• Service providers, contractors and other vendors who provide services on our behalf
• Internet service providers (“ISPs”)
• Operating systems and platforms
• For job applicants, recruiting and talent agencies
• For job applicants, your job references
• For job applicants, data brokers, such as public databases, credit bureaus, credit reporting service providers and background check services
• Professional services organizations (such as PR firms, other law firms, and pro bono organizations)
• Business partners (such as those with whom we may cohost events)
• Social networks
• Government entities

4. Disclosure of Personal Information

During the 12-month period prior to the Last Updated date of this California Privacy Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this California Privacy Statement, we may have disclosed personal information about you to government entities and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.

We do not sell or share for cross-context behavioral purposes personal information and have not sold or shared personal information during the 12-month period prior to the Last Updated date of this California Privacy Statement. We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

5. California Privacy Rights

You have certain choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you.
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request. To submit an access, correction or deletion request, please complete our Privacy Rights Request Form or call us at 800-592-6738.To submit a request as an authorized agent on behalf of a California resident, please contact dataprivacy@HuntonAK.com.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or correction or deletion of your personal information, we may require you to provide certain information, including: (a) name, (b) postal address, (c) email address and (d) telephone number. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the California resident whose personal information is the subject of the request. If you designate an authorized agent to make an access or deletion request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This California Privacy Statement is available in alternative formats upon request. Please contact dataprivacy@HuntonAK.com or call 800-592-6738 to request this California Privacy Statement in an alternative format.